United States      WH-K2         EPA 440/1 86/079
           Environmental Protection   Washington, DC 20460    October 1985
           Agency


           Water
&ERA      Development
           Document for
           Effluent Limitations
           Guidelines and
           Standards for the
           Pesticide
           Point Source Category

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             DEVELOPMENT DOCUMENT

                      FOR

          BEST AVAILABLE TECHNOLOGY,
         PRETREATMENT TECHNOLOGY, AND
      NEW SOURCE PERFORMANCE TECHNOLOGY

                    IN THE



         PESTICIDE CHEMICALS INDUSTRY
     U..S. ENVIRONMENTAL PROTECTION AGENCY
                 Lee M. Thomas
                 Administrator
                 Edwin Johnson
Acting Assistant Administrator, Office of Water
                 Jeffery Denit
   Director, Industrial Technology Division
                George M. Jett
                Project Officer
                September 1985
        Industrial Technology Division
   Office of Water Regulations and Standards
     U.S. Environmental Protection Agency
            Washington, D. C. 20460

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                            ABSTRACT


The  purpose  of  this report is to  provide  a   technical  data
base   for   the promulgation of effluent  limitations guidelines
by  the U.S.  Environmental Protection  Agency for the  Pesticide
Chemicals Industry.  For the purpose of this study, the Pesticide
Industry  consists of organic pesticide chemicals  manufacturers,
metallo-organic pesticide  chemical manufacturers,  and pesticide
chemicals formulator/packagers.


Effluent     limitations   guidelines  for    Best      Available
Technology     Economically  Achievable   (BAT),    New    Source
Performance   Standards  (NSPS),   Pretreatment   Standards   for
Existing  Sources (PSES) and New Sources (PSNS),  are promulgated
under  authority  of the amended Clean Water  Act.    The  report
addresses     126    priority    pollutants    as     well     as
nonconventional pesticide pollutants under 40 CFR Part 455.


Analytical     methods     were     developed,     during     the
verification   sampling  portion of this study at  16   pesticide
manufacturing   facilities,  using Gas or  Liquid  Chromatography
(GC    or    LC)  for   nonconventional    pollutant    pesticide
pollutants.   The  results of these analyses were evaluated along
with data  from the EPA-conducted screening sampling programs  at
30   plants  and   data  from  sampling  and  analysis   by   the
manufacturers  themselves.   Additional  data  from  the  Organic
Chemical  Plastics  and Synthetic Fibers and the  Pharmaceuticals
Industries  were also evaluated and utilized.   These  data  were
also  used in conjuction with process chemistry  evaluations   of
individual    pesticide  processes    to determine  the  expected
priority pollutants associated with  manufacturing sources.   The
process  chemistry  evaluation  was used to  confirm  data  based
findings  and  to make the determinations as to the  presence  of
priority pollutants   where  no  monitoring  data were available.


The   principal   groups   of  pollutants  detected  or indicated
by  the process chemistry evaluation to be present  in  untreated
pesticide    process   wastewaters  were:    phenols,   volatiles
(aromatics,   halomethanes,   and  chlorinated    ethanes     and
ethylenes),    nitrosamines,   dienes,   cyanide,   metals,   and
pesticides.


Treatment   units   recommended  for  the   control   of    these
pollutants    are    activated    carbon,    resin    adsorption,
hydrolysis,   steam   stripping,   chemical   oxidation,   metals
separation,  and biological oxidation.   All of these   treatment
units  are  currently  installed  and  operating at a significant
number of plants within the industry.

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Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.
For additional information on this document contact:

          George M. Jett
          Environmental Protection Agency
          Industrial Technology Division (WH-552)
          401 M Street, S.W.
          Washington, D.C.  20460
          or call (202) 382-7180 between
          9:00 a.m. to 5:00 p.m. EST

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                     TABLE OF CONTENTS


Section                                                   Page

ABSTRACT                                                   i i


  I    EXECUTIVE SUMMARY                                   1-1

  II   CONCLUSION                                          II-l

            TABLES                                         II-4

  III  INTRODUCTION                                        III-l

            PURPOSE AND LEGAL AUTHORITY                    III-l
            SCOPE OF STUDY                                 II1-3

              Types of Products Covered                    III-3
              Definition of Wastewaters Covered            III-5
              Status of Pesticide Intermediates            III-5
              Effect of Previous Regulations               III-6
              Wastewater Sampling and Data Acquisition     III-9

            METHODOLOGY                                    II1-9

              Definition of the Industry                   III-9
              Manufacturing 308 Survey                     III-ll
              Formulator/Packagers 308 Survey              III-ll
              Screening Sampling                           111-12
              Verification Sampling Program                111-12
              Industry Self-Sampling Program               111-14
              Quality Assurance/Quality Control            111-14
              Audit of Actual Wastewater Analytical Data   111-15
              Industry Data Provided as Part
                of Public Comments                         111-15
              Process Chemistry Evaluation                 111-16
              Raw Waste Load Summary                       II1-16
              Treatment Technology Evaluation              111-16
              Subcategorization                            111-17
              Cost and Energy                              111-17

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                      TABLE OF CONTENTS


                  (Continued, Page 2 of 8)


Section                                                    Page

              Nonwater Quality Impact                      111-18
              Selection of Pollutant Parameters            111-18
              Selection of Expanded Best
                Practicable Technology                     111-18
              Selection of Best Available Technology       111-19
              Selection of NSPS Technology                 111-19
              Selection of Pretreatment Standards
                Technology                                 111-19
              Selection of BAT and NSPS Effluent Limitations
                and Pretreatment Standards for Existing
                (PSES) and New Sources (PSNS)               111-19
              Environmental Assessment                     111-20
              Appendices                                   111-20

  IV   INDUSTRY PROFILE                                    IV-1

            ECONOMIC AND INVENTORY DATA                    IV-1

              Pesticide Utilization                        IV-1
              Structural Grouping of Pesticides            IV-3
              Geographical Location of Plants               IV-3
              Market Value of Pesticides                   IV-3
              Level of Pesticide Production                IV-4
              Number of Pesticides Produced Per Plant      IV-5
              Number of Days Each Pesticide Produced       IV-5
              Number of Plants Producing Pesticides        IV-5
              Number of Plants Owned by Companies          IV-6
              Other Operations at Pesticide Plants         IV-6
              Methods of Wastewater Disposal               IV-6
              Type of Wastewater Treatment                 IV-7
              Formulator/Packagers                         IV-7
              Metallo-Organic Pesticide Manufacturers      IV-9

            TABLES                                         IV-10
            FIGURES                                        IV-19

  V    RAW WASTE LOAD CHARACTERIZATION                     V-l

            FLOW                                           V-4
            PRIORITY POLLUTANTS                            V-5
                                ll

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                 (Continued, Page 3 of 8)


Section                                                    Page

              Volatile Aromatics                           V-7
              Halomethanes                                 V-9
              Cyanides                                     V-ll
              Haloethers                                   V-12
              Phenols                                      V-13
              Polynuclear Aromatics                        V-15
              Metals                                       V-16
              Nitrosamines                                 V-21
              Phthalates                                   V-21
              Dichloropropane and Dichloropropene          V-22
              Priority Pollutant Pesticides                V-23
              Dienes                                       V-24
              TCDD                                         V-25
              Miscellaneous                                V-26
              PCBs                                         V-27
              Benzidines                                   V-27
              Nitro-substituted Aromatics                  V-27

            NONCONVENTIONAL POLLUTANTS                     V-27

              Nonconventional Pesticides                   V-27
              COD                                          V-28
              TOC                                          V-28
              TOD                                          V-28

            CONVENTIONAL POLLUTANTS                        V-28

              BOD                                          V-28
              TSS                                          V-28

            DESIGN RAW WASTE LOADS                         V-29
            ZERO-DISCHARGE PRODUCTS                        V-29
            TABLES                                         V-30
            FIGURES                                        V-125

  VI   CONTROL AND TREATMENT TECHNOLOGY                    VI-1

            INTRODUCTION                                   VI-1
            BACKGROUND AND OPTIONS                         VI-2
            SOURCE CONTROL                                 VI-3
                                ill

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                 (Continued, Page 4 of 8)


Section                                                    Page


            TREATMENT TECHNOLOGIES IN-USE  IN THE INDUSTRY  VI-4

              In-Plant Control                             VI-5

                Steam Stripping                            VI-5
                Chemical Oxidation                         VI-10
                Metals Separation                          VI-13
                Granular Activated Carbon                   VI-17
                Carbon Regeneration                        VI-28
                Resin Adsorption                           VI-29
                Hydrolysis                                 VI-32

              Incineration                                 VI-36

              Other Technologies                           VI-43

                Wet Air Oxidation                          VI-43
                Solvent Extraction                         VI-45
                Membrane Processes                         VI-46

              End-of-Pipe Treatment                        VI-47
                Biological Treatment                       VI-47
                Zinc Process for the Removal of Mercury    VI-55
                Equalization                               VI-55
                Neutralization                             VI-56
            TABLES                                         VI-57
            FIGURES                                        VI-112

  VII  INDUSTRIAL SUBCATEGORIZATION                        VII-1

            INTRODUCTION                                   VII-1
            CATEGORIZATION BASIS                           VII-1

              Product Type                                 VII-2
              Manufacturing Processes                      VII-2
              Raw Materials                                VII-2
                                IV

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                 (Continued,  Page 5 of 8)
Section                                                    Page

              Geographical Location                        VII-3
              Dominant Product                             VII-3
              Plant Size                                   VII-4
              Plant Age                                    VII-4
              Non-water Quality Characteristics            VII-5
              Treatment Cost                               VII-5
              Energy Cost                                  VII-6

  VIII COST, ENERGY, AND NONWATER QUALITY ASPECTS          VIII-1

            COST AND ENERGY                                VIII-1

              Pesticide Manufactures                       VIII-1
              Metallo-Organics Pesticide Manufacturers     VIII-4
              Pesticide Formulator/Packagers               VIII-4

            NONWATER QUALITY ASPECTS                       VIII-8

              Air Quality                                  VIII-8
              Solid  Waste Considerations                  VIII-10
              Protection of Ground Water                   VIII-11

            TABLES                                         VIII-12
            FIGURES                                        VII1-18

   IX   SELECTION OF POLLUTANT PARAMETERS RECOMMENDED
         TO BE REGULATED                                   IX-1

            INTRODUCTION                                   IX-1
            POLLUTANTS OF PRIMARY, DUAL, OR SECONDARY
              SIGNIFICANCE                                 IX-3

            PRIORITY POLLUTANTS                            IX-4

              Volatile Aromatics                           IX-4
              Halomethanes                                 IX-6
              Cyanides                                     IX-7
              Haloethers                                   IX-8
              Phenols                                      IX-9
              Nitrosubstituted Aromatics                   IX-10
              Polynuclear Aromatic Hydrocarbons            IX-11
              Chlorinated Ethanes and Ethylenes            IX-14
              Nitrosamines                                 IX-16
              Phthalate Esters                             IX-16
              Dichloropropane and Dichloropropene          IX-17
              Priority Pollutant Pesticides                IX-18

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                      TABLE OF CONTENTS

                  (Continued,  Page 6 of 8)

Section                                                   Page


              Dienes                                       IX-21
              TCDD                                         IX-21
              Miscellaneous Priority Pollutants            IX-21
              Polchlorinated Biphenyls                     IX-22
              Benzidines                                   IX-22
              Nonconventional  Pesticide Pollutants         IX-22

            TABLES                                         IX-42

    X  ANALYTICAL TEST METHODS                             X-l

            BACKGROUND                                     X-l

            PROPOSED ANALYTICAL TEST METHODS               X-3
            SELECTION OF ANALYTICAL METHODS FOR
              PROMULGATION                                 X-9
            RATIONALE FOR SELECTION/REJECTION OF
              EACH METHOD                                  X-ll
    XI  BEST AVAILABLE TECHNOLOGY ECONOMICALLY ACHIEVABLE
         (BAT)                                              X-l
            INTRODUCTION                                   XI-1
            IDENTIFICATION OF BAT                          XI-1
            RATIONALE FOR SELECTION OF BAT                 XI-2
            BENEFITS OF BAT IMPLEMENTATION                 XI-3
            TABLE                                          XI-4

    XII   NEW SOURCE PERFORMANCE STANDARDS                 XII-1

            INTRODUCTION                                   XII-1
            IDENTIFICATION OF NEW SOURCE PERFORMANCE
              STANDARDS TECHNOLOGY                         XI1-2
                                VI

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                  (Continued,  Page 7 of 8)
Section
Page
  XIII    PRETREATMENT STANDARDS                          XIII-1

            INTRODUCTION                                  XIII-1
            IDENTIFICATION OF PRETREATMENT TECHNOLOGY     XIII-1
            RATIONALE FOR SELECTION OF PRETREATMENT
              TECHNOLOGY                                  XIII-1
            PRETREATMENT STANDARDS                        XIII-2
            BENEFITS OF IMPLEMENTATION                    XII1-2
          TABLES
XIII-3
  XIV     DERIVATION OF EFFLUENT LIMITATIONS AND
          STANDARDS FOR THE ORGANIC PESTICIDE CHEMICALS
          MANUFACTURING SUBCATEGORY                        XIV-1

          INTRODUCTION                                     XIV-1
          SELECTION OF RECOMMENDED TREATMENT TECHNOLOGIES  XIV-1

          SELECTION OF THE DATA BASE USED TO DEVELOP
            LIMITATIONS AND STANDARDS                      XIV-1
          METHODOLOGY FOR DETERMINING THE LIMITATIONS
            AND STANDARDS                                  XIV-4
          BAT EFFLUENT LIMITATIONS GUIDELINES FOR
            PRIORITY POLLUTANTS                            XIV-4
          PRETREATMENT STANDARDS FOR PRIORITY
            POLLUTANTS                                     XIV-5
          BAT LIMITATIONS FOR NONCONVENTIONAL
            PESTICIDE POLLUTANTS                           XIV-6
          PRETREATMENT STANDARDS FOR NONCONVENTIONAL
            PESTICIDE                                      XIV-6
          CONFIRMATORY  DATA                               XIV-6

          TABLES                                           XIV-8
                                Vll

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                  (Continued, Page 8 of 8)
Section
Page
  XV    DERIVATION OF EFFLUENT LIMITATIONS AND STANDARDS
        FOR THE METALLO-ORGANIC PESTICIDE MANUFACTURING
        SUBCATEGORY AND THE FORMULATING /PACKAGING
        SUBCATEGORY                                         XV-1

        INTRODUCTION                                        XV-1
        SELECTION OF RECOMMENDED TREATMENT TECHNOLOGIES     XV-1
          Metallo-Organic Manufacturers
          Pesticide Formulator/Packagers
 XV-2
 XV-3
  XVI   ENVIRONMENTAL ASSESSMENT                            XVI-1

  XVII  ACKNOWLEDGEMENTS                                    XVII-1

  XVIII BIBLIOGRAPHY                                        XVIII-1

  XIX   GLOSSARY                                            XIX-1

  XX    APPENDICES                                          XX-1

         1.   PRIORITY POLLUTANTS BY GROUP                   XX-1
         2.   LIST OF PESTICIDE ACTIVE INGREDIENTS           XX-4
         3.   BPT EFFLUENT LIMITATIONS GUIDELINES            XX-25
         4.   CONVERSION TABLE                               XX-27
         5.   FORMULATOR PACKAGER 308 QUESTIONNAIRE          XX-29
         6.   PRIORITY POLLUTANTS REGULATED IN PESTICIDE
               WASTEWATERS                                  XX-45
         7.   DESIGN CRITERIA FOR RECOMMENDED TECHNOLOGY     XX-62
         8.   PESTICIDE ANALYTICAL METHODS AVAILABILITY/
               STATUS                                       XX-65
         9.   LIST OF APPROVED TEST PROCEDURES FOR
               NONCONVENTIONAL PESTICIDE POLLUTANTS         XX-74
        10.   PRIORITY POLLUTANTS AND SUBCATEGORIES
               EXCLUDED                                     XX-76
                                Vlll

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                       LIST OF TABLES


Table                                                         Page



                           Section II
   II-l     Priority  Pollutant  Effluent Limitations and       II-4
              Standards for BAT, NSPS, PSES and PSNS

   II-2     Nonconventional Pesticide Pollutant Effluent
              Limitations and Standards for BAT, NSPS,
              PSES and PSNS                                     I1-5

   II-3     Pesticides Regulated by PSES, NSPS, and PSNS
              When Formulated and Packaged.                     I1-8
                           Section IV


  IV-1      Pesticide Production by Class (1977)                IV-10

  IV-2      Pesticide Production by Class (1982)                IV-11

  IV-3      Structural Grouping of Pesticides                   IV-12

  IV-4      Types of Operations at Pesticide Plants (1985)      IV-13

  IV-5      Methods of Wastewater Disposal at Pesticide
            Plants (1985)                                       IV-14

  IV-6      Treatment Utilized at Plants Disposing Pesticide
            Wastewaters to Navigable Waters                     IV-15

  IV-7      Treatment Utilized at Plants Disposing Pesticide
            Wastewaters to POTWs                                IV-16

  IV-8      Formulator/Packager Production Distribution         IV-17


  IV-9      Percent of Formulator/Packager Pesticide Classes    IV-18
                                IX

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                         Section V
V-l       Indicated/Detected Frequency of Priority
          Pollutant Groups                                    V-30
V-2       Volatile Aromatics Indicated to be Present in
          Pesticide Process Wastewaters                       V-31
V-3       Volatile Aromatics Detected in Pesticide Process
          Wastewaters                                         V-35
V-4       Halomethanes Indicated to be Present in Pesticide
          Process Wastewaters                                 V-46
V-5       Halomethanes Detected in Pesticide Process
          Wastewaters                                         V-48
V-6       Cyanides Indicated to be Present in Pesticide
          Process Wastewaters                                 V-55
V-7       Cyanides Detected in Pesticide Process Wastewaters  V-56
V-8       Halogenated Ethers Indicated to be Present in
          Pesticide Process Wastewaters                       V-57
V-9       Haloethers Detected in Pesticide Process
          Wastewaters                                         V-58
V-10      Phenols Indicated to be Present in Pesticide
          Process Wastewaters                                 V-61
V-ll      Phenols Detected in Pesticide Process Wastewaters   V-62
V-12      Polynuclear Aromatic Hydrocarbons Indicated to be
          Present in Pesticide Process Wastewaters            V-69
V-13      Polynuclear Aromatic Hydrocarbons Detected in
          Pesticide Process Wastewaters                       V-70
V-l4      Metals Indicated to be Present in Pesticide
          Process Wastewaters                                 V-74
V-15      Metals Detected in Pesticide Process Wastewaters    V-75
V-16      Chlorinated Ethanes and Ethylenes Indicated to
          be Present in Pesticide Process Wastewaters         V-77
V-17      Chlorinated Ethanes and Ethylenes Detected in
          Pesticide Process Wastewaters                       V-78

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V-18      Nitrosamines Indicated to be Present in Pesticide
          Process Wastewaters                                 V-84

V-19      Nitrosamines Detected in Pesticide Process
          Wastewaters                                         V-85

V-20      Phthalates Indicated to be Present in Pesticide
          Process Wastewaters                                 V-86

V-21      Phthalate Esters Detected in Pesticide Process
          Wastewaters                                         V-87

V-22      Dichloropropane and Dichloropropene Indicated to
          be Present in Pesticide Process Wastewaters         V-89

V-23      Dichloropropane and Dichloropropene Detected in
          Pesticide Process Wastewaters                       V-90

V-24      Priority Pollutant Pesticides Indicated to be
          Present in Pesticide Process Wastewaters            V-91

V-25      Priority Pollutant Pesticides Detected in
          Pesticide Process Wastewaters                       V-92

V-26      Dienes Indicated to be Present in Pesticide
          Process Wastewaters                                 V-97

V-27      Dienes Detected in Pesticide Process Wastewaters    V-98

V-28      TCDD Indicated to be Present in Pesticide
          Process Wastewaters                                 V-99

V-29      TCDD Detected in Pesticide Process Wastewaters      V-100

V-30      Asbestos Detected in Pesticide Process Wastewaters  V-101

V-31      Nonconventional Parameters Detected in Pesticide
          Process Wastewaters                                 V-104

V-32      Conventional Parameters Detected in Pesticide
          Process Wastewaters                                 V-115

V-33      Summary of Raw Waste Load Design Levels             V-123

V-34      Plants Manufacturing Pesticides With No Process
          Wastewater Discharge                                V-124
                              xi

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                         Section VI

VI-1A     Applicability of Treatment Technologies to Various VI-57
          Pollutant Groups
VI-1B     Principal Types of Wastewater Treatment/Disposal   VI-58
VI-1C     Pollutants Removed by Selected Plant Technologies  VI-59
VI-2      Plants Using Stripping for Pesticide Wastewaters   VI-60
VI-3      Steam Stripping Operating Data                     VI-61
VI-4      Plants Using Chemical Oxidation for Pesticide
          Wastewaters                                        VI-63
VI-5      Chemical Oxidation Operating Data                  VI-64
VI-6      Plants Using Metals Separation for Pesticide
          Wastewaters                                        VI-66
VI-7      Plants Using Granular Activated Carbon for
          Pesticide Wastewaters                              VI-67
VI-8      Granular Activated Carbon Operating Data           VI-69
VI-9      Plants Using Resin Adsorption for Pesticide
          Wastewaters                                        VI-75
VI-10     Resin Adsorption Operating Data                    VI-76
VI-11     Plants Using Hydrolysis for Pesticide Wastewaters  VI-80
VI-12     Hydrolysis Operating Data                          VI-81
VI-13     Plant 10 Hydrolysis Data for Thiocarbamate
          Pesticides                                         VI-82
VI-14     Hydrolysis Data—Triazine Pesticides               VI-83
VI-15     Plants Using Incineration for Pesticide
          Wastewaters                                        VI-84
VI-16     Plants Using Biological Treatment for Pesticide
          Wastewaters                                        VI-86
VI-17     Biological Treatment Operating Data                VI-88
VI-18     Plants Disposing all Pesticide Wastewater
          by Contract Hauling                                VI-101
                              xii

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VI-19     Plants Using Evaporation Ponds for Pesticide
          Wastewaters                                        VI-102

VI-20     Plants Disposing Pesticide Wastewaters by
          Ocean Discharge                                    VI-103

VI-21     Plants Using Deep Well Injection for Pesticide
          Wastewaters                                        VI-104

VI-22     Treatment Technology Selected as Best Performance  VI-106

VI-23     Criteria for Best Performance Treatment
          Technologies                                       VI-107

VI-24     Best Performance Removal System for Non-
          conventional Pesticides by Treatment Technology    VI-108

                         Section VIII

VIII-1    Basis for Capital Costs Computations              VIII-12

VIII-2    Basis for Annual Cost Computations                VIII-13

VIII-3    Treatment Technology Cost Summary for Direct
          and Indirect Dischargers for Pesticide
          Manufacturing Plants                              VIII-13

VIII-4    PSES Costs for Indirect Discharge Metallo-Organic
          Manufacturers                                     VIII-15

VIII-5    Summary of Annual and Capital Cost for
          Formulator/Packagers                              VIII-16

VIII-6    Wastewater Recycle Costs for High Flow
          Formulator/Packagers                              VIII-17
                              Xlll

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                         Section IX


IX-1     Pollutants of Primary Significance                 IX-42

IX-2     Pollutants of Dual Significance                    IX-43

IX-3     Pollutants of Secondary Significance               IX-44

                         Section X

X-l       NCP's Where Data was Used to Develop Effluent
          Limitations and Standards But Which had No
          Promulgated Method in November 1982.               X-2

X-2       Industry Methods Proposed February 1983            X-4

X-3       Contractor Methods Proposed February 1983          X-6

X-4       Methods Proposed June 1984                         X-8

X-5       Analytical Test Methods Promulgated at 40 CFR 455  X-17

X-6       NCP's with Analytical Test Methods Promulgated
          at 40 CFR 136                                      X-18

X-7       Priority Pollutant Pesticides Analytical Test
          Methods Promulgated at 40 CFR 136                  X-19

                         Section XI

XI-1      Model Treatment Technology for BAT                 XI-4

                         Section XIII

XIII-1    Model Treatment Technology for PSES                XIII-3

XIII-2    Model Treatment Technology for PSES
          (Metallo-organic, Formulator/Packagers)            XIII-5

                         Section XIV

XIV-1     Treatment Technology Selected as Best
          Performance                                        XIV-8

XIV-2     Criteria for Best Performance Treatment
          Technologies                                       XIV-9

XIV-3     Physical/Chemical Confirmatory Treatment
          Data from OCPSF Industry                           XIV-10
                              xiv

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                    LIST OP FIGURES
Figure                                                      Page
                      Section IV
  IV-1      Geographical Location of Pesticide Manufacturers   IV-19
  IV-2      Market Value of Pesticides (1977)                  IV-20
  IV-3      Daily Level of Pesticide Production (1977)         IV-21
  IV-4      Annual Level of Pesticide Production (1977)        IV-22
  IV-5      Number of Pesticides Produced per Plant (1977)     IV-23
  IV-6      Frequency of Pesticide Production (1977)           IV-24
  IV-7      Number of Plants Each Producing the Same
            Pesticide (1977)                                   IV-25
  IV-8      Number of Plants Owned by Each Company (1977)      IV-26
                       Section V
  V-l       Probability Plot of Pesticide Product Flow Ratios  V-125
  V-2       Probability Plot of Pesticide Product Flows        V-126
                      Section VI
  VI-1     Range of Flows for Pesticide Treatment/Disposal    VI-112
  VI-2     Recommended BAT Technology—Steam Stripping        VI-113
  VI-3     Recommended BAT Technology—Metals Separation      VI-114
  VI-4     Recommended BAT Technology—Pesticide Hydrolysis   VI-115
  VI-5     Recommended BAT Technology—Carbon Adsorption      VI-116
  VI-6     Recommended BAT Technology—Carbon Regeneration    VI-117
  VI-7     Recommended BAT Technology—Resin Adsorption       VI-118
                                xv

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                    LIST OF FIGURES
Figure
                      Section VI
  VI-8     Recommended BAT Technology—Aeration Basin
  VI-9     Recommended BAT Technology—Clarification
  VI-10    Recommended BAT Technology—Incineration
                     Section VIII
  VIII-1   Treatment Cost Curves—Pump Station
  VIII-2   Treatment Cost Curves—Equalization
  VIII-3   Treatment Cost Curves—Steam Stripping
  VIII-4    Treatment Cost Curves—Chemical Oxidation
  VIII-5    Treatment Cost Curves—Metals Separation
  VIII-6    Treatment Cost Curves—Pesticide Hydrolysis
  VIII-7    Treatment Cost Curves—Neutralization
  VIII-8    Treatment Cost Curves—Dual Media Pressure
            Filtration
  VIII-9    Treatment Cost Curves—Carbon Adsorption
  VIII-10   Treatment Cost Curves—Carbon Regeneration
  VIII-11   Treatment Cost Curves—Resin Adsorption
  VIII-12   Treatment Cost Curves—Resin Regeneration
  VIII-13   Treatment Cost Curves—Nutrient Addition
  VIII-14   Treatment Cost Curves—Aeration Basin
  VIII-15   Treatment Cost Curves—Clarification
Page

VI-119
VI-120
VI-121

VIII-18
VIII-19
VIII-20
VIII-21
VIII-22
VIII-23
VIII-24

VIII-25
VIII-26
VIII-27
VIII-28
VIII-29
VIII-30
VIII-31
VIII-32
                                   xvi

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VIII-16   Treatment Cost Curves—Sludge Thickener           VIII-33
VIII-17   Treatment Cost Curves—Aerobic Digestion          VIII-34
VIII-18   Treatment Cost Curves—Vacuum Filtration          VIII-35
VIII-19   Treatment Cost Curve—Solar Evaporation           VIII-36
                              xvii

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                            SECTION I

                        EXECUTIVE SUMMARY


This  document  supports the final Pesticides Effluent  Guideline
regulation   which  limits  the  discharge  of  pollutants   into
navigable  waters  of the United States and into  publicly  owned
treatment  works by facilities that manufacture and/or  formulate
and  package  pesticide   chemicals.   The  Pesticides   Effluent
Guideline  regulation establishes effluent limitations guidelines
at  40 CFR Part 455 based on "best available  technology"  (BAT),
new   source   performance  standards  (NSPS)  based   on   "best
demonstrated  technology" and pretreatment standards for new  and
existing dischargers (PSES and PSNS).  EPA is also   promulgating
new test procedures for the analysis of nonconventional pesticide
pollutants  in the Pesticide Chemicals Category under 40 CFR Part
455.


The   Pesticides   Effluent  Guideline    regulation   is   being
promulgated under authority of Sections 301,  304, 306, 307, 308,
and  501  of  the Clean Water Act (the  Federal  Water  Pollution
Control  Act  Amendments of 1972,  33 U.S.C.  1251  et  seq.,  as
amended  by  the  Clean Water Act  of  1977,  P.L.   95-217  (the
"Act")).


This regulation is divided into three industrial subcategories:

     1.    Manufacturers  of organic pesticide chemical products,
Standard Industrial Classification ("SIC") code 2869.

     2.    Manufacturers  of metallo-organic  pesticide  chemical
products, SIC code 2869.

     3.    Formulators  and packagers of pesticide products,  SIC
code 2879.


The scope of the regulation under subcategory 1 includes  control
for priority pollutants in process wastewater from 280 pesticides
manufactured by 119 plants.  Forty-five of these plants discharge
process   wastewater  to  navigable  waters,   37  are   indirect
dischargers, and 50 dispose of wastewater by land  disposal, deep
well  injection,   incineration,  contract  hauling,  evaporation
ponds,  or  ocean dumping with no discharge of process wastewater
to  a  POTW  or  naviagable  water.    Nine  plants  generate  no
wastewater.  Subcategory 2 includes all metallo-organic pesticide
manufacturers  of mercury,  copper,  cadmium,  and  arsenic-based
products     and     Subcategory     3     includes     pesticide
formulator/packagers.
                            I- 1

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The principal groups of priority pollutants detected or likely to
be  present in untreated pesticide wastewaters were found to  be:
volatile aromatics,  halomethanes, phenols, cyanides, chlorinated
ethanes  and  ethylenes,   metals  (copper,  mercury  and  zinc),
nitrosamines,  dienes, and pesticides.   Nonconventional pollutant
pesticides  were found at concentrations greater than 1  mg/1  in
approximately   75   percent  of  all  raw  untreated   pesticide
wastewaters  sampled  and  are  therefore  also  regulated  where
appropriate analytical methods exist.


The  major  treatment units currently employed by plants  in  the
industry   are:     biological   oxidation,   activated   carbon,
incineration,evaporation,  chemical oxidation,  hydrolysis, steam
stripping,  multimedia filtration,  resin adsorption,  and metals
separation.   These units,  when properly designed and  operated,
can   effectively  remove  the  principal  priority   pollutants,
conventional   pollutants,   and  pesticides  found  in   process
wastewaters.    Data   transfer  for  steam  stripping   (organic
chemicals  and  pharmaceutical industries),  and  for  biological
treatment  systems  from  the organics  industry was  utilized  in
developing   regulations   for   this    industry.     Wastewater
characterization   and  treatment  performance  data  from  these
industrial  categories  were  compared   with  pesticide  industry
wastewater and treatment performance.  It was determined that the
waste  and  wastewater treatment technologies  were  similiar  to
those in the Pesticide industry.   The  Agency therefore used this
information in developing regulations for the pesticide industry.


Analytical  methods  are currently available for  detecting   147
nonconventional  and priority pollutant pesticides in wastewater.
EPA approved 304(h) analytical methods  are available for all  the
remaining  priority  pollutants (40 CFR Part 136)  controlled  by
this  regulation.   The Agency is promulgating in 40 CFR Part 455
14 analytical methods for 61 nonconventional pesticide pollutants
concurrently  with the limits and standards for these  compounds.
These  61  are a subset of the 147 total for which  EPA  approved
analytical  methods  are available;  analytical methods  for  the
other 86 pesticides are promulgated at  40 CFR Part 136.


The  effluent limitation guidelines and standards are  summarized
in Section II.  The analytical methods  are discussed in Section X
and the specific regulations are discussed in Section XI  through
XIII.  The  rationale and methodology for deriving the limits and
standards  is presented in Sections XIV and XV.
                            1-2

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                           SECTION II

                           CONCLUSION
The  U.   S.  Environmental  Protection  Agency  has  promulgated
effluent  limitations guidelines and standards for BAT and  NSPS,
PSES and PSNS for the Pesticide Chemicals Industry based upon the
technical   information  contained  in  this   document,   public
comments, and other information as appropriate.


This  document  supports regulations the Agency  promulgated  for
controlling  priority pollutants and certain pesticides from  279
organic   pesticide  chemicals  manufacturing   processes,   from
indirect  discharging manufacturers of metallo-organic pesticides
which contain arsenic,  cadmium,  copper,  and mercury, from  new
source  direct  discharging   formulator  packagers,   and   from
indirect   discharging  formulator  packagers.   These  different
manufacturing processes have been grouped into 3 subcategories as
discussed in Section VII.
The Agency is promulgating BAT limits for 34 priority  pollutants
and  pretreatment standards for 28 priority pollutants which,  in
addition  to  the  zero discharge requirements  for  two  of  the
subcategories,  adequately  controls the discharge of 70 priority
pollutants   known  or  expected  to  be  associated   with   the
manufacture    of   pesticide   products   within   these   three
subcategories.   The rationale for selecting these pollutants and
for  calculating these limits and standards is found  in  Section
IX.
The  Agency  is also promulgating effluent limitations guidelines
and standards for 89  nonconventional pollutant  pesticides.  The
rationale for this is found in Section XIV.


Analytical Methods Summary


The  recommended  treatment units to achieve these PSES  and  BAT
effluent  levels  for  Subcategory  1 are listed below,  and  the
rationale for this recommendation is found in Section VI.
                           II-l

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     Steam Stripping
     Chemical Oxidation
     Evaporation
     Metals Separation
     Pesticide Removal (Activated Carbon, Resin Adsorption,
      Hydrolysis)
     Biological Oxidation


The   treatment/disposal   units  recommended  to   achieve   the
promulgated  PSES effluent levels for Subcategories 2 and  3  are
listed below,  and the rationale for this recommendation is found
in Section VI.

     Recycle and Reuse
     Contract Hauling and Incineration
     Mercury Precipitation and Removal by Zinc Dust


BAT  effluent  limitations  for Subcategory 1  Organic  Pesticide
Chemicals  Manufacturers are the values presented in Tables  II-l
and II-2 for the priority pollutant and nonconventional pesticide
pollutants,  respectively.  BAT effluent limitations for metallo-
organic pesticide manufacturers and formulator/packagers are  not
necessary  since  the  existing BPT requires  zero  discharge  of
process wastewater pollutants.   For a detailed discussion of the
rationale see Section XI.
NSPS  for  new direct discharge Subcategory 1 - Organic Pesticide
Chemicals   Manufacturers  is set equal to BAT for  the  priority
pollutant and nonconventional pesticide parameters and to BPT for
conventional pollutants and for 48 pesticide products which  were
previously  regulated under BPT.   Because of the potential small
number of plants, an NSPS is not being established for new direct
dischargers   in  Subcategory  2   -  Metallo-Organic   Pesticide
manufacturers  of  cadmium,  copper,  mercury  and  arsenic-based
products.   NSPS  for new direct dischargers in Subcategory  3
Pesticide   formulator/packagers   is  set  equal  to  the   PSES
requirement of no discharge of priority pollutants and  pesticide
pollutants for which there are analytical methods approved by the
Agency.  The rationale for this is discussed in Section XII.  The
nonconventional pesticides covered by this Subcategory are listed
in Table II-3.


Pretreatment  standards  for  new and existing  Subcategory  1
manufacturing sources (PSNS and PSES) are equal to BAT levels for
incompatible  pollutants.   Pretreatment  standards for  new  and
existing  Subcategory 3 - formulating/packaging sources have been
developed based on new information from that used in establishing
the  existing BPT regulation and are the same as the  NSPS.   See
Table  II-3 for coverage.   Pretreatment standards  for  existing
Subcategory   2  - metallo-organic  pesticide  manufacturers   of
cadmium, copper, and arsenic-based products  are equal to the BPT

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direct   discharge   limitations.   Because  of   the   potential
environmental   harm  of  incineration  of  mercury  waste,   the
technology  basis of the zero requirement for the other types  of
metallo-organic compounds,  contract hauling and incineration, is
inappropriate for mercury.    The daily maximum PSES standard for
mercury  is  0.45 mg/1 with a monthly average  standard  of  0.27
mg/1.  The rationale for this is found in Section XIII.   Because
of  the  small  number of potential sources,  PSNS is  not  being
established for this subcategory.
                           II-3

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    TABLE II-l.  Priority Pollutant Effluent Limitations and
             Standards For BAT, NSPS, PSES and PSNS
Priority Pollutants
Benzene(l)
Chlorobenzene(1)
Toluene(l)
1,2-Dichlorobenzene(2)
1,4-Dichlorobenzene(2)
1,2,4-Trichlorobenzene(2)
Methyl bromide
Carbon tetrachloride
Chloroform
Methyl chloride
Methylene chloride
Cyanide
Bis(2-chloroethyl) ether(2)
2,4-Dichlorophenol
2,4-Dinitrophenol
4-Nitrophenol
Pentachlorophenol
Phenol(l)
Copper
Zinc
1,2-Dichloroethane(1)
Tetrachloroethylene(1)
N-nitrosodi-n-propylamine
1,3-Dichloropropene(2)
Hexachlorocyclopentadiene
a-BHC-Alpha(3)
b-BHC-Beta(3)
d-BHC-Delta(3)
g-BHC-Gamma(3)
a-Endosulfan-Alpha(3)
b-Endosulfan-Beta(3)
Endrin(3)
Heptachlor(3)
Toxaphene(3)
Maximum
for any
1 day
(mg/L)
0.057
0.045
0.035
0.11
0.045
0.13
0.15
0.13
0.075
0.11
0.56
0.64
zero
0.050
0.12
0.050
0.25
0.040
0.27
0.26
1.0
0.085
0.090
zero
0.13
0.090
0.090
0.090
0.090
0.090
0.090
0.18
0.090
0.005
Monthly
Average
shall not
exceed
(mg/L)
0.021
0.023
0.018
0.040
0.018
0.055
0.042
0.038
0.031
0.032
0.16
0.22
zero
0.023
0.034
0.019
0.15
0.017
0.13
0.18
0.41
0.034
0.028
zero
0.037
0.032
0.032
0.032
0.032
0.032
0.032
0.057
0.032
0.002
1  BAT/NSPS only

2  Regulated  only  in  those  processes  in  which  it  is   the
   manufactured product.

3  Limits  apply  only  for PSES, NSPS, and PSNS.  BPT limits are
   established by 455.20(b).
                               II-4

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    TABLE II-2.  Nonconventional Pesticide Pollutant Effluent
      Limitations and Standards for BAT, NSPS, PSES and PSNS
Pesticide Active Ingredient
Alachlor
Atrazine
Azinphos methyl(1)
Barban
Benfluralin
Benomyl
Bolstar
Bromacil
Busan 40
Busan 85
Butachlor
Carbam-s
Carbendazim
Carbofuran
Carbophenothion
Chlorpropham(1)
Chlorpyrifos
Chlorpyrifos methyl
Coumaphos
2,4-0(1)
2,4-D isobutyl ester
2,4-D isooctyl ester
2,4-DB
2,4-DB isobutyl ester
2,4-DB isooctyl ester
DBCP
Demeton
Demeton-o(l)
Demeton-s(l)
Diazinon(l)
Dichlofenthion
Dichlorvos
Dinoseb
Dioxathion
Disulfoton(l)
Diuron(l)
Ethalfluralin
Ethion
Fensulfothion
Fenthion

Maximum
for any
1 day
(mg/L)
0.17
19.3
1.4
Zero
0.20
13.3
0.002
0.31
0.44
0.44
0.006
0.44
13.3
8.5
0.16
12.2
0.16
0.16
0.16
3.3
3.9
3.9
0.025
0.041
0.041
1.6
0.17
0.14
0.14
0.15
0.15
0.021
0.79
0.16
0.82
0.090
0.40
0.15
2.6
0.91
Monthly
Average
shall not
exceed
(mg/L)
0.041
7.2
0.37
Zero
0.11
4.1
0.0008
0.095
0.22
0.22
0.003
0.22
4.1
2.6
0.076
5.1
0.076
0.076
0.076
1.5
1.7
1.7
0.014
0.019
0.019
0.78
0.061
0.046
0.046
0.069
0.071
0.007
0.42
0.076
0.25
0.050
0.21
0.071
0.85
0.38
                              II-5

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TABLE II-2. Nonconventional Pesticide Pollutant Effluent
 Limitations and Standards for BAT, NSPS, PSES and PSNS
                (Continued Page  2 of 3)
Ferbam
Fluometuron
Glyphosate
Isopropalin
KN methyl
Linuron(l)
Malathion(l)
Mancozeb
Maneb
Metham
Methomy1
Metribuzin
Mevinphos
Naled
Neburon(l)
Niacide
Oxamyl
Parathion Ethyl(l)
Parathion Methyl(1)
PCNB(l)
PCP salt
Phorate
Profluralin
Prometon
Prometryn
Propachlor
Propazine
Propham(l)
Propoxur(1)
Ronnel
Silvex(l)
Silvex isooctylester
Silvex salt
Simazine
Simetryne
Stirofos
Swep(l)
2,4,5-T(l)
Terbacil
Terbufos
Terbuthylazine
Terbutryn
Tributyltin benzoate
Trichloronate
1.2
0.054
130.
0.20
0.44
0.056
0.15
1.2
1.2
0.44
30.0
1.6
0.22
0.31
0.090
1.2
25.7
0.014
0.014
0.21
4.7
0.15
0.005
3.7
19.3
0.030
19.3
12.5
8.5
0.16
1.9
zero
zero
19.3
3.7
0.031
12.2
1.9
30.3
0.15
19.3
19.3
zero
0.16
0.39
0.030
32.
0.11
0.22
0.031
0.071
0.39
0.39
0.22
9.7
0.48
0.074
0.16
0.050
0.39
9.3
0.004
0.004
0.064
1.0
0.071
0.003
1.4
7.2
0.012
7.2
3.8
2.6
0.076
0.79
zero
zero
7.2
1.4
0.015
5.1
0.79
9.6
0.071
7.2
7.2
zero
0.076
                              II-6

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TABLE II-2. Nonconventional Pesticide Pollutant Effluent
 Limitations and Standards for BAT, NSPS, PSES and PSNS
                (Continued Page  3 of 3)
Trifluralin(l)                     0.043       0.023
Vancide 51Z                        zero        zero
Vancide 51Z dispersion             zero        zero
ZAC                                1.2         0.39
Zineb                              1.2         0.39

1. Limits apply only for PSES, NSPS, and PSNS.  BPT limitations
  are established by 455.20(b).
                              II-7

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   TABLE II-3.  Pesticides Regulated by PSES, NSPS, and PSNS
                     When Formulated and Packaged
 1. Alachlor
 2. Aldrin
 3. Ametryn
 4. Aminocacb
 5. AOP
 6. Atraton
 7. Atrazine
 8. Azinphos methyl
 9. Bacban
10. Benfluralin
11. Benomyl
12. Bentazon
13. a-BHC-Alpha
14. b-BHC-Beta
15. c-BHC-Delta
16. y-BHC Gamma (Lindane)
17. Bis(2-chloroethyl)ether
18. Bolstar
19. Bromacil
20. Busan 40
21. Busan 85
22. Butachlor
23. Captan
24. Carbam-S
25. Carbaryl
26. Carbendazim
27. Carbofuran
28. Carbophenothion
29. Chlordane
30. Chlorobenzene
31. Chlorobenzilate
32. Chloropropham
33. Chloropyrifos
34. Chloropyrifos methyl
35. Coumaphos
36. Cyanazine
37. 2f4-D and its salts and esters
38. 2f4-DB
39. 2f4-DB isobutyl ester
40. 2f4-DB isooctyl ester
41. DBCP
42. 4f4'-DDD
                             II-8

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TABLE II-3.  Pesticides Regulated by PSES, NSPS, and PSNS When
        Formulated and Packaged (Continued Page 2 of 3)


 43. 4,4'-DDE
 44. 4,4'-DDT
 45. Deet
 46. Demeton-0
 47. Demoton-S
 48. Demeton
 49. Diazinon
 50. Dicamba
 51. Dichlofenthion
 52. Dichloran
 53. 1,2-Dichlorobenzene
 54. 1,4-Dichlorobenzene
 55. 1,2-Dichloropropane
 56. Cis - 1,3-Dichloropropene
 57. trans - 1,3-Dichloropropene
 58. 1,3-Dichloropropene
 59. Dichlorvos
 60. Dicofol
 61. Dieldrin
 62. Dimethyl phthalate
 63. Dinoseb
 64. Dioxathion
 65. Disulfoton
 66. Diuron
 67. Endosulfan I
 68. Endosulfan II
 69. Endosulfan sulfate
 70. Endrin
 71. Endrin aldehyde
 72. Ethalfluralin
 73. Ethion
 74. Etridiazole
 75. Fensulfothion
 76. Fenthion
 77. Fenuron
 78. Fenuron - TCA
 79. Ferbam
 80. Fluometuron
 81. Glyphosate
 82. Heptachlor
 83. Heptachlor epoxide
 84. Hexachlorobenzene
 85. Hexazinone
                               II-9

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TABLE II-3.  Pesticides Regulated by PSES, NSPS, and PSNS When
       Formulated and Packaged (Continued Page 3 of 3)


 86. Isodrin
 87. Isopropalin
 88. KN Methyl
 89. Linuron
 90. Malathion
 91. Mancozeb
 92. Maneb
 93. Mephosfolan
 94. Metham
 95. Methiocarb
 96. Methorny1
 97. Methoxychlor
 98. Methylbromide
 99. Metribuzin
100. Mevinphos
101. Mexacarbate
102. Mirex
103. Monuron
104. Monuron - TCA
105. NABAM
106. Naled
107. Napthalene
108. Neburon
109. Niacide
110. Oxamyl
111. Parathion methyl
112. Parathion ethyl
113. PCNB
114. Pentachlorophenol ("PCP")
115. PCP Salt
116. Perthane
117. Phorate
118. Profluraline
119. Prometon
120. Prometryn
121. Propachlor
122. Propazine
123. Propham
124. Propoxur
125. Ronnel
                                11-10

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TABLE II-3.  Pesticides Regulated by PSES, NSPS, and PSNS When
         Formulated and Packaged (Continued Page 4 of 3)


126. Secbumeton
127. Siduron
128. Simazine
129. Simetryne
130. Stirofos
131. Strobane
132. Swep
133. 2,4,5-T
134. 2,4,5-TP (Silvex) and its salts and esters
135. Terbacil
136. Terbufos
137. Terbuthylazine
138. Terbutryn
139. Toxaphene
140. Triadimefon
141. Trichlorobenzene
142. Trichloronate
143. Tricyclazole
144. Trifluralin
145. ZAC
146. Zineb
147. Zirara


In addition Vancide 51Z, Vancide  51Z  dispersion,  and  metallo-
organic  active ingredients containing mercury, cadmium, arsenic,
copper, or tin.
                            11-11

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                           SECTION III

                          INTRODUCTION


The Federal Water Pollution Control Act Amendments


The  Federal Water Pollution Control Act (the Act) Amendments  of
1972,  33 USC 1251 e_t seq., stated the national goal of attaining
by  July  1,  1983,  a  water  quality  which  provides  for  the
protection and propagation of fish and shellfish,  for recreation
in  or  on the nation's waters,  and the goal of eliminating  the
discharge of pollutants into navigable waters by 1985.


Purpose and Authority


The  Federal  Water  Pollution Control  Act  Amendments  of  1972
established  a comprehensive program to "restore and maintain the
chemical,  physical,  and  biological integrity of  the  Nation's
waters,"  Section 101(a).   Existing industrial dischargers  were
required   to   achieve  "effluent  limitations   requiring   the
application  of the best practicable control technology currently
available" ("BPT"),  Section 301(b)(1)(A);  these dischargers were
required   to   achieve  "effluent  limitations   requiring   the
application   of  the  best  available  technology   economically
achievable...  which  will result in reasonable further  progress
toward  the  national goal of eliminating the  discharge  of  all
pollutants" ("BAT"), Section 301(b)(2)(A).   New industrial direct
dischargers  were required to comply with Section 306 new  source
performance   standards   ("NSPS"),   based  on  best   available
demonstrated  technology;  and  new and existing  dischargers  to
publicly   owned  treatment  works  ("POTW")  were   subject   to
pretreatment  standards under Sections 307(b) and (c) of the Act.
While  the  requirements  for  direct  dischargers  were  to   be
incorporated into National Pollutant Discharge Elimination System
(NPDES) permits issued under Section 402 of the Act, pretreatment
standards  were made enforceable directly against dischargers  to
POTW (indirect dischargers).


Although Section 402(a)(l) of the 1972 Act  authorized the setting
of  requirements for direct dischargers on  a case-by-case  basis,
Congress  intended  that for the most part   control  requirements
would  be  based on regulations promulgated by the  Administrator
providing  guidelines for effluent limitations setting forth  the
degree  of effluent reduction attainable through the  application
of  BPT  and BAT.   Sections 304(c) and 306 of the  Act  required
promulgation  of  regulations  for  NSPS,  and  Sections  304(f),
307(b),  and  307(c)  required promulgation  of  regulations  for
pretreatment  standards.   In  addition to  these regulations  for


                           III- 1

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designated  industry  categories,   Section  307(a)  of  the  Act
required the Administrator to develop a list of toxic  pollutants
and  promulgate effluent standards applicable to all  dischargers
of  toxic  pollutants.    Finally,  Section  501(a)  of  the  Act
authorized   the   Administrator  to  prescribe  any   additional
regulations "necessary to carry out his functions" under the Act.


The EPA was unable to promulgate many of these regulations by the
dates  contained in the Act.   In 1976,  EPA was sued by  several
environmental groups, and in a settlement of this lawsuit EPA and
the  plaintiffs  executed  a  "Settlement  Agreement"  which  was
approved by the Court.   This Agreement required EPA to develop a
program  and adhere to a schedule for promulgating  BAT  effluent
limitations  guidelines,  pretreatment standards,  and new source
performance standards for 65 "priority" pollutants and classes of
pollutants  for  21  major  industries.   See  Natural  Resources
Defense Council,  Inc.  versus Train,  8 ERC 2120 (D.D.C.  1976),
modified  12 ERC 1833 (D.D.C.  1979),  modified by  orders  dated
October 26,  1982,  August 2, 1983, January 6, 1984, July 5, 1984
and January 7, 1985.


On  December 27,  1977,  the President signed into law the  Clean
Water  Act  of 1977.   Although this law makes several  important
changes in the Federal water pollution control program,  its most
significant feature is its incorporation of several of the  basic
elements  of the Settlement Agreement program for toxic pollution
control.   Sections 301(b)(2)(A) and 301(b)(2)(C) of the Act  now
require   the  achievement   of  effluent  limitations  requiring
application  of  BAT for "toxic"  pollutants,  including  the  65
"priority" pollutants under 307(a) of the Act.   Likewise,  EPA's
programs  for  new source performance standards and  pretreatment
standards are now aimed principally at toxic pollutant  controls.
Moreover, to strengthen the toxics control program Section 304(e)
of  the  Act  authorizes  the Administrator  to  prescribe  "best
management  practices" ("BMPs") to prevent the release  of  toxic
and  hazardous  pollutants from plant site  runoff,  spillage  or
leaks,  sludge or waste disposal,  and drainage from raw material
storage  associated with,  or ancillary to,  the manufacturing or
treatment process.

In keeping with its emphasis on toxic pollutants, the Clean Water
Act  of  1977  also  revised the  control  program  for  nontoxic
pollutants.    Instead  of  BAT  for  "conventional"   pollutants
identified  under Section 304(a)(4) (including biochemical oxygen
demand, suspended solids, fecal coliform and pH), the new Section
301(b)(2)(E)   requires  achievement  of  "effluent   limitations
requiring  the  application of the  best  conventional  pollutant
control technology" ("BCT").  The factors considered in assessing
BCT  for an industry include the cost of attaining a reduction in
effluents and the effluent reduction benefits derived compared to
the costs incurred by and the effluent reduction benefits from  a
publicly  owned  treatment  works  (Section  304(b)(4)(B)).   For
nontoxic,  nonconventional pollutants,  Sections 301(b)(2)(A) and

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(b)(2)(F)  require achievement of BAT effluent limitations within
three years after their establishment  but not later than July 1,
1987.


The   purpose  of  these  regulations  is  to  provide   effluent
limitations   guidelines  for  BAT,   and  to   establish   NSPS,
pretreatment   standards   for  existing  sources   (PSES),   and
pretreatment  standards for new sources  (PSNS),  under  Sections
301,  304,  306,  307,  and  501  of the Clean Water Act for  the
pesticides manufacturing and formulating/packaging industry.


SCOPE OF STUDY
Types of Products Covered


This   study  covers  the  manufacturing  of   pesticide   active
ingredients  listed  in Section XX—Appendix  2  of  this report.
The  BPT  regulation  established effluent  limitations  for  the
pesticide  active ingredient in  only 49  pesticide   wastewaters
because  there were available Agency approved analytical  methods
for  only those 49 pesticides.   Two of these pesticides,  aldrin
and dieldrin, have been banned  from  manufacture  and use by EPA
and are also covered by regulations promulgated under 0307 of the
Act.  Forty-seven  pesticides which   were  previously  regulated
which  were  under  BPT for pesticide parameters   are   combined
with   223  pesticides   not  previously regulated  by   BPT  for
pesticide  paramater.  The  manufacturing of  a  total   of   279
pesticides   are now included  in the scope of  this  regulation.
These  279  pesticides  were the pesticides  of  most  commerical
importance   on   the 1978 FIFRA regulation list  after  removing
compounds  such  as  copper sulfate which are  covered  by  other
regulations.


Because of the lack of data or an analytical method  for  most of
the  279  pesticides,  many of the pesticide pollutants  are  not
specifically  limited in today's regulation.   Specific  effluent
limitations  are  promulgated for only 89  individual  pesticides
(Table II-2).    However, priority pollutants associated with the
280 pesticides are controlled by today's regulations.


The   formulation  of  147  organic  chemical  pesticide   active
ingredients  also:  vancide  51Z,  vancide  51Z  dispersion,  and
metallo-organic pesticides containing arsenic,  cadmium,  copper,
mercury,  and  tin  (for  which  there  are  approved  analytical
methods) into liquids,  dusts and powders, or granules, and their
subsequent   packaging in a marketable container is also  covered
under  this  study  for new and existing   indirect  dischargers.
The manufacture of mercury,  cadmium, copper,  and  arsenic-based
pesticides   is   addressed   for   new  and  existing   indirect


                           III-3

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dischargers.  Direct   discharge   of   wastewaters   from  these
metallo-organic  pesticides and formulating/packaging  facilities
was prohibited  by  BPT  regulations.


The     definition    of   a   pesticide   differs   among    the
governmental,  industrial, and  scientific  communities. For  the
purposes  of  this  regulation a pesticide  is  defined  as  "any
technical grade ingredient intended to prevent,  destroy,  repel,
or mitigate any pest,  subject  to  the following categories":
Product Classes Generally Included in Regulation
Insecticides
Herbicides
Fungicides
Nematicides
Rodenticides
Acaricides
Algicides
Miticides
Molluscicides
Avicides
Slimicides
Piscicides
Ovicides
Defoliants
Desicants
Repellents
Synergists
Botanicals
Fumigants
Product Classes Generally Not Included in Regulation*
Bactericides
Inorganic Pesticides
Plant Growth Regulators
Sex   Attractants
Quaternary Ammonium Salts
Microbials
Wood Preservatives**
Sanitizers
Disinfectants
Chemosterilants
     Pesticides produced outside the
      United States
     Organic, Pharmaceutical, Plastic
      and  Synthetic, or Other Industry
     Compounds Regulated Elsewhere
     Pesticides Produced in Limited
      quantities at stand alone research
      facilities
 *   Specific   products   not  included  are  itemized  in   the

     administrative record for the regulation.


**   The  wood preservative pentachlorophenol is included due  to

     its high-volume production.


Compounds   defined  in  Section  XX—Appendix   1  as  "priority
pollutant pesticides" are known hereafter as priority pollutants,
whereas all other pesticides are referred to as  "nonconventional
pollutant pesticides."
                           III-4

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Definition of Wastewaters Covered
This  study assesses only process wastewater associated with  the
manufacture   or   formulating/packaging  of   pesticide   active
ingredients.   As  shown  in  the  Glossary,   Section  XIX,  the
definition of "process wastewater" adopted is ... any aqueous
discharge  which  results from or has had contact with the  final
synthesis   step  in  the  manufacturing  of   pesticide   active
ingredients,  or  with the formulating/packaging of those  active
ingredients, to include the following:


     1.    Final  synthesis  reaction  wastewater or  water  used
           directly in the process.


     2.   Wastewater  from vessel/floor washing in the  immediate
          manufacturing and formulating/packaging area.


     3.   Stormwater runoff from the immediate manufacturing  and
          formulating/packaging process area or, the
          transportation loading area.


     4.   Wastewater from air pollution or ventillation
          scrubbers utilized in the manufacturing process or
          in the immediate manufacturing and formulating/
          packaging area.


     5.   Potentially contaminated process wastestreams that are
          the result of the washing of clothing, safety equipment
          etc. or the safety testing of packaging containers.


Wastewater  which  is not contaminated by the  process,  such  as
boiler blowdown,  cooling water,  sanitary sewage, or storm water
from outside the immediate manufacturing area, is not included in
the definition of process wastewater.


Status of Pesticide Intermediates


The  manufacture  of pesticide intermediates is  not  within  the
scope  of  this regulation because they are generally organic  or
inorganic  compounds which have multiple uses,  not just  in  the
manufacture of pesticides covered in this document.   As noted in
Section  XIX,   Glossary,  the  definition  of  "manufacture   of
pesticide  intermediates" adopted is ...  the manufacture  of
materials  resulting  from each reaction step in the creation  of


                           III-S

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pesticide  active  ingredients,   except for the  final  synthesis
step, and are, in most cases,  nonconventional pollutants.  In the
pesticide  industry  these intermediates may  be  purchased  from
other  manufacturers,  produced .  on-site in the exact  quantities
required for pesticide production,  or produced on-site in excess
of that required.


Process  wastewater  resulting from the production  of  pesticide
intermediates by use of a separate chemical manufacturing process
which  is  not an integral part  of the  pesticides  manufacturing
process,  where  the intermediate is a manufactured inorganic  or
organic chemical,  are covered by either the inorganic or organic
chemicals  effluent guideline   regulations.  If,  however,  these
inorganic   or  organic  processes  are  not  covered  by   other
industrial regulations,  the permit writer may on a  case-by-case
basis write Best Professional  Judgment (BPJ) permits.


Effect of_ Previous Regulations


BPT Effluent Limitations


In  general,  the BPT technology level represents the average  of
the best existing performances of plants of various ages,  sizes,
processes,   or   other  common   characteristics.    The  factors
considered  in  defining  best  practicable  control   technology
currently available (BPT) include the total cost of applying such
technology  in  relation to the  effuent reductions  derived  from
such  application,  the age of equipment and facilities involved,
the  process  employed,  nonwater quality  environmental  impacts
(including   energy   requirements)   and   other   factors   the
Administrator considers appropriate (section 304(b)(1)(B)).   The
Agency balances the total cost of applying the technology against
the effluent reduction achieved.    Where existing performance  is
uniformly  inadequate,  BPT may be transferred from a  different
subcategory or category.


Final  BPT  regulations for direct dischargers in  the  Pesticide
Chemicals  Industry  were published in the  Federal  Register  on
April  25,  1978,  and were amended on September 29,  1978.   The
effects of these regulations on  the current study are as follows:


1.   Several  pesticides  and   classes  of  pesticides  (such  as
     triazines)  were excluded from the  BPT  regulations.   This
     study  addresses  nonconventional  pesticide  pollutant  and
     priority  pollutant  removal technology for both direct  and
     indirect  dischargers  for   many  of  these  processes  (see
     Section  XX—Appendix  3  for a list of  previously  excluded
     pesticides).
                           III-6

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2.    Forty-nine  pesticide  parent  compounds  were  specifically
     identified  and  regulated in the BPT regulation for  direct
     dischargers  because  EPA had promulgated analytical methods
     available for the pesticide parameters.    COD, BOD, TSS, and
     pH  were also  regulated for these  compounds.   This  study
     addresses  the  priority pollutants for  direct and  indirect
     dischargers  which  are present in any of  these  pesticides
     manufacturing  processes (see Section XX—Appendix  3 for  a
     list  of  these 49 pesticides)/  and addresses most  of  the
     present pesticides  for the indirect dischargers.  There are
     exceptions  in  that  for 5 of the 49  previously  regulated
     pesticides;   Aldrin,  dieldrin,  DDT, ODD, and DDE, coverage
     under  this regulation is not required because discharge  of
     wastewater from the  manufacture  and/or  formulation of these
     pesticides  was  prohibited by Section 307(a)  of  the  Clean
     Water   Act published in the Federal Register,  January  12,
     1977  (40   CFR  Part  129).  The  same    rule   established
     acceptable   levels  for  direct   discharges  for  the   two
     pesticide parameters  endrin and  toxaphene (see January  12,
     1977  Federal  Register).    Process  wastewaters  from  the
     manufacturing  of  endrin and toxaphene  will be  subject  to
     BAT/PSES  regulations   for associated  priority  pollutants
     (direct and indirect discharge) and PSES regulations for the
     pesticide   pollutants   endrin  and   toxaphene   (indirect
     discharge).


3.    All the 280 pesticides covered by this regulation except for
     25 which were specifically excluded under BPT were regulated
     under BPT for the direct discharge of BOD, COD, TSS, and pH;
     See Appendices 2 and 3, respectively.  Therefore this  study
     addresses  the  nonconventional  pollutant   pesticides  and
     priority  pollutants  for  products  in   this   group  being
     directly or indirectly discharged.


4.    The   metallo-organic  pesticides  with   mercury,   cadmium,
     copper,  or  arsenic  bases were  assigned  a  zero-discharge
     limitation  under BPT for direct   dischargers.   This  study
     addresses    process        wastewater    pollutants    from
     manufacturing these metallo-organic pesticides      that are
     discharged to POTWs which are subject to PSES regulations.


5.    Formulators/packagers  of pesticide active ingredients  that
     discharge  wastewater  to navigable waters were  assigned  a
     zero discharge limitation under BPT.  This study  addresses
     formulators/packagers  that discharge process wastewater  to
     POTWs which are subject to PSES and PSNS regulations.
                           III-?

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BAT Effluent Limitations
In  general,  the  BAT technology represents the  best  treatment
system  available economically achievable by plants  within  each
subcategory  of  the  industry.  The Act established BAT  as  the
principal  national means of controlling the direct discharge  of
toxic  and nonconventional pollutants to navigable  waters.   The
factors   considered  in  assessing  best  available   technology
economically  achievable (BAT) include the age of  equipment  and
facilities involved,  the process employed,  process changes, and
nonwater   quality   environmental  impacts   (including   energy
requirements)   (section   304(b)(2)(B)).   The  Agency   retains
considerable  discretion in assigning the weight to  be  accorded
these  factors.   As  with BPT,  uniformly  inadequate  treatment
system  performance within an industry may require transfer of  a
BAT  treatment technology from a different industry   subcategory
or  category.   BAT  may  include  process  changes  or  internal
controls,  even  when these technologies are not common  industry
practice.


New Source Performance Standards
New  Source  Performance Standards (NSPS) are based on  the  best
available   demonstrated   technology.    New  plants  have   the
opportunity  to  install the best and most  efficient  production
processes and wastewater treatment technologies,  and, therefore,
Congress  directed EPA to consider the best demonstrated  process
changes,    in-plant   controls,    and   end-of-pipe   treatment
technologies to reduce pollution to the maximum extent feasible.


Pretreatment Standards for Existing Sources


Pretreatment  Standards for Existing Sources (PSES) are  designed
to  prevent  the  discharge  of  pollutants  that  pass  through,
interfere with,  or are otherwise incompatible with the operation
of  well-operated  publicly  owned treatment  works  (POTW)  with
secondary  treatment  installed.   Compliance  must  be  achieved
within three years of the date of promulgation.


The  Act  requires pretreatment for toxic  pollutants  that  pass
through  the POTW in amounts that would violate direct discharger
effluent  limitations  or  interfere with  the  POTW's  treatment
process  or  chosen  sludge  disposal  method.   The  legislative
history of the 1977 Act indicates that pretreatment standards are
to   be  technology-based,   analogous  to  the  best   available
technology  for removal of toxic pollutants.   EPA has  generally
determined  that  there  is pass through  of  pollutants  if  the
percent  of pollutants removed by a well-operated POTW  achieving
secondary  treatment is less than the percent removed by the  BAT


                           III-8

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model  treatment system.   The general pretreatment  regulations,
which  serve  as the framework for the  categorical  pretreatment
regulations are found at 40 CFR Part 403.   43 FR 27736 (June 26,
1978); 46 FR 9462 (January 28f 1981).


Pretreatment Standards for New Sources
Like  PSES,  Pretreatment Standards for New Sources (PSNS) are to
prevent the discharge of pollutants which pass through, interfere
with,  or  are otherwise incompatible with the operation  of  the
POTW.   PSNS  are  to be issued at the same time  as  NSPS.   New
indirect  dischargers,  like  new  direct  dischargers  have  the
opportunity   to  incorporate  the  best  available  demonstrated
technologies.    The   Agency  considers  the  same  factors   in
promulgating PSNS as it considers in promulgating PSES.


Wastewater Sampling and Data Acquisition


Data has been obtained over a long period of time,  and from many
sources.  The first data source consisted of a screening sampling
program  conducted  by EPA regions and  private  contractors.   A
verification  sampling program was then conducted  to  accurately
define   the   source  and  level  of  pollutants  in   pesticide
wastewaters.   Following verification sampling, an industry self-
sampling  program was instituted.  Additional priority  pollutant
and  nonconventional  pesticide data was also  received  directly
from  manufacturers as a result of various 308 surveys  conducted
over a seven year period.   The final source of data consists  of
information  from the Organic Chemicals,  Plastics and  Synthetic
Fibers  and  Pharmaceuticals  industries as well  as  information
received  from  the  pesticide  industry  from  comments  to  the
November  30,  1982  proposed regulations (47 FR 33492)  and  the
notices of new information, dated June 13, 1984 (49 FR 24492) and
January 24,  1985 (50 FR 3366) and the  proposed  analytical
methods published February 10, 1983.


METHODOLOGY


A  brief  description of the methodology used in the  conduct  of
this  study  is given below to provide a better understanding  of
the organization and logic of this report.


Definition of the Industry
                           III-9

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The  first  task upon commencing this project was  to  accurately
define the pesticide producers which would be covered.  A list of
pesticides  potentially  manufactured  was  developed  from   the
following sources:


     1.   Existing records from the BPT study;


     2.   Listing of pesticide facilities made available  through
          the EPA/Office of Pesticides Programs;


     3.   1977 Director of Chemical Producers/  Stanford Research
          Institute;


     4.   Pesticides Process Encyclopedia, Marshall Sittig, 1967;


     5.   Source  Assessment:  Prioritization of Stationary Water
          Pollution  Sources,   U.S.   EPA,  1977(Listof  108
          Environmentally Significant Pesticides); and


     6.   1977 Chemical Economics Handbook—Pesticides,  Stanford
          Research Institute.


As  a  result of this initial review,  a total of  167  potential
manufacturers were identified.


A total of 279 pesticides were selected after a review of the 600
plus  registered active ingredients to determine which should  be
covered  under the 1976 consent decree.   Many of the  registered
active  ingredients  are  products that are outside  of  the  the
agricultural   pesticide   chemicals  category.    They   include
inorganic  compounds  (sodium borate),  organic  compounds  whose
primary  use is other than  pesticides  (formaldehyde),  products
made  exclusively outside the United States,  products previously
excluded  from  regulations  under paragraph  8  of  the  consent
decree,  (e.g.  soaps  and  detergents)  and  products  that  are
regulated  under other industrial categories,  such as  inorganic
chemicals,  adhesives  and  sealants.   The specific reasons  for
exclusions  of  products are included in the proposal  record  in
Section  II  B.I.   Products included are pesticides  which  have
significant  production or commercial use.   Research  facilities
were  excluded because the pesticides produced for research  were
not produced in significant quantities.
                           Ill-10

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Manufacturers 308 Survey


A 308 Survey was drafted by EPA and reviewed and approved by  the
Effluent  Guidelines  Subcommittee of the  National  Agricultural
Chemicals  Association (NACA).   After approval was obtained from
the Office of Management and Budget (OMB I158-R0160),  the survey
was distributed in July 1978.  A copy of OMBf 158-R0160 is  found
in  Appendix 5,  Section XX  of the proposed development document
(EPA  400/l-82/079b).   The purpose of this survey was to  obtain
basic data concerning manufacturing,  disposal, and treatment, as
well  as  to identify potential sources of  priority  pollutants.
For  those plants previously contacted during BPT,  much  of  the
basic  data was already available and was not requested a  second
time.   Instead,  specific  questions concerning the conventional
and nonconventional pollutants were asked along with the  general
priority  pollutant   portion  of  the  survey.   Responses  were
received during August,  September,  and October 1978.   Based on
this  information  119  plants were selected for  further  study.
Approximately  90  follow-up  308 letters were  sent  during  the
months  of March,  April,  and May 1979 to clarify the record  on
each plant as well as to request specific priority pollutant data
and  the results of any available treatability  studies.   During
the months of March and April 1980 308 letters were sent to  over
50  selected plants requesting specific data to be used primarily
for statistical analysis.  These 308 survey results were  updated
by  the  respondents in comments and data received in response to
the November 30, 1982 proposal and June 13, 1984 NOA.  Additional
information  and  data  were received  from  respondents  through
telephone  calls and letters after close of the the  NOA  comment
period, to clarify the comments.


Formulator/Packagers 308 Survey


EPA  proposed  a  PSES regulation in November 1982  requiring  no
discharge  of process wastewater pollutants to navigable  waters,
applied to all wastewaters from the formulation and packaging  of
all  pesticides  (see tables on page III-6).   The proposed  PSES
regulation   was  similar  to  the  previously  promulgated   BPT
regulation for direct discharging PFP plants.  The same data base
was used to support the proposed zero discharge PSES standard.


EPA  conducted a telephone survey of a representative portion  of
the   entire   pesticide  formulators  and   packagers   industry
registered  with EPA under the Federal Insecticide Fungicide  and
Rodenticide Act (FIFRA).


These  surveys  identified  PFP facilities  which  formulated  or
packaged agricultural and/or household pesticides and which  also
discharged process wastewater to a  POTW.    A copy of this survey
is  provided in Section XX - Appendix 4.

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A  questionnaire  was then sent to the facilities so  identified,
under  authority  of  8308 of the  Clean  Water  Act,  requesting
detailed economic, production, and process information (OMB 2040-
0041).   A copy of this questionnaire is also provided in Section
XX  - Appendix  5.   Facilities   which  formulated  or  packaged
products  other  than agricultural and/or  household  pesticides,
such as sanitizers, disinfectants, inorganics, and surface active
agents,  were  excluded  from the  questionnaire  survey.   After
evaluating  this new data we then notified the public of our  new
data  in  a  June 13,  1984 notice of  availability  ("NOA")  and
summarized the results.


Screening Sampling

A screening,  sampling, and analysis program was conducted during
1977  and  1978 as the first step in determining the  source  and
level of priority pollutants in the pesticides industry.  A total
of  30  plants  were sampled,  27 by EPA  Regional  Sampling  and
Analysis  teams  and the remainder  by  EPA  contractors.   These
samples  were  taken and analyzed by GC/MS for the  126  priority
pollutants  using the March 1977 analytical methods and  sampling
protocol developed by the Effluent Guidelines program (U.S.  EPA,
1977g).   Nonconventional  pesticides where an analytical  method
was  available were also analyxed these data were used to  assist
in  the selection of plants for verification sampling and in  the
identification  of  specific pollutants to be analyzed  at  those
plants.


Verification Sampling Program


An  evaluation  of existing data as well as 308 Survey  responses
was  used to select 16 plants for the verification  sampling  and
analysis  program to develop additional quantitative data on  the
raw  waste  and  effluent levels of pollutants in  the  pesticide
industry.   These  16  plants  were  selected  if  they  met  the
following criteria:  (1) process chemistry analysis or  screening
sampling   indicated  the  existence  or  suspected  presence  of
priority pollutants in the raw waste or treated effluent; (2) the
plant  employed a potential BAT wastewater treatment  technology;
and (3) the plant manufactured a variety of pesticide types.


The following procedures were employed at each of the  individual
plants:


     1.   An engineering visit was scheduled and  conducted.
          At  this visit a comprehensive engineering  survey
          of  the  plant  was  made,  historical  data  were
          reviewed,  potential  priority  pollutant  sources
          were identified, and grab samples were taken of at


                           III- 12

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     least  the  process  intake  water,   raw  process
     wastewater,  and treated effluent.   These samples
     were  transferred  to  the  individual  contractor
     laboratories for analysis.  An engineering  report
     was  filed  and provided to  plant  personnel  for
     review and comment.
     A   sampling  plan  was   prepared   which,   upon
     conclusion  of  laboratory  efforts  to  determine
     analytical  methods,  provided  the rationale  for
     selection of future sampling sites and  parameters
     along with a step-by-step analytical procedure for
     each of the pollutants to be measured.   A copy of
     this  report was provided to the plant in  advance
     of any further wastewater sampling.
     A  verification  sampling visit was scheduled  and
     conducted, consisting of one grab sample and three
     24-hour composites taken at each site specified in
     the  sampling  plan.     Teams  of  engineers   and
     technicians  took  samples,  preserved  them,  and
     shipped   them  to  contractor  laboratories   for
     analysis  of  conventional,  nonconventional,  and
     priority   pollutants.    In   some  cases   plant
     personnel  also  collected  wastewater  from   EPA
     sampling  sites or  were provided split samples  by
     the  EPA  contractor   during verification  sampling
     visits.
4.   A   verification  sampling  report  was  filed  on
     completion of the laboratory analyses.   A copy of
     this report was provided to the plants for  review
     and  comment.   The  report contained  results  of
     analyses,   documentation  of problems encountered,
     and evaluation of treatment system performance.
5.    A  final plant report was prepared for  each  site
     visited   to  include  all  the  above   mentioned
     material, plant correspondence, sampling logs, and
     final   analytical  procedures  utilized.    These
     reports  were  also  provided  to  the  individual
     plants for comment.
6.   A  laboratory  data report was prepared  for  each
     plant    including    individual    chromatograms,
     laboratory  notebooks,   and documentation  of  all
     quality   control   measures   employed.      GC/MS
     procedures were used to confirm GC analysis,  when
     specific  problems existed,  for approximately  10
     percent of the verification samples.
                      111-13

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Industry Self-Sampling Program


EPA  solicited  volunteers  for self-sampling  and  self-analysis
programs  to be conducted for 30- to 45-day periods  at  specific
plant/process  waste streams.   The purpose of the program was to
obtain long term data on selected priority pollutants.


The  recommendation for the selection of plants to undergo  self-
sampling/self-analysis  was based on a review of the adequacy  of
plant data, indicated or detected presence of priority pollutants
proposed for regulation, and whether potential BAT technology was
currently   in  place.    From  this  review  nine  plants   were
recommended for the self-sampling program.   However,  only  four
plants participated in this program.


Data  from each of the volunteer plants was received,  processed,
and evaluated.
Quality Assurance/Quality Control


The  entire verification program was designed to be conducted  in
accordance  with  a written sampling  protocol  (ESE,  1979)  and
within  specific  analytical  Quality  Assurance/Quality  Control
(QA/QC) guidelines (Jayanty,  March 1979).  The sampling protocol
specified  methods of container preparation,  sample  fractioning
and preserving,  sample transportation,  and sample documentation
and tracking.

The elements of the QA/QC program were:


     1.   Preparation  of a QA/QC manual which  consolidated
          analytical contractors.


     2.   Establishment   of   quality  control  goals   for
          duplicate  and spike analyses;  in this  case  all
          first  day  verification samples were  duplicated,
          and   all  third  day  samples  were  spiked   and
          recoveries calculated.
     3.   Implementation  of quality assurance  testing  for
          each  analytical laboratory.   Each contractor was
          forwarded  test  samples  containing  unidentified
          concentrations  (both  high and low) of  compounds
          common  to two of the plants analyzed by the  lab.
          These samples,  prepared in distilled water,  were
                           111-14

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          analyzed  utilizing  the same procedures  used  on
          actual plant wastewaters.  In addition, one sample
          with identical constituents was sent to all of the
          analytical  contractors for a  comparative  basis.

          The results of these analyses were returned to the
          QA/QC  contractor  for comparison with  the  known
          concentrations  of each parameter as determined by
          gravimetric measurement.  The results of the QA/QC
          program  are available in a series of  reports  in
          the proposal administrative record.


The  precision  and accuracy goals of the QA/QC study  were:   an
overall precision of  25 percent, including sampling, extraction,
and GC measurement;  and spike recovery equal to or greater  than
70 percent.


Audit of Actual Wastewater Analytical Data


After evaluating the results of the QA/QC program, it was decided
to  audit  portions  of  the  actual wastewater  analytical  data
obtained by the verification program.  At least 10 percent of the
data  from each of the four verification contractors was  audited
by   the  QA/QC  contractor.    Since  the  audit  revealed  some
deviations from protocol,  an additional audit took place of  the
remaining  90  percent  of the data.  The results of  the  above-
mentioned  audits were used to eliminate data deviating from  the
specified protocols from  the data set and the remaining data was
incorporated into the data tables found in this report. Data that
failed  the QA/QC audit were not included in the  calculation  to
develop  limits and standards.  The data were,  however,  used in
conjunction with the process chemistry review.


Industry Data Provided as^ Part of_ Public Comments


Commentors  submitted  additional information to  the  Agency  in
response to the November 30,  1982 proposal and the June 13, 1984
and  January  24,  1985 Notices of Availability.   The number  of
commentors to the proposal and the two NOAs were 55,  41,  and 25
respectively.    The   new  information  submitted   included   a
considerable  amount of plant effluent data.   Most of this  data
were  composed of corrections on previously submitted  flow,  raw
waste,   and   treatment  system  influent  and  effluent   data.
Approximately  one dozen commentors provided new data on priority
pollutants and nonconventional pesticide pollutants to the Agency
which   significantly  affected  the  final  data  base  and  the
calculation of long term averages and variability factors used in
deriving  the  final  limits.    Consequently,   the  promulgated
effluent  limitations guidelines reflect these modifications  and
the submittal of new data.
                           111-15

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Process Chemistry Evaluation


Because there are 119 plants in the industry and 16 were  sampled
during  the  verification program,  an evaluation of each of  the
pesticide  processes  not  sampled  was  performed  in  order  to
determine which priority pollutants were likely to be present for
the industry as a whole.   This review was accomplished using the
process  descriptions,  feedstock  materials  including  solvents
used, information and products information provided by each plant
as part of the 308 Survey response as well as using existing  BPT
and  published  technical  information on the  processes  in  the
literature.  EPA  determined  that  pollutants are likely  to  be
present  in the process because they are the  final  manufactured
product,  used as raw materials, are known impurities in the feed
materials,  or  were  reported by-products or impurities  of  the
reaction.  The  results of this process chemistry evaluation were
compared  with any available data and confirmed.  The results  of
the process chemistry evaluation of 280 pesticides are  presented
in  Section V.   A separate summary report has been prepared with
greater  detail  on the process chemistry review and  is  in  the
confidential  record.   Due to the confidential nature of much of
this  material,  details of each process are in  pesticide  group
reports in the confidential portion of the record (Volume 107  to
110).


Raw Waste Load Summary


All  available raw waste load data were gathered and presented in
conjunction    with    the    process    chemistry    evaluation.
Representative   historical  data  from  BPT,   screening   data,
verification data,  and 308 data, are consolidated and summarized
in  Section  V of this document according to groups  of  priority
pollutants as defined in the Glossary, Section XIX.


Treatment Technology Evaluation


Treatment  and control technology currently utilized  within  the
pesticide  chemicals  manufacturing  industry were  evaluated  in
terms  of  its performance in removing  priority  pollutants  and
pesticides.    Control   and  treatment  technologies   routinely
accomplishing  exemplary removal of specific pollutants in  other
industrial  categories  were evaluated to determine whether  they
would  be  applicable to the pesticide industry  where  treatment
performance data were either absent or based on an evaluation  of
the treatment system performance.  The Agency concluded there was
inadequate  treatment  of  certain pollutants  by  the  pesticide
industry.   EPA   has  determined  that  treatment  and   control
technology from other industrial categories can be transferred to


                           111-16

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the   pesticide  industry  because  the  wastewater  from   these
industries  are similiar to those in the pesticides industry  and
the  technologies are similarily effective in removing pollutants
common  to  the   separate  industries.   Physical/chemical   and
biological  treatment  system performance data  were  transferred
from  the OCPSF and pharmaceutical industries for solvents common
to  all  three industries (where raw waste levels  are  similar).
The  theory of each technology,  full-scale design and  operating
data, and treatability data are all discussed in Section VI.


Technologies  were analyzed to determine  their effectiveness  in
removing  each  individual or group of  priority  pollutants  and
nonconventional pollutant pesticides.  Based on this review, flow
diagrams  describing  the individual treatment  technology  units
were  developed  along with the design parameters  and  operating
criteria  which establish what constitutents a well designed  and
operated  treatment system.   Data were deleted if they failed to
meet editing criterion.   This criterion is discussed in  chapter
VI.
Based  on technology evaluations,  criteria expressed as  percent
removal  and  minimal  effluent levels were established  for  the
purpose  of determining best performing  plants.   This  criteria
provided  a  performance  description  of  a  well  designed  and
operated  BAT  treatment  system.    The data from  those  plants
meeting  these  criteria  were then used  to  develop  the  final
limitations.   The  discussion of best performing plants is  also
presented in Section VI.


Subcategorization


Factors  such as raw materials,  wastewater  treatability,  prior
regulatory   status,    wastewater   characteristics,   disposal,
manufacturing processes,  plant location,  age, and size were all
considered  prior  to  arriving at  the  final  Subcategorization
scheme.  Based  on these evaluations the manufacturing  processes
for  organic pesticide chemicals were placed in one  subcategory.
The   manufacturing   processes  for  metallo-organic   pesticide
chemicals  were  placed  in a second  subcategory  and  pesticide
formulating and packaging was placed in a third  subcategory.   A
further discussion of Subcategorization is given in Section VII.


Cost and Energy


As presented in Section VIII,  cost curves representing cost as a
function  of  flow  were  prepared for each  of  the  recommended
treatment  units.   The  design parameters used  in  establishing
these  cost  curves  were based on maximum  raw  waste  pollutant
concentrations.  The cost curves used in this report differ  from


                           111-17

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the curves used in the proposed development document.  The design
data were updated by the use of new  information from the Organic
Chemicals, Plastics and Synthetic Fiber (OCPSF) Industry Category
for  steam stripping and data provided by commentors on both  the
proposal  and  the  NOA.  A reevaluation showed that  both  steam
stripping  costs  and carbon regeneration costs  were  previously
overestimated  for the Pesticides Industry.   These  cost  curves
were  used to derive plant-by-plant capital,  annual,  and energy
costs.   All  other cost curves were updated since  the  proposed
development  document  was published and the revised cost  curves
are presented in Section VIII.


Nonwater Quality Impact


The  potential  air  and  solid  waste  effects  of   recommended
treatment are discussed in Section VI.
Selection of Pollutant Parameters


The  selection  of  pollutant parameters was based on  the  toxic
pollutant list in the case of priority pollutants as desirbed  in
Section  V.   In the case of nonconventional pesticide pollutants
it  was  based on the availability  of  analytical  methods,  the
presence  of  these  compounds  in  pesticide  wastewaters,   and
treatment  system performance data or data from another pesticide
from which a technology transfer of performance could be made.


Selection of Expanded Best Practicable Technology


The  Agency  proposed  expanding  the  1978  BPT  regulation   to
establish  BPT  limitations on BOD,  COD,  TSS and pH for  plants
manufacturing  21  of  the  23  pesticides  and  two  classes  of
pesticides  which  were previously excluded;  see Appendix  3  of
Section  XX.   The proposed expanded BPT was based on  biological
treatment  preceded in certain cases by hydroloysis or  activated
carbon  physical/chemical  treatment to  protect  the  biological
treatment  system.   The plants which produce these 21 pesticides
or  classes of pesticides already have this  treatment  in-place,
and  are  in compliance with limitations which are based  on  BPJ
(Best Professional Judgement) determinations by industrial permit
writers.  It  was  therefore  concluded  that  the  proposed  BPT
expansion  was not necessary and was therefore  not  promulgated.
The   BAT   regulation  will  control  the  priority   pollutants
discharged by these plants.
                           111-18

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Selection of Best Available Technology


Based on technical feasibility and actual performance data,  four
levels  of treatment were initially considered for  the  proposed
regulations.  Level  one  was based on BPT (pesticide removal  by
adsorption  or  hydrolysis  followed  by  biological  treatment).
Level  two  included  combinations  of  BPT  technologies   steam
stripping,   chemical   oxidation,   and   metals  separation  as
necessary.  Level  three  was based on level  2  technology  plus
effluent  polishing  through  the  use of a  dual  media  filter.
Level  4  was  based on level 3 plus  tertiary  activated  carbon
adsorption for final removal of dissolved organics.   The  design
effluents for each level of treatment were determined.   Then, an
evaluation  of the economic and technical aspects of implementing
regulations at the design effluents led to the selection of level
2 as Best Available Technology for the proposed  regulation.   As
discussed in Section XI, the BAT model treatment technology which
forms  the basis for todays regulation varies depending upon  the
pollutant.


Selection of_ NSPS Technology


NSPS is based on consideration of process modifications, in-plant
controls, and end-of-pipe technology, as defined in Section  XII.
NSPS   is  equal  to  BAT  for  the  organic  pesticide  chemical
manufacturer's  subcategory  and  equal  to  PSES  for  the   PPP
subcategory  but is excluded for the metallo-organic  subcategory
because of the potential small number of sources.


Selection of Pretreatment Standards Technology


The   PSES technology is the same as BAT for many of the NCPs and
two   priority  pollutants  controlled  in   the   manufacturer's
subcategory  because of the need for biological treatment.   Zero
discharge  of process wastewater pollutants requirement  for  the
other  two  subcategories  except  in the  case  of  mercury  for
subcategory  2 was derived based on the existing BPT  requirement
confirmed  as  appropriate by the additional analysis which  were
performed.   The  PSES  model  technologies  are  identified  and
discussed Section XIII.
Selection  of  BAT  and   NSPS  EffluentLimitations  and

Pretreatment Standards for Existing (PSES)  and New  Sources

(PSNS)

The  data  from  best  performing  wastewater  treatment   plants
presented in Section VI was used to determine pollutant long-term


                           III-19

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averages and variability factors.   From these results, which are
presented  in Section XIV and XV,  the daily and monthly  maximum
effluent   limitations   and  pretreatment  standards  for   each
regulated  pollutant  were  calculated,  such that  they  can  be
achieved  by well-operated plants a high proportion of the  time.


Environmental Assessment
As discussed in Section XVI,  an assessment of the  environmental
effects of implementing the promulgated standards and limitations
is  presented  in a separate document prepared by  EPA/Monitoring
and  Data  Support  Division.    This  assessment  projects   the
significance  of  post-regulatory discharges  of  nonconventional
pesticides and priority pollutants on human health, aquatic life,
and the operation of POTWs.


Appendices

Appendices  XX-1  through  XX-10 are provided to  list  important
reference  data  too  lengthy for the body  of  this  report  and
pollutant data that are helpful in interpreting the report.
                           111-20

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                      SECTION IV

                   INDUSTRY PROFILE
ECONOMIC AND INVENTORY DATA


This  section discusses the structure of the Pesticide  Chemicals
Industry  and  presents  economic  and inventory data related  to
this industry.


The   pesticide   chemicals  industry   includes   plants   which
formulate  and  package  pesticide  active  ingredients.     Most
formulator/ packagers generate little or no wastewater.  However,
wastewaters  that are generated through equipment  washes,  floor
washes, and air pollution control can contain high concentrations
of  pollutants.  Formulator/packager  information  is   presented
as   a subsection to this section.


Information  presented  in  this section includes  119  pesticide
manufacturing  plants  currently producing 248  pesticide  active
ingredients.  An additional 32 pesticide active ingredients  have
been  included  in the scope of this study but are not  currently
manufactured.  There is one known manufacture of  metallo-organic
pesticide  chemicals with an indirect discharge and approximately
1264 pesticide formulator/packagers.


Pesticide Utilization
The   major  classes of pesticides are presented in  Table  IV-1.
The  total  1977  production  volume   for   reported  pesticides
within    the    scope  of  this  study  was  approximately   1.6
billion   pounds   according   to  the  Industry    308   Survey.
Although   published   data  on industry output lag  as  much  as
three  to  four years,   it is  estimated  that  this  production
volume  accounts  for  more than 95 percent of the  compounds  of
interest.    A  1980  article  (Chemical   Week,   May  7,  1980)
estimates pesticide shipments of 1.7 billion pounds in 1978.  The
relative  percentage  of  production  for  pesticide  classes  is
consistent with prior data;  however,  a trend  toward increasing
volumes    of  insecticide  and  decreasing volumes of  herbicide
production   is  indicated.    The number  of   products   within
each  class of pesticides conforms roughly to the volume produced
for each class.
                        IV-1

-------
As reported by Eichers,  et al.  (1978),  the total pesticide use
for  farm  and   nonfarm  purposes  in 1976  was   estimated   at
1.67  billion  pounds.   Farmers used an  estimated  661  million
pounds  of all pesticides,  a 38 percent increase over 1971.   In
1976   a   total  of 394   million  pounds  of   herbicides   was
applied   by farmers,  an increase of  76  percent   over   1971.
The  leading   crop   herbicides  used by farmers  in  1976  were
atrazine  (90 million pounds) and alachlor  (89  million pounds).
In   1976,  162 million pounds of insecticides were used on  74.9
million  acres of major   field   crops,  hay,    pasture,    and
rangeland.    The   organochlorine insecticides accounted for  60
percent  of all farm  crop insecticides  in  1966,   46   percent
in   1971,   and 29 percent  in  1976.    The  increased  use  in
1976   of organophosphate  and  carbamate  insecticides helped to
reduce the  organochlorine  residue  problems  but  has increased
potential hazards to farm workers.   Although there has  been   a
shift   away  from  organochlorines,  toxaphene  was the  leading
insecticide used in 1976,  at 30.7 million pounds.  Toxaphene has
subsequently  been  dropped from production in 1984.   The  major
fungicides used in 1976 were    chlorothalonil    and      copper
compounds.  Approximately  43.2  million pounds (4.1  pounds  per
acre)  of  fungicides were applied in 1976.   The overall  growth
rate  of  pesticide  use  between  1971 and 1976 was 40  percent.
The  volume  of  exports was 621 million  pounds (36  percent  of
industry total) in 1978,  and exports are expected  to  reach  43
percent by 1990 (Chemical Week, May 7, 1980).


The primary factors behind the  1976/1977  growth  from  previous
years     are    increased    pesticide    usage    by   farmers,
particularly  on  cotton   and   soybeans crops,    and increased
foreign demand for domestic pesticides (NACA,  1978).   Pesticide
shipments are expected to increase by 7 percent per  year,  while
costs  are  predicted to rise 6 percent  per  year  through  1990
(Chemical Week, May 7, 1980).


The 1982 quantity of production was estimated from the production
quantities (in pounds) reported for 1977 in the 308  Survey,  and
was adjusted to reflect changes in production levels between 1977
and  1982.   Where current product-specific actual production was
available it was used.


The  U.S.  International  Trade Commission (ITC)  publishes  data
annually on the total quantity of active ingredients produced and
the  average unit value (dollars per pound) for  all  pesticides,
based  on  reports  of manufacturers.   The ITC data  shows  that
overall  production levels of pesticide active  ingredients  have
dropped  significantly  between  1977  and  1982.   In  addition,
production   levels  for  different  products  have  changed   at
different  rates.   Therefore,  the 1977 production level of each
pesticide reported in the 308 Survey was adjusted,  if no  actual
data  were available,  by applying the ratio of quantity sold  in
1982 to quantity produced in 1977 for the relevant product class.


                        IV- 2

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This  yields  an  estimate shown on Table IV-2  of  the  quantity
produced in 1982 (Meta, June 1984).


Structural Grouping of Pesticides


It  is  useful  to   examine  pesticides   in  terms   of   their
functional  groups.   Similarities in molecular weight, polarity,
and  solubility  may be found in  pesticides  with    the    same
structure.     These  similarities  may  translate  into  similar
levels  and  types  of pollutant generated  and  similarities  in
pollutant   treatability.    For  example,   hydrolysis treatment
under   the    proper    pH   and    temperature  conditions   is
effective  for certain triazine compounds because they possess  a
similarly  bound  chloride  ion which  can  be  displaced  by  an
hydroxyl  ion,   thereby  changing    the    nature    of     the
compound    to  a   hydroxytriazine.   Table IV-3 presents the 27
structural groups developed by EPA for the November 1982 proposed
regulations.   These  groupings  were also found to  be  a  valid
method  of  grouping  pesticides for the purposes  of  evaluating
treatability.  In a detailed analyses performed by EPA (Technical
Documentation   of   Technology  Transfer   for   Nonconventional
Pesticides,  1985,and  Report  to  the  Science  Advisory  Board,
"Technology Transfer for the Pesticide Chemicals Industry," March
21,  1983),  the 27 groups were found to be a technical basis for
transferring  treatability data from certain pesticide  compounds
to others.  This analyis is described in detail in the reference,
and is summarized in Section XIV and XV of this  report.  Further
identification   of  chemical  structure  and  configuration  for
typical  and major pesticides can be  found  in  BPT  development
document  (EPA 440/l-78-060e).   Pesticides  within  the scope of
this  study are defined by structural groups  in  the   Glossary,
Section  XIX.
Geographical Location of Plants


Figure   IV-1   presents  the geographical location  of  the  119
pesticide manufacturers included in or covered by this study.


Market Value of Pesticides
The   response  to the 308 Survey revealed that the  1977  market
value  for pesticides  covered by this  study  ranged  from   2.5
to 3 billion dollars.   Pesticide sales in  1978  were  estimated
to range  from  2.2 to 3.0 billion dollars (Chemical Week, May 7,
1980).


An  examination  of individual plant and  total  industry  market
value   ranges showed two major trends which were  considered  in


                        IV-3

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both  the  technical and economic  evaluation of  the   industry.
First,   as  shown  in Figure IV-2, almost half of the plants  in
1977  produced  products  with  an annual  market value  of  less
than  5  million  dollars for  all  pesticides  produced.    This
indicated   that  these plants  must  be  examined  closely  with
respect to  capital expenditures required for  pollution  control
facilities.   Second,  over  50  percent  of  the  total industry
market  value  is attributed to only 14  plants.  These    plants
have    a  greater  ability   to   finance    pollution   control
investments  as  well   as  to  maintain  staffs    capable    of
engineering,    operating,    and monitoring the control systems.
The   significance   of  this   concentration of  plants  at  the
extremes  of  market  value was further evaluated  in  terms   of
pollutant generation potential and technology requirements before
any    final  conclusions  were  drawn   concerning   appropriate
recommended  treatment  technologies and the resulting   economic
impact of this regulation.


The  estimated market value of pesticide active ingredients  sold
by  the  manufacturers  in  1982 is  based  on  the  unit  values
published  by  the International Trade Commission  for  subgroups
(classes)  which  they  have identified.   These  subgroups  have
correlated to the three main classes of pesticides  insecticides,
herbicides,  and  fungicides.   The  1982 total market  value  is
estimated  to  be $4.02 billion of which herbicides  account  for
$1.96 billion, insecticides for $1.76 billion, and fungicides for
$0.3 billion.


Level of_ Pesticide Production


Figure  IV-3  shows   that   the   distribution   of   individual
pesticide  production capacities is  skewed  toward  the low  end
of   the  scale.   In  1977,  the  Agency's  data  indicated  117
pesticide  plants made 248  discrete  pesticides  from  a   total
of  322 pesticide process sites.  Of the 322 processes, more than
44   percent  of  the  pesticides  were produced at  levels  less
than   10,000  pounds  per  day.   This is an indication of   the
specialized  nature and low demand for certain products.   Again,
it should be noted that there is a group of  14  to  18  products
with   high-volume,  heavy-usage   patterns  such as some  cotton
insecticides  or  selective  post-emergence  herbicides.    These
production   extremes  were  the  reason  the  Agency   performed
individual  plant  evaluations of the economic  impact  of   this
regulation.   Figure     IV-4   shows   the   annual   level   of
pesticide  production  for the 305 process  areas  with  reported
information.   More than  half  the  processes  produce less than
1 million pounds of pesticide per year.
                        IV-4

-------
In 1985, 119 pesticide plants made 248 discrete pesticides from a
total   of  327  pesticide  process  areas.    Current  pesticide
production   distribution  and  process-specific  production   is
similar to that demonstrated in 1977.
Number of Pesticides Produced Per Plant


Figure IV-5 demonstrates the highly  individual  nature of   each
pesticide   plant   and  the  narrow  product  base  from   which
business   is   conducted.     For   example,  approximately   95
percent of the plants produce no more than four pesticides, while
almost 50  percent  produce only  one.   When plants are found to
produce  more  than  one pesticide  the  products   are   usually
derived  from similar  reaction  chemistry,  thereby allowing the
same  unit  process   configurations  to  be  used   with   minor
changes  in raw materials.   Although several plants are known to
produce more than four pesticides  during  any one  year,  it  is
uncommon  for plants to run more than four to five process  lines
simultaneously.


Number of Days Each Pesticide Produced
The frequency of pesticide production for 1977 shown  in   Figure
IV-6   follows   the  same  pattern  as other  plant  operational
factors.  In this case, approximately 20 percent of all  reported
pesticides   were  produced less  than  30  days per year,  while
another  20  percent were produced for all 12   months   of   the
year.   This figure indicates the seasonal nature of the majority
of  pesticides  production,  along  with the  few  exceptions  of
continuous   production   for a group of  high- to  medium-volume
products.   Production frequency for 1985 is not available but is
assumed to be similar industry-wide to that reported for 1977.


Number of Plants Producing Pesticides


Figure IV-7 demonstrates the effect of patents  on  the operating
structure  of  the  industry.   Approximately 84 percent  of  all
patented  pesticides  are  only produced  by  individual  plants,
whereas after patent expiration each of the remaining 16  percent
is produced at from two  to four  different  plants.  These facts
contribute   to   the  difficulty  of  examining  and   comparing
wastewater  data among  identical  products.   There are  several
cases  where the same product is made  by  a different    process
by     different    plants,    thereby  resulting  in   different
pollutants, treatment technology required, and economic impact.
                        IV-§<

-------
Number of Plants Owned by Companies


As   demonstrated  in  Figure  IV-8,   approximately   73 percent
of   all   companies   own  only   one   pesticide  manufacturing
plant.   Of  the remaining 27  percent,   13 companies   own  two
plants  each,  four  companies  own four plants  each,  and  four
separate  companies  own  three,  five,   six,  and seven plants,
respectively.    The  above  illustrates  that  pesticide   plant
ownership  is generally not concentrated among a few   companies.
However,   it  should  be noted that certain companies may be the
sole producer of a pesticide sub-group.


Other Operations a_t Pesticide Plants


Another complicating factor in obtaining and evaluating data from
pesticide  facilities  is  that very   few   sites  produce  only
pesticide  active  ingredients.   Response to the  Industry   308
Survey  presented  in  Table IV-4 shows  that   approximately  59
percent  of  the  plants also  produce   pesticide intermediates.
In  addition,  approximately 76 percent of the  pesticide  plants
also   produce  other  miscellaneous  chemicals.  There are  only
seven  pesticide plants producing neither intermediates nor other
chemicals,  thereby  representing  less than 6  percent  of   the
industry.    More   than  90 percent   of  all  plants  have   at
least   one   shared treatment  system  for   pesticide  process,
intermediate  chemicals  process    and  miscellaneous  chemicals
process wastewaters.  This fact highlights the closeness of  this
industry   to  this  organic  chemicals  industry  in  terms   of
operators,    wastewater   characteristics,   treatment   methods
employed, and effluent characteristics.


Methods 
-------
Type of Wastewater Treatment


Tables  IV-6 and IV-7 identify the more than 30 different   types
of wastewater  treatment technologies  used.


There   are  45  plants  that  dispose  of wastewater  by  direct
discharge   to   navigable   waters.    In-plant  treatment  with
activated   carbon,    resin  adsorption,   hydrolysis,  chemical
oxidation,    steam    stripping,    or    metals separation   is
used  by  23 direct dischargers.   Further explanation   of   the
design   and  operation  of  these treatment  units  is  provided
in Section VI.   There are 28 discrete plants included  in  Table
IV-6   that   use biological  treatment for direct  discharge  of
pesticide wastewater.   Biological  systems  may  consist  of  an
aerated  lagoon,   activated  sludge  unit, or trickling filters.
Post-biological     or    tertiary    treatment   consisting   of
multimedia  filtration  or  activated carbon is   used   by   six
direct   dischargers.    There  are 38  discrete    manufacturers
included     in    Table    IV-7  discharging   to   a  municipal
treatment   system,   of  which  seven  plants  treat   pesticide
wastewater   by   activated   carbon,      resin      adsorption,
hydrolysis,    chemical oxidation, or steam stripping.  More than
20 percent of the  indirect dischargers  do  not  treat  at least
one pesticide waste stream.


Formulator/Packagers


In  formulating and packaging,   the raw   materials   used   are
the    pesticide   active  ingredients  which  may  be   procured
from   outside suppliers   or   may  be  manufactured  on   site.
The processing is    mechanical   and physical/chemical in nature
and  consists  of    formulating,    blending,    canning,    and
packaging operations.   The levels of  wastewater generation  and
contamination    are  considerably  lower  than  in  the  active-
ingredient   production,   and   are   sometimes     nonexistent.
Pesticide   formulations   and  packaged    products    generally
fall     into    three classifications:    water-based,  solvent-
based,  and dry-based.   Types of formulations include   powders,
dusts,  wettable     powders,     emulsifiable    concentrations,
granules, and aerosols.


EPA   proposed  no  discharge  of  process  wastewater   as   the
pretreatment  standards for existing indirect discharge pesticide
chemicals  formulator/packagers.   The Agency assumed that  these
indirect  dischargers would conduct the same types of  operations
and  would  incur  the  same  levels  of  costs  as  the   direct
dischargers  for  whom  zero discharge BPT  effluent  limitations
guidelines   and  standards  were  promulgated  in  1979.   Since
proposal,    EPA   has   acquired   additional   data   on    the
formulator/packager segment of the industry.  The Agency surveyed


                        iv- g

-------
approximately   32  percent  of  the  3980   formulator/packagers
registered  under  the  Federal  Insecticides,   Fungicides,  and
Rodenticides Act (FIFRA).  EPA randomly selected 1263 plants from
the  FIFRA list for initial contact through a phone survey,  then
followed up with questionnaires under 308 of the Clean Water  Act
to  potential indirect dischargers and to non-respondents to  the
telephone survey, (see Section XX -  Appendix 5).  The Agency, in
cooperation   with   representatives  from  industry  and   trade
associations  such  as the  Chemical  Specialities  Manufacturers
Association  (CSMA),  National Agricultural Chemical  Association
(NACA),  and the Pesticide Producers Association (PPA), developed
the   questionnaire  specifically  for  the   formulator/packager
segment  of the industry.   This questionnaire was mailed to  221
formulator/packagers  that indicated in the telephone survey that
they were indirect dischargers.   These questionnaires  solicited
information  on  types and volumes of  wastewaters,  methods  and
costs  for  disposing of these wastewaters,  discharges  of  both
nonconventional  and toxic pollutants,  the types of treatment in
place at the facility and the viability and achievability of  the
zero discharge standard.


The   Agency   excluded  formulators/packagers   which   produced
sanitizers,  disinfectants,  inorganics  or surface active agents
from  the  308 survey.   Subsequently,  the Agency  also  deleted
plants   which  only  formulate  and  package  pesticide   active
ingredients  for  which  there are  no  proposed  or  promulgated
analytical methods.   The results of the sample were extrapolated
to the total universe of 3980 plants on the FIFRA list.  Based on
public  comments and follow-up contacts the Agency corrected  and
adjusted the collected data.   The process for acquiring the data
and for making corrections is described in the report "Evaluation
Of  Regulatory  Options  And  The Development Of  PSES  and  NSPS
Compliance  Costs  For The Pesticide  Formulating  And  Packaging
Industry",   which  is  in  the  public  record.    Through  this
procedure,  the  Agency  determined that there are  approximately
1264 PFP plants of which about 169 discharge indirectly and about
1095  do  not discharge.   The remaining 2716 plants  are  either
closed,    foreign,    duplicates    or   are    not    pesticide
formulator/packagers.


The   scale  on  which  pesticides are formulated covers a  broad
range.   Many   of  the   small  firms  have  only  one   product
registration, and produce only a few hundred pounds of formulated
pesticides  each   year.  However one  plant  operating  in   the
range  of 100,000,000 pounds of formulated product per  year  has
been  identified.


Pesticide formulating and packaging product market value averages
$8.21 million per plant for low flow plants and $55.5 million per
plant  for high flow plants.   Production frequency  averages  28
weeks  annually  per  plant with only a few plants  operating  52
weeks annually.


                        IV-8

-------
At  formulating and packaging plants,  contaminated  wastestreams
are a small percent of the total wastes which are generated.


Zero discharge of process wastewater pollutants is being achieved
by 87 percent of all pesticide formulating and packaging  plants.
Contract hauling has been costed  as a no discharge technology at
low  flow plants,  whereas wastewater treatment and reuse appears
to be a less costly means of achieving no discharge at high  flow
plants.   For  a  more detailed discussion of the PFP  study  see
Evaluation  of Regulatory Options and the Development of PSES and
NSPS compliance costs for the Pesticide Formulating and Packaging
Industry, August 30, 1985.


Metallo-Organic Pesticide Manufacturers


Metallo-organic  pesticides include all compounds  with  metallic
bases  of  arsenic,   cadmium,   copper  and  mercury.    In  the
manufacturing   process  for  metallo-organic   pesticides,   the
principal sources of wastewater are: byproduct stripping, product
washing,  caustic scrubbing, tank and reactor clean-out, and area
washdowns.
The  promulgated  BPT  regulation for this  group  of  pesticides
requires  zero discharge of process wastewater  pollutants.   All
manufacturing sites achieved zero discharge.   However,  EPA  has
subsequently  identified one manufacturer producing mercury-based
metallo-organic compounds that has a discharge to a POTW.   After
evaluating  the data from this plant,  the Agency  has  concluded
that treatment of the process wastewater followed by discharge at
this one facility is an environmentally acceptable alternative to
incineration or contract hauling, the BPT recommended technology.
This issue is discussed in detail in Sections VI,  VII,  XII, and
XV.
                        IV-9

-------
Table IV-1.  Pesticide Production by Class (1977)
Class
Insecticide*
Herbicide
Fungicide*
Pungicide/Bactericide
Rodent icide
Plant Growth Regulator
Protectant
TOTAL
Number of
Products
108
86
60
15
9
1
1
280
Production Volume (1977)
Million Ibs
846
554
229**
NA
2
4
NA
1,635
Percent
51.74
33.88
14.01**
NA
0.12
0.25
NA
100
 * Includes miticides, nematicides, repellants, insect synergists,
   fumigants, insect growth regulators, insecticides.

 + Includes algicides and molluscicides.

** Include both fungicides and fungicide/bactericides.

++ Production not available from 30 (9.3 percent) of 322 process
   sites.

NA Not available
                        IV-10

-------
Table IV-2.  Estimated Pesticide Production by Class (1982)
Class
Insecticide*
Herbicide
Fungicide*
Fungicide/Bactericide
Rodenticide
Plant Growth Regulator
Protectant
TOTAL
Number of
Products
108
86
60
15
9
1
1
280
Estimated Production
Volume (1982)
Million Ibs
621
476
155**

2
3
NA
1,257++
Percent
49.40
37.87
12.33**

0.16
0.24
NA
100
 * Includes miticides, nematicides, repellants, insect synergists,
   fumigants, insect growth regulators/ insecticides.
 + Includes algicides, bactericides, mulluscicides.
** Includes both fungicides and fungicide/bactericides
++ Production not available from 35 (10.7 percent) of 327 process
   sites.
NA Not available
                        IV-11

-------
Table IV-3.  Structural Grouping of Pesticides
                                              Number of Pesticides
Structural Grouping of Pesticides                   in Group


Aldrin-Toxaphene                                         7
Amides                                                   9
Amide type                                               4
Botanicals                                               5
Carbamates                                              15
Chlorinated Aryloxyalkanoic Acids and Esters            15
Cyanates                                                 3
DDT type                                                 7
Dioxin type                                              1
Halogenated Aliphatics                                  10
Halogenated Aromatics                                   23
Heterocyclic with Nitrogen in the Ring                  20
Metallo-Organic*                                        14
Nitro                                                   13
Nonhalogenated aliphatics                                1
Nonhalogenated aromatics                                 8
Nonhalogenated Cyclic Aliphatics                         1
Organo Nitrogen-Others                                  17
Organo Sulfur                                            5
Phosphates and Phosphonates                              5
Phosphorothioates and Phosphorodithioates               36
Phosphorus-Nitrogen                                      6
Thiocarbamates                                          14
Triazines                                               14
Uracils                                                  2
Ureas                                                   11
Noncategorized Pesticides                               14

   TOTAL                                               279


* Does not include mercury, copper, cadmium, and arsenic-based
  products.
                           IV-12

-------
Table IV-4.  Types of Operations at Pesticide Plants (1985)


Type of Operation              Number of Plants    Percent of Total
 ^_ •• «^ ^^ *w» «

Manufacturer of Pesticide            119                   100
Active Ingredients

Manufacturer of Other                 90                    75.6
Miscellaneous Chemicals

Manufacturer of Pesticide             70                    58.8
Intermediates

Formulator/Packager                   57                    47.9
of Pesticides
                        IV-13

-------
Table IV-5.  Methods of Wastewater Disposal at Pesticide Plants
             (1985)

Type of Wastewater Disposal              Number of Plants*

Direct Discharge to Navigable Waters             45
Indirect Discharge (POTW, etc.)                  38
Deep Well Injection                              18
Incineration                                     15
No Wastewater Generated                          11
Contract Hauling of all Wastewater                9
Evaporation Ponds                                 6
Land Disposal                                     5
Not Available                                     2
* There are a total of 119 plants in the industry; however, many
  have more than one means of disposal.
  Includes wastewater which is recycled, reused, or because no
  wastewater is generated.
                        1V-14

-------
Table IV-6.  Treatment Utilized at Plants Disposing Pesticide
             Wastewaters to Navigable Waters
 __ __ __ ^.v .^ ^_ ..H ^_ _. _ ^_ ^_ _ ^_ ^_ .«- —_ _« .••» —I— ^B» «•• ^M <«• ^_t ••• <^B •_ ^B> -^BB V

Type of Wastewater Treatment             Number of Plants*


Activated Carbon                                 17+
Activated Sludge                                 17
Aerated Lagoon                                   17
Aerobic Digestion                                 2
Anaerobic Digestor                                1
API-Type Separator                                1
Chemical Oxidation                                7
Coagulation                                       5
Cyanide Detoxification                            1
Equalization                                     32
Evaporation Pond                                  2
Flocculation                                      4
Gravity Separation                               28
Hydrolysis                                        6
Liquid-liquid Extraction                          1
Metal Separation                                  2
Multimedia Filtration                             7**
Neutralization                                   31
None                                              2
Nutrient Addition                                 1
Pressure Leaf Filter                              2
Resin Adsorption                                  2
Skimming                                          8
Sludge Thickening                                 1
Solvent Extraction                                1
Stripping                                         4
Trickling Filters                                 3
Vacuum Filtration                                 1
Wet Scrubber                                      5
 * There are a total of 45 plants disposing to navigable waters;
   some use more than one type of wastewater treatment.

 + Activated carbon used as tertiary treatment in five waste
   streams.

** Multimedia filtration used as tertiary treatment in two
   waste streams.
                        IV-15

-------
Table IV-7.  Treatment Utilized at Plants Disposing Pesticide
             Wastewaters to POTWs


Type of Wastewater Treatment             Number of Plants*


Activated Carbon                                  2
Activated Sludge                                  3
Aerated Lagoon                                    2
Chemical Oxidation                                1
Coagulation                                       2
Crystallization                                   1
Equalization                                     11
Evaporation Pond                                  1
Flocculation                                      2
Gravity Separation                               14
Hydrolysis                                        1
Multieffect Evaporation                           1
Multimedia Filtration                             2
Neutralization                                   24
None                                              8
Not Available                                     1
Resin Adsorption                                  2
Skimming                                          6
Sludge Thickening                                 1
Stripping                                         3
Vacuum Filtration                                 2
Wet Scrubber                                      1


 * There are a total of 38 plants disposing to POTWs; some use more
   than one type of wastewater treatment.
                        IV 16

-------
Table IV-8.  Formulator/Packager Production Distribution
    Production                            Percent
(million Ibs/yr)                    Formulator/Packagers
    <0.5                                   24

 >0.5 to <5.0                              41

 >5.0 to <50                               35




    TOTAL                                 100
                        IV-17

-------
Table IV-9.  Percent of Formulator/Packager Pesticide Classes





       Class                              Percentage







  Herbicides                             40.0



  Insecticides                           32.0



  Fungicides                             19.4



  Fumigants                               8.6





  TOTAL                                 100
                        IV-18

-------
           400 MACS
r
•OOKHAMETOtt
  Figure IV  Geographical Location of Pesticide Chemicals Manufacturers
             (Total of 119 Plants)

-------
            0     5     10     25    78    >T5

           INDIVIDUAL PUNT MARKET VALUE RANGES
               (MILLIONS OF DOLLARS /YEAR)
          1800
                                     13M
             0     5     10    2ft    n   >7B
            INDIVIDUAL PLANT MARKET VALUE RANGES
               (MILLIONS OP DOLLARS /YEAR)
           (1) MARKET VALUE RANGES FOR 8 OF 117
              PLANTS NOT AVAILABLE
FIGURE 1V-2.   MARKET  VALUE  OF PESTICIDES (1977)
                      IV-20

-------
1
140-

130.
120.
110-
100-

H M-
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Q. TO-
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a
Z 50.
40.
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C*X*X*X*X*»* X"»*X*X*X*X*
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1 1 fl M|
0 20 30 40 50 80 70 80 90 100 >100
LEVEL OF PRODUCTION (1000 lb» /day)
(1) LEVEL NOT AVAILABLE FOR 45 (14%) OF 322 PROCESS SITES
FIGURE IV-3 DAILY LEVEL OF PESTICIDE PRODUCTION
(1977)
IV-21

-------
160-i
150-

140-

130-
120-
110-


100-
-. 90-
OT
U
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SSSSSS? i-xS$i$ * 5
^SSS S=x^i ^^x?i 5T55533 1 1 0 0 1
I " i " I 4 i li° 136 1~
LEVEL OF PRODUCTION (MILLIONS OF POUNDS/YEAR)
(1) LEVEL NOT AVAILABLE FOR 17 (5%) OF 322 PROCESS SITES
Figure IV-4 ANNUAL LEVEL OF PESTICIDE PRODUCTION (1977)
IV-22

-------
         i  as  4  s  17  i  • 10 11 ta 11 14 11 it 17 11 it to
                            PRODUCED PTO PLANT
NUMBER OJP	
  (1) Ni  117 PLANTS
FIGURE IV-5
 NUMBERlPF PESTICIDES PRODUCED
 PER  PLANT (1977)
                     IV-23

-------
                                                       48

       30    60   90   120   160   180  210   240   270   300

         NUMBER OF DAYS EACH PESTICIDE PRODUCED  (1977)
330
366
   (1) FREQUENCY NOT AVAILABLE FOR 48 (14.3%) OF 322 PROCESS SITES
 FIGURE IV-6  FREQUENCY OF PESTICIDE  PRODUCTION
	(1977)	

                         IV-24

-------
        NUMBER OF PLANTS EACH PRODUCING THE SAME PESTICIDE
             (1) n : 246 PESnCDES
RGURE IV-7  NUMBER OF PLANTS EACH PRODUCING
             THE SAME PESTICIDE  (1977)
                     IV-25

-------
           M -i
                1     a     a     4     s     a    r
             NUMBER OP PLANTS OWNED BY EACH COMPANY
             (1) n 3 76 COMPANIES
Figure IV-8 NUMBER OF PLANTS OWNED BY EACH COMPANY (1977)
                        IV-26

-------
                            SECTION V

                 RAW WASTE LOAD CHARACTERIZATION

     ORGANIC PESTICIDES CHEMICALS MANUFACTURING SUBCATEGORY
The  purpose of this section is to present information on the raw
waste  load  and  process wastewater characteristics for the  280
pesticides   covered  under  the organic pesticide  manufacturers
portion  of this  study  in  terms   of the priority  pollutants,
conventional,  and  nonconventional parameters  originating  from
these processes.  The term "raw waste load," as utilized  in this
document,  is  defined as the quantity of pollutant in wastewater
prior  to a  treatment  process.  The flow of the raw  waste   is
normally expressed in terms of million gallons per day (MGD),  or
gallons of wastewater per 1,000 pounds  of  pesticide  production
(gal/1/000   Ibs).     Raw   waste   load   characteristics   are
normally expressed in milligrams per liter (mg/1) or  pounds   of
pollutant    per    1,000   pounds   of    pesticide   production
(lbs/1,000 Ibs).


In  order to assess  the  pollutant  potential  for  the  organic
pesticide  chemical manufacturing industry  as  a whole,  it  was
necessary to approach the task from two  directions:  first,  all
available  raw waste load data were collected from the BPT study,
from pesticide manufacturers'   responses   to   the  308  Survey
and subsequent follow-up letters,  from screening  sampling, from
the  verification  sampling  program conducted at  16   pesticide
plants,  and  public  comment  responses  to  the  November  1982
proposal, June 13, 1984 NOA and January 24, 1985 NOA.  Second,  a
process chemistry evaluation of each pesticide was  conducted  in
order   to   determine  which  pollutants   were   likely  to  be
present.   Data  presented  within this section are  typical  raw
waste  loads  gathered  from  BPT  through  BAT  proposal.   Data
subsequent  to  BAT  proposal have been thoroughly  reviewed  and
evaluated  with  the results included in subsequent  sections  of
this document but are not included in this section since the  new
information  reaffirms  the Agency's previous conclusions on  raw
waste loads.
The   flow,   concentration   and  mass  per  unit  of production
were  calculated for each pollutant  at  each plant  where   data
were  available.   Pollutant  concentration  data was   evaluated
according  to  groups of priority pollutants which are similar in
chemical/physical   characteristics   and which are  measured  by
similar chemical analytical methods. Section XIX—Glossary,   and
Section     XX-Appendix    1,     provides   identification    of
specific  compounds  within  each priority pollutant group  which


                           V-l

-------
are  included  in  the scope of this study.


Priority   pollutants   likely to be present were  determined  by
conducting  a  process chemistry evaluation   for  each  pesticide
process.     The   possible   sources  of   the  pollutants  were
identified  as:  the manufactured product itself,   raw materials
used   in  pesticide    synthesis,   impurities   in  either  the
product  or  raw  materials,  byproducts of  synthesis  reactions,
solvents  used   as   a carrier   medium,  solvents  used  as  an
extraction medium, impurities   in   solvents,    catalysts,   and
impurities in the catalysts.


The  Agency  conducted these evaluations by  examining  propietary
process  chemistry  diagrams supplied  by manufacturers.   These
proprietary  diagrams  are  the bases for  some  of  the  process
chemistry  evaluations.   Supplemental  literature was also  used
which includes Considine (1974), Entomological  Society of America
(1974),   Kirk  and  Othmer  (2nd  Ed.),   Sittig   (1980),   SRI
International  (1979),  Ware  (1978),  Weast (1974) and  Worthing
(1979).   Process conditions such as pH,  temperature,  pressure,
and reaction time were considered in the evaluations.
The  Agency  proposed these evaluations  in  November  1982.   In
response to public comment, some modifications were considered as
set  forth in the June 13,  1984 NOA.    In response to the public
comment  on  the NOA additional  modifications  were  made.   The
process chemistry evaluation for the final regulation was done in
the following manner.


1.    An abbreviated process description was developed for all of
the pesticide products listed.    In some cases,  synthetic routes
to  the  raw  materials  were  also  developed.    These  process
descriptions  were developed and/or checked for applicability  to
specific plants by reference to five sources:

     a.   "Pesticide  Manufacturing and  Toxic Materials  Control
          Encyclopedia"  by Sittig.   This book is  based  on the
          patent literature and other  publicly available sources.

     b.   "The Pesticide Manual" by  the  British Crop Protection
          Council.  This  book   is based on the patent literature
          and other publicly available sources.

     c.   A   5-volume   confidential    review   of   pesticide
          manufacturing  processes prepared by an EPA  contractor
          and used to develop the  list in Section XX-Appendix 6.
          The  confidential 5-volume series incorporated comments
          submitted  on  the  proposal  concerning  the  priority
          pollutants   regulated   as   a result  of  our  process
          chemistry  evaluation.   If  there were questions  about
          the  process  review,  sources  (d) and (c)  were  also


                           V-2

-------
          utilized.

     d.   Process flow diagrams and other information in the  308
          questionnaire   submitted   by   the   plant(s)    that
          manufactured a particular pesticide product.

     e.   Direct   phone  contact   with   plant  (or  corporate)
          environmental   staff    that   submitted    the    308
          questionnaire, or by their referral to a plant  process
          chemist that was qualified to answer specific questions
          about  the  process  descriptions  given  in  the   308
          questionnaire.


2.    The  priority pollutants listed for each pesticide  product
were  examined  for  consistency with  the  process  descriptions
developed  in  Step  1.   For each  pesticide  product,  priority
pollutants were retained, added or deleted to make the associated
priority   pollutants  consistent  with  the  chemistry  of   the
respective processes.


3.    When the associated priority pollutants contained more than
one  member  of  a  generic  group  (e.g.,   chlorophenols),  the
predominant member of the group was listed for control,  and  the
other members were deleted.   This listing criterion was based on
the  fact  that  treatment to control the member present  at  the
highest  concentration would also control the other members  that
are present at lower concentrations.  Predominance was determined
principally   by  whether  the  pollutant  was  a  raw  material,
solvent,  product or byproduct in the process.  If one member was
a  raw material and an'other member was a solvent,  both would  be
considered predominate and acccordingly listed.  If none of these
process  ingredients was a priority pollutant,  then listing  was
determined by whether the pollutant was a likely impurity in  the
process ingredients.

Exceptions to the listing criterion were:


     a.   If  members  of the group were not amenable to the same
          or similar  control technology,  they were not deleted.
          For  a discussion of the treatability of pollutants  by
          the  same or similiar treatment technology see  chapter
          VI of the Development Document.  In  this case, members
          not  treatable  to  the  same  control  technology were
          listed separately  (e.g., chlorophenol vs.
          pentachlorophenol).


     b.   If all members of the group occur only as impurities in
          the process ingredients,  then all were retained in the
          listing.   in  this case,  there is no obvious means of
          establishing predominance.
                           V-3

-------
4.    Once  an independent process chemistry evaluation had  been
performed  pursuant to steps 1-3,  an evaluation was made of  the
NOA  comments  concerning the priority pollutants regulated as  a
result  of  our  process  chemistry  evaluation.   If  commenters
recommended that a priority pollutant be either added or  deleted
and their rationale was not obvious given steps 1-3, as described
above,  the  Agency  reviewed  the appropriate  308  data  and/or
telephoned the commenter to determine whether or not the priority
pollutant was associated with the manufacturing process.  If as a
result  of these steps a revision was considered appropriate,  it
was made.


The   indicated and detected presence  of  pollutants derived  in
this   manner   is   presented  in  Tables   V-l  through   V-30.
These   typical  data are also utilized in  later  sections    of
this    report   to  provide  a basis for design and costing   of
recommended  treatment  systems  and   to provide a basis for the
selection of priority pollutant parameters to be regulated.


FLOW
The process wastewater  flow  for  each  pesticide  was evaluated
to  determine the amount of flow per unit of pesticide production
(gal/1,000  Ibs)  and  the  amount   of  flow   (MGD)   from  all
pesticides produced at individual plants.


Figure  V-l  presents a  probability  plot  of  the   flow  ratio
(gal/1,000   Ibs)  for  269  of the 327 pesticide process   areas
for which   data   were   available.  Significant  information in
this  figure shows that:   11 percent of all pesticide  processes
have  no  flow;  50  percent  of all  pesticide  processes   have
flows  equal  to  or less than 1,000  gal/1,000   Ibs;   and   84
percent   (approximately    one  standard  deviation   above  the
median)  have flows equal to or less than 4,500  gal/1,000   Ibs.


Figure   V-2   presents  a  probability plot of  pesticide  flows
(MGD) at individual plants.   This  figure  shows that 50 percent
of  all  plants  have  flows  less  than  0.01  MGD,   and   that
virtually  all plants (98 percent) have flows less than 1.0  MGD.
In   Section  VIII  of  this report  treatment   cost   estimates
are based on the range of flows from 0.01 to 1.0 MGD.


Flows  reported  in the tables presented later in  this   section
represent  the  flow  measured at the given  sample  point  which
generally  does not represent either the pesticide  process  flow
or total plant flow (see tables listing  pollutants  detected  in
pesticide   process wastewaters).
                           V-4

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PRIORITY POLLUTANTS


An   overview  of  the  detected/indicated  frequency of priority
pollutant groups is presented  in  Table  V-l.  These  data  show
that   even  the  most  prevalent  pollutant   group,    volatile
aromatics,   is   indicated to be present in   only approximately
42  percent of the 280 pesticides in the scope   of   study.    A
specific    discussion   of   the significance  of each  priority
pollutant  in  relation to this industry is provided  in  Section
IX.   An  evaluation was conducted of the frequency of occurrence
of priority pollutants in pesticide process wastewaters, based on
308  questionnaire  data and  verification  sampling  data.   The
following  results  reflect  a  review  of  proposal  and  notice
comments  submitted  by  industry  and others as well  as  a  re-
evaluation  of  pre-existing  information  on  the  frequency  of
occurrence   of   priority  pollutants  in   pesticides   process
wastewaters   presented  in  the proposal.   Any  data  that *was
provided  was  reviewed  for  technical  quality  and  analytical
acceptability and incorporated into the process chemistry review.
Quality assurance/quality control guidelines used in their review
are discussed in Section III.


Priority pollutants which were detected in pesticide  wastewaters
or  indicated  to  be  present based  on  the  process  chemistry
evaluation  were  identified for each  nonconventional  pesticide
manufacturing  process regardless of the regulatory status of the
active ingredient.


Due to the variety and uniqueness of the pesticide  manufacturing
processes,  some  general  assumptions  were  used  to  determine
relative  concentrations  between  pollutant types  such  as  raw
materials   and   solvents,   and  byproducts   and   impurities.
Sufficient  information,  such  as kinetic measurements  for  all
reactions,  was  not  available to determine rates  of  pollutant
formation.    However,  general  assumptions  regarding  relative
quantitation were made based on knowledge of generalized chemical
reactions,   physical  processes,   reaction  sequence,  reaction
completion,  and  unreacted  feedstocks typical of all  pesticide
processes.    These  general  assumptions  were  verified  by  an
inspection of standard handbooks of chemistry,  by evaluation  of
308  questionnaires,   and  by  follow-up  plant  contacts.   The
following   general   assumptions,   upon  which  some   specific
assumptions depend, have been implicitly used.


1.   All chemical feedstocks are of less than 100 percent purity.
     The   contaminates  of  feedstocks  may  be  classified   as
     impurities or reaction byproducts.   The impurities that may
     be  present  in  feedstocks  are considered to  be  the  raw
     materials,  solvents, catalysts, and other compounds used in
     feedstock  synthesis.   In  regard to  chemical  feedstocks/


                           V-5

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     reaction  byproducts  are  secondary  compounds  formed   in
     feedstock  synthesis.   The process for producing a chemical
     feedstock  is based on information from Merck  Index  (1976)
     unless  otherwise  noted.   Although not always  true,  this
     process  is  assumed to be the  actual  industrial  chemical
     synthetic  route  employed by the supplier to the  pesticide
     plants.


2.   A  suspected impurity is assumed to be inert with regard  to
     the chemical reactions of pesticide synthesis.


3.   Unless information was available to the contrary, impurities
     in a raw material, solvent,  or catalyst used in a  pesticide
     process  are  not  suspected as wastewater  constituents  in
     significant quantities.


4.   Chemical  feedstock  reaction byproducts are assumed  to  be
     present  in  negligible  quantities and  are  therefore  not
     expected  to  be  present in a wastewater  produced  from  a
     pesticide  synthesis  using  that  chemical  feedstock  (see
     assumption  1  above).   Hexachlorobutadiene,  HCBD,  is  an
     exception  to this assumption.   HCBD is a byproduct  of the
     hexachlorocyclopentadiene, HCCPD, synthesis reaction, but it
     is  known  to  exist  in  high  concentrations   in  the  raw
     material.
5.   Reaction  byproducts are any compounds other than the  final
     product  that are formed during pesticide  synthesis.   They
     may  result from either the main synthesis reactions or  the
     side  reactions  described as  byproduct  reactions.   These
     byproducts   of  main  synthesis  reactions  are   sometimes
     referred to as co-products.


6.   If  members of a priority pollutant group are expected to be
     present  in a process wastestream,   then only the  pollutant
     likely  to  be most prevalent was selected as  the  effluent
     limited  priority pollutant for a priority pollutant  group,
     because technology used to control  the most prevalent  member
     adequately controls the other group members.


7.   If the chemical of concern in a process wastestream is not a
     priority  pollutant,  but  is typically associated with  low
     levels of priority pollutants,  then the associated priority
     pollutants would be considered.


These  general  assumptions provided support for the  qualitative
specific  assumptions found in each pollutant  group  subsection.
Specific  groups of pollutants were identified for the  Pesticide


                           V-6

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Industry.   Fourteen  priority pollutant groups are addressed  in
this   report.    Arranged   in  alphabetical  order  by   group,
confidential  Tables  1  through 14  found  in  the  confidential
addendum  to this document list the priority pollutants indicated
to  be present in pesticide process  wastewaters.   These  tables
also  depict  the  pollutant  source for each  pesticide  as  raw
material, solvent, catalyst, impurity, or byproduct.  Much of the
information  presented  in  these tables has  been  submitted  in
response  to  Agency's  request  for  information.    Information
requested  pursuant to Section 308 may not be withheld  from  the
Agency  on  the  ground  that it is  considered  confidential  or
proprietary.   Section 308(b), however, does accord protection to
trade  secrets.   As such,  some of the information  relating  to
production   processes   and  materials  has  been   claimed   as
confidential  and pesticide names and plant names are coded where
appropriate throughout this document.


Section  XX-Appendix  6  presents  a  listing  of  the  indicated
priority pollutants for each nonconventional pesticide.   It  was
determined  that  for  12 pesticides produced at  more  than  one
plant,  the  priority pollutants indicated to be present differed
from  plant to plant based on the manufacturing process  at  each
plant.   The  priority pollutants listed for these pesticides are
specified  by  plant  in  Appendix  6.    The  list  of  priority
pollutants  indicated  to be present was evaluated  by  pollutant
group  to  identify the pollutants of  primary  significance  for
regulation.   This evaluation paralleled that which was conducted
for  proposal and presented in the Proposed Development Document.


A  discussion  of the process chemistry  evaluation  employed  to
predict  the  priority  pollutants in  pesticide  wastewaters  is
presented  by  group  as follows in order of  prevalence  in  the
industry.


Volatile Aromatics
Benzene  and  its  derivatives  are used  widely  throughout  the
chemical  industry  as solvents and  raw  materials.   Table  V-2
contains  a  coded  list  of  the  suspected  presence  of  these
compounds  in the pesticide industry.   Table V-3 list historical
data  typically  detected in pesticide  process  wastewaters  for
volitile aromatics.
Mono-, di-, and trichlorobenzenes are used directly as pesticides
for  their  insecticidal  and  fungicidal  properties.   Benzene,
toluene,  and  chlorobenzene  are  used as raw materials  in  the
synthesis of at least 15 pesticides,  although their main use  is
as  a  carrier  solvent in 76 processes.   It is  predicted  that
additional priority pollutant aromatics and chlorinated aromatics
exist  as impurities or reaction byproducts due to the  reactions


                           V-7

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of the basic raw material and solvent compounds.


Process  descriptions  were  developed  for  all  the   pesticide
products  listed.   These  process  descriptions  were  developed
and/or  checked for applicability to specific plants by reference
to  the  five sources mentioned earlier  in  this  section.   The
volatile  aromatic listed for each pesticide product was examined
for consistency with process descriptions reviewed.   Assumptions
were  then  drawn from this examination to provide  a  basis  for
developing  the list of volatile aromatics suspected in pesticide
waste streams.  The assumptions are as follows:


1.   When  xylene  is  used as a solvent  in  the  process,  then
     impurities such as benzene,  toluene,  and ethylbenzene  are
     suspected to be present.


2.   When  trichlorodiphenylethane in a benzene solution is  used
     as  a raw material,  then benzene is suspected to be present
     as a raw material impurity.


3.   When toluene sulfonic acid is used as a raw  material,  then
     tol'uene  is  suspected  to  be present  as  a  raw  material
     impurity.


4.   When  parachlorobenzotrifluoride is used as a raw  material,
     then  chlorobenzene  is  suspected to be present  as  a  raw
     material impurity.


5.   When  1,1,1-trichloro - 2,2-diphenyl ethane is used as a raw
     material,  then benzene is suspected to be present as a  raw
     material impurity.


6.   When  tetrachlorobenzene  is used as a  raw  material,  then
     1,2,4-trichlorobenzene  is suspected to be present as a  raw
     material impurity.  Hexachlorobenzene was also identified by
     the  pesticide  manufacturer  as  a byproduct  in  the  PCNB
     process.


7.   When  producing the pesticide  DCPA,  hexachlorobenzene  was
     identified  by  the manufacturer as a byproduct  during  the
     esterification reaction.


8.   When   bis-chloromethyldodecyltoluene  is  used  as  a   raw
     material,  then  toluene is suspected to be present as a raw
     material impurity.
                           V-8

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9.   When  DDT is used as a raw material,  then chlorobenzene  is
     suspected to be present as a raw material impurity.


10.  When  p-toluene sulfonic acid is used as  a  catalyst,  then
     toluene  is  suspected to be present as an impurity  in  the
     catalyst.


11.  During  the  chlorination  of benzene,  byproducts  such  as
     chlorobenzene is suspected to be present.


12.  1,4-dichlrobenzene  is  suspected  as  a  byproduct  in  the
     formation of 1,2-dichlorobenzene, and 1-2-dichlorobenzene is
     suspected   as  a  byproduct  in   the   1,4-dichlorobenzene
     formation.
13.  When  2,2,2',4',5'-pentachloroacetophenone is used as a  raw
     material,  then  1,2,4-trichlorobenzene  is suspected to  be
     present as an impurity in the raw material.


14.  When  producing the pesticide toxaphene,  chlorobenzene  was
     identified by the manufacturer to be present in the process;
     however, the reaction source has not been determined.


15.  When  4-chlorothiophenol  is used as a  raw  material,  then
     benzene  and chlorobenzene are suspected to be impurities in
     the raw material.
16.  During the production of thiabendazole,  1,3-dichlorobenzene
     was  identified  by the manufacturer to be  present  in  the
     process;   however,   the   reaction  source  has  not  been
     determined.


17.  When dichlorophen is used as a raw material, then toluene is
     suspected to be present as a raw material impurity.


18.  When  2,4-dichlorobenzophenone  is used as a  raw  material,
     then  chlorobenzene  is  suspected to be present  as  a  raw
     material impurity.


Halomethanes
Table V-4  shows that methylene chloride,  chloroform, and carbon
tetrachloride (di-,  tri-, and tetra-chloromethane, respectively)


                           V-9

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are used mainly as raw materials and solvents in approximately 28
pesticide  processes.   Table V-5 list historical data  typically
detected  in  pesticide  process  wastewaters  for  halomethanes.
Bromomethanes can be expected in at least five pesticides as  raw
materials,  byproducts,  or  impurities  and  can function  as  a
fumigant,  in the case of methyl bromide.  The fluoromethanes are
used  as  aerosol  propellants,  but they  are  not  expected  in
pesticide process wastewaters.


Process   descriptions  were  developed  for  all  the  pesticide
products  listed.   These  process  descriptions  were  developed
and/or checked for applicability to specific plants by  reference
to  the  five  sources mentioned earlier in  this  section.   The
halemethane  listed for each pesticide product was  examined  for
consistency with process descriptions reviewed.  Assumptions were
than   drawn  from  this  examination  of  provide  a  basis  for
developing the list of halomethanes suspected in pesticide  waste
streams.  The assumptions are as follows:


1.   Methanol  in the presence of hydrogen chloride will react to
     form methyl chloride.


2.   When  trimethyl phosphite is reacted  with  chloral,  methyl
     chloroacetoacetate,   methyl  crotonamide,  or  pentachloro-
     acetophenone then methyl chloride is suspected to be present
     as  a  reaction byproduct and is vented as a gas and  either
     incinerated or recovered.   Methyl chloride is suspected  to
     be  presented in the incinerator scrubber or recovery system
     aqueous effluent.


3.   When  methylene  bromide is used as  a  raw  material,  then
     methyl  bromide,   bromoform,  and  methylene  chloride  are
     suspected to be present as impurities in the raw material.


4.   When  producing the pesticide ethylene dibromide,  bromoform
     was identified by the manufacturer;  however,  the  reaction
     source has not been determined.


5.   When  coke,  oxygen,  and carbon dioxide are reacted to form
     carbon  monoxide,  then methane is suspected as  aD@
     byproduct.  Upon chlorina
     phosgene,  methane  is also chlorinated and methyl chloride,
     methylene chloride, chloroform, and carbon tetrachloride are
     suspected to be present as reaction byproducts.


6.   When  cyanuric  chloride is used as  a  raw  material,  then
     carbon  tetrachloride  is suspected to be present as  a  raw
     material impurity.


                           V-10

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7.   When  trichloromethane  sulfenyl chloride is used as  a  raw
     material,  then  chloroform  is suspected to be  present as an
     impurity in the raw material.


8.   When  2,4-DB  is  used as a  raw  material,  then  methylene
     chloride  is  suspected to be present as an impurity in  the
     raw material.


9.   When  chlorobenzene  is used as a  phosgenation  solvent  then
     carbon  tetrachloride  is  suspected  to be  present  as  an
     impurity.


10.  When  producing certain pesticides,  methylene  chloride  is
     used as a purification solvent.


Cyanide


Cyanide  is  a known or suspected pollutant in  approximately  24
pesticide  processes,  as  shown in Table V-6.   Table V-7  lists
typical  cyanide  data detected in  pesticide  wastewaters.   The
primary  raw materials which favor the generation of cyanides  as
either  byproducts  or  impurities  are   cyanamides,   cyanates,
thiocyanates,  and cyanuric chloride.   Cyanuric chloride is used
exclusively in the manufacture of triazine pesticides.


Process   descriptions  were  developed  for  all  the  pesticide
products  listed.   These  process  descriptions  were  developed
and/or checked for applicability to specific plants by  reference
to  the  five  sources mentioned earlier  in  this  section.   If
cyanide  was  listed  for  a pesticide product  its  listing  was
examined  for  consistency with  process  descriptions  reviewed.
Assumptions  were  then drawn from this examination to provide  a
basis  for developing the list of cases where  cyanide  compounds
are suspected in pesticide waste streams.  The assumptions are as
follows:


1.   When  cyanuric  chloride  is used as a  raw  material,  then
     cyanide  is suspected to be present as a reaction  byproduct
     from the degradation product cyanogen chloride as well as  a
     raw material impurity.
                           V-ll

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2.   When methyl cyanocarbamate,  isophthalodinitrile, cyanamide,
     sodium   cyanate,   sodium   thiocyanate,   2-cyanopyridinef
     ammonium thiocyanate, cyanamide 50, or thiazole is used as a
     raw  material  in  the pesticide process,  then  cyanide  is
     suspected  to  be  present only as  an  impurity  introduced
     during the synthesis of these raw materials.


3.   When  sodium cyanate is used as a raw material then  cyanide
     is suspected to be present in the wastewater.


4.   When aminoisobutyronitrile is used as a raw  material,  then
     cyanide  is  suspected  to  be present  as  a  raw  material
     impurity.


5.   When  sodium  cyanide  is  used as a  starting  material  in
     producing  dichlorobenzin  then cyanide is suspected  to  be
     present as an impurity in dichlorobenzil.


6.   When  azobisisobutyronitrile  is  used as  a  catalyst  then
     cyanide  is  suspected to be present as an impurity  in  the
     catalyst.


7.   When pesticides that use cyanuric chloride as a raw material
     are  used as a feed stock,  then cyanide is suspected to  be
     present as a raw material impurity and reaction byproduct.


Haloethers


There  are five compounds classified as priority pollutants  that
contain  an  ether moiety and halogen atoms attached to the  aryl
and alkyl groups.  Table V-8 identified five pesticides suspected
to  contain  at  least one  compound  from  this  class.   Bis(2-
chloroethyl)ether  (BCEE)  is  used  as a  raw  material  in  two
pesticides, while BCEE itself, di(chloroethyl)ether, functions as
a  fungicide  or  bactericide in certain  applications.   In  the
remainder of the pesticides the ethers are shown to be  suspected
raw   material  impurities.    Table  V-9  list  historical  data
typically detected in pesticide process wastewaters.


Process  descriptions  were  developed  for  all  the   pesticide
products  listed.   These  process  descriptions  were  developed
and/or  checked for applicability to specific plants by reference
to  the  five sources mentioned earlier  in  this  section.   The
haloether compound listed for each pesticide product was examined
for consistency with process descriptions reviwed.  An assumption
was  then  drawn  from this examination to provide  a  basis  for
suspecting that BCEE is present in pesticide waste streams.   The


                           V-12

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assumption is as follows:


1.   When  butyl carbitol or butyl carbitol chloride is used as a
     raw material,  then BCEE is suspected to be present as a raw
     material impurity.


Phenols


Phenols  are  compounds having the hydroxyl (OH)  group  attached
directly  to  an  aromatic ring.   The phenolic  compounds  under
consideration  in  this  study  are  derivatives  of  phenol,  in
particular   chlorophenols,   nitrophenols,   and   methylphenols
(cresols).   Table  V-10 contains a coded list of  the  suspected
presence of the compounds in the pesticide industry.   Table V-ll
lists  historical  data typically detected in  pesticide  process
wastewaters.    These  compounds  may  be  found  throughout  the
pesticide industry as raw materials, impurities in raw materials,
or as byproducts of reactions utilizing related compounds such as
chlorobenzenes,  etc.   As  an example,  it can be concluded from
Table  10  that the use of 2,4-dichlorophenol as a  raw  material
will  tend  to generate variously  substituted  chlorophenols  in
process  wastewaters.    The  presence  of  nitrated  phenols  is
expected in six pesticides.   Methylated phenols are not expected
to  be significant since they are not used as raw materials,  but
they may appear as impurities of reaction from one pesticide  due
to use of 4-methylthio-m-cresol as a raw material.


Process   descriptions  were  developed  for  all  the  pesticide
products  listed.   These  process  descriptions  were  developed
and/or checked for applicability to specific plants by  reference
to  the  five  sources mentioned earlier in  this  section.   The
phenolic compound listed for each pesticide product was  examined
for consistency with process descriptions reviewed.   Assumptions
were  then  drawn  from this examination to provide a  basis  for
developing the list of phenolic compounds suspected in  pesticide
waste streams.  The assumptions are as follows:


1.   When  2,4-dichlorophenol  is used as a raw material  in  the
     process,    then   phenol,    2-chloropehnol,   and   2,4,6-
     trichlorophenol are suspected to be present as impurities in
     the raw material.


2.   When 4-nitrophenol is used as a raw material,  then phenol
     is suspected as an impurity in the raw material.


3.   When  the  sodium  salt of 4-nitrophenol is used  as  a  raw
     material  then 2-nitrophenol is suspected as an impurity  in
     the raw material.
                             V-13

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4.   When  4-methylthiophenol  is  used as a  raw  material  then
     phenol,  2,4-dichlorophenol,  and 2,4,6-trichlorophenol  are
     suspected to be present as impurities in the raw material.


5.   When  phenylacetate  is used as a raw material which  reacts
     with  bis (chloroethyl)ether,   then phenol is suspected to  be
     a raw material impurity.


6.   2,4-Dichlorophenol  was  identified by the  manufacturer  of
     dicamba and is suspected to be present as an impurity in the
     raw material.


7.   When  p-sec-butyl  phenol is used as a  raw  material,  then
     phenol and 2,4-dinitrophenol are suspected to be present  as
     impurities in the raw material.


8.   When  4-chlorophenol  is  used as a raw  material,   then  2-
     chlorophenol  and  2,4-dichlorophenol are  suspected  to  be
     present as impurities in the raw material.


9.   When  PCP is used as a raw material then phenol is  suspected
     to be present as an impurity in the raw material.


10.  When  dinitro-octylphenol is used as a  raw  material,  then
     phenol  is suspected to be present as an impurity in the raw
     material.


11.  When 4-methylthio-m-cresol is  used as a raw  material,  then
     4-chloro-m-cresol  is suspected to be present as an impurity
     in the raw material.


12.  When 2,4,5-trichlorophenol is  used as a raw  material,  then
     2,4,6-trichlorophenol   are  suspected  to  be  present   as
     impurities in the raw material.


13.  When  anisole  is  used as a raw material,  then  phenol  is
     suspected to be present as an  impurity in the raw material.


14.  When p-chloronitrobenzene is used as a raw material, then 2-
     nitrophenol and 4-nitrophenol  are suspected to be present as
     impurities in the raw material.
                             V-14

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15.  In certain pesticides,  2-chlorophenol,  2,4-dichlorophenol,
     and 2,4,6-trichlorophenol are suspected as byproducts of the
     chlorination reaction.
16.  In  certain   pesticides,   phenol,   2-chlorophenol,   2,4-
     dichlorophenol,  and  2,4,6-tirchlorophenol are suspected to
     be presented as reaction byproducts.


17.  When 2,4,5-trichlorophenyl dichlorothiophosphate is used  as
     a   raw  material,   then   phenol,   2-chlorophenol,   2,4-
     dichlorophenol,  and  2,4,6-trichlorophenol are suspected to
     be present as impurities in the raw material.


18.  When   2,4-D  is  used  as  a  raw   material,   then   2,4-
     dichlorophenol  is suspected to be present as an impurity in
     the raw material.
19.  When  thiophenol is used as a raw material,  then phenol  is
     suspected to be present as an impurity in the raw material.


20.  When  4-chloro-o-cresol is used as a raw material,  then  4-
     chloro-m-cresol  and phenol are suspected to be  present  as
     impurities in the raw material.


21.  When   producing  certain  pesticides,   2-nitrophenol,   4-
     nitrophenol,  and  2,4-dinitrophenol  are  suspected  to  be
     present as reaction byproducts.


22.  When    pentachlorobenzene   undergoes    nitration,    then
     pentachlorophenol  is suspected to be present as a  reaction
     byproduct.


Polynuclear Aromatics


There are 17 priority pollutant compounds which can be classified
as polynuclear aromatics (PNA's).  These compounds consist of two
or  more benzene rings which share a pair of carbon  atoms.  They
are all derived from coal tar,  with naphthalene being the single
largest  constituent.   Naphthalene  derivatives such  as  alpha-
naphthylamine   and  alpha-naphthol  are  used  in  a  number  of
pesticide processes;  therefore,  naphthalene is by far the  most
prevalent  PNA priority pollutant in the industry.   As shown  in
Table V-12 acenaphthylene,  anthracene,  fluorence, fluoranthene,
and  phenanthrene  are  found only as  raw  material  impurities.
Acenaphthene is found in one pesticide process as a raw material.
The   remaining  ten  polynuclear  aromatic  compounds  are   not


                             V-15

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suspected to be present in pesticide processes.   Table V-13 lists
historical  data  typically  detected in  the  pesticide  process
wastewaters.
Process   descriptions  were  developed  for  all  the  pesticide
products  listed.   These  process  descriptions  were  developed
and/or checked for applicability to specific plants by  reference
to  the  five  sources mentioned earlier in  this  section.   The
polynuclear  aromatics  listed  for each  pesticide  product  was
examined  for  consistency with  process  descriptions  reviewed.
Assumptions  were  then drawn from this examination to provide  a
basis for developing the list of polynuclear aromatics  suspected
in pesticide waste streams.  The assumptions are as follows:


1.   When   1-naphthoxide  is  used  as  a  raw  material,   then
     napthalene  is  suspected  to be  present  as  raw  material
     impurity.


2.   When a-naphthol is used as a raw material,  then napthalene,
     acenaphthene/acenaphthylene,   anthracene/phenanthrene   and
     fluorene/fluoranthene   are  suspected  to  be  present   as
     impurities in the raw material.


3.   When  a-naphthylamine  is  used  as  a  raw  material,  then
     napthalene is suspected to be present as impurity in the raw
     material.


4.   When   producing  the  pesticide  endrin,   naphthalene  was
     identified  by the manufacturer and confirmed by  wastewater
     sampling,   however   the  reaction  source  has  not   been
     determined.   The  suspected presence of  2-chloronapthalene
     also has been confirmed by wastewater sampling,  however the
     reaction source has not been determined.


5.   When acenapthene is used as a raw material,  then napthalene
     is  suspected  to  be  present as an  impurity  in  the  raw
     material.


6.   When producing certain pesticides,  naphthalene is suspected
     to be present as a reaction byproduct.


Metals


In   the  pesticide  industry  metals  are  used  principally  as
catalysts  or  as raw materials which are incorporated  into  the
active ingredients,  e.g.,  metallo-organic pesticides.   Certain


                           V-16

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priority  pollutant metals which are incorporated  into  arsenic,
cadmium, copper, and mercury based pesticides are included in the
scope  of  this  study as a separate segment  because  they  were
regulated  to a zero discharge of process wastewater to navigable
waters during BPT.


Table V-14 contains a coded list of the suspected presence of the
compounds in the pesticide industry.  Table V-15 lists historical
data  for pollutants typically detected in the pesticide  process
wastewaters.


As  shown  in  Table  V-14,  copper  is  found  or  suspected  in
wastewaters from at least 8 pesticides where it is used as a  raw
material  or  catalyst,  but is not incorporated into the  active
ingredient.   Of  the remaining priority pollutant  metals,  zinc
becomes part of the technical grade pesticide in seven processes;
whereas  mercury is used as a catalyst in one pesticide  process.
Manganese  and  tin-based  pesticides  are  still   manufactured;
however/ these are not priority pollutant metals.


Process   descriptions  were  developed  for  all  the  pesticide
products  listed.   These  process  descriptions  were  developed
and/or checked for applicability to specific plants by  reference
to the five sources mentioned earlier in this section.  The metal
listed  for  each pesticide product was examined for  consistency
with process descriptions reviewed.   Assumptions were then drawn
from this examination to provide a basis for developing the  list
of metals suspected in pesticide waste streams.   The assumptions
are as follows:
1.   When  copper  is used as a raw material or catalyst  in  the
     pesticide  process,  then it is suspected to be  present  in
     pesticide wastewaters.


2.   When  zinc  is  used as a raw material or  catalyst  in  the
     pesticide  process,  then  it is suspected to be present  in
     pesticide wastewaters.


3.   When  arsenic is used as a raw material or catalyst  in  the
     pesticide  process,  then  it is suspected to be present  in
     pesticide wastewaters.


4.   When  cadmium is used as a raw material or catalyst  in  the
     pesticide  process,  then  it is suspected to be present  in
     pesticide wastewaters.
                           V-17

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5.   When  mercury is used as a raw material or catalyst  in  the
     pesticide  process,  then  it is suspected to be present  in
     pesticide wastewater.


6.   When   producing  the  pesticide   acephate,   arsenic   was
     identified by the manufacturer as a raw material impurity.


7.   When  zinc chloride is used as a raw material,  then zinc is
     suspected to be present in pesticide wastewaters.


8.   When  Of0-diethyl-0-(4-methylthiophenol)phosphorothioate  is
     used  as a raw material,  then copper is suspected as a  raw
     material  impurity due to its use as a catalyst in  the  raw
     material manufacture.
9.   When mercury is used as a catalyst,  then it is suspected to
     be present in pesticide wastewater.


10.   When 0,0-dimethyl-S-[2- (ethylsulpenyl)ethyl]-phosphorothioate
     is used as a raw material,  then copper is suspected  to be
     present as a raw material impurity  due  to it as a catalyst
     in the raw material manufacture.
The   other  priority  pollutant  metals  (antimony,   beryllium,
chromium,  lead,  nickel,  selenium, silver, and thallium) may be
present  as  impurities in any pesticide  or  industrial  process
wastewaters  in trace amounts below the level of treatability due
to the following factors:


1.   Chromium,  copper,  nickel, and zinc are used extensively in
     stainless steel and /or other fabrication metal alloys;


2.   Machinery  bearings  often  contain  as much  as  5  percent
     antimony,  or  lead in addition to the other metals  present
     (copper, cadmium, nickel, and zinc);


3.   Antimony and arsenic are often found as hardening agents  in
     copper, lead, and other metals or metal alloys;


4.   Cadmium and lead are used in fusible alloys and some solders;


5.   Corrosion-resistant  tank linings and piping often use lead,
     nickel, and zinc;
                           V-18

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6.   Arsenic is combined in nature with phosphorous and therefore
     may enter the plant as a raw material impurity;
7.   Cadmium may be an impurity in lime;
8.   Chromium  is  added to noncontact cooling water  streams  to
     inhibit slime formation; and


9.   Any  compound may be found in plant intake  water.   It  is,
     however,  unlikely  that  thallium,  silver,  beryllium,  or
     selenium   will  be  found  in  significant  levels  in  any
     wastewaters.
Therefore,  the  above  impurities are not included  as  priority
pollutants  in  the pesticide  industry  manufacturing  processes
covered as regulated priority pollutants when these were the only
potential sources.
Chlorinated Ethanes and Ethylenes
The  chlorinated  ethanes  and ethylenes are  used  as
cleaning    agents,    and   intermediates.     Vinyl
(chloroethylene)  is used in the production of plastic
chloride.   In  the pesticide industry approximately 23
are  suspected  to  contain a member of this  group  of
pollutants (Table  V-16).  The principal pollutants suspected are
1,2-dichloroethane,   which   is  used  as  a  solvent  in  seven
pesticides and tetrachloroethylene, which is used as a solvent in
two  pesticides.   Table  V-17  list  historical  data  typically
detected in the pesticide process wastewaters.
solvents,
 chloride
polyvinyl
 products
 priority
Process  descriptions  were  developed  for  all  the   pesticide
products  listed.   These  process  descriptions  were  developed
and/or  checked for applicability to specific plants by reference
to  the  five sources mentioned earlier  in  this  section.   The
chlorinated   ethane  and  ethylene  compounds  listed  for  each
pesticide  product  were examined for  consistency  with  process
descriptions  reviewed.   Assumptions  Were then drawn from  this
examination  to  provide  a  basis for  developing  the  list  of
chlorinated ethane and ethylene compounds suspected in  pesticide
waste streams.  The assumptions are as follows:
1.   When 1,2-dichloroethane is used as a solvent in the process,
     then  impurities such as 1,1,2-trichloroethane and  1,1,2,2-
     tetrachloroethane are suspected to be present.
                           V-19

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2.   When   vinyl  chloride  is  used  as  a  raw  material  then
     impurities such as chloroethane are suspected to be  present
     as a raw material impurity.


3.   When  anhydrous  ethyl alcohol and phosphorous  pentasulfide
     are  reacted,  ethyl  dithiophosphone  acid  results.   Upon
     chlorination    of   ethyl   dithiophosphone   into    ethyl
     phosphorochlorodithionate,  chloroethane is suspected to  be
     present as a reaction byproduct.


4.   When producing the pesticide di(chloroethyl) ether,  1,2-di-
     chloroethane   was  identified  by  the  manufacturer  as  a
     byproduct.


5.   When  producing  the  pesticides  alachlor,  butachlor,  and
     propachlor,   lf2-dichloroethane   was  identified  by   the
     manufacturer as an impurity.


6.   When   producing   the   pesticide    methamidophos,    1,2-
     dichloroethane  was identified by the manufacturer,  however
     the reaction source has not  been determined.
7.   When  2,2-dichlorovinyl  ethyl  ether  is  used  as  a   raw
     material,  then trichloroethylene is suspected to be present
     as an impurity in the raw material.


8.   When producing the pesticide disulfoton,   vinyl chloride was
     identified  by  the  manufacturer as a  reaction  byproduct.
     Vinyl  chloride  is vented as a gas  and incinerated  and  is
     therefore  suspected  to  be  present  in  the   incinerator
     scrubber aqueous effluent.


9.   When     producing     the     pesticide      chlorothalonil,
     tetrachloroethylene  was  identified  by   the  manufacturer,
     however the reaction source has not  been  determined.


10.  When  di(chloroethyl) ether  is  used in   the  production  of
     certain  pesticides then 1,2-dichloroethane is suspected  to
     be present as a solvent impurity.


11.  When producing the pesticide toxaphene,  tetrachloroethylene
     was identified by the manufacturer;   however,  the  reaction
     source has not been determined.
                           V-20

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12.  When 1,1,2,2-tetrachloroethylsulfenyl chloride (TES) is used
     as a raw material,  then trichloroethylene is suspected as a
     raw material impurity.


Nitrosamines


N-nitrosamines  are  a  group  of compounds  characterized  by  a
nitroso  group  (N=O) attached to the nitrogen of an  aromatic  or
alphatic secondary amine.  In the pesticide industry N-nitrosodi-
n-propylamine   is  a  suspected  reaction  byproduct  from   the
nitrosation  of  di-N-propylamine.    Table  V-18  shows  that  2
pesticides  are suspected to contain some form of  N-nitrosamine.
Table  V-19 lists historical data typically detected in pesticide
process wastewaters.


Process  descriptions  were  developed  for  all  the   pesticide
products  listed.   These  process  descriptions  were  developed
and/or  checked for applicability to specific plants by reference
to  the  five sources mentioned earlier  in  this  section.   The
nitrosamine  compound  listed  for  each  pesticide  product  was
examined for consistency with process descriptions reviewed.   An
assumption  was  then  drawn from this examination to  provide  a
basis for suspecting that N-nitrosodi-n-propylamine is present in
pesticide waste streams.  The assumption is as follows:


1.   When  di-n-propylamine  is used as a raw material,  then  N-
     nitrosodi-n-propylamine  is  suspected to be  present  as  a
     reaction byproduct.


Phthalates


Phthalate  esters are used widely as plasticizers  in  commercial
polymers  and  plastic  end products  such  as  polyvinylchloride
plastics.   One  phthalate classified as a priority pollutant  is
suspected  to be present in three pesticide processes (see  Table
V-20).   Dimethyl  phthalate is known to be a raw material in two
products.  Table V-21 lists historical data detected in pesticide
process wastewaters.


Process  descriptions  were  developed  for  all  the   pesticide
products  listed.   These  process  descriptions  were  developed
and/or  checked for applicability to specific plants by reference
to  the  five sources mentioned earlier  in  this  section.   The
phthalate compound listed for each pesticide product was examined
for consistency with process descriptions reviewed.   Assumptions
were  then  drawn  from this examination to provide a  basis  for
developing the list of phthalate compounds suspected in pesticide
waste streams.  The assumptions are as follows:


                           V-21

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1.   When  dimethyl phthalate is used as a raw material,  then it
     is suspected to be present in the pesticides wastewaters.


2.   When  phthalimide is refluxed with methanol,  then  dimethyl
     phthalate   is  suspected  to  be  present  as  a   reaction
     byproduct.


Dichloropropane and Dichloropropene


1,3-Dichloropropene  is a raw material in  one  pesticide.   1,3-
Dichloropropene and the combined pollutants lf2-dichloropropane -
lf3-dichloropropene  are  pesticide products as well as  priority
pollutants and function as insecticidal fumigants.


Process  descriptions  were  developed  for  all  the   pesticide
products  listed.   These  process  descriptions  were  developed
and/or  checked for applicability to specific plants by reference
to the five sources mentioned earlier in this section (See  Table
V-22).   Table  V-23 lists historical data typically detected  in
pesticide   process   wastewaters.    The   dichloropropane   and
dichloropropene  compound  listed for each pesticide product  was
examined  for  consistency with  process  descriptions  reviewed.
Assumptions  were  then drawn from this examination to provide  a
basis   for   developing   the  list   of   dichloropropane   and
dichloropropene  compounds suspected in pesticide waste  streams.
The assumptions are as follows:


1.   When  1,3-dichloropropene  is used as a raw material in  the
     process,  then  impurities such as  1,2-dichloropropane  are
     suspected to be present.


2.   When 1,3-dichloropropene is produced as a product, then 1,2-
     dichloropropane  is  suspected to be present as  a  reaction
     byproduct.


3.   When  allyl  chloride is used as a raw material,  then  1,2-
     dichloropropane and 1,3-dichloropropene are suspected to  be
     present as impurities.


4.   When  propylene oxide is used as a raw material,  then  1,2-
     dichloropropane is suspected to be present as an impurity in
     the raw material.
                           V-22

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5.   When  vinyl  chloride is used as a raw material,  then  1,3-
     dichloropropene is suspected to be present as an impurity in
     the raw material.


6.   When  o-iso-propoxyphenol is used as a  raw  material,  then
     1,2-dichloropropane and 1,3-dichloropropene are suspected to
     be present as impurities in the raw material.


7.   When  2,3-dichloropropene  is used as a raw  material,  then
     1,3-dichloropropene  is  suspected to be present  as  a  raw
     material impurity.


Priority Pollutant Pesticides


There  are  only  18  priority  pollutants  which  are   commonly
classified as pesticides.  Only two priority pollutant pesticides
are  still in production;  heptachlor and chlordane.  As shown in
Table 24,  aldrin, dieldrin, and endrin aldehyde are suspected as
reaction byproducts in the endrin process;  however, it should be
noted that endrin aldehyde occurs as endrin ketone due to thermal
rearrangement.   Heptachlor  epoxide  will occur  as  a  reaction
byproduct  in both chlordane and heptachlor manufacturing.   ODD,
DDE,  and  DDT  can occur in the manufacture  of  one  pesticide.
Endosulfan  sulfate  can  occur as a reaction  byproduct  in  the
manufacture  of  endosulfan.   The priority pollutant  pesticides
BHC,   lindane,  DDE,  ODD,  and ^endosulfan  are  not  currently
manufactured,  and no raw waste load priority pollutant data  are
available  from  past  production  periods.    Table  V-25  lists
historical  data  typically  detected in  the  pesticide  process
wastewaters.


Process   descriptions  were  developed  for  all  the  pesticide
products  listed.   These  process descriptions   were  developed
and/or checked for applicability to specific plants by  reference
to  the  five  sources mentioned earlier in  this  section.   The
priority  pollutant pesticide listed for each  pesticide  product
was  examined for consistency with process descriptions reviewed.
Assumptions  were then drawn from this examination to  provide  a
basis  for  developing the list of priority pollutant  pesticides
suspected  in pesticide waste streams.   The assumptions  are  as
follows:
1.   When BHC and lindane are manufactured all isomers of BHC are
     produced as reaction byproducts.


2.   When chlordene and chlorine are used as raw materials,  then
     heptachlor epoxide is suspected to be present as a  reaction
     byproduct.    In   addition,   when  chlordane  is  produced


                           V-23

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     heptachlor  is  suspected  to  be  present  as  a   reaction
     byproduct  and  when  heptachlor is  produced  chlordane  is
     suspected to be present as a reaction byproduct.


3.   When  DDT  is used as a raw material,  then ODD and DDE  are
     suspected to be present as reaction byproducts.


4.   When producing the pesticide endosulfan,   endosulfan sulfate
     is suspected to be present as a reaction  byproduct.


5.   When producing the pesticide endrin,  reaction byproducts of
     aldrin,  dieldrin,  and endrin aldehyde are suspected to  be
     present.   Endrin,  endrin  aldehyde,  and aldrin all can be
     formed     by     the     Diels-Alder     reaction     using
     hexachlorocyclopentadiene as the raw material.   Dieldrin is
     suspected to be present as a reaction byproduct when  aldrin
     is epoxidized.


6.   When  DDT  is  produced  then DDD and DDE  are  expected  as
     byproducts.    When  DDD  is produced then DDT  and  DDE  are
     expected  as byproducts.   When DDE is produced then DDD and
     DDT are expected as byproducts.


7.   When  any of the priority pollutant pesticides are  produced
     then   that   particular  priority  pollutant  pesticide   is
     expected to  be present.


Dienes


There   are  four  manufactured  pesticides and  two  pesticides
currently  not manufactured which use a priority pollutant  diene
as a raw material.   The basic material for all six pesticides is
hexachlorocyclopentadiene    (HCCPD).     Two    pesticides    are
synthesized   by    a  Diels-Alder  condensation  of   HCCPD   and
cyclopentadiene to form chlorodene,  the intermediate.  Chlordene
is further chlorinated either by addition or by substitution. One
pesticide  process involves the stepwise reaction of  HCCPD  with
acetylene,   cyclopentadiene,  and  peroxyacetic  acid.   Another
pesticide is manufactured by the reductive coupling of HCCPD with
itself using a cuprous chloride catalyst.   As shown in Table 26,
the  priority  pollutant hexachlorobutadiene is suspected  to  be
present  in  the   wastewater because it is a byproduct  of  HCCPD
synthesis  and  used as a solvent in the  manufacture  of  mirex.
Table  V-27 lists historical data typically detected in pesticide
process wastewaters.
                           V-24

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Process  descriptions  were  developoed  for  all  the  pesticide
products  listed.   These  process  descriptions  were  developed
and/or checked for applicability to specific plants by  reference
to the five sources mentioned earlier in this section.  The diene
listed  for  each pesticide product was examined for  consistency
with process descriptions reviewed.  An assumption was then drawn
from  this  examination to procide a basis  for  suspecting  that
hexachlorocyclopentadiene  is present in pesticide waste streams.
The assumption is as follows:
1.   When  hexachlorocyclopentadiene  is used as a raw  material,
     then  hexachlorobutadiene  is suspected to be present  as  a
     byproduct from the raw material synthesis.


TCDD
2,3,7,8-tetrachlorodibenzo-p-dioxin  (TCDD) is believed to  be  a
byproduct  in  chemical processing generated by a  halophenol  or
chlorobenzene starting material.   An intermediate reaction would
occur  at  an  elevated temperature,  equal to  or  greater  than
160°C,  an  alkaline condition  or in the presence of a  free
halogen.   The  end  reaction  results in either  direct  dioxin,
intermediate   dioxin,   or  predioxin  formation   which   would
ultimately form dibenzo-p-dioxins (Dryden,  e_t al.,  1979).  TCDD
is  suspected  in  pesticide wastewaters listed  in  Table  V-28.
These  pesticides use such raw materials as 2,4,5-trichlorophenol
and  1,2,4,5-tetrachlorobenzene which are characteristic of  TCDD
precursors.    The   structurally  similar  pesticides  PCP   and
hexachlorophene are being examined for possible presence of  TCDD
in   wastewater.    Analytical  procedures  are  currently  being
upgraded.  A detection limit of 0.002 ug/1 (2 nanograms per liter
or  2  ng/1) is currently achievable (49 FR  43234,  October  26,
1984).   Table  V-29 lists historical data typically detected  in
pesticide process wastewaters.


A  study of Oswald in 1978 detailed results of analysis  of  fish
samples from three rivers in Michigan for 2,3,7,8-TCDD.   Thirty-
five  samples  were analyzed by high resolution capillary  column
gas   chromotography   interfaced  with  high   resolution   mass
spectrometry.  Concentrations in 35 samples ranged from 4 ng/1 to
695 ng/1.


A TCDD level as high as 111 mg/1 has been found in drums of waste
from  the production of the pesticide 2,4,5-T,  according to  the
Final Rules published May 19,  1980 in the Federal Register.  The
EPA  TCDD  task force is currently  reviewing  the  environmental
problems of TCDD residue.
                           V-25

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Process   descriptions  were  developed  for  all  the  pesticide
products  listed.   These  process  descriptions  were  developed
and/or checked for applicability to specific plants by  reference
to  the five sources mentioned earlier in this section.   If TCDD
was   listed  for  a  pesticide  product  it  was  examined   for
consistency  with process descriptions reviewed.   An  assumption
was  then  drawn  from  this  examination  to  provide  a   basis
suspecting that TCDD is present in pesticide waste streams.   The
assumption is as follows:


1.   When 2,4,5-trichlorophenol or 1,2,4,5-tetrachlorobenzene are
     used  as raw materials under alkaline conditions or  in  the
     presence  of  a  free halogen at temperatures  greater  than
     160°C,  then  TCDD  is  suspected to  be  present  as  a
     byproduct from the reaction.


Miscellaneous


Acrolein  is manufactured for use in plastics and  as  a  warning
agent  in  methyl chloride refrigerant.  It is not indicated, nor
has it been found,  to be present  as a process-related pollutant
in the pesticide industry.

                                                           t
Acrylonitrile   is  used in the manufacture of synthetic  fibers,
dyes,  and adhesives.  It  is  indicated  to  be present  in  the
one  pesticide  process  where  it  is suspected to be used as  a
raw   material   or   solvent.   Acrylonitrile   has   not   been
monitored in the pesticide industry.


Asbestos  is  in  widespread  usage  as  an  insulating material.
As    shown   in  Table  V-30,  total  mass chrysotile fibers  of
asbestos   were  found   in   pesticide  process  wastewaters  at
concentrations  from not detected or 0.000038 mg/1 to  0.3  mg/1.
These  data were reported as  part  of an EPA asbestos  screening
sampling   program   and  represents  monitoring   of    combined
pesticide  and nonpesticide process wastewaters.


1,2-Diphenylhydrazine   is a chemical intermediate which  is  not
used, and has not been found  in  the  pesticide industry.


Isophorone   is   a   diene  compound  (2-cyclohexene-l-one-3f5,5
trimethyl)  classified  as  a  priority  pollutant.  Unlike   the
other priority pollutant dienes, it is not chlorinated and is not
expected,  nor  has it been found,  to be present in any  of  the
processes investigated.
                           V-26

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PCB3


For    the   past   50   years   PCBs   have   had     widespread
industrial       applications      as      hydraulic      fluids,
plasticizers     in     synthetic     resins     and     rubbers,
adhesives,   heat   transfer  systems,  wax  extenders, dedusting
agents,     pesticide     extenders,     inks,  lubricants,   and
cutting oils.   Most of these uses have been banned, but PCBs are
still used in  vacuum  pumps,  gas  transmission  turbines,   and
electrical capacitors and transformers.


The only pesticide process where  PCBs  are  likely  to occur  in
the  actual  manufacturing  scheme is Al,  where  they  could  be
present  as reaction byproducts.   However,  the manufacture   of
Pesticide    Al   has   recently   been  ceased   and   is    not
anticipated to be produced in the future.   Therefore PCBs are no
longer indicated  to  be present in this industry.


Benzidines


Benzidine    compounds    are    synthetically-produced compounds
used  primarily  in the  manufacture  of  dyes.  They   art   not
indicated  nor  have  they been found to be present  as  process-*
related pollutants in the  pesticide industry,


Nitro-substituted Aromatics


Nitro-substituted  aromatics  are  used  in  the  production   of
explosives, soaps, shoe polish, as chemical intermediates but are
not indicated to be present as process-related pollutants in this
industry.


NONCONVENTIONAL POLLUTANTS


Typical   raw   waste   load   concentrations   and   flows   for
nonconventional pollutants are presented in Table  V-31 for  each
of  the  280  pesticides  for which data are available.


Nonconventional Pasticides


Nonconventional pesticides have been  measured in  44 percent  of
pesticide  raw  waste streams.   Table V-31 presents typical  raw
waste  load  concentrations ranging from not detected  to  11,200
mg/1.
                           V-27

-------
COD
COD  has  been monitored in 27 percent of  pesticide   raw  waste
streams.   Table V-31 presents typical COD concentrations ranging
from 14.0 mg/1 to 1,220,000 mg/1.


TOG
TOC  has  been monitored in 11 percent of  pesticide   raw  waste
streams.   Table V-31 presents typical TOC concentrations ranging
from 53.2 mg/1 to 79,800 mg/1.
TOD


Raw  waste  load  concentrations  of  TOD (total  oxygen  demand)
have  not  been monitored in the pesticide industry.


CONVENTIONAL POLLUTANTS


Typical  raw   waste   load   concentrations   and   flows    for
conventional  pollutants are presented in Table V-32 for each  of
the  280  pesticides  for  which   data   are available.


BOD
BOD   has   been monitored in 27 percent of pesticide  raw  waste
streams.    Table  V-19  presents  detected   BOD  concentrations
ranging  from  not  detected  to 60,000 mg/1.   The oxygen demand
is   quite  high  as  pesticide wastewaters  leave  the  process.
This  demand  must  be  further  evaluated  at  sampling   points
immediately   prior  to  biological  oxidation   systems,   since
pretreatment  steps    (such    as    activated    carbon)    can
effect considerable organic removal.


TSS


TSS   has   been monitored in 24 percent of pesticide  raw  waste

streams.    Table  V-32  presents  detected   TSS  concentrations

ranging from 2.00 mg/1 to 4,090 mg/1.
                           V-28

-------
DESIGN RAW WASTE LOADS
A   raw   waste   load must be selected in order  to  design  and
cost    recommended    treatment    and    control  technologies.
The  approach taken in this study is to design for the removal of
maximum   priority   pollutant  raw    waste   concentrations  as
reported  in  308  questionnaire  for  specific  plants.     This
ensured  that  the economic impact to treat high level pollutants
would be adequately considered in a plant-by-plant analysis.    A
summary  of  raw  waste  load  design levels is provided in Table
V-33.
ZERO-DISCHARGE PRODUCTS
Table  V-34  presents a listing of 29 pesticide   products  which
are   currently   being   manufactured  with  zero  discharge  of
process  wastewater  to  municipal   treatment  systems   or   to
navigable   waterways.    This   determination  was   made   froa
examination  of  process flow diagrams,  and from  manufacturers'
responses to  the  308  Survey  and follow-up letters.   Since no
known  raw  waste  load is associated  with  these  products,  no
treatment is recommended and no costs are developed.
                           V-29

-------
Table V-l,
Indicated/Detected Frequency of Priority Pollutant
Groups
     Priority
 Pollutant Group
                  Number of Pesticides
                     Indicated by
                    Process Chemistry
                       Evaluation
in Group
Detected in
Raw Waste
Volatile Aromatics
Halomethanes
Cyanides
Haloethers
Phenols
Polynuclear Aromatics
Metals
Chlorinated Ethanes (ylenes)
Nitrosamines
Phthalates
Dichloropropane ( ene )
Pesticides
Dienes
TCDD
Miscellaneous
PCBs
Benzidines
Nitro-Substituted Aromatics
118
50
24
5
36
6
19
23
2
3
8
11
6
5
1
0
0
0
44
25
13
4
20
5
8
10
1
1
3
5
4
4
76*
0
0
2
 * Refers to priority pollutant asbestos only,
                           V-30

-------
Table V-2.  Volatile Aronati.cs Indicated to be Present in Pesticide Process Wastewaters
Pesticide
Produced
Al
A2
A3
A4
A5
A6
A7
A8
A9
A10
All
A12
A13
A14
A15
A16
A17
A18
A19
A20
A21
A22
A23
A24
A25
A26
A27
A28
A29
A30
A31
A32
A33
A34

Benzene
_
—
—
—
—
—
—
—
—
—
R
R
—
IS
IS
—
—
IS
IS
R
—
IS
—
—
IS
—
—
—
—
—
—
—
—
IS

Toluene
S
—
S
S
S
S
S
—
S
S
—
R
S
IS
IS
S
S
—
IS
—
S
IS
S
S
IS
—
—
—
S
S
S
S
f S
IS

Ethylbz
^^^
—
—
—
—
—
—
—
—
—
—
—
—
IS
IS
—
—
—
IS
—
—
IS
—
IS
IS
—
—
—
—
—
—
—
—
IS
AROMATICS,
Chlorobz
__
S
—
—
—
—
—
R
—
—
B
—
—
—
—
—
—
IS
I
P
—
—
—
—
—
R
R
R
—
—
— —
—
—
——
CHLORINATED AROMATICS
1,2 di- 1,3-di- 1,4-di- Hexa- 1,2,4
chlorobz chlorobz chlorobz chlorobz TCBz
-
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
__ 	 _ — o __
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
— — — — —
__ __ __ __ __
— — ~ — — —
   Footnotes at end of Table
                                             V-31

-------
Table V-2.  Volatile Aronatics Indicated to be Present in Pesticide Process Wastewaters
            (Continued, Page 2 of 4)
ARQMATICS, CHLORINATED APOMATICS
Pesticide
Produced
Bl
B2
B3
B4
B5
B6
B7
B8
B9
BIO
Cl
C2
C3
C4
C5
C6
C7
C8
C9
CIO
Cll
C12
ci3
C14
CIS
Dl
D2
D3
D4
D5
D6
D7
D6
D9
D10
Benzene
«„-
	
—
	
— -
	
8
I
—
—
—
—
—
— •
—
IS
—
—
—
—
—
IS
—
—
—
—
—
IS
—
R
—
—
—
—

Toluene
,••
—
S
I
1C
S
—
—
S
—
S
S
S
I
I
IS
S
S
S
S
—
IS
S
S
S
S
I
IS
S
—
~
s
S
S
S
Ethylbz
••
—
~
—
—
—
—
—
~
—
—
—
—
—
—
IS
—
—
—
—
—
IS
—
—
—
—
—
IS
—
—
—
—
—
—

1,2 di- 1,3-di-
Chlorobz chlorobz chlorobz
R P —
R B — •
— — —
— — —
T «-"• __
— —
— —
—
— — —
C .•• •••
— —
—
— — —
__ — —
—
— — __
T — _ —
— — 	
	 	 	
	 	 	
D •• ••
__ — —
— — —
— — —
_- — —
__ __. —
— — —
— — —
— —
D •• «»^
G mm^ -»^
— —
— — —
— __ __

1,4-di- Hexa- 1,2,4
chlorobz chlorobz TCBz
n — -- •-_
o ••*• .««
— — —
— — —
— __ —
—
— —
— — —
— — —
— — —
—
— —
—
— — —
— —
— — —
— — —
— — —
— — —
— — __
—
— ~ —
— — .._
— — —
— — —
— — —
— — ..
__ — —
—
— — —
— —
— — —
— __ —
__ — — .

    Footnotes  at  end of  table
                                             V-32

-------
Table V-2.  Volatile Arcmatics Indicated to be Present in Pesticide Process Wastewaters
            (Continued, Page 3 of 4)
AROMATICS, CHLORINATED AROMATICS
Pesticide
Produced
El
E2
E3
E4
E5
E6
E7
E8
E9
E10
Fl
F2
F3
F4
F5
F6
F7
F8
F9
F10
Gl
G2
G3
G4
G5
G6
G7
G8
G9
G10
Gil
G12
Benzene
•AV*
—
—
S
—
—
—
IS
—
—
—
IS
IS
—
IS
—
—
—
—
S
S
—
S
IS
—
—
—
IS
—
—
—

1,2 di-
Toluene Ethylbz Chlorobz chlorobz
C -M. 	 __
O __ - _ _ _
C -~_ __ —
C —r, — • -P_
So _
^~^ O
S ~~ — ~ _i_.
__ __ c _-•
IS IS — —
C — • _M _^,
C — — — 	 ,
C —IT — — nt-r-
IS IS — —
IS IS
— — — —
TC TC «» _—
J.O J.O ^^
« R -___ _^_
_— _^ n _ —
— — R
S
— — — —
— — — —
So 	
O
— — — —
IS IS — —
C _.. — •—
o -^,_ __ — _
C — ^^ __
IS IS — —
o __ _.. „_
C _— > «« ««
o — _ _^ — —
s —
1,3-di- 1,4-di- Hexa- 1,2,4
chlorobz chlorobz chlorobz TCBz
^_ ^^ -!-,„ ^^
	 	 	 	
	 	 	 	
	 	 	 	
	 	 	 	
	 	 	 	
	 	
	 	
	 	 	 	
	 	 	 	
	 	 	 __
	 	 	 	
	 	 	 	
— — B I
— — — —
— — — —
— — — —
— — — —
— — — —
— — — —
— — — __
— — — —
— — — —
— — —
— — — —
— — — —
— — — —
— — — —
— — — —
— — _ —
— — — _ —

   Footnotes at end of table
                                            V-33

-------
Table V-2,  Volatile Arornatics Indicated to  be Present in Pesticide Process Wastewaters
             (Continued, Page 4 of 4)



              	AROMATICS,  CHLORINA3ED AROMATICS	
Pesticide                                             1,2 di-   1,3-di-   1,4-di-   Hexa-    1,2,4
Produced      Benzene  Toluene  Ethylbz  Chlorobz  chlorobz  chlorobz   chlorobz  chlorobz  TCBz



   til            «        C        -._        ---»        __        ——         __         _»       ——
   nJ.            ^^        o                                      ^^                    ^^       ^^
   ii*>            	        o        ___,        __        __        ___         ___         	       ____
   fl-*                      O

   H3            ^"™        *~~       ~"~        *"~        *~~"        ^^         ~-~         "~"™       I

   TtC            _r|M^        Q        ^__        __^        ___        __^_         ___         •__»       _,.•
   rj/T            __        O        ____        ____        ^^        ____         _,„         ^_       ___

   11*7            —        C        —        	        	        ___         _M         ___       ____
   n /                      o                  ^^
H10
11
12
13
14
15
16
17
IS IS IS U — — — —
O -.-. 	 	 _
.... ^ _ ->« « . —-- •»« •-•
R B B B B — B
•MB O ^^j ...^ -••• i_>^ .••a «• ••••
MM C ••. ... •• •• •• ••• •••
   t - Alpha,  beta, and delta iscmers.
   R • Raw material.
   I • Raw material impurity.
   S • Solvent.
  IS • Solvent impurity
  ST • Organic stripper solvent.
 1ST » Stripper impurity
   B » Reaction byproduct.
   U » Unknown—pollutant reported  by plant,  source not determined.
  — » Not suspected.
   P « Final product.
  1C » Catalyst impurity.
  Ethybz - Ethylbenzene
  Chlorobz - chlorobenezene
  TCBz - Trichlorobenzene
                                             V-34

-------
Table V-3.  Volatile Aromatics Detected in Pesticide
            Process Wastewaters

                  AROMATICS, CHLORINATED AROMATICS

                              BENZENE

Plant
1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
1
1
1
2
1
2
3
4
5
6
ND = Not
* = Dat<
Cone.
mg/1
ND
ND
0.073
0.0877
0.0877
<0.10
0.220
0.220
0.220
0.220
0.220
0.580*
2.68
3.00
52*
52*
52*
52*
180,000
30
0.580*
0.07
0.07
0.0051
<0.010*
<0.01*
<0.10
0.220
<0.30
detected.
i from cominal

(n)
(1)
(1)
(3)
(16)
(16)
(2)
(3)
(3)
(3)
(3)
(3)
(1)
(3)
(22)
(HI)
(111)
(111)
(HI)
(1)
(1)
(1)
(1)
(1)
(2)
(3)
(1)
(2)
(3)
(3)

pd oest

Flow (MGD)
0.0315
0.0315
0.012
0.0391
0.0391
2.3
28.2
28.2
28.2
28.2
28.2
1.8
1.241
0.00156
0.094
0.094
0.094
0.094
0.000276
1.5
1.8
0.7224
0.7224
0.009
0.1027
1.22
2.3
28.2
0.084

:icide streams.
(n) =
Data from comingled pesticide/other product streams,
Analysis not conducted per protocol.
Number of data points.
                             V-35

-------
Table V-3.  Volatile Aromatics Detected in Pesticide Process
            Wastewaters (Continued, Page 2 of 11)

                  AROMATICS, CHLORINATED AROMATICS

                              BENZENE

Plant
7
8
9
1
Cone.
mg/1
0.580*
0.767
2.68
2.68

(n)
(1)
(3)
(3)
(3)

Flow (MGD)
1.8
0.0717
1.241
1.241
  * = Data from comingled pesticide streams.
    = Data from comingled pesticide/other product streams.
(n) = Number of data points.
                             V-36

-------
Table V-3.
Volatile Aromatics Detected in Pesticide Process
Wastewaters (Continued, Page 3 of 11)

      AROMATICS, CHLORINATED AROMATICS

                  TOLUENE

Plant
1
2
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
1
2
1
2
1
2
3
4
5
6
7
8
NA =
ND =
* =
Cone.
mg/1 (n)
0.137 (1)
<69.3 (5)
Trace (1)
0.030 (3)
0.137 (1)
0.180* (1)
0.21* (1)
1.40 (3)
1.49 (10)
5.40 (3)
5.40 (3)
5.40 (3)
7.42 (2)
11.7 (E)
15.3 (3)
350 (1)
294,000 (1)
0.180* (1)
20,000 (1)
0.10* (1)
0.10* (1)
ND (3)
<0.0050 (2)
<0.01* (1)
0.016* (3)
0.180* (1)
0.21* (1)
5.40 (3)
15.3 (3)
Not available.
Not detected.

Flow (MGD)
0.030
0.0665
NA
0.012
0.030
1.8
1.8
2.3
0.130
28.2
28.2
28.2
2.3
0.161
1.241
0.000054
0.000276
1.8
0.00118 I
0.7224
0.7224
0.3283
0.009
1.22
0.1027
1.8
1.8
28.2
1.241


Data from comingled pesticide streams.
= Data from comingled pesticide/other product streams.
(E) =
(n) =
Estimate.
Number of data points.


                            V-37

-------
Table V-3.  Volatile Aromatics Detected in Pesticide Process
            Wastewaters (Continued, Page 4 of 11)
                  AROMATICS, CHLORINATED AROMATICS

                              TOLUENE

Plant
9
10
11
12
13
14
15
1
2
3
4
5
6
7
Cone.
mg/1
28.5*
28.5*
28.5*
370*
528
686
1,570
2.69*
2.69*
2.69*
5.80*
5.80*
5.80*
15.3

(n) I
(1)
(1)
(1)
(20)
(3)
(30)
(28)
(540)
(540)
(540)
(270)
(270)
(270)
(3)

rlow (MGD)
0.20
0.20
0.20
0.021
0.101
0.101
0.101
2.5
2.5
2.5
1.3
1.3
1.3
1.241
  * = Data from comingled pesticide streams.
    = Data from comingled pesticide/other product streams
(n) = Number of data points.
                           V-38

-------
Table V-3.  Volatile Aromatics Detected in Pesticide Process
            Wastewaters (Continued, Page 5 of 11)

                  AROMATICS, CHLORINATED AROMATICS

                            ETHYLBENZENE

Plant
1
1
2
3
4
5
6
7
1
1

1
2
3
4
Cone.
mg/1
0.338
<0.005
0.203
0.338
1.00
7.90
7.90
7.90
ND*
<0.01

ND*
ND
<0.01*
7.90

(n)
(1)
(3)
(2)
(1)
(1)
(3)
(3)
(3)
(1)
(1)

(1)
(2)
(1)
(3)

Flow (MGD)
0.030
0.012
2.3
0.030
2.3
28.2
28.2
28.2
1.8
6,050 gal/
1,000 Ibs
1.8
0.009
1.22
28.2
 ND = Not detected.
  * = Data from comingled pesticide streams.
    = Data from comingled pesticide/other product streams.
(n) = Number of data points.
                           V-39

-------
Table V-3.  Volatile Aromatics Detected in Pesticide Process
            Wastewaters (Continued, Page 6 of 11)

                  AROMATICS, CHLORINATED AROMATICS

                           CHLOROBENZENE

Plant
1
2
3
4
5
6
7
8
9
10
11
12
13
14
1
2
1
2
3
4
5
6
7
1
ND
NA
*

Cone.
mg/1
ND*
<0.005*
<0.005*
0.195
0.195
3.0
3.0
3.0
3.0
3.0
135*
135*
135*
135*
0.30*
0.30*
<0.01
<0.01
3.0
3.77
6.31
5.00
979
ND
Not detected.
Not available.
Data from comingled
Data from comingled

(n) Flow (NGD)
(1) NA
(1) 0.00002
(1) 0.00002
(16) 0.0391
(16) 0.0391
(3) 28.2
(3) 28.2
(3) 28.2
(3) 28.2
(3) 28.2
(111) 0.094
(111) 0.094
(111) 0.094
(111) 0.094
(1) NA
(1) NA
(3) 0.0033
(3) 1.22
(3) 28.2
(2) 2.3
(3) 0.0717
(3) 2.3
(1) 0.0163
(1) NA


pesticide streams.
pesticide/other product streams.
Analysis not conducted per protocol.
(n)
Number of data points.
                           V-40

-------
Table V-3.  Volatile Aromatics Detected in Pesticide Process
            Wastewaters (Continued, Page 7 of 11)

                  AROMATICS, CHLORINATED AROMATICS

                        1,2-DICHLOROBENZENE

Plant
1
2
3
4
5
6
7
8
9
10
1
2
3
4
NA = Not
ND = Not
* = Date
Cone.
mg/1
0.023
0.023
0.023
0.023
0.023
0.023
127*
127*
127*
127*
ND
ND
0.023*
<0.113
available.
detected.
» from cominaled ne

(n) ]
(3)
(3)
(3)
(3)
(3)
(3)
(HI)
(111)
(111)
(111)
(1)
(1)
(3)
(3)


stieide sti

Flow (MGD)
28.2
28.2
28.2
28.2
28.2
28.2
0.094
0.094
0.094
0.094
NA
2.3
28.2
0.0033


reams .
    = Data from comingled pesticide/other product streams,
(n) = Number of data points.
                           V-41

-------
Table V-3.  Volatile Aromatics Detected in Pesticide Process
            Wastewaters (Continued, Page 8 of 11)

                  AROMATICS, CHLORINATED AROMATICS

                        1,3-DICHLOROBENZENE

Plant
1
2
3
4
5
6
7
8
9
1
2
3
4
Cone.
mg/1
0.410
0.410
0.410
0.410
0.410
127*
127*
127*
127*
ND
ND
<0.120
0.410*

(n)
(3)
(3)
(3)
(3)
(3)
(HI)
(111)
(111)
(111)
(1)
(1)
(3)
(3)

Flow (MGD)
28.2
28.2
28.2
28.2
28.2
0.094
0.094
0.094
0.094
NA
NA
2.3
28.2
 NA = Not available.
 ND = Not detected.
  * = Data from comingled pesticide streams.
    = Data from comingled pesticide/other product streams.
(n) = Number of data points.
                             V-42

-------
Table V-3.  Volatile Aromatics Detected in Pesticide Process
            Wastewaters (Continued, Page 9 of 11)

                  AROMATICS, CHLORINATED AROMATICS

                        1,4-DICHLOROBENZENE

Plant
1
1
2
3
4
5
6
7
8
9
1
2
3
4
NA = Not available.
ND = Not detected.
* = Data from comii
Cone.
mg/1
ND
0.470
0.470
0.470
0.470
0.470
85*
85*
85*
85*
ND
ND
ND
0.470*


idled nes

(n)
(1)
(3)
(3)
(3)
(3)
(3)
(HI)
(HI)
(111)
(111)
(1)
(1)
(1)
(3)


ticide str

Flow (MGD)
NA
28.2
28.2
28.2
28.2
28.2
0.094
0.094
0.094
0.094
NA
2.3
NA
28.2


earns .
    = Data from comingled pesticide/other product streams,
(n) = Number of data points.
                             V-43

-------
Table V-3,
Volatile Aromatics Detected in Pesticide Process
Wastewaters (Continued, Page 10 of 11)

      AROMATICS, CHLORINATED AROMATICS

             HEXACHLOROBEN Z ENE

Plant
1
1
2
3
4
5
NA = Not available.
ND = Not detected.
* = Data from comin<
Cone.
mg/1
ND
ND
ND*
ND*
ND
<0.008


3led nesticid

(n)
(1)
(1)
(1)
(1)
(1)
(2)


e stre

Flow (MGD)
NA
NA
NA
NA
2.3
0.0033


ams .
    = Data from comingled pesticide/other product streams,
(n) = Number of data points.
                            V-44

-------
Table V-3.  Volatile Aromatics Detected in Pesticide Process
            Wastewaters (Continued, Page 11 of 11)

                  AROMATICS, CHLORINATED AROMATICS

                       1,2,4-TRICHLOROBENZENE

Plant
1
2
3
4
5
1
2
NA = Not available.
ND = Not detected.
* = Data from comina!
Cone.
mg/1
ND
36*
36*
36*
36*
ND
0.0296


Led oesticide

(n)
(1)
(47)
(47)
(47)
(47)
(1)
(2)


» stre;

Flow (MGD)
NA
0.094
0.094
0.094
0.094
2.3
0.0033


3ms.
    = Data from comingled pesticide/other product streams.
(n) = Number of data points.
                           V-45

-------
Table V-4.  Halonethanes Indicated to be Present in Pesticide Process Wasterwaters
Pesticide
Produced
Al
A2
A3
A4
A5
A6
A7
AS
A9
A10
All
Bl
B2
B3
B4
B5
B6
B7
B8
B9
BIO
Bll
Cl
C2
C3
C4
C5
C6
C7
C8
C9
CIO
Dl
D2
D3
D4

Methyl
chlorine
_„
B
—
—
—
R
—
—
B
—
—
—
—
B
—
—
—
—
—
R
B
—
—
B
—
—
—
—
—
—
—
—
—
—
—
B

Methyl
bromide
__
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
—
I
—
—
—
—
—
—
—
P
I
R
—

Methylene
chloride
ST
—
ST
—
—
—
S
s
S,B
S
—
S
s
B,S
ST
ST
I
I
—
—
—
—
S
B,S
I
—
—
—
—
S
—
S
—
I
—
^"^
HALOMBTHATCS
Dichloro- Chloro- Carbon
Chloro- Bromo- bromo- dibromo- tetra-
form form methane methane chlorine
^m^ *HH — «^ -T -~ ^m^
— — — — —
— — — — —
— — — — I
__ 	 — , - _ _ T
	 	 	 	 	
	 	 	 	 	
	 	 	 	 	
B — — B
— — — — —
__ __ __ — _ C
— — — — —
— — — —
B__ __. __ n
— — — jj
— — — — —
— — —
— — — — —
— — — — —
__ __ — — — C
— — — — —
— — —
_ M« • • —M T
— — — — —
B__ --,_. — n
— — — — o
T ^HV
— U — — —
T «... — 1_^ ^_ .— —
C __ __. ^^ .*.*
__ __ __ __ o
	 	 	 	 	
__ _„ __ __ T
	 	 	 	
	 	 	 	 	
I 	 	 	
	 	 	 	 	
______
   Footnotes at end of table
                                       V-46

-------
Table V-4.  Halcmethanes Indicated to be Present in Pesticide Process Wasterwaters
            (Continued, Page 2 of 2)


             	HALOMETHMES	
                                                            Dichloro-  Chloro-    Carbon
Pesticide     Methyl   Methyl   Methylene  Chloro-  Brono-    brono-   dibrono-   tetra-
Produced     chlorine  bromide  chloride    form    form     methane   methane   chlorine
D5
D6
D7
D8
D9
D10
El
E2
E3
E4
E5
E6
E7
E8
B — B,S B —
B__ __ c __ __ __
— ^ — — — — — _
— — — — — — —
— — — — — — —
T> __ __ __ __ __ __
B__ Q C D _ __ __
— — DfO D ^^
	 	 	 	 	 	 	
	 	 	 	 	 	 	
	 	 	 	 	 	 	
B — — — — — —
— — g — — — —
••»«• .»«• C __ — »_ — B^ — ^
	 	 	 	
Ti ^m^m D C T> ^ ^ ^^ ••«•
B
—
S
I
—
B
S
I
I
—
—
—
S
B
   R = Raw material.
   I » Raw material impurity.
   S = Solvent.
  IS = Solvent impurity.
  ST = Organic stripper solvent.
 1ST = Stripper impurity.
   B = Reaction byproduct.
  — = Not suspected.
   P = Final product.

   Methyl chloride = (Chloromethane).
   Methyl bromide = (Bromomethane).
   Methylene chloride = (Dichloromethane),
   Chloroform = (Trichloromethane).
   Bronoform = (Tribroncmethane).
   Carbon tetrachloride = (Tetrachloride)
                                               V-47

-------
Table V-5.  Halomethanes Detected in Pesticide Process Wastewaters

                            HALOMETHANES

                          METHYL CHLORIDE

Plant
1
2
3
1
2
1
1
2
3
NA = Not available.
ND = Not detected.
* = Data from comina!
Cone.
mg/1
ND
ND*
<1.0*
ND
ND*
ND
ND
ND*
ND


Led oesticide

(n)
(1)
(1)
(1)
(1)
(1)
(1)
(3)
(1)
(1)


streams.

Flow (MGD)
NA
NA
0.008
NA
NA
0.7224
0.3283
NA
NA



    = Analysis not conducted per protocol.
(n) = Number of data points.
                            V-48

-------
Table V-5.  Halomethanes Detected in Pesticide Process Wastewaters
            (Continued, Page 2 of 7)

                            HALOMETHANES

                           METHYL BROMIDE

Plant
1
2
3
Cone.
mg/1
1.10
53.8
2,600

(n)
(3)
(2)
(1)

Flow (MGD)
28.2
0.0086
0.0086
    = Data from comingled pesticide/other product stream.
(n) = Number of data points.
                           V-49

-------
Table V-5.  Halomethanes Detected in Pesticide Process Wastewaters
            (Continued, Page 3 of 7)

                            HALOMETHANES

                         METHYLENE CHLORIDE

Plant .
1
2
1
2
3
4
5
6
7
8
9
10
1
Cone.
mg/1
None
12.7
0.010*
<0.010
0.017*
0.0233
0.453*
0.55*
4.17
<75.2
76.0
31,000
<0,01*

(n)
(E)
(3)
(1)
(3)
(2)
(3)
(3)
(1)
(3)
(2)
(2)
(50)
(1)

Flow (MGD)
0.0451
0.00323
1.8
0.154
1.034
0.154
0.110
1.8
2.3
0.022
2.3
0.0014
NA
 NA = Not available.
  * = Data from comingled pesticide streams.
    = Data from comingled pesticide/other product stream.
    = Analysis not conducted per protocol.
(E) = Estimate.
(n) = Number of data points.
                            V-50

-------
Table V-5.
      Halomethanes Detected in Pesticide Process Wastewaters
      (Continued, Page 4 of 7)

                      HALOMETHANES

                      CHLOROFORM

Plant
1
1
2
3
4
5
6
7
8
1
2
1
1
2
3
NA = Not
* = Datt
Cone.
mg/1
<0.30
0.0149
<0.029
0.0367
0.111
0.170
0.200*
<1.55*
70.0*
70.0*
3,000
0.017*
0.382*
0.623*
6.31
available.
i from comincrled nestle

(n)
(3)
(3)
(2)
(3)
(2)
(3)
(1)
(3)
(10)
(10)
(2)
(1)
(3)
(3)
(3)

:ide streams

Flow (MGD)
0.00323
1.24
0.022
0.154
2.3
0.154
1.8
0.110
0.043
0.043
0.021
NA
0.1893
1.22
0.0717

•
(n)
Data from comingled pesticide/other product stream,
Analysis not conducted per protocol.
Number of data points.
                             V-51

-------
Table V-5.  Halomethanes Detected in Pesticide Process Wastewaters
            (Continued, Page 5 of 7)

                            HALOMETHANES

                             BROMOFORM
Plant
1
1
2
1
Cone.
mg/1
ND
ND
<0.010
ND
(n)
(1)
(3)
(2)
(1)
Flow
(MGD)
0.0533
2.3
2.3
1.8


 ND = Not detected.
    = Data from comingled pesticide/other product stream.
(n) = Number of data points.
                            V-52

-------
Table V-5.  Halomethanes Detected in Pesticide Process Wastewaters
            (Continued, Page 6 of 7)

                            HALOMETHANES

                        DICHLOROBROMOMETHANE

                    Cone.
Plant               mg/1           (n)         Flow (MGD)

No data available.
                        CHLOROOIBROMOMETHANE

                    Cone.
Plant               mg/1           (n)         Flow (MGD)

No data available.
                             V-53

-------
Table V-5.  Halomethanes Detected in Pesticide Process Wastewaters
            (Continued, Page 7 of 7)

                            HALOMETHANES

                        CARBON TETRACHLORIDE

Plant
1
2
3
4
5
1
2
3
4
1
2
3
4
5
6
ND = Not
* = Date
Cone.
mg/1
ND
<0.001
<0.010
<0.010
0.025
10.5*
67.9*
67.9*
121
<0.160*
<0.160*
<0.160*
0.168*
0.168*
0.168*
detected.
i from cominaled oes

(n)
(3)
(3)
(2)
(3)
(3)
(3)
(3)
(3)
(3)
(270)
(270)
(270)
(540)
(540)
(540)

jticide stream.

Plow (MGD)
0.154
0.022
2.3
0.154
2.3
1.22
0.1893
0.1893
0.0717
1.3
1.3
1.3
2.5
2.5
2.5


(n) =
Data from comingled pesticide/other product stream,
Number of data points.
                             V-54

-------
 Table V-6.  Cyanides Indicated to be present in Pesticide Process
             Wastewaters
Pesticide
Produced
A
B
C
D
E
F
G

H
I
J
K
L
M
N
0
P
0
R
S
T
U
V
W
X
Potential Cyanide
Raw Material Contamination
Atrazine
Cyanuric chloride
Cyaruric chloride
Methyl cyanocarbamate
Dichlorobenz il
Isophthalodinitrile
Cyanuric chloride
Aminoisobutyronitrile
Azobisisobutyronitrile
Cyanamide
Soduim cyanate
Sodium thiocyanate
Cyanamide 50
Sodium thiocyanate
Cyanamide
2-Cyanopyridine
Propazine
Propazine
Cyanuric chloride
Cyanuric chloride
Simazine
Anmonium thiocyanate
Cyanuric chloride
Terbuthylazi ne
Thiazole
If
If
I,
I
I
I
I,
I
1C
I
I
I
I
I
I
I
I,
I,
If
If
I,
I
I,
If
I
B
B
B



B









B
B
B
B
B

B
B

 R = Raw material.
 I = Raw material impurity
 B = Reaction byproduct.
1C = Catalyst impurity.
                                    V-55

-------
Table V-7.  Cyanides Detected in Pesticide Process Wastewaters



                              CYANIDE



                              CYANIDE

Plant
1
1
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
NA -
ND =
s
* ss
Cone.
mg/1
ND
1.22*
ND*
ND*
ND*
0.105*
0.105*
0.105*
1.22*
1.22*
1.22*
1.22*
1.22*
1.22*
1.22*
2.16*
3.02
5.04
5,503
Not available.
Not detected.
Data from comingled
Data from comingled

(n)
(1)
(772)
(270)
(270)
(270)
(540)
(540)
(540)
(772)
(772)
(772)
(772)
(772)
(772)
(772)
(3)
(44)
(34)
(3)


pesticide/other

Flow (MOD)
0.0202
1.42
1.3
1.3
1.3
2.5
2.5
2.5
1.42
1.42
1.42
1.42
1.42
1.42
1.42
1.2412
NA
NA
0.0634


product streams.
pesticide streams.
- Analysis not conducted per protocol.
(n) *
Number of data points.
                             V-56

-------
Table V-8.  Halogenated Ether Indicated to be Present in Pesticide Process
            Wastewaters
Pesticide
Produced
PRIORITY POLLUTANT HALOQENATED ETHER
       bis(2-chloroethyl) ether
   AA
   BB
   CC
   DO
   EE
                S
                P
                I
                R
                I
R = Raw material.
I - Raw material impurity.
B * Reaction byproduct.
P = Final product.
S = Solvent.
                                    V-57

-------
Table V-9.  Haloethers Detected in Pesticide Process Wastewaters

                PRIORITY POLLUTANT HALOGENATED ETHER

                      BIS(2-CHLOROETHYL)  ETHER
Plant
1
1
1
Cone.
mg/1
ND
ND
0.582
(n)
(1)
(1)
(3)
Flow (MGD)
0.030
NA
1.49
 NA = Not available.
 ND = Not detected.
    = Data from comingled pesticide/other product streams,
(n) = Number of data points.
                     2-CHLOROETHYL VINYL ETHER

                    Cone.
Plant               mg/1           (n)         Flow (MGD)

1                    ND            (1)           0.03
1                    ND            (1)            NA
 NA = Not available.
 ND = Not detected.
(n) = Number of data points.
                            V-58

-------
Table V-9.  Haloethers Detected in Pesticide Process Wastewaters
            (Continued, Page 2 of 3)

                PRIORITY POLLUTANT HALOGENATED ETHER

                    BIS(2-CHLOROISOPROPYL) ETHER
Plant
1
1
Cone.
mg/1
ND
ND
(n)
(1)
(1)
Flow (MGD)
0.03
NA
 NA = Not available.
 ND = Not detected.
(n) = Number of data points.

                    BIS(2-CHLOROETHOXY)  METHANE

                    Cone.
Plant               mg/1            (n)         Flow (MGD)

1                    ND            (1)           0.03

1                    ND            (1)            NA
 NA = Not available.
 ND = Not detected.
(n) = Number of data points.
                            V-59

-------
Table V-9.  Haloethers Detected in Pesticide Process Wastewaters
            (Continued, Page 3 of 3)

                PRIORITY POLLUTANT HALOGENATED ETHER

                    4-CHLOROPHENYL PHENYL ETHER

Plant
1
2
Cone.
mg/1
ND
ND

(n)
(1)
(1)

Flow (MGD)
NA
0.03
 NA = Not available.
 ND = Not detected.
(n) = Number of data points.

                     4-BROMOPHENYL PHENYL ETHER

                    Cone.
Plant               mg/1           (n)         Flow (MGD)

No data available.
                             V-60

-------
Table V-10. Phenols Indicated to be Present in Pesticide Process Wastewaters
AROMATICS, CHLORINATED AROMATICS
Pesticide

Produced P 2-CP 24-DCP 246-TCP PCP 2-NP 4-NP 24-DNP 4-CMC
A I I R
B I — I
C I,B — —
D I I R
E I I R
F — — I
GT
_ _ ±
H_^ __ T
« _ ^
T ••• •"•• T
J I I R
K — I I
L I I R
M I
N I —
0 I
p B —
Q _ —
RT — — __
i. ^^
S II I
T I —
U I — —
V I —
W I I R
V — — •• «.
V mm,mm, — • _.-
n —— mm^ — —
AA R B B
BB I —
CC B B B
DD B B B
BE II I
FF II I
GG II I
HH II R
II — I I
JJ II I
P =» Phenol.
2-CP » 2-Chlorophenol.
24-DCP » 2,4-Dichlorcphenol.
246-TCP - 2,4r6JTrichloro?henol.
PCP * Pentachlorophenol.
2-NP » 2-Nitro?henol.
4-NP » 4-Nitrophenol.
24-DNP » 2,4-Dinitrophenol.
T mmt*Mi «*^ ^B^ ^*^m «»^
	 	 	 — — —
	 	 	 	 	 	
T ~»~. _.«» ^.» ••« Ml^
I —— • ^^ — •— — •
— — — — —
— — — — — —
— — — — — —
— — — — — —
J — __ — — —
— — — — — —
I — — — — —
B B B
— — — — i —
	 	 	 R 	 	
	 	 	 	 — —
	 	 	 I
	 	 	 	 	 	
I 	 	 	 	 	
	 	 	 	 	 I
__ - _ ^. __ T
^
	 	 	 — 	 	
I — I I ~ ~
— I R —
— I R
— B — — — —
B P — —
	 R 	 	 	 	
B — — — — —
B ~"™ ~"™ "*— *"~ — **
T _» — • — • -mrr —mm
I 	 	 	 	
I 	 	 	 	 	
I 	 	 	 	 	
	 	 	 	 	 	
T .... _. __ ^». «••_
4-CMC * 4-Chloro-m-cresol (parachlorometa cresol).
24-DMP » 2,4-Dimethylphenol.
R * Raw material.
I * Raw material impurity.
B = Reaction byproduct.
P « Final product.
— = Not suspected.

                                          V-61

-------
Table V-ll.  Phenols Detected in Pesticide Process Wastewaters

                    PHENOLIC PRIORITY POLLUTANTS

                               PHENOL

Plant
1
2
3
4
5
6
7
8
9
1
2
3
4
5
6
7
8
9
10
11
Cone.
mg/1
0.27*
0.290
0.290
0.290
<0.51
16.0*
47.0*
47.0*
61.8
0.290
<1.82*
44.1*
<110*
<110*
<110*
200*
200*
200*
280
1,101

(n)
(1)
(3)
(3)
(3)
(3)
(21)
(1)
(1)
(762)
(3)
(3)
(31)
(337)
(337)
(337)
(312)
(312)
(312)
(3)
(22)

Flow (MGD)
1.8
28.2
28.2
28.2
0.022
0.065
0.00002
0.00002
0.124
28.2
0.120
0.138
0.20
0.20
0.20
0.20
0.20
0.20
0.015
0.0035
    = Data from comingled pesticide/other product streams,
    = Data from comingled pesticide streams.
    = Total phenols.
    = Reported as total phenols.
(n) = Number of data points.
 *
**
                              V-62

-------
Table V-ll,
Phenols Detected in Pesticide Process Wastewaters
(Continued, Page 2 of 7)

       PHENOLIC PRIORITY POLLUTANTS

              2-CHLOROPHENOL

Plant
1
2
3
4
5
6
7
8
1
2
3
Cone.
rag/1
0.062
0.062
0.062
3.00*
<5.00*
<5.00*
30.5
<1,000
0.062
<5.09*
11.2*

(n)
(3)
(3)
(3)
(21)
(1)
(1)
(3)
(8)
(3)
(31)
(3)

Flow (MGD)
28.2
28.2
28.2
0.065
0.00002
0.00002
0.022
0.02
28.2
0.138
0.120
  * = Data from coraingled pesticide streams.
    = Data from comingled pesticide/other product streams.
(n) = Number of data points.
                              V-63

-------
Table V-ll.  Phenols Detected in Pesticide Process Wastewaters
             (Continued, Page 3 of 7)

                    PHENOLIC PRIORITY POLLUTANTS

                         2,4-DICHLOROPHENQL

Plant
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
1
2
3
4
5
6
Cone.
mg/1
0.042*
0.042*
0.290
0.290
0.290
<5.00*
<5.00*
<7.74*
<7.74*
15.0*
118
>1,000
3,000
3,600
6,650
0,290
9.08
36.0
53.7*
92.2*
42,000

(n)
(2)
(2)
(3)
(3)
(3)
(1)
(1)
(301)
(301)
(21)
(3)
(9)
(1)
(1)
(6)
(3)
(30)
(3)
(3)
(31)
(3)

Flow (MGD)
1.8
1.8
28.2
28.2
28.2
0.00002
0.00002
0.0960
0.0960
0.065
0.022
0.02
0.002
0.00125
0.0034
28.2
0.101
0.3283
0.120
0.138
0.015
  * = Data from comingled pesticide streams.
    = Data from comingled pesticide/other product streams,
(n) = Number of data points.
                           V-64

-------
Table V-ll,
Phenols Detected in Pesticide Process Wastewaters
(Continued, Page 4 of 7)

       PHENOLIC PRIORITY POLLUTANTS

          2,4,6-TRICHLOROPHENOL

Plant
1
2
3
4
5
6
7
8
9
1
2
3
4
5
Cone.
mg/1
0.022*
0.110
0.110
0.110
3.00*
<5.00*
<5.00*
<100
481
0.110
<0.794
2.20*
<3.69*
8,700

(n)
(2)
(3)
(3)
(3)
(21)
(1)
(1)
(8)
(3)
(3)
(30)
(3)
(31)
(3)

Flow (MGD)
1.8
28.2
28.2
28.2
0.065
0.00002
0.00002
0.02
0.022
28.2
0.101
0.120
0.138
0.015
  * = Data from comingled pesticide streams.
    = Data from comingled pesticide/other product streams.
(n) = Number of data points.
                            V-65

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Table V-ll.  Phenols Detected in Pesticide Process Wastewaters
             (Continued, Page 5 of 7)

                    PHENOLIC PRIORITY POLLUTANTS

                         PENTACHLOROPHENOL

Plant
1
2
Cone,.
mg/1
1.00*
>1,000

(n)
(21)
(9)

Flow
0.
0.

(MGD)
065
02
  * = Data from comingled pesticide streams.
(n) = Number of data points.
                           2-NITROPHENOL

                    Cone.
Plant               mg/1           (n)         Flow (MGD)

No data available.
                            V-66

-------
Table V-ll
Phenols Detected in Pesticide Process Wastewaters
(Continued, Page 6 of 7)

       PHENOLIC PRIORITY POLLUTANTS

              4-NITROPHENOL

Plant
1
1
2
3
Cone.
mg/1
0.002
174
461*
461*

(n)
(1)
(121)
(610)
(610)

Flow (MGD)
0.006
0.215
0.75
0.75
  * = Data from comingled pesticide streams,
(n) = Number of data points.
Plant

1
       Cone.
       mg/1

        7.91
2,4-DINITROPHENOL


          (n)

          (4)
Flow (MGD)

   1.06
    = Data from comingled pesticide/other product streams.
(n) = Number of data points.
                            V-67

-------
Table V-ll.  Phenols Detected in Pesticide Process Wastewaters
             (Continued, Page 7 of 7)
                    PHENOLIC PRIORITY POLLUTANTS
                       PARACHLOROMETA CRESOL
Plant
No data available.
Cone.
mg/1
      (n)
            Flow (MGD)
Plant
No data available.
Cone.
mg/1
2,4-DIMETHYLPHENOL

          (n)
                       Flow (MGD)
Plant
No data available.
Cone.
mg/1
4,6-DINITRO-O-CRESOL

           (n)         Flow (MGD)
                            V-68

-------
Table V-12.  Polynuclear Aromatic Hydrocarbons Indicated to be Present in Pesticide
             Process Wastewaters

Pesticide
Product
A
B
C
D
E
F


Naphthalene
B
I
u.
I
I .
I
POLYNUCLEAR
2-Chloro-
naphthalene
^ ^
—
U
—
—
™™
AROMATIC PRIC3RITY POLLUTANTS
Acenaphthene
Acenaphthylene
_^
—
—
I
--
R
Anthracene
phenanthrene
^^
—
—
I
—
•••••
Fluorene
Fluoranthene
- -
—
— .
I
~
•^••B
  I » Raw material impurity.
 — « Not suspected.
  U = Unknown—pollutant reported by plant, source not determined.
                                     V-69

-------
Table V-13
Polynuclear Aromatic Hydrocarbons Detected in Pesticide
Process Wastewaters

 POLYNUCLEAR AROMATIC PRIORITY POLLUTANTS

               NAPHTHALENE

Plant
1
2
1
2
NA =
ND =
* =
(n) =




Not available.
Not detected.
Cone.
mg/1
0.066*
0.066*
ND
1.06*


Data from comingled pesticide
Number of data points.

(n)
(3)
(3)
(1)
(3)


streams.

Flow (MGD)
28.2
28.2
NA
0.1893



                       2-CHLORONAPHTHALENE

Plant
1
2
NA =
ND =
* =
(n) =
Cone.
mg/1
ND
<0.01*
Not available.
Not detected.
Data from comingled pesticide
Number of data points.

(n)
(1)
(1)


streams .

Flow (MGD)
NA
0.189



                              V-70

-------
Table V-13.  Polynuclear Aromatic Hydrocarbons Detected in Pesticide
             Process Wastewaters (Continued, Page 2 of 4)

              POLYNUCLEAR AROMATIC PRIORITY POLLUTANTS

                            ACENAPHTHENE

Plant
1
Cone.
mg/1
ND

(n)
(1)

Flow (MGD)
NA
 NA = Not available.
 ND = Not detected.
(n) = Number of data points.
                           ACENAPHTHYLENE

                    Cone.
Plant               mg/1           (n)         Flow (MGD)

No data available.
                           V-71

-------
Table V-13.  Polynuclear Aromatic Hydrocarbons Detected in Pesticide
             Process Wastewaters (Continued, Page 3 of 4)

              POLYNUCLEAR AROMATIC PRIORITY POLLUTANTS

                             ANTHRACENE
Plant
1
Cone.
mg/1
ND
(n)
(1)
Flow (MGD)
NA
 NA = Not available.
 ND = Not detected.
(n) = Number of data points.
                            PHENANTHRENE

                    Cone.
Plant               mg/1           (n)         Flow (MGD)

No data available.
                              V-72

-------
Table V-13   Polynuclear Aromatic Hydrocarbons Detected in Pesticide
             Process Wastewaters (Continued, Page 4 of 4)

              POLYNUCLEAR AROMATIC PRIORITY POLLUTANTS

                              FLUORENE
Plant
1
Cone.
mg/1
NO
(n)
(1)
Flow (MGD)
NA
 NA = Not available.
 ND = Not detected.
(n) = Number of data points.
                            FLUORANTHENE

                    Cone.
Plant               mg/1           (n)         Flow (MGD)

No data available.
                           Vr73

-------
Table V-14.  Metals Indicated to be Present  in Pesticide  Process Wastewaters
Pesticide                                    PRIORITY POLLUTANT JETAL
Produced                        Hg        As          Cu          Zn          Cd
  A                             _         j           _          _          _

  B                             C          —          ~          —          —
                                C__         -._          r*           — —          —
                                                      \^                       —
  D                             —         —          C           —          —



  G                                                   C           —          —
                                H-...         __          /i           __          	
                                __         __          ^           __          __


  J                             —         —          —          R           —
                                K__         __          -.„          B           __
                                           	          ——          K           —

  L                             ~~         -~          R           ~~          ~~
  M                             ___!           —          _-

  N                             _         _          _          C           —
  0                             _____          R           —
  p                             ______          R           _
  Q                             ______          R
  R                             ______          R
  S                             _____          R           _

  T                             R          R           R           —          R
  C = Catalyst.
  R = Raw material.
  I = Inpurities  in raw materials or catalysts.
 — = Not suspected.
                                      V-74

-------
Table V-15,
Metals Detected in Pesticide Process Wastewaters

         PRIORITY POLLUTANT METAL

                 ARSENIC
Plant
1

Plant
1
1
2
1
2
3
4
5
1
Cone.
mg/1
2.0

Cone.
mg/1
1.0
ND*
0.05*
ND*
4,500
5,350*
47,000
59,000
0.204
(n)
(12)
COPPER
(n)
(1)
(1)
(1)
(1)
(325)
(72)
(1)
(1)
(3)
Flow (MGD)
0.27

Flow (MGD)
0.03
1.8
1.8
1.8
0.021
0.016
0.000946
0.001
1.24
 ND = Not detected.
  * = Data from comingled pesticide streams
(n) = Number of data points.
                                  V-75

-------
Table V-15.   Metals Detected in Pesticide Process Wastewaters
             (Continued, Page 2 of 2)

                      PRIORITY POLLUTANT METAL

                               NICKEL

                    Cone.
Plant               mg/1           (n)         Flow (MGD)

No data available.
                                ZINC

                    Cone.
Plant               mg/1           (n)         Flow (MGD)

1                   247*           (2)          0.0749
2                   247*           (2)          0.0749
  * = Data from comingled pesticide streams,
(n) = Number of data points.
                             V-76

-------
Table V-16.
Chlorinated Ethanes and Ethylenes Indicated to be Present in Pesticide
Process Wastewaters
Pi
Pi

R
I
S
IS
SI
1ST
B
U
—
CHLORINATED ETHANES AND ETHYLENES
Educed CE DCE DCE TCE TCE TETCE CE GET DCET DCET TCET GET
A "*™ X — ~ ™™ *"*• "** "*~ ™" "*~ ~~ ™" ~~
	 a 	 	 TO TQ __ 	 __ - __ __
•• a — •— xo xo — — — — —
	 O __ — — TO TO - - 	 __ 	 __ __
— o — ~ xo xo ^^ ^^ ^^
	 O - 	 TO TO 	 	 __ 	 	 __
— o — — xo xo ^^ ^^ ^^ ^^
g MM XO ^ * ^ * ^ " — "" "*— ^ * "*^ "*"" "" *** ^^
P_ T __ _ __ 	 _ 	 	 	 	 __
__ X ^^ ^^ ^^ ^^ ^^ ^^ ^^ ^^ ^^
G._ _. 	 __ ..._ . 	 T __
_ __ __ __ _ __ __ — __ __ ^ «
H_ 	 	 	 _. .__ __ .__ 	 	 - o
__ __ __ __ _ _ _ _ __ __ __ jg
	 ._ - - 	 __ __ 	 	 	 __ Tf
__ __ __ __ y
J__ n 	 -_ 	 __ __ 	 __ __ - __
"""• D ^^ ~ ~ ^^ — — ^^ ^^ ~~ ^^ *"•• ^^
K-_ o 	 __ TC TC — — 	 	 	 __ __
^^ o xo xo
L.__ 	 	 	 	 	 	 o 	 	 	 — —
__ __ __ __ __ __ __ g __ _ — — —
MT 	 _ _ n 	 	
X ^^ ^^ ^^ ^~ ^^ K ^^ ^~^ ^^
	 O 	 __ TO TO 	 	 __ 	 	 __
"•• o ^^ XO XO
Off 	 	 _- 	 	 	 	 _ . _ 	
__ y — — _ — _ — — — — — — — — — — — —
	 	 __ 	 - 	 ._ __ 	 	 	 O
•• ^M» ^^ ^^ ^^ ^^ ^^ ^^ O
OD 	 -— 	 	 	 	 	 	 __ __ __
o —- ~~ ~~
R_ TO _ __ 	 _ 	 	 _
__ xo ^^ ^^ ^^ ^^ ^^ ^-^
	 	 	 	 	 	 	 	 	 	 T __
__ __ __ __ __ __ __ _ _ ^ _
U__ O 	 __ TO TO 	 	 	 	 	 __
O XO XO ^^
V.__ o 	 __ TO TO 	 __ 	 	 _
__ O ^^ ^^ XO XO ^^ ^^ "^ ^~^
	 	 	 _^ - 	
— — — — — —
Raw material
Raw material impurity.
Solvent.
Solvent impurity.
Organic stripper solvent.
Stripper impurity.
Reaction byproduct.
Unknown — pollutant reported by plant,
source not determined.
- Not suspected.
~~
CE
DCE
TCE
TfcTCfc!
GET
DCET
TCET

__ mm^ mm^ mm^ rj
Chlorethane.
Dichloroe thane .
Tr ichloroe thane .
Tetrachloroethane .
Vinyl chloride (Chloroethylene)
Dichloroethylene .
» Trichloroethylene.

                                                   V-77

-------
Table V-17.  Chlorinated Ethanes and Ethylenes Detected in Pesticide
             Process Wastewaters

                 CHLORINATED ETHANES AND ETHYLENES

                            CHLOROETHANE
Plant

No data available.
Cone.
mg/1
(n)
                                               Flow (MGD)
                         1 , 2 -DI CHLOROETHANE
Plant
1
2
3
4
1
1
NA = Not
ND = Not
Cone.
mg/1
ND
0.010*
0.37*
10,000
0.37*
0.010*
available.
detected.
(n)
(1)
(1)
(1)
(3)
(1)
(1)

Flow (MGD)
NA
1.8
1.8
0.0002
1.8
1.8

  * = Data from comingled pesticide streams.
(n) = Number of data points.
                                    \/_7R

-------
Table V-17
Chlorinated Ethanes and Ethylenes Detected in Pesticide
Process Wastewaters (Continued, Page 2 of 6)

    CHLORINATED ETHANES AND ETHYLENES

            1,1-DICHLOROETHANE

Plant
1
2
1
NA =
ND =
* =
(n) =
Cone.
mg/1
ND*
ND*
ND*
Not available.
Not detected.
Data from comingled pesticide
Number of data points.

(n)
(1)
(1)
(1)


streams.

Flow (MGD)
NA
NA
NA



                       1,1,1-TRICHLOROETHANE

Plant
1
1
2
1
NA =
ND =
* =
(n) =
Cone.
mg/1
ND
ND*
ND*
ND*
Not available.
Not detected.
Data from comingled pesticide
Number of data points.

(n)
(1)
(1)
(1)
(1)


streams.


Flow (MGD)
NA
NA
NA
NA




                               V-79

-------
Table V-17.  Chlorinated Ethanes and Ethylenes Detected in Pesticide
             Process Wastewaters (Continued, Page 3 of 6)

                 CHLORINATED ETHANES AND ETHYLENES

                       1,1,2-TRICHLOROETHANE
Plant
1
1
Cone.
mg/1
0.020*
0.020*
(n)
(1)
(1)
Flow (MGD)
1.8
1.8
  * = Data from comingled pesticide streams.
(n) = Number of data points.
                     1,1,2,2-TETRACHLOROETHANE
Plant
1
1
2
1
Cone.
mg/1
1.70*
ND*
1.70*
1.70*
(n)
(1)
(1)
(1)
(1)
Flow (MGD)
1.8
NA
1.8
1.8
 NA = Not available.
 ND = Not detected.
  * = Data from comingled pesticide streams.
(n) = Number of data points.
                                 V-CO

-------
Table V-17.  Chlorinated Ethanes and Ethylenes Detected in Pesticide
             Process Wastewaters (Continued, Page 4 of 6)

                 CHLORINATED ETHANES AND ETHYLENES

                          HEXACHLOROETHANE

                    Cone.
Plant               mg/1           (n)         Flow (MGD)

No data available.
                           VINYL CHLORIDE

                    Cone.
Plant               mg/1           (n)         Flow (MGD)

No data available.
                                  V-81

-------
Table V-17.  Chlorinated Ethanes and Ethylenes Detected in Pesticide
             Process Wastewaters (Continued, Page 5 of 6)

                 CHLORINATED ETHANES AND ETHYLENES

                        1,1-DICHLOROETHYLENE
Plant
1
2
1
Cone.
mg/1
ND*
ND*
ND*
(n)
(1)
(1)
(1)
Flow (MGD)
NA
NA
NA
 NA = Not available.
 ND = Not detected.
  * = Data from comingled pesticide streams.
(n) = Number of data points.
                     1,2-TRANS-DICHLOROETHYLENE

                    Cone.
Plant               mg/1           (n)         Flow (MGD)

No data available.
                                    V-82

-------
Table V-17,
Chlorinated Ethanes and Ethylenes Detected in Pesticide
Process Wastewaters (Continued, Page 6 of 6)

    CHLORINATED ETHANES AND ETHYLENES

            TRICHLOROETHYLENE

Plant
1
1
1
NA =
ND =
* =
(n) =










Cone.
mg/1
ND*
0.052*
0.052*

(n)
(1)
(1)
(1)


Flow (MGD)
NA
1.
1.

8
8
Not available.
Not detected.
Data from
Number of
comingled pesticide
data points.
streams.


                        TETRACHLOROETHYLENE
Plant
1
2
1
2
Cone.
mg/1
0.37*
<98.0
0.467*
0.467*
(n)
(1)
(6)
(3)
(3)
Flow (MGD)
1.8
0.00185
0.1893
0.1893
  * = Data from comingled pesticide streams,
(n) = Number of data points.
                                     V-83

-------
Table V-18.  Nitrosamines Indicated to be Present in Pesticide Process
             Wastewaters
Pesticide       	PRIORITY POLLUTANT NITROSAMINE	
Produced        N-Nitrosodimethylanine           N-Nitrosodi-n-propylaniine
   AA                    —                                 B
   BB                    B                                  B
B = Reaction byproduct,
                                      V-84

-------
Table V-19.  Nitrosamines Detected in Pesticide Process Wastewaters

                   PRIORITY POLLUTANT NITROSAMINE

                       N-NITROSODIMETHYLAMINE
Plant

1
Cone.
mg/1

0.00005
(n)

(240)
Flow (MGD)

   0.352
(n) = Number of data points.
                     N-NITROSODI-N-PROPYLAMINE

Plant
1
2
3
Cone.
mg/1
0.069
0.123
1.85

(n)
(592)
(360)
(3)

Flow (MGD)
0.076
0.352
0.0678
(n) = Number of data points.
                       N-NITROSODIPHENYLAMINE
Plant

No data available.
Cone.
mg/1
(n)
Flow (MGD)
                               V-85

-------
Table V-20.  Phthalate Indicated  to be  Present  in Pesticide Process
             Wastewaters
Pesticide                                     PRIORITY POLLUTANT PHTHALATE
 Process                                           Dimethyl phthalate
   AA                                                      R
   BB                                                      B
   CC                                                      R
R = Raw material.
I = Raw material impurity.
B = Reaction byproduct.
                                        V-86

-------
Table V-21.  Phthalate Esters Detected in Pesticide Process Wastewate

                    PRIORITY POLLUTANT PHTHALATE

                         DIMETHYL PHTHALATE
Plant

No data available.
Cone.
mg/1
          (n)
Flow (MGD)
Plant

1
Cone.
mg/1

 ND*
DIETHYL PHTHALATE


          (n)

          (1)
Flow (MGD)

    1.8
 ND = Not detected.
  * = Data from comingled pesticide streams,
(n) = Number of data points.
                                     V-87

-------
Table V-21.  Phthalate Esters Detected in Pesticide Process Wastewate
             (Continued/ Page 2 of 2)
                    PRIORITY POLLUTANT PHTHALATE
                        DI-N-BUTYL PHTHALATE
                    Cone.
Plant               mg/1           (n)         Plow (MGD)
No data available.
                       BUTYL BENZYL PHTHALATE
                    Cone.
Plant               mg/1           (n)         Flow (MGD)
No data available.
                    BIS(2-ETHYLHEXYL) PHTHALATE
                    Cone.
Plant               mg/1           (n)         Plow (MGD)
No data available.
                               v-e

-------
 Table V-22.  Dichlorcpropane and Dichloropropene Indicated to be Present
              in Pesticide Process Wastewaters
 Pesticide                             PRIORITY POLLUTANT
  Process                 1,2-Dichloropropane           1,3-Dicnloropropene
    All
    B                             P                              P
    C                             B                              P
    D                             I                              R
    E                             —                             I
    F                             I
    Gil
    H                             —                             I
 P - Product.
 R = Raw material.
 I = Raw material impurity.
 S = Solvent.
IS - Solvent impurity.
 B = Reaction byproduct.
— = Not suspected.
                                         V-89

-------
Table V-23.  Dichloropropane and Dichloropropene Detected in
             Pesticide Process Wastewaters

                         PRIORITY POLLUTANT

                        1,2-DICHLOROPROPANE

Plant
1
NA =
ND =
* =
(n) =
Cone.
mg/1
ND*
Not available.
Not detected.
Data from coming led pesticide
Number of data points.

(n)
(1)


streams.


Flow (MGD)
NA




                        1,3-DICHLOROPROPENE
Plant
1
2
NA =
ND =
Cone.
mg/1
ND*
ND*
Not available.
Not detected.
(n)
(1)
(1)

Flow (MGD)
NA
NA

  * = Data from comingled pesticide streams,
(n) = Number of data points.
                             V-90

-------
  Table V-24.  Priority Pollutant Pesticides  Indicated to  be Present  in Pesticide Process Wastewaters
             	PRIORITY POLLUTANT PESTICIDE	
                                          Endo-
  Pesticide                    Endo-      sulfan           Endrin               Heptachlor       DDT,ODD,
  Produced   Aldrin  Dieldrin  sulfan's*  Sulfate   Endrin aldehyde  Heptachlor  epoxide  BHC's*   DDE   Chlordane Toxaphene
VO
     A
     B
     C
     D
     E
     F
     G
     H
     I
     J
     K
P.B
P.B
         B.P.B
         B.B.P
         P.B.B
         R,B,B
     R = Raw material.
     P = Product.
     B = Reaction byproduct.
    — = Not suspected.
     * = Al1 isomers.
     t - Alpha, beta and delta isomers

-------
Table V-25.  Priority Pollutant Pesticides Detected in Pesticide
             Process Wastewaters

                    PRIORITY POLLUTANT PESTICIDE

                               ALDRIN
Plant
1
Cone.
mg/1
0.012*
(n)
(3)
Flow (MGD)
0.1893
  * = Data from comingled pesticide streams,
(n) = Number of data points.
                              DIELDRIN

Plant
1
Cone.
mg/1
0.382*

(n)
(3)

Flow (MGD)
0.1893
  * = Data from comingled pesticide streams.
(n) = Number of data points.
                    ENDOSULFANS—ALL ISOMERS
Pesticide Produced

No data available.
Plant/
Subcategory
Cone.
mg/1
(n)
Flow (MGD)
                             V-92

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Table V-25.  Priority Pollutant Pesticides Detected in Pesticide
             Process Wastewaters (Continued, Page 2 of 5)

                    PRIORITY POLLUTANT PESTICIDE

                         ENDOSULPAN SULFATE
Plant
No data available.

Plant
1
2
Cone.
mg/1


Cone.
mg/1
<0.510
0.516
(n)

ENDRIN
(n)
(171)
(3)
Flow (MGD)


Flow (MGD)
0.184
0.1893
(n)  * Number of data points,
                              V-93

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Table V-25
Priority Pollutant Pesticides Detected in Pesticide
Process Wastewaters (Continued, Page 3 of 5)

       PRIORITY POLLUTANT PESTICIDE

             ENDRIN ALDEHYDE

Plant
1
NA =
ND =
* =
(n) =
Cone.
mg/1
ND*
Not analyzed.
Not detected.
Data from comingled pesticide
Number of data points.

(n)
(1)

streams.

Flow (MGD)
NA


                             HEPTACHLOR
Plant
1
2
Cone.
mg/1
0.095
0.320
(n)
(3)
(184)
Plow (MGD)
0.1893
0.184
(n) = Number of data points.
Plant

1
       Cone.
       mg/1

        ND*
HEPTACHLOR EPOXIDE



          (n)


          (1)
Flow (MGD)

    NA
 NA = Not available.
 ND = Not detected.
  * = Data from comingled pesticide streams,
(n) = Number of data points.
                                V-94

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Table V-25.  Priority Pollutant Pesticides Detected in Pesticide
             Process Wastewaters (Continued, Page 4 of 5)

                    PRIORITY POLLUTANT PESTICIDE

                BHCs—ALPHA, BETA, AND DELTA ISOMERS
Plant

No data available.
Cone.
mg/1
      (n)
 Flow (MGD)
Plant

1
Cone.
mg/1

<1.54
4,4'-ODD


     (n)

     (16)
Flow (MGD)

   NA
 NA = Not available.
  * = Not presently manufactured.
(n) = Number of data points.
                              4,4'-DDE

Plant
1
2
Cone.
mg/1
7.34
174

(n)
(16)
(1)

Flow (MGD)
NA
0.0163
 NA = Not available.
  * = Not presently manufactured.
(n) = Number of data points.
                               V-95

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Table V-25.  Priority Pollutant Pesticides Detected in Pesticide
             Process Wastewaters (Continued, Page 5 of 5)
                    PRIORITY POLLUTANT PESTICIDE

                              4,4'-DDT

Plant
1
2
Cone.
mg/1
<0.20
135

(n)
(16)
(1)

Flow (MGD)
NA
0.0163
 NA » Not available.
  * = Not presently manufactured.
(n) « Number of data points.
                             CHLORDANE
Plant
1
NA =
ND =
* =
(n) =
Cone.
mg/1
ND*
Not available.
Not detected.
Data from comingled pesticide
Number of data points.
(n)
(1)
stream.
Flow (MGD)
NA

Plant

1
2
Cone.
mg/1

0.065
5.32
                             TOXAPHENE
(n)

(4)
(3)
Flow (MGD)

   1.22
   0.0717
    = Analysis not conducted per protocol,
(n) = Number of data points.
                              V-96

-------
Table V-26.  Dienes Indicated to be Present in Pesticide Process Wastewaters
Pesticide
Process
AA
BB
CC
DD
EE
FF

HCCPD
R
R
R
R
R
R
PRIORITY POLLUTANT
Hexachlorobutadiene
B
B
B
B
B
B,S
S 3 Solvent.
R 3 Raw material.
B = Raw material synthesis byproduct.
HCCPD » Hexachlorocyclopentadiene.
                                           V-97

-------
Table V-27
             Dienes Detected in Pesticide Process Wastewaters

                         PRIORITY POLLUTANT

                     HEXACHLOROC YCLOPENTADIENE

Plant
1
2
1
1
2
3
4
Cone.
mg/1
Trace
180
2,500
0.435*
0.435*
0.827*
0.827*

(n)
(1)
(1)
(2)
(50)
(50)
(3)
(3)

Flow (MGD)
0.000946
0.001
0.10
0.184
0.184
0.1893
0.1893
  * =
      Data from comingled pesticide streams.
    = Data exceed published solubility of compound in water apparentl
      due to sampling from organic, nonaqueous streams.
    = Attributed to intermediate.
(n)  = Number of data points.
                        HEXACHLOROBUTADIENE
Plant

1
2
                    Cone.
                    mg/1

                    0.191*
                    0.191*
(n)

(3)
(3)
Flow (MGD)

0.1893
0.1893
  * = Data from comingled pesticide streams
(n) = Number of data points.
                               V-98

-------
Table V-28.  TCCD Indicated to be Present in Pesticide Process Wastewaters
Pesticide                                            PRIORITY POLLUTANT
 Process                   Raw Material                    TCDD
   AA                      2,4,5-Tri chlorophenol             B
   BB                      1,2,4,5-Tetrachlorobenzene        B
   CC                      1,2,4,5-Tetrachlorobenzene        B
   DD                      2,4,5-Trichlorophenol             B
   EE                      2,4,5-Trichlorophenol             B
TCCD = 2,3,7,8-Tetrachlorodibenzo-p-dioxin.
   B = Reaction byproduct.
                                              V-99

-------
Table V-29.  TCDD Detected in Pesticide Process Wastewaters



                         PRIORITY POLLUTANT



                2,3,7,8-TETRACHLORODIBEN1O-P-DIOXIN

Plant
1
1
2
3
4
5
6
ND =
* =
(E) -
(n) =
Cone.
rag/1
ND
<0. 000002*
<0. 000002*
<0. 000002*
0.022*
0.022*
0.022*
Not detected.
Data from comingled pesticide
Estimate.
Number of data points.

(n)
(E)
(3)
(3)
(3)
(1)
(1)
(1)

streams.



Flow (MGD)
0.0031
0.20
0.20
0.20
0.20
0.20
0.20




                              V-1QO

-------
Table V-30.  Asbestos Detected in Pesticide Process Wastewaters
                    PRIORITY POLLUTANT ASBESTOS

Plant
1
2
3
4
5
6
7
8
9
1
1
12
13
14
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
Cone.
mg/1
ND*
ND*
ND*
ND*
ND*
ND*
0.000038*
0.000038*
0.0003*
0.000824*
0.000824*
0.0027*
0.049*
0.049*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
0.000038*
0.000185*
0.0003*
D. 000824*
0.0027*
0.0027*
0.0027*
0.003*
0.049*
0.049*
0.049*
0.049*
0.049*

(n)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)

Plow (MOD)
0.900
8.00
8.00
0.030
8.00
8.00
NA
NA
0.187
1.739
1.739
NA
33.5
33.5
8.00
0.960
8.00
0.036
8.00
0.080
0.080
8.00
0.960
NA
0.030
0.187
1.739
NA
NA
NA
0.187
33.5
33.5
33.5
33.5
33.5
Footnotes at end of table
                               V-101

-------
Table V-30.
Asbestos Detected in Pesticide Process Wastewaters
(Continued, Page 2 of 3)
                    PRIO1ITY POLLUTANT ASBESTOS

Plant
23
24
25
26
27
28
29
30
31
32
33
34
35
36
1
1
1
2
3
1
2
1
3
4
5
6
7
8
9
Cone.
mg/1
0.049*
0.049*
0.049*
0.049*
0.049*
0.049*
0.049*
0.049*
0.3*
0.3*
0.3*
0.3*
0.3*
0.3*
0.0027*
ND*
0.000038*
0.000038*
0.000038*
ND*
ND*
ND*
ND*
ND*
0.00093*
0.00093*
0.0027*
0.0027*
0.049*

(n)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)
(1)

Flow (MGD)
33.5
33.5
33.5
33.5
33.5
33.5
33.5
33.5
0.100
0.100
0.100
0.100
0.100
0.100
NA
0.960
NA
NA
NA
0.900
8.00
0.080
0.036
0.083
1.90
1.90
NA
NA
33.5
Footnotes at end of table
                              V-102

-------
Table V-30.
Asbestos Detected in Pesticide Process Wastewaters
(Continued, Page 3 of 3)
                    PRIORITY POLLUTANT ASBESTOS

Plant
10
11
12
13
14
1
2
3
4
5
6
7
8
9
10
11
NA = Not
ND = Not
* = Dat*
Cone.
mg/1
0.049*
0.049*
0.3*
0.3*
0.3*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
ND*
0.0003*
available.
detected.
i from cominaled wastewatei

(n)
1)
1)
1)
1)
1)
1)
1)
1)
1)
1)
1)
(1)
1)
1)
1)
1)




Flow (MGD)
33.5
33.5
0.100
0.100
0.100
0.960
0.900
0.960
0.960
0.960
0.960
0.960
0.960
0.960
0.960
0.187



    = Total calculated mass chrysotile fibers only.
      plant averages reported.
(n) = Number of data points.
                                        Maximum of all
                              V-103

-------
Table V-31,
       Nonconventional Parameters Detected in Pesticide Process
       Wastewaters

               NONCONVENTIONAL PARAMETERS

                       PESTICIDES

Plant
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
1
2
3
NA =
ND =
* =
Cone.
mg/1
ND*
ND
ND
None
None
None
0.003
<0.0336
1.60
3.32*
3.49
7.57
8.03*
10.4
10.9
16.0**
41.8
160
430
477
720
747
1,090
3,000
4,320
5,995
6,478
6,800
11,200
NA
ND
0.000953
Not available.
Not detected.
Data from cominaled oesti

(n)
(11)
(1)
(E)
(E)
(E)
(E)
(1)
(25)
(8)
(3)
(10)
(5)
(18)
(221)
(4)
(1)
(147)
(3)
(3)
(163)
(1)
(1)
(2)
(E)
(150)
(E)
(1)
(1)
(690)
(180)
(1)
(29)


cide streams

Flow (MGD)
0.405
0.000002
0.00005
0.0048
0.0048
0.0004
0.101
1.8
1.15
1.88
NA
0.0315
0.0923
1.08
1.224
0.03
0.242
0.00323
0.187
0.006
0.01
0.0451
0.0072
0.022
0.005
0.00020
0.00281
0.0034
0.005
0.012
0.000002
0.8


•
 **
(E)
(n)
Analyzed as hydrolysis product.
Average of pilot plant data.
Estimate.
Number of data points.
                                 V-104

-------
Table V-31
Nonconventional Parameters Detected in Pesticide Process
Wastewaters (Continued, Page 2 of 11)

        NONCONVENTIONAL PARAMETERS

                PESTICIDES

Cone.

Plant mg/1 (n) Flow (MGD)
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
*

(E)
(n)
<0.019 (10)
<0.0817 (105)
<0.0918 (33)
<0.159 (7)
0.175 (2)
<0.189 (18)
0.207 (2)
0.240 (4)
0.439 (20)
0.470 (3)
0.527 (8)
0.58 (4)
0.615 (3)
0.70 (11)
<0.850 (59)
1.08 (1)
1.10 (3)
1.54 (6)
2.00 (E)
2.5 (9)
3.0 (3)
4.26 (365)
6.30 (173)
7.75 (1)
9.0 (22)
13.2 (365)
14.4 (89)
15.0 (2)
17.0 (449)
19.9 (3)
25.8* (2)
29.1 (1)
30.3 (30)
= Data from comingled pesticide streams.
= Data from comingled pesticide/other product
= Estimate.
= Number of data points.
1.8
1.8
1.8
1.8
0.00854
1.8
2.3
28.2
1.8
28.2
0.130
0.09425
1.241
3.6
1.8
0.144
28.2
3.6
0.161
3.6
28.2
1.034
0.104
0.0202
0.00156
1.034
1.034
0.012
0.135
2.3
0.0749
0.144
0.0792

streams.


                                V-105

-------
Table V-31
Nonconventional Parameters Detected in Pesticide Process
Wastewaters (Continued, Page 3 of 11)

        NONCONVENTIONAL PARAMETERS

                PESTICIDES

Plant
37
38
39
40
41
42
43
44
45
46
47
48
49
50
51
52
53
54
55

56
57
58
59
60
61
62
63
64
65
66
67
68
69
70
71
NA = Not
* = Date
Cone.
mg/1
36*
45.9
53.8
71.1
85*
93.1
104
127*
135*
136
<152
174
212
218
260
300
320
335
600

863*
863*
863*
863*
863*
973
1,100
1,290
1,630
1,778
2,600
3,460
3,586
4,580
5,500*
5,500*
available.
i from cominaled D«

(n)
(47)
(3)
(2)
(125)
(111)
(11)
(570)
(HI)
(HI)
(30)
(150)
(173)
(1)
(5)
(2)
(1)
(13)
(3)
(E)

(1)
(1)
(1)
(1)
(1)
(30)
(474)
(12)
(180)
(5)
(1)
(3)
(2)
(210)
(1)
(1)

jsticide streams

Flow (MGD)
0.094
1.241
0.0086
0.08026
0.094
0.08026
0.0634
0.094
0.094
0.2088
0.08026
0.104
0.145
0.0315
0.022
0.30
0.208
0.154
4,140 gal/
1,000 Ibs
0.144
0.144
0.144
0.144
0.144
0.792
0.1633
0.163
0.012
NA
0.0086
0.0181
0.00125
0.008
0.00002
0.00002

• •
    = Values reported are after pretreatment,
(E) = Estimate.
(n) = Number of data points.
                              V-106

-------
Table V-31,
Nonconventional Parameters Detected in Pesticide Process
Wastewaters (Continued, Page 4 of 11)

        NONCONVENTIONAL PARAMETERS

                PESTICIDES

Plant
1
2
3

1
2
3
4
1
2
3
4
5
1
2
3
4
5
6
7
1
2
3
4
5
6
7
8
9
10
11
* =
r:
(E) =
(n) =
Cone.
mg/1
6.9
6.9
481

12.2
<23.5
60.0
<1,418
Trace
<0.820
25.8*
25.8*
863*
12.2*
12.2*
14.8
26.8
27
184
5,950
0.00846
<0.010
0.065
0.095
0.2
0.320
0.457
<0.510
0.518
<0.753
1.48

(n)
(13)
(E)
(E)

(7)
(72)
(1)
(4)
(1)
(23)
(2)
(2)
(1)
(606)
(606)
(3)
(14)
(85)
(26)
(690)
(3)
(3)
(4)
(3)
(4)
(184)
(2)
(171)
(3)
(120)
(3)

Flow (MGD)
3.6
3.6
9,150 gal/
1,000 Ibs
1.23
1.42
1.5
0.10
0.000946
1.8
0.0749
0.0749
0.144
0.75
0.75
0.0678
0.06
0.05
0.081
0.010
1.241
0.1027
1.224
0.1893
28.2
0.184
0.0033
0.184
0.1893
1.8
2.3
Data from comingled pesticide streams.
Analysis not conducted per
Estimate.
Number of data points.
protocol.





                              V-107

-------
Table V-31
Nonconventional Parameters Detected in Pesticide Process
Wastewaters (Continued, Page 5 of 11)

        NONCONVENTIONAL PARAMETERS

                PESTICIDES

Plant
12
13
14
15

16

17
18
19
20
21
22
23
24
25
26
27
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
Cone.
mg/1
<2.00
<3.02
5.32
15.5

17.2

32.3
49.7
66.5
82.5
83.0
190
228
326
330
535
9,300
<0.01
<3.58
<4.93
<6.32
<6.64
<7.67
<8.51
<15.8
<17.7
18.1
40.7
45.7*
45.7*
45.7*
83.4
133*
133*
133*

(n)
(1)
(75)
(3)
(25)

(17)

(1)
(1)
(1)
(28)
(3)
(2)
(2)
(1)
(3)
(30)
(3)
(26)
(80)
(49)
(28)
(22)
(9)
(41)
(28)
(87)
(4)
(154)
(540)
(540)
(540)
(3)
(270)
(270)
(270)

Flow (MGD)
2.3
1.8
0.0717
505 gal/
1,000 Ibs
117 gal/
1,000 Ibs
0.20
0.20
0.20
0.138
0.120
0.0163
0.0163
0.042
0.3283
0.101
0.015
1.8
1.8
1.42
1.42
1.42
1.42
1.42
1.42
1.42
1.224
1.01
2.5
2.5
2.5
0.0634
1.3
1.3
1.3
  * = Data from comingled pesticide streams.
(n) = Number of data points.
                              V-108

-------
Table V-31.
Nonconventional Parameters Detected in Pesticide Process
Wastewaters (Continued/ Page 6 of 11)

        NONCONVENTIONAL PARAMETERS

                   COD

Plant
1
2
3
4
5
6
7
8
9
10
11

12

13
14
15
16
17
18
19

20
21
22

1
2
3
4
5

6

NA =
* =
Cone.
mg/1
<100.0 **
431*
895*
2,750
2,750
2,830
2,830
4,500 **
4,750*
5,800
7,070*

8,120

14,400
17,000*
17,000*
17,000*
18,900*
22,650
23,900

150,000
150,000
1,220,000

14.0*
14.0*
360
431*
711*

711*

Not available.
Data from comingled pesticide

(n)
(1)
(3)
(3)
(3)
(3)
(1)
(1)
(1)
(5)
(8)
(59)

(E)

(1)
(E)
(E)
(E)
(12)
(1)
(E)

(1)
(1)
(E)

(1)
(1)
(449)
(3)
(E)

(E)


streams
= Data from comingled pesticide/other
** =
(E) =
(n) =
Pilot plant data average.
Estimate.
Number of data points.




Flow (MGD)
NA
0.110
1.22
1.88
1.88
2.01
2.01
NA
0.0315
0.106
1,900 gal/
1,000 Ibs
1,200 gal/
1,000 Ibs
0.0013
0.02
0.02
0.02
0.105
0.0034
774 gal/
1,000 Ibs
0.018
0.018
156 gal/
1,000 Ibs
NA
NA
0.135
0.110
8,000 gal/
1,000 Ibs
8,000 gal/
1,000 Ibs

•
product streams.



                              V-109

-------
Table V-31,
Nonconventional Parameters Detected in Pesticide Process
Wastewaters (Continued,  Page 7 of 11)

        NONCONVENTIONAL  PARAMETERS

                   COD

Plant
7

8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25
26

27

28

29

30
31

32
33
34
NA =
* =
=
(E) =
(n) =
Cone.
mg/1
711*

1,318*
1,318*
1,320*
1,660
1,660
1,660
1,710
2,190
2,450
3,340*
3,710
4,750*
4,900
5,250
5,250
5,700
5,870
5,870
7,070*

7,070*

7,070*

7,070*

14,000
16,000

16,800
28,000
40,000
Not available.

(n)
(E)

(365)
(365)
(365)
(3)
(3)
(3)
NA
(421)
(1)
(3)
(30)
(5)
(1)
(1)
(73)
NA
(3)
(3)
(59)

(59)

(59)

(59)

(3)
(E)

NA
(3)
(1)


Flow (MGD)
8,000 gal/
1,000 Ibs
1.034
1.034
1.034
2.3
2.3
2.3
0.2088
0.124
0.018
0.1027
0.792
0.0315
0.010
0.09
0.1633
0.0792
1.241
1.241
1,900 gal/
1,000 Ibs
1,900 gal/
1,000 Ibs
1,900 gal/
1,000 Ibs
1,900 gal/
1,000 Ibs
0.048
1,200 gal/
1,000 Ibs
0.0634
0.0181
0.30

Data from comingled pesticide streams.
Data from comingled
Estimate.
Number of data points
pesticide/other

.
product streams.


                                v-no

-------
Table V-31
Nonconventional Parameters Detected in Pesticide Process
Wastewaters (Continued, Page 8 of 11)

        NONCONVENTIONAL PARAMETERS
Plant

35
36
37
38
1

1
1
2
3
4
5

1
2
3
4
5
6
7
8
9

10

11
12
                                COD
       Cone.
       mg/1

       75,500
      150,000
      150,000
      195,000
        1,570


       17,000*

        7,070*
          436*
          436*
        5,109
        9,740
      150,000

          594
          674*
          674*
        1,610
        1,660
        3,340*
        3,340*
        5,870
        7,070*

        7,070*

       18,900*
      148,000
(n)

(1)
(1)
(1)
(E)
(E)


(E)

(59)
(606)
(606)
(3)
(375)
(1)

(3)
(3)
(3)
(3)
(3)
(3)
(3)
(3)
(59)

(59)

(12)
(6)
Flow (MGD)

0.0202
0.018
0.018
4,718 gal/
1,000 Ibs

9,150 gal/
1,000 Ibs

0.02

1,900 gal/
1,000 Ibs

0.7224
0.7224
0.0678
0.213
0.018

0.0717
0.1893
0.1893
0.0033
2.3
0.1027
0.1027
1.241
1,900 gal/
1,000 Ibs
1,900 gal/
1,000 Ibs
0.105
117 gal
1,000 Ibs
 NA = Not available.
  * = Data from comingled pesticide streams.
    = Data from comingled pesticide/other product streams.
(E) = Estimate.
(n) = Number of data  points.
                              V-lll

-------
Table V-31.  Nonconventional Parameters Detected in Pesticide Process
             Wastewaters (Continued, Page 9 of 11)

                     NONCONVENTIONAL PARAMETERS

                                COD

Plant
1
2
3
4
5
6
7
8
9
Cone.
mg/1
353*
353*
353*
468*
468*
468*
895*
5,870
17,444

(n)
(270)
(270)
(270)
(540)
(540)
(540)
(3)
(3)
(1)

Flow (MOD)
1.3
1.3
1.3
2.5
2.5
2.5
1.22
1.241
0.0634
  * = Data from comingled pesticide streams.
    = Data from comingled pesticide/other product streams.
(n) = Number of data points.
                               V-112

-------
Table V-31,
Nonconventional Parameters Detected in Pesticide Process
Wastewaters (Continued, Page 10 of 11)

        NONCONVENTIONAL PARAMETERS

                   TOC

Plant
1
2
3
4
5
6
7
8
9
1
2
3
4
5
6
7
8
9
1
2
1
1
2
3
4
5
6
7
8

Cone.
mg/1
900
900
1,650*
4,420
4,420
5,850*
11,400
50,000
50,000
122*
1,650*
1,810
1,810
3,230
19,500
28,500
50,000
50,000
122*
523*
50,000
53.2
341*
341*
441
1,810
2,660*
5,850*
79,800


(n)
(1)
(1)
(5)
(3)
(3)
(12)
(19)
(1)
(1)
(47)
(5)
(3)
(3)
(503)
(1)
(3)
(1)
(1)
(47)
(469)
(1)
(3)
(3)
(3)
(3)
(3)
(3)
(12)
(6)


Flow (MGD)
2.01
2.01
0.0315
1.88
1.88
0.105
0.01
0.018
0.018
0.551
0.0315
1.241
1.241
0.1633
0.0202
0.0181
0.018
0.018
0.551
0.15
0.018
0.0717
0.1893
0.1893
0.0033
1.241
0.243
0.105
117 gal/
1,000 Ibs
  * = Data from comingled pesticide streams.
    = Data from comingled pesticide/other product streams.
(n) = Number of data points.
                               V-113

-------
Table V-31.  Nonconventional Parameters Detected in Pesticide Process
             Wastewaters (Continued, Page 11 of 11)

                     NONCONVENTIONAL PARAMETERS

                                TOC

Plant
1
2
3
4
5
6
7
Cone.
mg/1
178*
178*
178*
585*
585*
585*
1,810

(n)
(540)
(540)
(540)
(270)
(270)
(270)
(3)

Plow (MGD)
2.5
2.5
2.5
1.3
1.3
1.3
1.241
  * = Data from comingled pesticide streams.
    = Data from comingled pesticide/other product streams.
(n) = Number of data points.
                                TOD
Plant

No data available.
Cone.
mg/1
(n)
Flow (MGD)
                              V-114

-------
Table V-32,
Conventional Parameters Detected in Pesticide Process
Wastewaters

         CONVENTIONAL PARAMETERS

                   BOD

Plant
1
2
3
4
5
6
7
8
9

10

11
12
13
14
15
1
2
3
4
5
6
7
8
9
10

11

12

13
NA =
* =
Cone.
mg/1
<103
103*
120
137*
572
791
791
2,000 **
2,260*

2,450

3,490
6,600*
16,000
60,000
60,000
103*
120
120
120
120
120
120
120
179*
355*

355*

355*

610
Not available.
Data from comingled pesticide

(n)
(3)
(3)
(3)
(3)
(8)
(2)
(2)
(1)
(14)

(E)

(1)
(12)
(1)
(1)
(1)
(3)
(3)
(3)
(3)
(3)
(3)
(3)
(3)
(41)
(E)

(E)

(E)

(4)


Flow (MGD)
0.00323
0.110
28.2
1.22
0.106
1.88
1.88
NA
1,900 gal/
1,000 Ibs
1,200 gal/
1,000 Ibs
0.0034
0.105
0.0013
0.018
0.018
0.110
28.2
28.2
28.2
28.2
28.2
28.2
28.2
0.551
8,000 gal/
1,000 Ibs
8,000 gal/
1,000 Ibs
8,000 gal/
1,000 Ibs
2.3

streams.
= Data from comingled pesticide/other
** =
(E) =
(n) =
Pilot plant data average.
Estimate.
Number of data points.



product streams.



                             VrllS

-------
Table V-32,
Conventional Parameters Detected in Pesticide Process
Wastewaters (Continued, Page 2 of 7)

         CONVENTIONAL PARAMETERS

                   BOD

Cone.
Plant rog/1
14
15
16
17
18
19
20
21
22
23

24

25

26

27
28
29

30
31
32

33

34
35
1

*


(E)
(n)
610
610
630*
630*
630*
1,000
1,940
1,940
2,000
2,260*

2,260*

2,260*

2,260*

3,330
3,500
4,840

5,680*
7,200
8,500

19,600

60,000
60,000
703

= Data from comingled
= Data from comingled
= Values reported are
= Estimate.


(n) Flow (MGD)
(4)
(4)
(202)
(202)
(202)
(1)
(3)
(3)
(1)
(14)

(14)

(14)

(14)

(2)
(1)
(E)

(3)
(3)
(E)

(E)

(1)
(1)
(E)

pesticide streams.
pesticide/other product
after pretreatment .

2.3
2.3
1.034
1.034
1.034
0.018
1.241
1.241
0.010
1,900 gal/
1,000 Ibs
1,900 gal/
1,000 Ibs
1,900 gal/
1,000 Ibs
1,900 gal/
1,000 Ibs
0.0181
0.30
4,140 gal/
1,000 Ibs
0.1027
0.048
1,200 gal/
1,000 Ibs
4,140 gal/
1,000 Ibs
0.018
0.018
9,150 gal/
1,000 Ibs

streams.


= Number of data points.
                             V-116

-------
Table V-32.  Conventional Parameters Detected in Pesticide Process
             Wastewaters (Continued, Page 3 of 7)

                      CONVENTIONAL PARAMETERS

                                BOO

Plant
1
2
1

1
2
1
2
3
4
5
6
7
8

9

10
11
12
13

1
2
3
4
5
6
7
8
9
Cone.
mg/1
179*
2,082
2,260*

4,320
60,000
58.2
120
331*
331*
610
1,940
1,940
2,260*

2,260*

5,680*
5,680*
6,600*
45,200

ND*
ND*
ND*
137*
300
1,940
2,082
2,082
2,082

(n)
(41)
(756)
(14)

(85)
(1)
(3)
(3)
(3)
(3)
(4)
(3)
(3)
(14)

(14)

(3)
(3)
(12)
(6)

(270)
(270)
(270)
(3)
(1)
(3)
(756)
(756)
(756)

Flow (MOD)
0.551
1.42
1,900 gal/
1,000 Ibs
0.213
0.018
0.0717
28.2
0.1893
0.1893
2.3
0.084
1.241
1,900 gal/
1,000 Ibs
1,900 gal/
1,000 Ibs
0.1027
0.1027
0.105
117 gal/
1,000 Ibs
1.3
1.3
1.3
1.22
0.0634
1.241
1.42
1.42
1.42
 ND = Not detected.
  * = Data from comingled pesticide streams.
    = Data from comingled pesticide/other product streams.
(n) = Number of data points.
                             V-117

-------
Table V-32.  Conventional Parameters Detected in Pesticide Process
             Wastewaters (Continued, Page 4 of 7)

                      CONVENTIONAL PARAMETERS

                                BOD

Plant
10
11
12
13
Cone.
mg/1
2,082
2,082
2,082
2,082

(n)
(756)
(756)
(756)
(756)

Flow (MGD)
1.42
1.42
1.42
1.42
    = Data from comingled pesticide/other product streams.
(n) = Number of data points.
                               V-118

-------
Table V-32
Conventional Parameters Detected in Pesticide Process
Wastewaters (Continued, Page 5 of 7)

         CONVENTIONAL PARAMETERS

                   TSS

Cone.
Plant mg/1
1
2
3
4
5
6
7

8

9
10
11
12
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
NA
*


(E)
(n)
59.0
69.0*
87.7
110
143
143
181

246*

340
340
350
750
2.00*
2.00*
3.00
3.00
3.00
32.8*
32.8*
32.8*
37.3
68.6*
56.6*
59.0
59.0
59.0
59.0
59.0
59.0
59.0
= Not available.
= Data from comingled
= Data from comingled
= Values reported are
= Estimate.


(n) Flow (MGD)
(3)
(3)
(3)
(146)
(3)
(3)
(E)

(37)

(1)
(1)
(8)
(1)
(1)
(1)
(3)
(3)
(3)
(365)
(365)
(365)
NA
(5)
(3)
(3)
(3)
(3)
(3)
(3)
(3)
(3)

pesticide streams.
pesticide/other product
after pretreatment.

28.2
0.110
0.00323
0.242
1.88
1.88
1,200 gal/
1,000 Ibs
1,900 gal/
1,000 Ibs
2.01
2.01
0.106
0.0034
NA
NA
2.3
2.3
2.3
1.034
1.034
1.034
0.2088
0.0315
0.1027
28.2
28.2
28.2
28.2
28.2
28.2
28.2


streams.


= Number of data points.
                              V-119

-------
Table V-32.  Conventional Parameters Detected in Pesticide Process
             Wastewaters (Continued, Page 6 of 7)

                      CONVENTIONAL PARAMETERS

                                TSS

Plant
19
20
21
22
23

24

25

26

27
28
29
30
31

32

33

34
1

1
1

1
2

Cone.
mg/1
69.0*
78.0
100
124
246*

246*

246*

246*

269
269
300
3,000
3,800*

3,800*

3,800*

4,090
1,720

375
246*

141
360


(n)
(3)
(30)
(1)
(1)
(37)

(37)

(37)

(37)

(3)
(3)
(1)
(1)
(E)

(E)

(E)

(3)
(E)

(73)
(37)

(30)
(12)


Flow (MGD)
0.110
0.792
0.010
0.0792
1,900 gal/
1,000 Iba
1,900 gal/
1,000 Iba
1,900 gal/
1,000 Iba
1,900 gal/
1,000 Iba
1.241
1.241
0.018
0.0202
8,000 gal/
1,000 Ibs
8,000 gal/
1,000 Ibs
8,000 gal/
1,000 Ibs
0.0181
9,150 gal/
1,000 Ibs
1.42
1,900 gal/
1,000 Ibs
0.352
1,510 gal/
1,000 Ibs
  * = Data from comingled pesticide streams.
    = Data from comingled pesticide/other product streams.
(E) = Estimate.
(n) = Number of data points.

-------
Table V-32,
Conventional Parameters Detected in Pesticide Process
Wastewaters (Continued, Page 7 of 7)

         CONVENTIONAL PARAMETERS

                   TSS

Cone.
Plant mg/1
3
1
2
3
4
5
6
7
8

9

10
11

12
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
NA
407
3.00
56.6*
56.6*
59.0
208*
208*
226
246*

246*

269
1,460

2,720
253*
253*
253*
269
375
375
375
375
375
375
375
411*
411*
411*
474
= Not available.


(n) Flow (MGD)
(1)
(3)
(3)
(3)
(3)
(3)
(3)
(3)
(37)

(37)

(3)
(6)

(3)
(530)
(530)
(530)
(3)
(73)
(73)
(73)
(73)
(73)
(73)
(73)
(270)
(270)
(270)
(1)

= Data from comingled pesticide/other product
*

(n)
= Data from comingled pesticide
= Post pretreatment.
= Number of data points.
streams.


NA
2.3
0.1027
0.1027
28.2
0.1893
0.1893
0.0033
1,900 gal/
1,000 Ibs
1,900 gal/
1,000 Ibs
1.241
117 gal/
1,000 Ibs
0.0717
2.5
2.5
2.5
1.241
1.42
1.42
1.42
1.42
1.42
1.42
1.42
1.3
1.3
1.3
0.0634

streams.



                             V-121

-------
Table V-33.  Summary of Raw Waste Load Design Levels
Pollutant Group
Design Level
   (mg/1)
    Percent of
Detected Pesticide
    Wastewaters
  at Design Level*
Volatile Aromatics
Halomethanes
Cyanides
Haloethers
Phenols
Nitro-Substituted Aromatics
Polynuclear Aromatics
Metals — Copper
— Zinc
Chlorinated Ethanes & Ethylenes
Nitrosamines
Phthalates
Dichloropropane & Dichloropropene
Pesticides
Dienes
TCDD
Miscellaneous
PCBs
Benzidine
BOD
COD
TSS
N/A = Not applicable.
ND = Not detected.
* = Remainder of known oesticid*
127-293,000
122-2,600
5,503
0.582
100-42,000
ND
1.06-1.2
4,500
247
98-10,000
1.96
ND
ND
10-11,200
2,500-15,000
0.022
N/A
N/A
N/A
1,470
3,886
266


2 wastewaters are i
24
23
6.0
17
45
100
25
17
100
18
100
100
100
45
50
100
N/A
N/A
N/A
33
45
14


selow desian leve
      Prior to biological oxidation.
                             V-122

-------
Table V-34.  Plants Manufacturing Pesticides With No Process
             Wastewater Discharge*
Plant
Code
     Pesticide
        Comment
  2

  3
  5

  6

  7
  9

 10

 11


 12
2,4-D dimethyl amine salt
2,4-D isooctyl ester
Silvex dimethyl amine salt
Silvex isooctyl ester

Pyrethrins

Ethoprop
Merphos

Amobam
Fluoroacetamide
Sodium monofluoroacetate

Metasol J-26

Chloropicrin

Dichloroethyl ether
HPMTS

Vancide 51Z
Vancide 51Z dispersion
Vancide TH
Ziram

Glyodin

Dichlorophen salts

D-D
Dichloropropene

D-D
No Wastewater Generated
No Wastewater Generated
No Wastewater Generated
No Wastewater Generated

No Wastewater Generated

Wastewater Evaporated
Wastewater Evaporated

No Wastewater Generated
No Wastewater Generated
No Wastewater Generated

No Wastewater Generated

Recycle/Reuse

Wastewater Evaporated
Wastewater Evaporated

No Wastewater Generated
No Wastewater Generated
No Wastewater Generated
No Wastewater Generated

No Wastewater Generated

No Wastewater Generated

No Wastewater Generated
No Wastewater Generated

Recycle/Reuse
Footnotes at end of table
                            V-123

-------
Table V-34,
 Plants Manufacturing Pesticides With No Process
 Wastewater Discharge* (Continued, Page 2 of 2)
Plant
Code
     Pesticide
        Comment
 13

 14



 15

 16


 17



 18
Barban

Alkylamine hydrochloride
BBTAC
Tributyltin benzoate

Chloropicrin

Chloropicrin
Dowicil 75

D-D
Dichloropropene
Biphenyl

Tributyltin oxide
Wastewater Evaporated

No Wastewater Generated
No Wastewater Generated
No Wastewater Generated

Recycle/Reuse

Recycle/Reuse
Wastewater Evaporated

No Wastewater Generated
No Wastewater Generated
Wastewater Incinerated

No Wastewater Generated
* = "No process wastewater discharge"  can be accomplished via
    recycle/reuse, evaporation,  incineration,  or if no wastewater
    is generated.
                            V-124

-------
1
    1000
    100"
     10
    1.0
                                                       ' '100000
                                                       -•10000
          HI  U I  I   I  ft  M
                        MM
                                         1000
                                         100
                                         10
                                         1.0
                             MM  ML*
            HffWMMUTY OF FLOW RATIO OOMQ $ (MVW VALW (OAU1000RM)
RQURE V-1
PROBABILITY PLOT OF PESTICIDE
   PRODUCT FLOW RATIOS
                             V-125

-------
I
I-1
ro
          0.0001
          o.oooot
                                                                                 0.00001
                        O.S 1
6   10   20  M 40 10  60 70  n   90  M


KPROBABUJTY OF FLOW BEING £ GIVEN VALUE (MOD)
                                                                        H.a
                                                                               99.99
          FIGURE V-2    PROBABILITY  PLOT OF PESTICIDE  PRODUCT FLOWS

-------
                          SECTION VI

                CONTROL AND TREATMENT TECHNOLOGY
INTRODUCTION


This    section   identifies   the  in-plant   and    end-of-pipe
control   and   treatment   technologies   used for the   removal
of conventional,   nonconventional,  and  priority  pollutants by
the  pesticides  industry.    The effectiveness   of    potential
technologies  is  evaluated,  and recommended unit treatments are
specified.   Flow diagrams for the major unit treatments are also
presented.  The  specific  technologies selected as the basis for
the  regulation  represent only one of several  methods  for  the
effective  removal   of   the  pollutants  under   consideration.
Wastewater   monitoring   and   treatability  studies  should  be
conducted  for a particular facility in order to  determine   the
most   effective   method  for meeting  these  regulations.   The
design bases used in Section VIII primarily came from  the  full-
scale   treatment  unit  data  as  presented  in  this   section.
Therefore,   the   installation   of   similarly   designed   and
properly   operated   systems   is  expected  to  result  in  the
attainment of equivalent effluent levels.  The major change  from
the  proposed  development  document  summary,  based  on  public
comment, is that the Agency is no longer using evaporation as the
model  technology for the formulator/packager subcategory because
it is not effective in all situations.  Instead, contract hauling
and  incineration and treatment with wastewater recycle  are  the
model technologies for this subcategory.


As  discussed in Section III much of the information provided  by
industry   relates   to  proprietary  products   and   processes.
Therefore,  pesticide names and associated data are coded in this
report.


The  data  presented in this section is primarily from  the  data
collection   efforts  undertaken  prior  to  the  November   1982
proposal.   However, additional data were supplied as a result of
the 1984 and 1985 NOAs.  These data were primarily updates on the
performance   of  treatment  systems  already  included  in  this
section.
The new data that were deemed "best performance" are included  in
the  record  and  have  been incorporated and  presented  in  the
development  of  limitations  and  standards  sections  of   this
document.    The  information in this section is representative of
the combined data received.
                          VI-1

-------
BACKGROUND AND OPTIONS

On  November 30,  1982,  EPA proposed BAT,  NSPS,  PSES and  PSNS
effluent  limitations and standards for the  pesticide  industry.
In each case,  technology options were considered, and one option
selected  as the basis for this regulation.   The options were as
follows:
BAT

Option

  1
  3


  4
    Technologies

In-plant activated carbon
In-plant hydrolysis
Biological treatment

Option (1) Plus steam
stripping, chemical
oxidation, and metals
precipitation

Option 2 plus end-of-pipe
multi-media filtration

Option 3 plus end-of-pipe
activated carbon
Selection Option
                   Technologies

               BAT option 2

               BAT option 3

               BAT option 4



                   Technologies

               In-plant activated carbon
               In-plant hydrolysis
               In-plant steam stripping
               In-plant chemical oxidation
               In-plant metals precipitation(2)

               Option 1 plus
               Biological treatment
                                  Selected options

                                          X
                                  Selected option

                                          x
                          VI-2

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Table  VI-1A  lists  the pollutants that can be  removed  by  the
technologies  outlined above.   As can be seen by the  technology
options,  the Agency  has found that the primary treatment scheme
used by organic pesticide chemicals manufacturers is selected in-
plant controls for the removal of highly concentrated  pollutants
followed by biological treatment.


In  some  cases,  further  end-of-pipe  or  other  site  specific
alternatives  are used to further reduce effluent concentrations.
These are the bases for more stringent options considered by  the
Agency.


Table  VI-1B lists all of the principle wastewater treatment  and
disposal methods used by this industry.  However, this final rule
uses  as its basis only the model technologies used in EPA's 1982
proposal,   and  reiterated  in  the  June  1984  notice  of  new
information.   The following discussion presents descriptions  of
each  of  these  technologies,  their use in  the  industry,  and
performance   data  collected  from  full   scale,   pilot,   and
demonstration  facilities,   as  well  as  treatability  studies.


SOURCE CONTROL
Although  source  control  is not  necessary  for  meeting  these
regulations,  their  application  can be extremely  effective  in
reducing   the  costs  for  in-plant  controls  and   end-of-pipe
treatment,  and  in  some cases can eliminate the need  for  some
treatment units entirely.  The first and most cost-effective step
which can be taken to reduce wastewater pollutant discharge is to
control them at the source.  The following  discussion  addresses
some  techniques  which  have general application throughout  the
industry.


Waste  segregation  is  an important step in   waste   reduction.
Process wastewaters containing specific pollutants  can often  be
isolated   and  disposed  of  or treated  separately  in  a  more
technically efficient,  and  economical  manner.   Highly  acidic
and   caustic  wastewaters are usually more effectively  adjusted
for pH  prior  to  being  mixed  with  other  wastes.    Separate
equalization   for  streams of highly variable characteristics is
utilized by more than  41  plants  to  improve overall  treatment
efficiency.
                          VI-3

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Water  reduction  can be achieved by replacing steam jet eductors
and  barometric  condensers  with  vacuum   pumps   and   surface
condensers  such  as  has been demonstrated by Plant 6.  Reuse or
recycle can be applied to reactor and  floor  washwater,  surface
runoff, scrubber effluents, and vacuum seal water as demonstrated
by Plant 7.  Reboilers can be used instead of live steam.


Good  housekeeping procedures and wastewater monitoring  programs
can  effect considerable water reductions and can prevent  permit
violations  due to spills and leaks.   Flow measuring devices and
pH  sensors with automatic alarms (such as at Plant 8),  in order
to  detect  process upsets,  is just one of many ways  to  effect
reductions in water use.   Dry clean-up of  spills  can  be  used
instead   of   washing  spilled wastes into  floor  drains.  This
technique   has  been  demonstrated  to  be  effective   in   the
formulation and packaging portion of the industry.  Prompt repair
and  replacement  of faulty equipment can also reduce  wastewater
losses.
Raw   material  recovery  can  be   achieved   through    solvent
extraction,  steam  stripping,  and  distillation  operations  as
reported  at  Plants   9  and  10.    Dilute   streams   can   be
concentrated   in evaporators  and  then recovered.   Water-based
reactions   can   be   conducted  in   solvents   assuming   that
subsequent solvent recovery is practiced regularly.


Specific    pollutants    can   be   eliminated   by   requesting
specification  changes from raw material suppliers in cases where
impurities  are  present and known to be  discharged  in  process
wastewaters.
TREATMENT TECHNOLOGIES IN-USE IN THE INDUSTRY


This  section  identifies  the treatment technologies  that  were
found  to  be  applicable for the  treatment  of  pesticides  and
priority  pollutants  in wastewaters generated by the  pesticides
industry.   Figure  VI-1  presents  the range of  flows  for  the
various  types of treatment used in the pesticides  industry.  As
can be seen, most technologies are used over a wide range of flow
conditions.   As  presented earlier,  Table VI-1A lists  thirteen
treatment  technologies  currently  utilized  by  the  pesticides
industry   to  remove  various  pollutant  groups  from   process
wastewaters.   The  primary unit treatment recommended  for  each
pollutant group is designated with a "1".  After treatment by the
recommended  primary  unit,  further removal is  accomplished  by
follow-on treatment, which is designated with a "2".


Table  VI-1B presents the number of plants currently using   each
of  the technologies listed in Table VI-1A.   It should be  noted


                          VI-4

-------
that  many plants use more than one type of treatment  technology
to effect significant removals of pollutants.


Figures  VI-2  through VI-10 provide schematic diagrams  for  the
major treatment technologies discussed in this section.


In-Plant Controls


Table  VI-IC  lists those prioity pollutants and pesticides  that
can be removed by each of the 6 primary in-plant controls:  steam
stripping, activated carbon, resin adsorption, metals separation,
chemical oxidation and hydrolysis.   Steam stripping can   remove
volatile  organic  materials;  activated carbon can remove  semi-
volatile  organic  compounds  and  many  pesticides;   and  resin
adsorption,  chemical oxidation and hydrolysis can treat selected
pesticides.   Metals separation can treat those metals of concern
to  this industry.   Each of these technologies are discussed  in
detail below.
Steam Stripping


Stripping operations involve passing a gas  or  vapor  through  a
liquid  with  sufficient  contact so that volatile components are
transferred from liquid to the gas phase.  The driving force  for
such  an  operation is the concentration differential between the
liquid and  concentrated  equilibrium  point  of  the  gas.   The
transferred  compound  may  then  be  recovered by condensing the
stripping vapor.  More complete separation of components  may  be
obtained  through  refluxing  of the stripped condensate.  In the
pesticide industry both steam  and  vacuum  stripping  have  been
demonstrated  to  be  applicable to groups of priority pollutants
such as volatile aromatics, halomethanes, and  chloroethanes,  as
well  as  a  variety  of  nonpriority pollutant compounds such as
xylene, hexane, methanol,  ethylamine, and ammonia.


Full-Scale Systems


Table  VI-2 presents the design data for eight stripping  systems
used in the  pesticide  industry.
                          VI-5

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Plant 1 operates separate steam strippers for wastewater from the
A, B, C, and D pesticide processes.  The B pesticide stripper  is
designed   primarily   for  the  removal  of  methylene  chloride
(dichloromethane).  The stripper  contains  15  feet  of  packing
containing  1  inch  polypropylene saddles, to which is fed 8,000
pounds per hour wastewater  and  1,860  pounds  per  hour  steam.
Stripped  compounds  are  recycled  to  the  process  with  a net
economic savings being realized.


The  stripper used for C and D pesticide wastewater at Plant 1 is
operated for the removal of a nonpriority pollutant, xylene.  The
A pesticide process utilizes a vacuum stripper for  the  recovery
of  a  nonpriority  pollutant,  isobutyl  alcohol.   No  data are
available to  document  the  removal  efficiency  for  xylene  or
isobutyl alcohol in the above mentioned systems.


Plant   2  operates  a  steam  stripper  to  treat  the  combined
wastewaters  of  Pesticides  E,  F,  G,  and  other  nonpesticide
products.    As   shown  in  Table  VI-3,  the  stripper  removes
chloroform and hexane to less than 5 mg/1 at a  removal  rate  of
greater  than  92.9  percent.   Forty-five  gallons per minute of
wastewater is preheated  before  entering  the  24-tray  stripper
comprising  six  theoretical  units.   The stripped compounds are
disposed of by on-site incineration.


Plant 3 utilizes steam stripping treatment for wastewater from 10
of its pesticide  processes.   Methanol,  toluene,  and  ethylene
dichloride  are  stripped and recovered from wastewater when they
are used in the process or as extraction solvents.  No  data  are
available  to  document  the  effectiveness  of  these individual
pretreatment units since the plant would not participate  in  EPA
verification  sampling;  however,  no volatile organics have been
detected over 1 mg/1 in screening sampling of  the  combined  raw
waste load at this plant.


Plant  4 operates a steam stripper for the removal of ammonia and
ethylamine from Pesticide  R  process  wastewater.   The  process
water   enters   the   stripper  at  a  flow  of  0.072  MGD  and
approximately 100°C.


Plant   5   uses   steam   stripping  for  the  removal  of  1,2-
dichloroethane from Pesticide  S  and  Pesticide  S  intermediate
process  wastewaters.   1,2-Dichloroethane, a solvent used in the
Pesticide S process, is recovered and recycled  to  the  process.


Plant  6  operates a packed bed steam stripper for the removal of
ammonia  from  Pesticide  T  process  wastewater.   Pesticide   T
wastewater  enters the stripper at a temperature of 80°C  and
pH of 12 to enhance ammonia removal.  Steam is added at a rate of


                          VI-6

-------
1,400  pounds   per  hour  to  the  0.0326-MGD  stream.  Stripper
overheads  containing  ammonia,  and organics are incinerated on-
site.


Plant   7 uses steam stripping treatment for  process  wastewater
from the U pesticide process.  Methylene  chloride  is  recovered
from  the steam  stripper and recycled to the process.   Stripped
spent beer wastewater is pretreated and discharged to a POTW.  No
data   are  available   to  document  the  effectiveness  of  the
steam  stripper  treatment system for the  removal  of  methylene
chloride.


Plant  8  operates a vacuum stripper for  treatment   of  process
wastewater from  the  V,   W,   and  X  pesticide processes.  The
original  design  was to remove toluene,  used as  an  extractant
solvent,  from  approximately   600  mg/1  to less than 10  mg/1,
while  at the same time reducing the temperature of the   process
stream  so  as  to improve   resin   adsorption   effectiveness.


During  1980  an  in-depth  sampling  and  analytical program was
conducted at three plants in the Organic Chemicals Industry which
utilize  steam  stripping  on wastewaters similar  in  nature  to
pesticide  manufacturing plants.   Data from these  studies   are
presented  as  follows,  with emphasis on those pollutants to  be
regulated in the Pesticide Industry.  Plant A conducted more than
30   days   of  sampling on a steam stripper designed  to  remove
nitrobenzene  from  process  wastewater.     Data   showed   that
benzene,   a   pollutant   to   be  regulated  in  the  Pesticide
Industry,   was   reduced  from an influent of 15.4  mg/1  to  an
effluent of 0.230 mg/1 (98.5 percent removal efficieny).


Plant B conducted more than  40  days  of  sampling  on  a  steam
stripper  designed  to  remove  vinyl  chloride  from wastewater.
Operating data for pollutants to be regulated  in  the  Pesticide
Industry  were:  99.5 percent removal of methylene chloride, from
3.02  mg/1 to 0.0141 mg/1;  and 70.3 percent removal of  toluene,
from 178 mg/1 to 52.8 mg/1.


Plant C conducted approximately 1 week of sampling at each of two
strippers  designed  to  remove  chloroethane.     Representative
operating   data  for pollutants to be regulated in the Pesticide
Industry were:
                          VI-7

-------
                                      Stripper 1*
                         Influent       Effluent          Percent
 Compound                 (mg/1)         (mg/1)           Removal

Dichloromethane           1,430           0.0153          >99.99
Carbon tetrachloride        665           0.0549          >99.99
Chloroform                 8.81           1.15             86.9

                                      Stripper 2
                         Influent       Effluent          Percent
 Compound                 (mg/1)         (mg/1)           Removal

Dichloromethane            4.73          0.0021          >99.95
Chloroform                18.6           1.9              89.8
1,2-Dichloroethane        36.2           4.36             88.0
Carbon tetrachloride       9.7           0.030            99.7
Benzene                   24.1           0.042           >99.8
Toluene                   22.3           0.091           >99.6

*=Preproposal Data


Additional  sampling  of steam stripping treatment in the Organic
Chemicals   Industry  was  conducted  at  Plant   D's   facility.
Results  for pollutants to be regulated in the Pesticide Industry
were as follows:

                         Influent       Effluent          Percent
 Compound                 (mg/1)         (mg/1)           Removal

Methylene chloride           34          0.01            >99.97
Chloroform                4,509          0.01            >99.99
1,2-Dichloroethane        9,030          0.01            >99.99


Data   from   one  full  scale  steam  stripper   used   in   the
pharmaceutical industry for the removal of methylene chloride was
also  obtained  by the Agency.   This stripper is used  to  treat
solvent-bearing  wastewaters from chemical synthesis  operations,
which  are very similiar in nature to solvent-bearing  wastewater
in  this  industry.   The  stripper is a packed  column,  and  is
usually  operated  12 hours per day,  five days  per  week.   The
unit's average performance is as follows:

               average influent, mg/1 - 8,800

               average effluent, mg/1 - 6.9

               average percent removal - 99.92


These data substantiate the high removal data presented earlier.
                          VI-8

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Treatability Studies—Coco, et al. (1978) evaluated the treatment
of  process  effluents  containing  chlorinated  hydrocarbons and
aromatic hydrocarbons using steam stripping.  This unit operation
removed  up  to  99  percent  of  the  chlorinated   hydrocarbons
(ethylene  dichloride,  which  was the major organic component in
the process effluent was  consistently  reduced  from  more  than
1,000  mg/1  in  the  stripper  feed  to  less than 1 mg/1 in the
stripper bottoms) and up to  75  percent  of  the  total  organic
carbon  (TOC).


Hwang and Fahrenthold (1980) performed  treatability  evaluations
to  determine the extent to which organic priority pollutants can
be  steam  stripped.   Both  mixture  thermodynamics   and   tray
efficiencies  were  considered  in  this evaluation.  The results
indicated that due to volatility and high  activity  coefficients
of  certain  organic  priority pollutants (see the  list  below),
steam   stripping  is  an  effective  means  of  removing   these
pollutants  from  wastewater.    Based   on   a  raw  waste  load
solubility,  and  a  column operating with  aqueous  reflux,  the
following effluent concentrations, tray requirements,  and column
efficiencies  were  predicted  for  priority  pollutants  to   be
regulated in the pesticide industry:


                          Effluent      Number of       Column
                       Concentration   Actual Trays   Efficiency
 Compound                (ppb)        Required       (Percent)

Carbon tetrachloride         50             4             100
Chloroform                   50             6             100
Methyl chloride              50             6             100
Methylene chloride           50             6             100
Bis(2-chloroethyl) ether    140            20              53
Benzene                      50             5             100
Chlorobenzene                50             5             100
Toluene                      50             5              98
1,3-Dichloropropene          50             5             100
1,2-Dichloroethane           50             6             100
Tetrachloroethylene          50             4              99
Methyl bromide               50             3             100
1,2-Dichlorobenzene          50             4              96
1,4-Dichlorobenzene          50             4             100
1,2,4-Trichlorobenzene       50             4              99


ESE  (1975)  conducted  bench  and  pilot  scale  steam stripping
studies at an  ethyl  benzene/styrene  monomer  chemicals  plant.
Benzene   was  reduced from  102  mg/1  to  0.6  mg/1  at optimum
conditions; a full-scale  system  was  designed  to  remove  99.4
percent  of the aromatic hydrocarbons with a 2-foot diameter, and
18-foot-high  column  with 9 feet of packing  for   a   flow   of
30,000 gallons per day.
                          VI-9

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CHEMICAL OXIDATION


Oxidizing  agents  have  been shown to be extremely effective for
the removal of many complex organics from  wastewater,  including
phenols,  cyanide, selected pesticides such as ureas and uracils,
COD,  and  organo-metallic  complexes.   The  most  widely   used
oxidants  in  the  pesticide  industry  are chlorine and hydrogen
peroxide.


Oxidation reactions and kinetics can be selectively controlled by
altering the pH of the wastewater.  For example,  under  alkaline
conditions  the  hypochlorite  ion  destroys  compounds  such  as
glycols,  chlorinated  alcohols,  organic  acids,   and   ketones
(Mulligan,  1976),   as   well   as  cyanide and  organo-metallic
pesticides.   In using  chlorine  the  potential  for    creating
chloromethanes,  chloroamines,  or  chlorophenols should also  be
considered.


Hydrogen  peroxide  oxidizes  phenol readily when the reaction is
catalyzed by ferrous sulfate;  however, it has generally not been
economically  practical  to  complete  the  oxidation  to  carbon
dioxide and water (Strunk, 1979).  Hydrogen peroxide can also  be
used   to  reduce  odor  which  may  be present due to the use of
sulfur compounds.


Hydrogen peroxide oxidation removes both cyanide  and  metals  in
cyanide-containing  waters  (U.S.  EPA,  1980c).   The cyanide is
converted to cyanate,  and the metals are precipitated as  oxides
or  hydroxides.   The  metals are then removed from  solution  by
either  settling  or filtration.   This process can reduce  total
cyanide  to  less  than  0.1  mg/1 and metals such  as  zinc  and
cadmium to less than 1 mg/1.


Ozone  has  been  shown  (Gould,  1976)   to   completely  remove
phenol,  and provide 70 to 80 percent removal of COD; however, it
becomes  costly  as 100 percent organic removal  is   approached.
Because  ozone  is unstable and must be generated on-site, safety
factors must also be considered when this treatment is  selected.


Full-Scale  Systems—Tables VI-4  and  VI-5  present  design  and
operating   datafor  nine  pesticide  manufacturers  utilizing
chemical oxidation.  In these systems over 98 percent of- cyanide,
phenol,   and  pesticides  are  removed,  while  COD  and   other
organics are greatly reduced.


Plant  1  uses  batch  chemical oxidation treatment of wastewater
for five of its pesticide processes.   Hydrogen peroxide is  used
for  the  reduction of phenolic compounds in the wastewaters from


                          VI-10

-------
Pesticides Af C, D, and E.  Sodium hypochlorite is used primarily
for odor control in the B pesticide process.  Although the  plant
declined  to  allow  EPA  contractor  sampling  to  document  the
effectiveness of these individual pretreatment  units,  two  data
points for phenol were observed during screening and verification
sampling  to  be  less than 1 mg/1 in the combined raw waste load
prior to secondary treatment and direct discharge  of  wastewater
at this plant.


Plant  2  adds  formaldehyde to cyanide-containing wastewaters to
form cyanohydrin, which hydrolyzes to ammonia and glycolic  acid,
in  their F pesticide process discharge.  This system is designed
to add 1.0 gpm formaldehyde to a 110 gpm waste stream  to  reduce
cyanide  from 200 mg/1 to less than 1 mg/1 after a detention time
of four days.   Table  VI-5  shows  that  during  three  days  of
verification   sampling,   cyanide was reduced 99.6 percent  from
5,503 mg/1  to  19.7  mg/1,  although  these  analyses  were  not
conducted per protocol.  It should be noted that plant monitoring
after   chemical  oxidation,  hydrolysis,  steam  stripping,  and
biological oxidation and before  direct  discharge  show  cyanide
levels reduced  to  less than 0.0125 mg/1.   During  verification
sampling  it  was  also  determined   that   chemical   oxidation
removed   99.8  percent of Pesticide F,  from 83.2 mg/1 to  0.145
mg/1.


Plant  3 has in the past used chlorine chemical oxidation for the
purpose of reducing fish toxicity in wastewaters from its G and H
pesticide processes.  During three days of verification  sampling
at  this  treatment  unit,  only  Pesticide  H was in production.
Table VI-5 shows the results of split samples taken and  analyzed
by  the verification contractor.  The principal pollutant removed
in the chemical oxidation unit  was  the  Pesticide  H, which was
reduced  by more than 99.9 percent from 398 mg/1 to  0.187  mg/1.
Plant  data  have indicated a long-term removal of  83.4  percent
Pesticide H.
Significant removal of Pesticides S (63.6  to  99.3  percent),  T
(99.5  percent),   G  (90.5  percent),   and  U  (54.4 percent) was
observed.    When   chlorine  is  added   to  wastewater  containing
compounds   such  as  methylene chloride,  chemical substitution of
hydrogen by halogens may create or increase the concentration  of
compounds   such  as  chloroform.  For  example, split verification
samples showed chloroform increasing from less than 0.1  mg/1  to
approximately  1  mg/1.  The wastewater from chlorine oxidation at
Plant 3 receives  subsequent biological  treatment  before  direct
discharge.


Plant 4 has recently designed and constructed a hydrogen peroxide
oxidation    system.    Operating  data  are  not  yet  available.
Pretreatment of pesticide and pesticide  intermediate  wastewater
by  chemical  oxidation  was deemed necessary to make this stream


                          VI-11

-------
suitable  for  subsequent  biological  treatment.    Treatability
studies  were  conducted  which  predicted  removals of pesticide
(48.8 percent), COD (50 percent), and TOC (41 percent), based  on
addition  of  1  percent  by  volume  of  hydrogen peroxide after
acidification  to  pH  1  to  encourage  precipitation.    Sodium
hypochlorite   was   found to be an equally effective,  and  more
economical oxidant;  however,  it was abandoned due to  potential
formation  of  chlorinated hydrocarbons.    The  wastewater  from
chemical  oxidation  at  Plant 4 receives  subsequent  biological
treatment before direct discharge.


Plant 5 uses hydrogen peroxide to oxidize both phenol and COD  in
its pesticide wastewaters.  As shown in Table VI-5, the phenol is
reduced  by  99.8  percent  from  1,100  mg/1 to 2.03 mg/1.  This
removal was achieved by using a 1:1 ratio of 100 percent hydrogen
peroxide to phenol in the plant's aerated lagoon.   At  the  same
time,  pesticides in the wastewater are reduced to 0.023 mg/1.  A
3:1 ratio of 100 percent hydrogen peroxide to phenol has recently
been  used  to  improve  COD  removal.   The  plant  subsequently
disposes of wastewater via direct discharge.


Plant  6  operates  a chlorine oxidation treatment unit to remove
toxic  compounds  from  wastewater  generated  in  the  L  and  M
pesticide  processes.   The  wastewater is held approximately one
hour at pH 10-12 and temperature of 107°C.  Chlorine is added
at  a   rate   of 3.25 gallons per 1,000  gallons  of  wastewater
treated.   Pesticides  are   not   detected   in   the   effluent
discharge   from  chlorine treatment.     The   wastewater   from
chlorine    oxidation   is subsequently evaporated to achieve  no
discharge.


Plant 7 uses sodium hypochlorite to remove odor and COD generated
by diethylamine from its  N  pesticide process.    Wastewater  is
held   for   0.5  to 8.0 hours at pH 7-12 while  1.5  gallons  of
sodium hypochlorite bleach (12 to 15 percent available  chlorine)
is   added   to  each  1,000  gallons.     The  wastewater   from
chlorine oxidation is subsequently discharged to a POTW.


Plant 8 is reported to use  chemical  oxidation  for  wastewaters
from its 0, P, and Q pesticide processes.  According to the Plant
308  response,  no  data  on this system are currently available.
The plant subsequently discharges wastewater to a POTW.


Plant 9 uses chemical oxidation to treat wastewaters from  its  R
pesticide  process.   Cobaltous chloride is used as a catalyst in
the presence of  diffused  air  to  oxidize  sulfites  and  other
potentially  toxic compounds.  No analyses of priority pollutants
are conducted by the plant.  Wastewater from  chemical  oxidation
is disposed of by direct discharge.
                          VI-12

-------
Barnes  (1978)  reports  that  oxidation  by chlorine is a common
treatment employed by 90 companies in the electroplating industry
for the removal of cyanide.  By analyzing  data  from  58  plants
with  oxidation  treatment,  it  was  concluded  that  36 percent
achieve total cyanide effluent values less than or equal to  0.04
mg/1   and 50 percent achieve total cyanide effluent values  less
than 0.11 mg/1.


Cyanide may be precipitated and settled out of wastewaters by the
addition  of  zinc  sulfate  or  ferrous sulfate.  Data from coil
coating  plants  (EPA 440/1-82/071) using  cyanide  precipitation
show a cyanide mean effluent concentration of 0.07 mg/1.


Treatability Studies—Plant 10 conducted a treatability study  on
a   wastewater   containing   phosphorous-sulfur  compounds,  and
chlorides.  Several chemical oxidants  were  considered  in  this
study  including dichromate, hydrogen peroxide, and permanganate.
Treatment with  peroxide  was  the  most  effective  showing  COD
removals in the 65 to 75 percent range on the raw waste and 45 to
50  percent  on  the  effluent from a nine-stage biological pilot
plant.


In the manufacture of cyanuric chloride for triazine  pesticides,
hydrocyanic  acid  and  cyanic  acid  may  be present.  Lowenback
(1978) reports that these cyanides  may  be  oxidized  to  carbon
dioxide  and  nitrogen  gas  in  the  presence of excess base and
chlorine.
Sweeny (1979) reported complete or nearly complete degradation of
selected organic compounds including cyclodienes,  atrazine,  and
DDT  type   pesticides by methods such as chemical reduction  and
use  of   columns   (diluted   and   fluidized    beds).      The
reductive     degradation     process     primarily      involved
dechlorination,   using  catalyzed  iron as  the  most  effective
reducing agent.   The use  of a  column  was found to be the most
efficient  method.   Sweeny reported a 99.8 percent p-nitrophenol
reduction at a flow rate  of  22.8  gpm/sq.  ft.  in a  fluidized
bed.
Metals Separation


Metallic   ions   in  soluble  form  are  commonly  removed  from
wastewater by conversion to  an  insoluble  form  followed  by  a
separation process.  Metallic hydroxides are formed at optimum pH
(approximately  pH  =  9.0  for  copper  and  zinc  found  in the
pesticide industry) through alteration of the  ionic  equilibrium
by an agent such as lime, soda ash, or caustic.  Clarification or
filtration  is  normally  employed to remove the precipitate from


                          VI-13

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solution.       Alternative  processes  which  also remove metals
are ion  exchange,   oxidation  or  reduction,   reverse osmosis,
and activated carbon.
Full-Scale    Systems—Three    priority    pollutant      metals
separation   systems  are  operating  in  the pesticide  industry
as shown in Table VI-6.   Plant  1  operates  a hydrogen  sulfide
precipitation  system  in  order to remove copper  from   its   A
pesticide   wastewater.    Other   separation  methods  attempted
were      precipitation     of     copper     using      ammonium
thiocyanate, and extraction with liquid  ionic  exchange  resins.
The  operating  system  consists  of  an agitated precipitator to
which the hydrogen sulfide is  added,   a  soak  vessel  to  which
sulfur  dioxide  is  added,  a neutralization step using ammonia,
followed by  gravity  separation  and   centrifuging.   Copper  is
removed from 4,500 to 2.2 mg/1 or from 5,350 to 2.8 mg/1.


Pl.inl  ;"'  utilizes sodium sulfide for  the precipitation of copper
from the B pesticide wastewater.    Although  removals  of copper
through  precipitation  is unknown, verification sampling data by
EPA contractors showed copper concentration in all plant  process
waters to primary secondary treatment  to be 23 ug/1.


Plant  3  has  installed  a  chemical   precipitation step for the
removal of arsenic and zinc from surface  water  runoff.   Ferric
sulfate  and  lime are alternately added, while the wastewater is
vacuum filtered  and  sludge  is  contract  hauled.   The  entire
treatment  system  consists  of  dual   media  filtration,  carbon
adsorption, ion  exchange,  chemical  precipitation,  and  vacuum
filtration.   Verification  sampling  across the entire system by
EPA contractors showed arsenic removal from 6.9 to 0.2 mg/1 (97.1
percent) and zinc removal from 0.34 to 0.11 mg/1 (67.6  percent).


Barnes  (1978)  reports  that  high  pH  adjustment  followed  by
clarification  is  a  common full-scale treatment employed in the
electroplating industry.  Data  from  25  plants  utilizing  this
treatment  show  that  the  average  effluent  concentrations for
copper and zinc are 0.49 mg/1 and 0.72 mg/1, respectively.


As reported in the Development  Document  for  the  Coil  Coating
industry,   data   from  55  full-scale  metal separation systems
in  the  metal industry employing pH  adjustment  and   hydroxide
precipitation  using  lime or caustic  followed by settling (tank,
lagoon,  or clarifier)  for  solids  removal  show mean  effluent
concentrations  and percent removal for metals as follows:
                          VI-14

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                      Mean Raw Waste     Mean Effluent
          No. Data    Concentration      Concentration    Percent
Metal      Points         (mg/1)             (mg/1)       Removal

  Copper      74            23.2               0.61          97.4
  Zinc        69            27.7               0.40          98.6
The  Development  Document  for the Coil  Coating  Industry  also
reports   long-term   data  from  two  plants  in   the  industry
using      precipitation-settling     systems     followed     by
filtration.  Both plants neutralize  wastewater  and  precipitate
metals  with  lime.  A  clarifier is used as settling media.  For
removal of suspended solids, Plant 4 uses pressure filtration and
Plant 5 uses a rapid sand filter.  The data  from  these  systems
are as follows:
                  Plant 4                        Plant 5
          Raw Waste        Mean         Raw Waste        Mean
Metal  Range (mg/1) Effluent (mg/1)  Range (mg/1) Effluent (mg/1)

  Zinc    33.2-32.0         0.2         2.35-3.39        0.035
  Copper  0.08-0.45         0.0175      0.09-0.27        0.011


These  systems  confirm  that metals can be treated to  very  low
levels by the precipitation process.


Mercury Removal—Only one facility currently uses mercury in  the
manufacture of metallo-organic pesticides.  This plant's data was
used  as the basis for regulating this pollutant.   The plant has
classified  this  data  as  confidential,  however,  its  mercury
effluent data can be summarized as follows;

               Long term average - 0.02 mg/1

               Monthly variability factor - 1.35

               Daily variability factor - 2.34


The  plant has reported a removal of 99.99 per cent from the  raw
waste load.


Treatability Studies—Amron  Corporation  (1979)  reported  on  a
system designed to remove  high  concentrations  of  heavy metals
in their wastewater.  The method is an hydroxide/modified sulfide
precipitation  system  that  uses ferrous  sulfide  an  insoluble
sulfide  salt which has a solubility greater than the heavy metal
sulfide  to   be  precipitated.    Heavy metal removals  reported
represent   mean  values  obtained  over  a  6-month  period   of
operations. Representative percent removals are listed below:


                          Vl-15

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  Metal

   Phosphorus
   Zinc
   Iron
   Chromium
   Nickel
Influent (mg/1)      Effluent (mg/1)
       247
        27
        85
         2
         0.61
         0.40
         0.10
         0.04
         0.10
         0.10
     Removal
    (Percent)

        99.8
        99.6 +
        99.9
        95 +
        83.6
Lanouette and Paulson (1976) have made a literature review of the
various methods employed to treat  wastewaters  containing  heavy
metals.   Typical  estimates  of  the achievable concentration of
heavy metals using precipitation were:
   Heavy Metal

     Copper
     Zinc
     Cadmium
     Nickel
     Chromium (total)
                 Achievable
           Concentration (mg/1)
                     0
                     0
                     0
                     0
                     0.5
                  Precipitating
                    Agent

                  Caustic, lime
                  Caustic, lime
                  Soda ash
                  Soda ash
                  Caustic, lime
Gupta,  et al.  (1978) reported on a bench test where arsenic was
effectively  treated  from  various  waters.    Experiments  were
carried out on fresh water,  sea water,  a 10:1 mixture of  fresh
water  and sea water,  and a sodium chloride solution.   The best
removal rate occurred with arsenic in the +5 oxidation state  and
a  pH of 4 to 7 using columns of activated media.   The materials
used  were activated bauxite,  activated alumina,  and  activated
carbon.  A summary of the results are listed below:
                      Percent Arsenic Removal
Fresh Water
Saltwater 1:10
Sea Water
NaCl
    Activated
     Bauxite

      97-100
      93-97.3
      92.5-97.5
      87-94
Activated
 Alumina

   99-100
   98-99
   97-99
   95.8-97
Activated
 Carbon

  83.5-96.5
  74.3-95
  71.1-92.8
  62.6-89.7
Pilot plant tests performed by Muruyama, et al. (1975)  evaluated
the  effect  of  precipitation with lime or coagulation with iron
followed  by  activated  carbon  to  remove  heavy  metals   from
wastewater.   Data  results are presented in the Activated Carbon
Treatability Studies section.
                          VI-16

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Granular Activated Carbon


Activated carbon adsorption is a physical separation  process  in
which   highly  porous  carbon  particles  remove  a  variety  of
substances from water.  Adsorption is affected  by  many  factors
including   molecular   size  and  weight   of   the   adsorbate,
solubility  and polarity of the adsorbate and pore  structure  of
the    carbon.   The   characteristics   of    activated   carbon
treatment   that   apply   to   the  pesticide  industry  may  be
summarized below:
1.   Increasing  molecular  weight   is   conducive   to   better
adsorption.

2.   The  degree  of adsorption increases as adsorbate solubility
decreases.

3.  Aromatic compounds tend to  be  more  readily  adsorbed  than
aliphatics.

4.  Adsorption is pH dependent.


Full-Scale  Systems—Table VI-7 provides design criteria  for  17
plants using activated  carbon  in  the  treatment  of  pesticide
wastewaters.   Table  VI-8  presents operating data on these same
systems.


Pesticides,   phenols,   and  nitrosamines  are  all  effectively
removed   by  activated  carbon.   Volatile organics  and  oxygen
demanding  substances can be significantly removed  although  the
degree  of  removal is plant specific.    The majority  of   these
systems   use  long  contact times and  high  carbon  usage  rate
systems  which are applied as a pretreatment for the removal   of
organics from  concentrated waste streams.   Three plants operate
tertiary  carbon  systems  which use shorter contact  times   and
have  lower  carbon usage rates.


Plant  1  operates  an  activated  carbon  treatment  system  for
wastewaters from nine pesticide processes.  Activated  carbon  is
used  as  pretreatment  to  remove  phenols, Pesticides A, B, and
other structurally similar pesticides prior  to  discharge  to  a
POTW.
Wastewater  at  Plant  1  first enters a 3,000 gallon surge tank,
then is transferred to a  160,000  gallon  equalization  tank  to
permit  handling a number of separate variable flows on different
production  schedules  from  the   nine   process   areas.     The
equalization   tank   also  permits  a  constant  flow  rate  for


                          VI-17

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maximizing carbon adsorption efficiency.  The adsorbers are sized
for 120-gallon per minute flow with normal flow of  approximately
50 gallons per minute.  The wastewater at pH 1.0 to 1.5 is pumped
through two 8,000 gallon Douglas Fir wooden tanks operating in an
upflow  series mode each containing 18,000 pounds of carbon each.
The low pH of the influent stream facilitates adsorption of these
phenolic compounds.  An empty bed contact time of 320 minutes  is
provided.   The  carbon treated effluent is adjusted to pH 5.5 to
9.0 using a lime slurry prior to  discharge.   Area  drainage  is
treated for phenols as needed by two additional carbon columns of
the same size.
As  shown  in  Table  VI-8,  verification  sampling  at  Plant  1
indicated that total phenol in the effluent  from  the  activated
carbon   columns   averaged less than 0.143 mg/1 and  0.329  mg/1
from two separate monitoring periods.   This  represents  a  99.8
percent removal  of total phenol.   Plant operating data over the
past  two years have shown an effluent phenol level of less  than
1.0  mg/1.  The  columns also remove 99.9 percent of Pesticides A
and B.
Plant  1  contracts  for off-site thermal reactivation of carbon.
Normally, carbon usage is 26 pounds per 1,000 gallons  wastewater
treated.


Plant  2  uses  a  two-column  series  activated carbon treatment
system for J and K pesticide  wastewater.   The  downflow  carbon
system  is designed to operate at 30 gallons per minute, 24 hours
per day, during a  production  run.   This  pesticide  production
schedule  is  normally  5  days  a week, 24 hours a day.  Process
wastewater, process  area  drainage,  and  spent  acid  from  the
manufacturing  process  are  treated  in  the  carbon unit.  Each
column is charged with 20,000 pounds  of  carbon.   Because  both
pesticides  are batch production units, wastewater and spent acid
are fed into holding tanks with several days retention time.  The
wastewater  is treated in the carbon system at a pH range of  0.5
to   4.0  with   an  empty  bed  contact  time  of  588  minutes.
Carbon column effluent is combined in a holding tank  with  other
nonpesticide  wastewater  and  pH  adjusted   prior   to   direct
discharge.


Verification sampling at Plant 2 showed that the concentration of
Pesticide  K  was reduced from a  level  of  0.465 mg/1  to  less
than  0.001  mg/1  constituting a 99.8+ percent removal  by   the
carbon  adsorption unit.   Previous Pesticide K sampling at  this
plant  during  1977 had  shown  removal  of   99.9   percent   to
0.0182 mg/1.  Total phenol was reduced to a concentration of less
than 0.001 mg/1 with a removal of 82.1 percent.  The reduction in
the  concentration  of volatile organics was not consistent.  The
removal of conventional pollutants ranged from 36.2  percent  for
TSS to 90.7 for TOC.
                          VI-18

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The carbon usage rate at Plant 2 for this unit is 81.5 pounds per
1,000   gallons.   Normal plant procedure requires the carbon bed
to  be replaced every  30  days.    Prior  to   off-site  thermal
reactivation   carbon  is  hydraulically  pumped from the  column
into  a  caustic  soda  neutralization  tank.
Plant 3 operates an activated carbon treatment system for aqueous
wastes  from  the L, M, N, and 0 pesticide processes.  The carbon
unit treats 1.2 to 1.4 MGD wastewater and  operates  24  hours  a
day.   The  system  consists  of  five  carbon towers operated in
parallel.  Normally three towers are in operation.  The flow rate
into each carbon bed is 3.6 gallons per minute per  square  foot.
The  average  detention time is 19.1 minutes.   Prior  to  carbon
treatment and direct discharge,  the  wastewater  is  pH adjusted
to   7.0 for maximum carbon adsorption of pesticides and organics
present   in  this  stream.    Following  carbon  treatment   the
wastewater is directly discharged.


The carbon system at  Plant  3  removed  between  92.3  and  96.9
percent  of  L,  M,  and  0  manufactured  pesticides  during EPA
verification sampling, as shown in Table VI-8.  In each case  the
carbon  effluent  contained  less than 1 mg/1 pesticide.  Plant 3
reported >85.7 and >91.2 percent removal for Pesticides L and  M,
respectively,  during the period from January 1979 to April 1980.
An average carbon  effluent  concentration  of  0.0055  mg/1  for
Pesticide 0 was reported for 154 monitoring days.


Halomethanes  at  Plant  3 were adsorbed with typical removals of
66.3  percent  for  chloroform  and  77.9  percent   for   carbon
tetrachloride.    During   EPA   verification  sampling,  minimal
reductions  of  low  level  phenols  by  carbon  treatment   were
observed.   As  shown  in Table VI-8 there was an increase in BOD
across the system.  In this  case  it  is  likely  that  organics
measured  as  BOD  were  desorbed as a result of displacement  by
more adsorbable influent compounds.


Approximately 20,000 pounds of carbon are  exchanged  per  column
every 13 days.  The carbon usage rate is calculated as 3.9 pounds
per  1,000  gallons of treated wastewater.  Plant 3 uses off-site
thermal reactivation of carbon.
Plant   4  uses  two  activated  carbon  treatment  systems   for
wastewaters from the P  and  Q  pesticide  processes.  Rain water
runoff  and  spent  caustic  from air pollution control scrubbers
from the P pesticide process passes through activated carbon beds
at a rate of 15,000 gallons per day.  Effluent from the  beds  is
combined with cooling tower blowdown before treatment in the main
biological  plant.   The  carbon  system  was installed mainly to


                          VI-19

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reduce levels of the pesticide and phenols.    Plant  data  showed
that  Pesticide  P enters the carbon system at a concentration of
9,300 mg/1 and is reduced to 1.7 mg/1 constituting a 99.9 percent
removal.     The  compound  2,4-dichlorophenol  is  reduced  99.99
percent from 42,000 to 0.82 mg/1.   Other phenols,  and  volatile
organics  are also significantly reduced.


The  carbon  bed  dedicated to the Q pesticide process at Plant 4
was installed to treat combined wastewater from  the  N-isopropyl
aniline  distillation,  the  neutralized   HCL  cleanup  effluent,
cooling tower blowdown,  storm water runoff,  and  washdown  water.
Approximately  12,000  gallons  per  day   is treated by this unit
prior to  combining with other plant effluents in  the  biological
treatment  system.   The  activated  carbon  bed  was designed to
remove the pesticide and volatile organics in the wastewater.  As
shown in  Table VI-8, plant data indicated that  Pesticide  Q  was
reduced   from   15 to 0.01 mg/1.   The percent removal  is  99.9
percent.   Benzene and toluene were reduced by  greater  than 86.3
percent   and   66.7  percent,  respectively.   Halomethanes  and
phenols were also reduced by significant  levels which ranged from
88.9 to greater than 98.9 percent.  The Pesticide Q spent  carbon
is  incinerated  without regeneration.   No additional information
is available for either carbon system.


Plant  5  installed an activated carbon treatment system to  treat
wastewater  from  the  pesticide process.   The major  source  of
wastewater fed to the unit is the aqueous discharge  from  vacuum
filtration  of  the  mother  liquor.   Approximately 1.30 million
gallons per day of wastewater enters the  adsorbers at a pH  of  6
to  12.   The  carbon system consists of  three 2-stage adsorption
trains operated in parallel.  The empty bed contact time of  each
train is  18 to 52 minutes.


System  start-up  data  at  Plant  5  showed a pesticide influent
concentration  of   45.7   mg/1   and   an   estimated   effluent
concentration  of 12.4 mg/1, constituting a 72.9 percent removal.
Subsequent analyses during 1978 and 1980  revealed that the carbon
system  was achieving 96.5 percent  pesticide  removal  with   an
effluent   pesticide  concentration of 4.7 mg/1.  The carbon usage
rate is 20 to 33.5 pounds per 1,000  gallons  wastewater  treated
with  a  loading  of  9  to  15 pounds TOC per 100 pounds carbon.
Spent carbon is  reactivated  on-site  by  an  infrared  electric
furnace.


Toluene  was  reported  by  Plant 5 at 0.1 mg/1,  a >98.3 percent
removal,   following  carbon   adsorption.    The   reduction   of
conventional parameters was inconsistent, with a removal range of
zero to 93.7 percent.
                          VI-20

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Plant  6  operates an activated carbon system as pretreatment for
removal  of  nitrosoamines  and   Pesticide   U   from    certain
process  wastes.    Amination wastes from the U active-ingredient
pesticide  process are treated in three carbon columns  operating
in  series.  Wastewater  enters  the  system  at  a pH of 8.5  to
9.5.   Between  50,000 to 75,000 gallons per day  of   wastewater
is   treated  by these  adsorbers,   and  the empty  bed  contact
time is 1,000 minutes.   Carbon in the lead column  is   replaced
about   once   a week,  resulting in a carbon usage rate  of  136
pounds  per  1,000 gallons treated.     When  produced,  V  and  W
pesticide  wastewaters  are  also  treated  in  the  same  carbon
treatment system.


Approximately 0.025 to 0.030 MGD of  nitration wastes from  the  U
pesticide  intermediate  process at  Plant 6 are treated by carbon
adsorption in three columns operating in series,  with  a  fourth
column   used   for  storage.    Each column has a bed volume  of
2,500  gallons.   The  pH of the  intermediate   waste   is  1.5.
Approximately   571   minutes   of   contact   time   is  usually
required.  The arrangement of the columns in the treatment scheme
is changed once per day, with the former lead column being placed
in storage.  Effluent from both series of carbon columns  is  fed
to aerobic biological treatment lagoons, clarified, and passed to
tertiary  treatment  prior  to  final discharge.  Spent carbon is
thermally reactivated off-site.


In the amination process carbon system at Plant  6,  U  pesticide
wastes  were removed during verification sampling, from 14.6 mg/1
to 0.0713 mg/1, or 99.5 percent.  Plant data also showed a  long-
term  average removal of from 98.5 to 99.8 percent.  The compound
N-nitrosodi-n-propylamine was reduced during  verification  to  a
level  of  0.0041  mg/1, a 99.8 percent removal.  Plant data have
indicated a long-term removal of from 77.6  to  90.3  percent  as
shown  in  Table  VI-8.  Incidental  removal of methylene chloride
was also noted.  Other parameters not  mentioned  above  did  not
show  a  significant  decrease  in  concentration.  The nitration
carbon  system  effectively reduced  nitrosoamine levels from   82
to greater than 95 percent.


Wastewaters   from  Plant  7's X and Y batch pesticide  processes
are treated  by  an   activated   carbon    system.     Pesticide
and  miscellaneous  chemical  process wastewater is combined with
area drainage and washdown water and sent to  carbon   treatment.
Wastewater first enters an equalization/neutralization pond where
the pH is adjusted to between 6 and  8.   Neutralized wastewater is
pumped  to  a  holding  pond and then to the carbon system at the
rate of 30,000 gallons per  day.  The  system  consists  of  two
carbon  columns operating in series.  Carbon usage is reported at
20,000 pounds per week (95 pounds per 1,000 gallons treated) at a
loading of 0.25  pounds  TOC  per pound  carbon.    Based  on  an
approximate  bed  volume  of  5,000  gallons per adsorber, a total
system empty bed contact time of 8  hours  is  realized.   Carbon


                          VI-21

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effluent  flows  to  a  holding  pond  and  is  pumped to a spray
aeration pond prior to final discharge.


As shown in Table VI-8, manufactured pesticides at  Plant  7  are
removed  by 99.4 percent and greater.  Traditional parameters are
reduced by 32.1 to  90.7  percent.   Toluene  was  reduced  to  a
concentration    of   less   than   0.007   mg/1  (94.9   percent
removal).    Other  organics  were   reduced   to   nondetectable
levels.   Plant  7  uses  off-site, thermal reactivation of spent
carbon.  As the result of a recent treatability  study,  Plant  7
plans  to  construct  a biological oxidation system to remove the
bulk of the organics from  the  wastewater.   The  carbon  system
would  be retained for lower strength wastewaters which have been
segregated.


Plant  8  operates  two  activated  carbon  columns  for  process
wastewater  from the water-based manufacture of Pesticide Z.  The
columns operate in series,  each  having  a  capacity  of  20,000
pounds of carbon.  At 0.16 MGD, the contact time is approximately
100  minutes.   The  average  usage  of carbon is 2.89 pounds per
1,000 gallons treated.  Wastewater  from  the  process  is  first
pumped  to  a holding tank and fed through two multimedia filters
to prevent suspended solids from plugging  the  adsorbers  carbon
system  at  a pH of 8 to 12.  Effluent from the carbon columns is
pH  adjusted  and  clarified  before  discharge  to  a  municipal
treatment  facility.   The plant uses regenerated carbon supplied
by an off-site contractor.


Both  verification  sampling and plant reports at Plant 8 show  a
removal  of 63.6  to  68 percent for Pesticide Z.   This  removal
is  determined by an effluent objective of 10 mg/1 for  Pesticide
Z  which  has been   arbitrarily   set  by  the  plant.   Greater
removal   can  be achieved,  if   desired,   by   more   frequent
carbon  replacement.    Total suspended solids were reduced  from
77.5 mg/1 to 32.3 mg/1, or a 58.3 percent removal.


Plant 9 operates an activated carbon  treatment  unit  for  basic
(high  pH)  wastewater  from the AA pesticide process.  This unit
was   designed   to   reduce   concentrations    of    pesticide,
monochlorobenzene, and 1,2-dichloroethane which are raw materials
used  in  the reaction process. Wastewater is treated by peroxide
oxidation  prior  to  carbon  adsorption.  Approximately   70,000
gallons  per  day is passed through this unit before treatment in
the central biological treatment system.  No data currently exist
to document the efficiency of this activated  carbon  unit  since
the plant is still in a start-up phase.


Plant   10  uses  granular  activated  carbon  as  treatment  for
wastewaters  from  reactor  exterior,   and  floor  washings   in
the   manufacturing    area   of   the  BB   pesticide   process.


                          VI-22

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Wastewater  is  stored in 6,000-gallon tanks prior  to  the   two
activated  carbon columns.    Influent  wastewater enters at a pH
range of 5 to 9.   Due to the low volume of wastewater,  the flow
through  the  columns  is intermittent,   operating  two to three
hours  per day.   Each column has a capacity of 20,000 pounds  of
carbon   and   operates  in a downflow  mode  in   series.    The
approximate  detention  time is 250 minutes with a  carbon  usage
rate   of  69.3  pounds  of  carbon  used  per    1,000   gallons
wastewater      treated.       Following     carbon    treatment,
wastewater is held in  a  storage  tank  for  complete  reuse  as
washwater  in  order  to  achieve  zero discharge status.   Spent
carbon is contracted for off-site reactivation.
Both plant and verification monitoring data  at  Plant  10   show
that  Pesticide    BB   can  be  removed  from   wastewaters   by
granular activated carbon at greater  than  99  percent  removal.
In   this  same treatment  system  traditional  parameters,   and
halomethanes were also effectively reduced.


Plant 11 operates a granular activated  carbon  column  to  treat
0.001  MGD  wastewaters  from  the  CC pesticide process and  500
gallons  per day of discharge from the DD pesticide process dryer
operation.  This  waste  is combined with  other  process  waste,
noncontact  cooling water and sanitary waste,  and passes through
an equalization basin,  aerobic digester,   and  clarifier  prior
to  carbon adsorption.   The plant has stated that  no  operating
data  are  currently  available  for this treatment system.


Plant  12  uses a tertiary activated carbon unit to treat process
waste, once-through cooling water, and surface water runoff  from
the  EE  pesticide  manufacturing  process.   Approximately 2,800
gallons per day of wastewater is combined with other nonpesticide
waste and passed through primary and secondary treatment as  well
as  a  sand  filtration  system  prior  to carbon treatment.  The
carbon system  consists  of  two  columns  operating  in  series.
Treated   effluent   is  chlorinated  before   final   discharge.
Spent  carbon  is reactivated on-site by a regeneration  furnace.
Furnace  product  is  combined  with fresh  carbon  makeup,  then
recycled to the system.


Plant 13 uses tertiary activated carbon  columns  for  wastewater
from  the FF pesticide process.  Wastewater treated by hydrolysis
(0.01 MGD) from the FF pesticide process is combined  with  0.028
MGD   of   Pesticide   FF  intermediate  waste  and  2.0  MGD  of
nonpesticide   process   waste.    Preceding  carbon   treatment,
all  wastewater    passes    through    equalization,   skimming,
gravity separation,  neutralization,  and multimedia  filtration.
Influent wastewater  to  the  columns  has a pH of 6.   The three
activated carbon columns operate in the upflow mode in  parallel.
Empty   bed   contact time  is approximately  109  minutes.   The
amount of carbon in each column is 154,000 pounds.   Carbon usage


                          VI-23

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rate  is  0.92  pounds  of carbon  per  1,000  gallons wastewater
treated.  Plant 13 regenerates spent carbon on-site.


Final   plant   effluent   at   Plant   13   contains   4.0   MGD
noncontact   cooling  water;  Pesticide  FF  was  recorded  at  a
concentration  of 0.00602 mg/1.   Pesticide removal through   the
carbon  columns has  not been measured.   TOC removal averages 29
percent for this high-flow, low carbon usage system.


At Plant 14,  Pesticide  GG  was  produced  until  January  1978.
Although  the  wastewater  was  discharged  to a public treatment
system, Pesticide GG was pretreated in an activated carbon system
prior to discharge.  The raw  waste  was  collected  in  a  1,000
gallon  surge tank, passed through columns (2 feet in diameter by
10 feet high) at a pH of less than 1 with an  empty  bed  contact
time of 35 minutes, and stored until analysis had been completed.
If the total of all pesticide chemicals was less than 5 mg/1, the
wastewater  was discharged to the municipal treatment system.  If
not,  it was recycled through the  columns  again.    The  carbon
was    regenerated   with   isopropanol   and   the  solvent  was
incinerated.   Carbon   was   replaced  approximately  twice  per
year.  This system was inefficient because of the small detention
time,  and  the  necessity  for  frequent  fresh carbon addition.
Low flows allowed frequent  recycling. Table  VI-8 presents 5-1/2
months of pesticide data by the plant,  and 6 days BOD, COD, TOC,
TSS,  and  pesticide chemicals  data  by  the   plant,   and   17
days  of sampling analyzed by the EPA contractor.


Plant  15  installed  two  activated  carbon columns operating in
series to treat wastewater from the HH pesticide process.  The pH
of  the  wastewater is lowered to approximately pH  2  prior   to
carbon  treatment.    The  plant  reports  an  empty bed  contact
time  of  7 hours.   Approximately 27,700 gallons  per   day   of
Pesticide  HH wastewater  is treated.   The carbon usage rate  is
reported to be 451 pounds per 1,000 gallons treated.   Due to the
relatively  high  carbon  usage rate,   Plant 15 is investigating
additional  treatment   methods.    Carbon  treatment    effluent
currently    passes   through   steam   stripping   for   ammonia
removal   and  is  combined with other process  wastes  prior  to
entering   the   central  biological   treatment    system    for
subsequent direct discharge.


Verification  sampling  at Plant 15 showed that approximately  77
percent  of   the   TOC  is  removed  in   the   carbon  columns.
Split  sample  results reported by the plant  indicated  an  83.1
percent   removal.  Analysis   of  the  pesticide  parameter   by
verification  sampling  resulted  in  a  99.8  percent   removal.
However,   plant  monitoring,   and verification  split  sampling
data   provided by the plant showed removals of  66.7  and   68.4
percent,  respectively.   Plant  15 participated   in   a   self-
sampling   monitoring   program   which  determined  a  long-term


                          \ ">24

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removal  efficiency  of  from  98.6   to   99.9  percent.     The
influent    suspended    solids   were  found  in  concentrations
from 3,000 to 4,094 mg/1.    Traditional  parameter removals  are
inconsistent.
Plant  16  uses  activated  carbon  to  treat wastewater from the
ammonia recovery and neutralization steps  of  the  II  pesticide
process.   Wastewater  at  pH 11.6 to 12.5 enters two carbon beds
operating  in a downflow mode in series.   The vessel size is  11
feet  high by 10 feet in diameter.   Approximately 20,000  pounds
of  carbon  is contained in each bed.  The empty bed contact time
for  the system is 91.5 minutes when operated at 120,000  gallons
per  day  flow,   and 60.8  minutes  when  operated  at   180,000
gallons per day.   Each adsorber is replaced approximately  every
2.3  days   resulting in a carbon usage rate of 71.6  pounds  per
1,000  gallons treated for a flow of 0.120 MGD,  and 47.7  pounds
per  1,000  gallons at  0.180  MGD.    Plant  16  uses   off-site
reactivation of carbon.  Activated carbon effluent flows  through
an  aerated  lagoon  treatment  system  prior  to discharge to  a
navigable waterway.


As shown in Table VI-8, Pesticide II was found at a concentration
of  less  than  1,418  mg/1  in  the carbon influent at Plant 16.
Pesticide II was reduced by 77.9 percent to less  than  314  mg/1
following  adsorption.   TOC  was  reduced by 68.4 percent from a
concentration of 523 to 165 mg/1.


Plant  17  operates  an  activated carbon  treatment  system  for
stormwater  runoff,  and  washdown  water from  the  JJ   and  KK
pesticide  process areas.   The small flow of 400 to 500  gallons
per  day of JJ and KK pesticide  wastewater  is treated  for   30
minutes  in  each  of the two carbon beds.  The carbon beds are 8
feet  in diameter  by  20  feet  in  height  and operate   in   a
downflow  mode.   The  carbon  usage rate is 2 pounds  per  1,000
gallons   treated.    An  off-site  method   of   spent    carbon
regeneration  is used.  Following carbon treatment, wastewater is
combined with other  process  waste,  neutralized  and  clarified
prior  to  entering a series of evaporation ponds, and ultimately
is discharged to a navigable waterway.


The pollutants of interest for the KK pesticide process at  Plant
17  are  chlorobenzene and toluene; however, the plant has stated
that no data  currently  exist  to  document  the  carbon  system
efficiency.   However,  prior  to final discharge both Pesticides
JJ and KK were detected at a concentration of 0.002  mg/1.   This
does  indicate that these pesticides are removed by the treatment
system to very low levels.


Treatability Studies—A  detailed  review  of  activated   carbon
treatability  studies  was  presented in the Development Document


                          VI-25

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for Effluent Limitation Guidelines for  the  Pesticide  Chemicals
Manufacturing    U.S.    EPA   440/l-78/060e.    Additional  data
received since 1978 are presented below.


Pilot studies were performed at Plant 18 to  evaluate  biological
treatment   effluent   using   a  multimedia  filter,   and  four
granular activated  carbon  columns  in  series.    Data   showed
that   granular  activated  carbon  can  be  applied  to   reduce
total   pesticide concentrations in the wastewater from 5.0  mg/1
to less than  0.05 mg/1,  a removal efficiency of greater than 99
percent.


Plant  19  reported  that  in-house  carbon isotherm studies show
essentially complete removal of a pesticide at high carbon dosage
levels.  The plant currently incinerates its wastewater.


Pilot plant treatability studies were performed by ESE  (Beaudet,
1979a)  to  determine percent removal  efficiencies  of  benzene,
toluene,  and  six  selected polynuclear  aromatic   hydrocarbons
(naphthalene,  acenaphthylene, fluorene, phenathrene, anthracene,
and pyrene).   The light hydro-carbon cracking units   wastewater
normally   pretreated  by  the plant  for primary oil  separation
and  solids removal was further pretreated in the pilot plant  by
granular  media  filtration,    then  passed   through   multiple
downflow,   granular   activated   carbon  columns.   This  study
showed   that  benzene  and  toluene  were   removed   to   below
detection  limits  of  10  ug/1 from  multimedia  filtered  waste
containing  21  to  71  mg/1  benzene,   and   5   to   13   mg/1
toluene.  Influent   levels   as   high as 24  mg/1  total  PNA's
(defined   as  the  sum   of   the     individual     polynuclear
aromatic    hydrocarbons monitored)  were  generally  reduced  to
less  than  the detection limit of 10 ug/1 in 83 percent  of  the
samples analyzed.


Another treatability study by ESE (Beaudet, 1979b) was  performed
on  hydrocarbon  process  wastewater to determine removal of 1/2-
dichloroethane   (EDC),   and  other  chlorinated    hydrocarbons
(1,1,2-trichloroethane,  carbon tetrachloride, trichloroethylene,
and  tetrachloroethylene).  Results showed  removal  of  EDC   to
below detection  limits of 10 ug/1 from a waste stream containing
14 to 950 mg/1 EDC.  The other chlorinated hydrocarbons monitored
were adsorbed more readily than EDC.


Hydroscience  (Toxler,  1980)  reviewed  the literature to gather
performance data on the  current  use  of  activated  carbon  for
treating  wastewaters  from the manufacture of organic chemicals.
In general, it was reported that nonpolar, high molecular  weight
organics  with  limited  solubility  generally  tend  to  be more
readily adsorbed although there is an upper  limit  of  molecular
size  above  which adsorption is adversely affected.  They report


                          VI-26

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that branched-chain compounds are more adsorbable than  straight-
chain   compounds.    Aware   Engineering  (1979)  also  reported
extremely  good  percent  removals  of  high  molecular    weight
compounds,   and  erratic  removal of several intermediate weight
compounds such as naphthalene and dicyclopentadiene.


Hydroscience (Toxler, 1980) reports that the adsorptive  capacity
of  the  column  could  be increased with the increase of the bed
depth (contact time).  The report  shows  data  illustrating  the
increase  on activated carbon loading of sodium nitrophenol (SNP)
with the increase in bed depth.  This increase in loading is  due
to  the  greater  saturation  of  the  upper  bed  layers  as the
adsorption zone moves through the column.


Zogorski and Faust (1977) reported on the  influence  of  various
operational  parameters on the removal of 2,4-dichlorophenol from
water via fixed beds of granular activated carbon.   One  of  the
parameters  studied  was  the  height  of the mass transfer zone.
This parameter, as it  increases,  causes  greater  effluent  bed
contact  time  to be required to reduce an organic pollutant to a
desired effluent concentration.  It was found that the height  of
the mass transfer zone increased markedly:


1.  With an increase in the linear velocity of the fluid,
2.  With an increase in the size of the adsorbent, especially for
carbon particle sizes greater than 0.65 mm, and
3.   When  the  pH  value  of  the  solution  exceeds  the acidic
dissociation constant of the adsorbate.
The effect of pH  was  also  reported  by  Hydroscience  (Toxler,
1980).   Dissolved organics generally adsorb more readily at a pH
which imparts the least polarity to the molecule.   For  ^x.arrple.
phenol,  a weak acid, can be expected to adsorb better at- low pH,
whereas  amines,  a  weak   base,   exhibit   better   adsorption
characteristics at higher pH.  Influence of substituent groups or
adsorbability   is  also  important.    For  example:    (1)  The
Nitro Group—generally increases adsorbability,  and (2) Aromatic
ring—greatly  increases adsorbability.   Huang,  et  al.  (1977)
reported  that  the adsorption  rate  of  phenols  decreased   in
order of phenol,  o-aminophenol,   pyrocatacol,  and  resorcinol.
For  phenols,   the adsorption capacity is greatly increased when
an amino or hydroxyl group is substituted at the ortho position.


Muruyama, et al. (1975) evaluated the effect of a two-step method
that  includes  precipitation  with  lime  followed  by activated
carbon to remove heavy metals  from  water.   Pilot  plants  were
dosed  with  metal concentrations in the influent of 0.5 mg/1 for
mercury  and 5.0 mg/1 for all other metals.   The  representative
percent  removals obtained are listed below:
                          VI-27

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   Metal
      Mn2 +
      Ni2 +
      Zn2+
      Cu2+
      Cd2+
      Ba2 +
Percent
Removal

92-98.5
94-99.5
86-94
90-96
92-99.4
85-99
Metal

Pb2 +
Cr3 +
Cr6 +
As3 +
Hg2+
Percent
Removal

96-99
95-99.5
94-98
80-85
92
Tertiary  treatment  of pesticides was studied (Saleh,  1982) at a
1-MGD  pilot  plant  receiving  biologically   treated    domestic
wastewater.   Activated  carbon treatment was the most  effective,
with an empty bed contact time of  38  minutes  providing  nearly
complete   removal   for  aldrin,  dieldrin,  and  2,4-D  esters.
Carbon Regeneration
Carbon regeneration is required when the carbon consumption  rate
for  removal of toxic pollutants is very high.    For the proposed
regulation, the Agency costed on-site carbon regeneration systems
for all the pesticides plants that need activated carbon systems,
regardless of the flow rates and operating days.   This increased
the overall carbon treatment cost significantly, particularly for
small  plants  with small waste flow  rates  and  short-operating
durations.   Since many of the pesticide plants discharge a small
quantity  of wastewater (less than 0.1 MGD),  it is not generally
cost-effective  for  these  plants  to  install  on-site   carbon
regeneration systems.


After  a telephone survey of five  carbon regeneration firms  and
vendors of carbon regeneration systems, the Agency found that the
average   cut-off   point  for  installing  on-site  systems   is
approximately 2,000 Ibs/day of carbon consumption.   Therefore, a
combination  of  2,000 Ibs/day carbon consumption  rate  and  260
operating  days/yr was used to determine the cut-off point.   The
2,000  Ib/day  was  based on the following  survey  of  activated
carbon suppliers:
                          VI-28

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      Source
Rates  Above Which On-Site
   Regeneration ^s Used
  Calgon, Chicago, IL

  Westvaco, Covington, VA

  Camerou Yakima, VA

  Envirotrol, Sewickley, PA

  Adsorption Systems, Inc., Milburn, NJ
        1,640 to 2,190 Ibs/day

        2,000 Ibs/day

        2,000 Ibs/day

        2,740 Ibs/day

        2,739 Ibs/day
Resin Adsorption
Adsorption by synthetic polymeric resins is an effective means of
removal   and   recovery  for specific  chemical  compounds  from
wastewater.   Polymeric   adsorption  has  been  found   to    be
applicable  for  all members  of  the  phenol  family  as well as
amines, caprolactam, benzene,  chlorobenzenes,  and   chlorinated
pesticides.     The  adsorption   capacity  of  polymeric  resins
depends on the type and concentration of specific organics in the
wastewater  as   well   as  the   pH,   temperature,   viscosity,
polarity,  surface  tension,  and background  concentrations   of
other   organics   and   salts.    For  example,   a   high  salt
background  will enhance phenol adsorption,  while increasing the
pH  will  cause the adsorptive capacity of the  resin  to  change
sharply  since  the  phenolic  molecule goes   from   a  neutral,
poorly   disassociated  form at low and neutral pH to an  anionic
charged  disassociated  form  at  high  pH.    As   with   carbon
adsorption,  the  adsorptive  capacity  increases  as  solubility
decreases.
The adsorbants used are hard,  insoluble beads of porous,  cross-
linked polymer,  and are available in a variety of surface  areas
and  pore-sized   distributions.     The  binding energies of  the
polymers  are normally lower than  those  of   activated   carbon
for  the  same organic   molecules,   thereby   allowing  solvent
and    chemical  regeneration  and  recovery  to  be   practiced.
Regeneration  can  be accomplished with  caustic,   formaldehyde,
or   in solvents such as methanol,   isopropanol,   and  acetone.
Batch   distillation    of regenerant  solutions can be  used  to
separate and return products to the process.


Full-Scale System—Tables VI-9  and  VI-10  present  design   and
operating  datafor  the  four  resin  systems  in the pesticide
industry.  Phenol, pesticide, and diene compounds are  all  being
effectively  removed  by  these  systems.   At  least  one system
realized a significant  product  recovery  via  regeneration  and
distillation.
                          VI-29

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Plant   1   operates   a  resin  adsorption  treatment  unit  for
wastewaters from its A pesticide process.    After  neutralization
and  settling  in  lagoons,   the  wastewater  is filtered through
anthracite and sand to remove suspended  solids  before  entering
one  of two identical vessels filled with amberlite XAD-4  resin.
An empty bed contact time of 7.5 minutes is provided  at  a  flow
rate   of  4  gpm/ft2.   According to plant  monitoring,  the
effluent  Pesticide A concentration averages below 0.00123  mg/1,
representing   a   99.1   percent   removal   across   the  resin
system.      Verification    monitoring   by   EPA    contractors
confirmed these results by detecting an effluent of 0.00067  mg/1
over   a  3-day period.   During this same  sampling  period  the
reduction  of  volatile  priority  pollutants  such   as   carbon
tetrachloride,  chloroform,    and  chlorobenzene ranged from 28.4
to  59.4 percent,  as shown in Table VI-10.   The resin  effluent
is then directly discharged  to navigable waters.


The  resin  system  at Plant 1 required regeneration only once in
the period of one year.  In that instance methanol was used as  a
regenerant,   and  then  was  disposed  of as supplemental boiler
fuel.  Isopropyl  alcohol  may  be used in  the   future   as   a
regenerant; however,  distillation  of  the solvent, and recovery
of pesticide have been ruled out as uneconomical.


Plant 2 designed and  installed  a  resin  adsorption  system  to
remove  Pesticide B and nitrated phenols from process wastewater.
The wastewater is adjusted to pH  4.5  to  favor  the  conversion
of sodium nitrophenol (SNP)  to para-nitrophenol (PNP),  which  is
much  less   soluble   in   water  and,  therefore,  is  strongly
attracted  to  the  hydrophobic  resin.    In  contrast,  SNP  is
hydrophilic   and  is not attracted to the resin.   The column is
chemically   regenerated  with    sodium    hydroxide,    thereby
reconverting  PNP back to SNP so that greater than 99 percent can
be recovered and reused.


Plant 2 conducted exhaustive studies on the removal of  PNP  from
Pesticide  B  wastewater  by  adsorption  on XAD-4  resins.  They
determined that after approximately 100 regeneration  cycles  the
capacity   of  the  resin leveled off at 3.3 Ibs  PNP/ft^  of
resin.  This  was  conducted at an influent PNP concentration  of
1,000 mg/1 with approximately 1 mg/1 in the resin effluent.   The
wastewater  was   to  be  further  treated by  activated  carbon;
however, plant production of Pesticide B was discontinued.  Plant
3   constructed a  resin  adsorption unit in 1976 as part  of  an
EPA   demonstration   grant  for  removal  of   pesticides   from
wastewaters.    The   system    is  preceded    by     wastewater
settling,  and  pressure  filtration; approximately 15 minutes of
detention time is provided at a  flow rate  of  3.5  gpm/ft2.
According   to   the  final report for  the  demonstration  grant
(Marks,  1980),  it is possible to maintain  an average  effluent


                          VI-30

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level of 0.005 mg/1 for Pesticides C and D with daily values less
than  0.01  mg/1.   This  would  represent  95  to  99.5  percent
removals.  As shown in Table VI-10, between 85.1 and 92.2 percent
of  the  dienes were removed.   Volatile toxic organics  such  as
carbon tetrachloride and toluene were removed in the 34.5 to 64.7
percent  range.    The  resin   effluent   is   neutralized   and
discharged to a POTW.


Although  isopropanol  was  used  to regenerate the resin beds at
Plant 3 during the EPA demonstration  grant,  methanol  has  been
found  to be equally effective at lower cost.  The alcohol can be
successfully recovered for use in further regenerations by  means
of pot distillation, or it can be disposed of as boiler fuel.


Plant  4  operates  a  resin  system  for the removal of phenols,
Pesticide E, and  other  structurally  similar  pesticides.   The
process  wastewater  is pretreated by vacuum stripping to prevent
toluene from building up in the regenerant.   The  wastewater  is
then  filtered  to  remove suspended solids and cooled to prevent
crystallization.  One part of wastewater is mixed with two  parts
of  recycled resin-treated resin  with  15  minutes   empty   bed
contact  time.   Columns  last  approximately  13  hours  between
regenerations.   Both  the plant and EPA contractors have sampled
the resin system.   As shown in Table VI-10, Pesticides E, Fr and
G  were  removed  by  76.5  to  97   percent  to    levels     of
approximately   20   mg/1.   Phenol  and  2,4-dichlorophenol were
reduced to levels between 0.5  to  4  mg/1.  Toluene was shown to
be reduced approximately 60 percent. Additional sampling/analysis
of  this system is being conducted by EPA  Region   IV,    Resin-
treated  wastewater  is  neutralized, and discharged to a POTW.


Plant 4 regenerates the resin with 1-1/2 bed volumes of methanol.
The  methanol,   and  desorbed  pesticides,   and   phenols   are
distilled for product recovery and solvent reuse.


Treatability  Studies—Aware (1979) conducted pilot scale studies
with adsorbent resins at Plant 3.  For  a  loading  rate  of  7.5
gpm/ft2,  and  an  empty  bed  contact  time  of  6  minutes,
the following average removals were observed:
                          VI-31

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                               Influent      Effluent      Percent
    Parameter                   (ug/1)        (ug/1)       Removal

     Pesticide C                   123           3.7          96.9
     Pesticide D                    40           2.1          94.7
     Chlordane                     283           2.1          99.3
     Hexachlorocyclopentadiene   1,129           5.5          99.5
     Heptachlor epoxide             11           0.2          98.2
     Toluene                     2,360           198          91.6
     Chloroform                  1,430           509          64.4
     Carbon tetrachloride       20,950         8,670          58.6
     Tetrachloroethylene            34           1.1          96.8
     Naphthalene                   529           100          81.1


Plant 5 is reported to be  conducting  bench  scale  treatability
studies  using XAD-4  resin for removal of phenols and pesticides
in wastewater from their pesticide process.


Hydrolysis


In hydrolysis an hydroxyl or hydrogen ion attaches itself to some
part of the pesticide chemical molecule, either  displacing  part
of  the  group  or  breaking a bond, thus forming two or more new
compounds.


The primary design parameter to be considered  in  hydrolysis  is
the  half-life  of  the  original  molecule,  which  is  the time
required to react 50 percent of the original compound.  The half-
life   is   generally   a  function  of  the   type  of  molecule
being  hydrolyzed,   and   the   temperature  and   pH   of   the
reaction.   A  detailed  review of the theory of  hydrolysis  and
laboratory   data  was   presented   in   the   BPT   development
document for pesticide chemicals. EPA 440/l-781/060e.  Additional
full-scale   and   treatability  data  received  since  1978  are
presented below.


In  assessing the treatability of pesticide compounds, hydrolysis
should be  considered  a  logical  candidate  for  the  following
structural  groups:  amide  type;  carbamates;  heterocyclic with
nitrogen   in   the   ring;    phosphates    and    phosphonates;
phosphorothioates  and  phosphorodithioates;  thiocarbamates  and
triazines EPA 440/l-78/060e.   According to this   listing,   the
use   of  hydrolysis  can  reasonably be expected to apply to  at
least one-third of all pesticides manufactured.


Full-Scale  Systems—Table  VI-11  presents  the design data  for
nineplants employing full-scale hydrolysis  treatment  systems.
Table   VI-12   presents operating  data for  these  systems.   A
detention  time up to ten days is used in the industry to  reduce


                          VI-32

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pesticide  levels by more than 99.8 percent resulting in  typical
effluents less than 1 mg/1.


Plant  1  hydrolyzes  washdown  and  rainwater  runoff from its A
pesticide process.   Wastewater is adjusted with caustic to raise
the  pH above 9.0  and  detained in one of two identically  sized
batch  hydrolysis basins from 4.5 to 31.0  days.    As shown   in
Table   VI-12,   Pesticide  A concentration is reduced an average
of  99.8  percent,  from  3,300 mg/1 to  5.49  mg/1.   The  basin
effluent   is  neutralized,   and  then  spray   irrigated   with
zero discharge to navigable waters.


Plant   2  operates  a hydrolysis basin for wastewater from its B
pesticide process.  A pH less than 1 is maintained for  8  to  15
days  in  order  to  reduce the Pesticide B concentration by 99.9
percent from 57 mg/1 to 0.049 mg/1.  The basin effluent  is  then
combined   with   other   plant  wastewaters,   and  sent  to   a
biological treatment plant for subsequent direct discharge.


Plant 3 operates a hydrolysis basin for  wastewater  from  its  C
pesticide  process.   The  wastewater  is  detained in one of two
identical batch basins for approximately  3  hours  at  pH  12.7.
Steam   is   added   to   raise  the  wastewater  temperature  to
approximately 46°C.   As a result,  Pesticide  C  is  reduced
from  93.7   to   97.9 percent,  from approximately  27  mg/1  to
between  1.7 and 0.56 mg/1.   The basin effluent is combined with
other   plant wastes,   and  sent  to  a   biological   treatment
system  prior to subsequent direct discharge.


Plant  4  hydrolyzes  wastewater  from  its  D  and  E  pesticide
processes.   The  acidic  wastewater  is hydrolyzed by passing it
through  a  limestone pit,  and two parallel holding tanks  where
the  pH  is adjusted to between 7 and 10.   After 3  to  5  hours
detention  time in  the  holding  tanks it is further  hydrolyzed
in  four  parallel aeration basins for a period of three to  five
days.   Pesticides are  reduced  by  more than 99.9 percent, from
12.2 mg/1 to 0.01 mg/1 prior to discharge to a POTW.


Plant  5  operates  hydrolysis treatment units  for   11  of  its
pesticide  processes.   A maximum of six vessels are used at  any
one time,  four on a continuous basis,  and two on a batch basis.
Because  the  units  are  relatively  small  (1,200   to   12,000
gallons),  high  pH  (up to 13+),  and high  temperature  (up  to
100°  C) is  used  to  hydrolyze pesticides rapidly (within 1
to  4  hours).  As   shown   in   Table   VI-12,   actual   plant
wastewater  sampling demonstrates  that  all  pesticides  can  be
reduced below 1 mg/1 (Pesticide K would require an additional  45
minutes   detention).   After    pretreatment    by   hydrolysis,
pesticide   wastewater   is combined with other plant wastes  and
sent  to biological treatment for subsequent  direct   discharge.


                          VI-33

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Plant   6  uses  two  separate hydrolysis  treatment  units   for
wastewaters  from  its  pesticide  processes.   The  Pesticide  Q
hydrolysis  system  is  a  proprietary unit  designed  to  remove
more  than  95 percent of all pesticide  compounds   structurally
similar    to   Pesticide   Q.     Actual verification   analyses
of  this  unit  were inconsistent with  plant  and  EPA  expected
results;  therefore,  a  longer term re-sampling  study is  being
planned.


Four other pesticides are hydrolyzed at Plant 6 for 12  hours  at
43°C   while   the  pH  is  maintained  between  12  and  14.
These  pesticides  are  removed to below their  detection  limits
according to  plant  monitoring records.   After pretreatment  by
hydrolysis,   all   pesticide   wastewaters  are   sent   to    a
biological  treatment system for subsequent direct discharge.


Plant  7  used  both  alkaline  and  acid  hydrolysis  to  remove
pesticides from their W and X pesticide wastewaters.  A pH of  10
to   12  is  maintained  for  80  minutes  at  104°C  in  the
first hydrolysis unit,  while a pH of 4 to 6 is maintained for 50
to   60 minutes at 104°C in the second unit.   Pesticide W is
reduced  from 55  mg/1  to  nondetectable  levels in the  system;
Pesticide  X  is  reported  by  the  plant  to   hydrolyze   more
readily,   although   no analyses   are   currently    available.
After    pretreatment   by  hydrolysis,    the   wastewater    is
chemically  oxidized  and   then evaporated with no discharge  to
navigable waters.


Plant  8  operates  a hydrolysis basin for wastewaters from its Y
pesticide process.  Wastewater is maintained at  pH  9.0  for  19
hours  at 75°C,  during which time the Pesticide Y is reduced
from  720  to  90 mg/1.   Plant experimental data  show  that  by
increasing  the  temperature to 85°C and increasing the pH to
10.0,  the  half-life  for Pesticide Y would change from 6  to  2
hours.   Under   such experimental  conditions   the   hydrolysis
basin   effluent   would  be  approximately  1    mg/1.     After
pretreatment   by  hydrolysis,  the effluent  is  combined   with
other   plant  wastes  and  sent  to activated  carbon  treatment
for subsequent direct discharge.


Treatability Studies—Plant 9 reports  that  it  is  planning  to
modify  its  treatment  system  to use hydrolysis for wastewaters
from their pesticide processes.  Laboratory data on  which  these
plans  are  based  show  percent  removal of pesticides to be  97
and   93,   respectively,   at  specific  conditions  of  pH  and
temperature.


Plant 10 reports that the  following  pesticides  will  hydrolyze
under  alkaline  conditions:  Z, AA, BB, CC, and DD.  Table VI-13
contains hydrolysis data for these compounds.


                          VI-34

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Plant 11 states that organophosphate pesticides will hydrolyze in
warm alkaline water.
Studies  on  triazine  pesticides  not  reported   in   the   BPT
Development  Document  are presented in Table VI-14.  In general,
acid  hydrolysis  provides   sufficient   degradation   to  allow
feasible   fullscale   design  of  systems  removing   pesticides
through 10 half-lives (99.9 percent).


Kinetic studies conducted by Wolfe (1976) indicate  second  order
rate  constants  for the hydrolysis of atrazine with sulfuric and
hydrochloric acid in waters.   The reported values at pH  0.5 and
40°C plus or minus 0.02°C are:

          Hydrochloric—(6.9 plus or minus 0.6) x 10-5 kM-ls-1
          Sulfuric—(1.9 plus or minus 0.2) x 10-4 kM-ls-1


Half-life for atrazine at the same conditions were calculated as:

          Hydrochloric—529 plus or minus 38 minutes
          Sulfuric—192 plus or minus 18 minutes

Studies  performed by Armstrong, et al. (1967) on atrazine showed
that  pesticide  hydrolysis follows  first  order   kinetics   at
constant pH, but the rate is also pH dependent.  Authors reported
hydroxyatrazine as the primary hydrolysis product of atrazine and
that  it  is  quite resistant to microbial degradation.   However,
Kearney, et al.  (1969)  reported  a  decrease  in  phototoxicity
proportional  to a decrease in the actual concentration of the s-
triazine, thereby demonstrating that degradation products do  not
have herbicidal properties.


Munnecke (1976) reported that seven commonly used organophosphate
insecticides were hydrolyzed at rates significantly higher (40 to
1,005  times  faster) than chemical hydrolysis through the use of
enzymes. Parathion metabolites, such as  p-nitrophenol,   did  not
significantly  influence  enzyme  activity.  The optimum pH range
for enzymatic hydrolysis of the eight organophosphate  pesticides
range from 8.5 to 9.5 with less than 50 percent activity at pH 7.
Munnecke notes that the ability of cell-free enzymes to degradate
pesticides     has    been    demonstrated    for    phenylureas,
phenylcarbamates, acylanilides, and phenol  herbicides.    Through
culture   enrichment   and   enzyme   production  techniques  the
hydrolysis kinetics on these pesticides may  be  demonstrated  on
actual pesticide wastewaters in full scale applications.


In  1978,  Munnecke  reported  that the application of soluble or
immobilized enzymes can degrade toxic pesticides  to  less  toxic


                          VI-35

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metabolites.    In  laboratory  studies  on  parathion  hydrolyze
activity an immobilized enzyme was stabilized at a  half-life  of
280 days.


Incineration
Incineration is a controlled process for oxidizing solid, liquid,
or gaseous combustible wastes  to carbon dioxide, water, and ash.
In  the pesticide industry,  thermal incinerators are employed to
destroy  wastes  containing  compounds  such   as:   hydrocarbons
(toluene);   chlorinated   hydrocarbons  (carbon   tetrachloride,
ethylene   dichloride,   etc.);   sulfonated   solvents   (carbon
disulfide);  and pesticides.  Greater than 99.9 percent pesticide
removal,  as  well as greater than 95 percent BOD,  COD,  and TOC
removal,  can  be achieved provided that sufficient  temperature,
time, and turbulene are utilized.  It should be noted that sulfur
and    nitrogen-containing   compounds   will    produce    their
corresponding  oxides  and  should  not  be  incinerated  without
considering   their   effects  on   air   quality.    Halogenated
hydrocarbons  may not only affect the air quality but may corrode
the incinerator.


Full-Scale  Systems—Table  VI-15  provides design  data  for  14
pesticide  manufacturers using incineration for flows ranging  up
to 39,000 gallons per day.


Plant  1  uses  an  incinerator to  dispose  of  the  centrifugal
filtrate  and floor washings from the A pesticide  process  area.
Since  other  nonpesticide organic residues are aslo atomized  by
the  two  bricklined  incinerators,   only  5.7  percent  of  the
wastewater processed is attributed to Pesticide A.   The residues
sustain  combustion  in the reactors operationg  at  1,400°C.
The  heat value of waste is estimated at 98,000 BTU  per  gallon.
As  shown  in Table VI-15,  the incinerator capacity is 30 to  35
million  BTU  per hour for both reactors operationg  in  parallel
using  a  common  scrubber.   Steam is continuously  fed  to  the
reactors to supply hydrogen to form hydrochloric  acid.   Because
these  residues are highly chlorinated,  the thermal  degradation
yields  carbon  dioxide and hydrochloric acid.   The  off-gas  is
water  quenched  in  a carbon block  spray  tower,  tower  before
venting  to  atmosphere.   The dilute hydrochloric acid from  the
scrubber  system  is neutralized and discharged  to  a  municipal
treatment       system.        Prior       to       incineration,
toluene/orthochlorotoluene  and  Pesticide  A raw  materials  are
found at levels of 24 and 8 mg/1,  respectively;  however,  there
are no data available for the scrubber discharge waste stream.


Plant  2 uses a Trane thermal incinerator to oxide high  strength
wastes   from  six  pesticide  processes.    Sixty   percent   of
incinerator uses been devoted to pesticides; however, on only two


                          VI-36

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occasions  for  testing  purposes has pesticide  wastewater  been
oxidized.  In both instances the pesticide wastewaters were mixed
with total plant effluents.   Therefore,  no pesticide data exist
for the scrubber discharge.


The  incinerator  capacity is 36 million BTU per  hour  and  will
process  an average pesticide wastewater volume of 18,000 gallons
per  day.   The  wastewater  characteristics  for  the  pesticide
portion  of the incinerator influent are as follows:  2,700  mg/1
phosphorus; 6,200 mg/1 sulfur; 60,000 mg/1 BOD; 150,000 mg/1 COD;
and  50,000 mg/1 TOC.   Plant 3 uses two on-site incinerators  to
oxidize process off-gases and waste organic liquid streams.   One
incinerator  has  a capacity of 8.7 million BTU per hour  and  is
designed  to operate in excess of  871°C.   This  combination
liquid-vapor  incinerator  is entirely devoted to  H,  I,  and  J
pesticides.   The flue gas scrubber effluent is combined with the
general  aqueous effluent from these pesticides prior to entering
the treatment system.   At present there are no available data to
document removal;  however, during the EPA verification visits it
was estimated by plant personnel to remove all pesticides.


The second pesticide incinerator at Plant 3 has a capacity of  20
million  BTU  per hour.   This two-stage,  John Zink oxidizer  is
designed to handle effluents with high chemically-bound  nitrogen
content maintaining acceptably low levels of NOx emissions.  This
unit  is  totally dedicated to the K  pesticide  operation.   The
design raw waste load data is as follows:  TOC 33.0 lbs/1,000 Ibs
production and TOD 207.8 lbs/1,000 Ibs production.


Plant  4  operates  two  thermal oxidizers  used  to  dispose  of
wastewater from six pesticide products.  One of the oxidizers was
built  by  the  John Zink Company,  and has  rated  heat  release
capacity  of 35 million BTU per hour.   The second oxidizer has a
heat release capacity of 70 million BTU per hour and was built by
the Trane Thermal Company.


The thermal oxidizers at Plant 4 were designed to dispose of  two
different  wastes.   The  first primary feed stream  consists  of
approximately  95  percent organics,  and 5 percent  water.   The
second stream consists of approximately 5 percent  organics,  and
95  percent  water.   The energy generated in the burning of  the
primary  stream  is  anticipated to vaporize  all  water  in  the
secondary  stream  and  to oxidize all of the  organics  persent.
Wastes  from the 0 and P pesticide processes currently  use  0.55
and 4.68 percent,  respectively, of the incinerator capacity.  As
shown in Table VI-15,  available informtion shows that pesticides
incinerated have a combined wastewater volume of 0.0074 MGD.


The  incinerator scrubber water at Plant 4 was sampled during the
EPA verification program.  The scrubber effluent is discharged to


                          VI-37

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the tertiary treatment system t a rate of 0.992 MGD.   Cyanide was
found  at a level of 0.00633 mg/1 or 0.0239 pound per day in  the
incinerator  scrubber water.   No other conventional  or  priority
pollutants   have   been  measured   to   determine   incinerator
efficiency.


Plant  5 operates an incinerator with a capacity of 3,000 BTU per
thousand pound feed to dispose of wastes from the manufacture  of
Pesticides  Rf  Sf  T,  U,  and V.   Approximately 0.05 MGD of  T
pesticide  wastewater  is  incinerated.    The  stream  from  the
extraction  phase of Pesticide S production is also  incinerated.
This  stream  is 2,000 gallons per day.   Waste streams from  the
reaction  processes of Pesticides R and V are also  incincerated.
Spills,  leaks,  and  scrubber  discharge from  the  U  pesticide
process are incinerated at a rate of 500 gallons per  day.


The  incinerator  feed at Plant 5 separates into an  aqueous  and
organic  phase.   The  water  content  of the  aqueous  phase  is
approximately  82  percent.     At  present,  22  percent  of  the
incinerator  feed  contains  pesticide  active  ingredients.   All
incinerator    feed   originates   in   pesticidde    operations.
Incineration  at  Plant  5  effectively  reduces  levels  of  the
priority pollutants methylene chloride,  benzene, and toluene, as
well as controlling odor and COD.


Plant 5 incinerator feed data indicate pesticide levels up to 130
pounds per thousand pounds of production.   As shown  by  effluent
data from the incinerator's  stack gas water scrubbers,  pesticide
removal  is  from  50 to 99.9  percent.   Traditional  parameters
average 95.9 percent destruction.   Nitrogen destruction  average
63.9 percent.  A possible explanation for this low destruction is
that   although  initial  ammonia  may  be   destroyed,   partial
destruction  of organic nitrogen to ammonia nitrogen  results in a
significant  amount  of ammonia in  the  scrubbing  liquid.   The
effluent  from  the stack gas water scrubber combines with  other
plant wastes before biological treatment.


Plant  6 uses an on-site incinerator to treat organic waste  from
the manufacture of Pesticide W.   The organic waste contains  all
of the reaction byproducts as well as sufficient methanol to keep
it  fluid.   Approximately 5.5 million pounds of incinerator feed
was  generated  in 1977 averaging 10.4 percent  Pesticide  W,  33
percent methanol, and 56.6 percent byproducts.


The daily flow of Pesticide  W organic waste into the   incinerator
at Plant 6 is 2,000 gallons  per day.  The incinerator capacity is
rated  at 10 million BTU per hour and operates between 1,370  and
1,540°C.  The dwell time for this unit is 0.4 to 0.6  seconds.
There   are  no  scrubber  or  wastewater  discharges  from   the
incinerator.   Exhaust  gases are vented to the  atmosphere.   No


                          VI-38

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data currently exist to document the incinerator effficiency.


Plant 7 operates three thermal oxidizers that dispose of organica
which  have  been  skimmed  off  process  wastewater  from  eight
pesticide  effluents.   The incinerators were installed to remove
pesticides  as  well as benzene and toluene before  discharge  by
deep well injection.


As shown in Table VI-15,  two of the incinerators at Plant 7 have
capacities   of   9  million  and  12  million  BTU   per   hour,
respectively.    The   pesticide   volume   oxidized   for   both
incinerators is 276 gallons per day.   The average pounds per day
incinerated for pesticides and volatiles is shown below:


     Organic Liquid Waste               Pounds per Day

      Benzene                               414
      Toluene                               322
      Pesticide X                            23
      Other Pesticides (Y-EE)               968
      Byproducts                            576


Approximately  15 to 20 percent of the units are devoted  to  the
liquid waste.


The third incinerator at Plant 7 mainly oxidizes waste from the X
pesticide  process.   Approximately  60  percent of the  unit  is
devoted to liquid waste.   Five hundred and fifty-two gallons per
day  of pesticide wastewater is incinerated averaging 230  pounds
of  Pesticide X,  1,705 pounds of toluene,  and 2,672  pounds  of
byproducts.   This  unit operates at a rate of 20 million BTU per
hour.


All  incinerators at Plant 7 operate at 815° with an  exhaust
stack height of 100 feet.


Plant 8 operates a waste gas  incinerator which uses FF pesticide
waste as supplemental fuel since its heat value is  approximately
120,000  BTU  per  gallon.   The source of this  waste  is  still
bottoms  from the FF pesticide distillation process.   The  rated
capacity   of  the  incinerator  is  5  million  BTU  per   hour.
Approximately  1,000 gallons per day of FF pesticide waste is fed
to the incinerator.   There is no air pollution control equipment
on the incinerator.  The plant has estimated that no FF pesticide
residue  is  in the process wastewater from the  plant  which  is
discharged to a navigable waterway.
                          VI-39

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data currently exist to document the incinerator effficiency.


Plant 7 operates three thermal oxidizers that dispose of organics
which  have  been  skimmed  off  process  wastewater  from  eight
pesticide  effluents.   The incinerators were installed to remove
pesticides  as  well as benzene and toluene before  discharge  by
deep well injection.


As shown in Table VI-15,  two of the incinerators at Plant 7 have
capacities   of   9  million  and  12  million  BTU   per   hour,
respectively.    The   pesticide   volume   oxidized   for   both
incinerators is 276 gallons per day.   The average pounds per day
incinerated for pesticides and volatiles is shown below:


     Organic Liquid Waste               Pounds per Day

      Benzene                               414
      Toluene                               322
      Pesticide X                            23
      Other Pesticides (Y-EE)               968
      Byproducts                            576


Approximately  15 to 20 percent of the units are devoted  to  the
liquid waste.


The third incinerator at Plant 7 mainly oxidizes waste from the X
pesticide  process.   Approximately  60  percent of the  unit  is
devoted to liquid waste.   Five hundred and fifty-two gallons per
day  of pesticide wastewater is incinerated averaging 230  pounds
of  Pesticide X,  1,705 pounds of toluene,  and 2,672  pounds  of
byproducts.   This  unit operates at a rate of 20 million BTU per
hour.


All  incinerators at Plant 7 operate at 815° with an  exhaust
stack height of 100 feet.


Plant 8 operates a waste gas  incinerator which uses FF pesticide
waste as supplemental fuel since its heat value is  approximately
120,000  BTU  per  gallon.   The source of this  waste  is  still
bottoms  from the FF pesticide distillation process.   The  rated
capacity   of  the  incinerator  is  5  million  BTU  per   hour.
Approximately  1,000 gallons per day of FF pesticide waste is fed
to the incinerator.   There is no air pollution control equipment
on the incinerator.  The plant has estimated that no FF pesticide
residue  is  in the process wastewater from the  plant  which  is
discharged to a navigable waterway.
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Plant 9 operates a J.D. Thorpe incinerator for the destruction of
wastes  from  the  manufacture  of Pesticides  GG  and  HH.   The
incinerator  treats only pesticide wastes.   Organic wastes  from
the HH pesticide plant,  aqueous, and organic solvent wastes from
the  GG  pesticide plant,  and some waste from  the  formulations
plant  are  injected  into  a  firebox,   operating  at  870   to
3,180°C, with approximately two seconds residence time.


The  heat  release capacity is 76.7 million BTU  per  hour.   The
39,000 gallons per day of GG pesticide waste which is incinerated
by Plant 9 is estimated to be composed of the following:


          Compound                 mg/1

          TOC                     35,800
          Nitrogen                29,600
          Chlorine                39,400
          Phosphorus               4,850
          Sulfur                  33,200
The  HH pesticide process at Plant 9 feeds 1,000 gallons per  day
of  waste  to  the  incinerator.    The  table  below  gives  the
characterstics of HH pesticide wastewater:


          Compound                 mg/1

          TOC                     4,140,000
          Chlorine                  301,000
          Sulfur                     67,900


The  source  of  the high TOC was found to be  the  HH  pesticide
solvent bleed stream which is primarily toluene.


The  incinerator  at  Plant  9 was designed  to  oxidize  organic
compounds to water and carbon  dioxide.   Sulfur,  chlorine,  and
phosphorus  are converted to sulfur dioxide,   hydrochloric  acid,
and phosphorus pentoxide.   The hot exhaust gases are quenched by
a   recirculating  neutral  salt  water  solution,   followed  by
scrubbing  a venturi.    The venturi operates  at pressure drops up
to 100 feet of water to remove phosphorus pentoxide.  The cooling
tower and heat exchanger cool down the exhaust gases from 87.8 to
71.7°C.   Over 50 million BTU per hour are recovered from the
condensation  of  water in the stack  gases.    The  recirculating
scrubber  solution (approximately 0.27 MGD) is  neutralized  with
sodium hydroxide.   Solids that remain are sodium sulfite, sodium
choride,  and sodium phosphate.   Sodium sulfite is then oxidized
to sodium sulfate in an air oxidizer prior to direct discharge.
                             VI-41

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The  average wastewater characteristics from the incinerated  and
air oxidized effluent at Plant 9 are shown below:
          Compound                 mg/1

          Pesticide HH             0.0026
          Pesticide GG             Not detected
          Paraquat*                Not detected
          Toxaphene*               Not detected
          Captan*                  0.0017
          Chlordane*               0.00013
          Arsenic                  2.0
          Zinc                     3.5
          NH3-N                  125

* Not manufactured at time of sampling.


Plant 10 operates an on-site Trane thermal oxidizer to dispose of
organic  and aqueous waste from the manufacture of Pesticide  II.
Approximately  0.024  MGD of wastewater is oxidized by this  unit
which is entirely devoted to pesticide wastes.   The heat release
capacity is 48 million BTU per hour.   The incinerator  off-gases
are passed through an alkaline wet scrubber and into an oxidation
tower.   The  incinerator separator liquid is drained off,  mixed
with  lime,  and  discharged  to a  sludge  lagoon.   The  lagoon
effluent and oxidation tower condensate (averaging 0.09 MGD)  are
combined  with  other plant wastes.   The plant has  stated  that
there  are  no  data available for the incineration  effluent  at
Plant 10 which is discharged to a navigable waterway.


Plant  11  incinerates  all  of the  waste  produced  by  the  JJ
pesticide  facility.   Both  aqueous  waste from  the  aminolysis
reaction  and  nonaqueous  still residue  from  distillation  are
oxidized.   The  average aqueous waste flow from the  process  is
approximately  2,900 gallons per day.   The incinerator  influent
contains  about  95  to 97 percent water,  1 to  3  percent  high
molecular  weight organics,  and 1 to 3 percent inorganic  salts.
As,  shown  in  Table VI-15 the rated capacity  of  the  oil-fired
incinerator  is  12 million BTU per hour;  however,  there is  no
useful heat value from the aqueous waste stream.  At present, the
incinerator  is used only to dispose of process  wastewater  from
Pesticide  JJ.   Air  pollution is controlled by a  caustic  soda
enriched  water scrubber.   The plant has stated that no data are
available for the wet scrubber effluent.


Plant  12 is reported'to use an on-site incinerator  for  aqueous
waste from the chlorinator step of the KK pesticide process.   No
additional details on this system are currently available.  Waste
from another pesticide product,  which cannot be recovered to the
process,  is used as boiler fuel at Plant 12, thereby allowing no
wastewater discharge from this process.
                              VI-42

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Plant  13  uses two incinerators to dispose of organic waste  and
vent gases from the LL and MM pesticide processes.   In addition,
aqueous  waste  from  the toluene purification  step  of  the  LL
pesticide   process  is  oxidized.    Periodically  the  pressure
filtration  treatment  system contributes organic  waste  to  the
incinerator  feed.   As shown in Table VI-15,  one incinerator at
Plant 13 degrades 11.1 gallons per day of LL pesticide waste  and
has a 100-foot exhaust stack.   The incinerator capacity is rated
at 14 million BTU per hour.


A second incinerator at Plant 13 combines wastes from both the LL
and MM pesticide processes.  Pesticide MM contributes 105 gallons
per  day,  and Pesticide LL provides 7.6 gallons per day of waste
to  this  10-million  BTU  per  hour  thermal   oxidizer.    This
incinerator  has  a  100-foot  exhaust stack  for  air  pollution
control.   At  present  the plant has stated that  there  are  no
available  data to document the efficiency of these  incinerators
prior to discharge of process wastewaters by deep well injection.


Plant  14 had installed an incinerator to destroy nonconventional
pesticide NN, which is contained in aqueous plant process wastes.
Performance   testing  showed  that  NN   pesticide   destruction
efficiencies  in excess of 99.9 weight percent were achieved at a
permitted  design  feed rate of 6 gpm,  oxidizer  temperature  of
1,800°F, and residence time of 2 seconds.  Additional testing
showed  that  99.9 percent pesticide destruction  could  also  be
achieved,  if  permitted,  at feed rates up to 8.4 gpm,  oxidizer
temperatures as low as 1,427°F,  and residence time as low as
1.8 seconds.   The 9.5 million BTU per hour incinerator was found
to  achieve 99.9 percent pesticide destruction  under  acceptable
conditions  of combustion efficiency,  stack opacity,  and sulfur
dioxide emissions.
Other Technologies


In addition to the technologies presented above,  which are  used
as   the  basis  for  this  regulation,   there  are  many  other
technologies  that  can  be used by pesticide plants  on  a  site
specific basis.  These are discussed below.


Wet Air Oxidation (WAO)


Wet  air  oxidation process is a liquid  phase  oxidation  and/or
hydrolysis  performed at elevated temperature and pressure.   The
process  can  be used as a pretreatment step  to  destroy  toxics
ahead  of  conventional biological treatment,  or  to  regenerate
powdered  activated  carbon from a biological  treatment  system.
                              VI-43

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Products  of oxidation stay in the liquid phase and do not create
a secondary air pollution problem.  The process can substantially
reduce COD of toxic waste streams.   When raw waste loads reach a
level of 20,000 to 30,000 mg/1 COD, the process becomes thermally
self-sustaining.   Phenols,  cyanide,  nitrosoamines, dienes, and
pesticides have been shown to be effectively removed by WAO.


Treatability  Studies—Wilhelmi  and  Ely  (1975)  reported  that
demonstration  work on the end of pipe effluent from a  pesticide
manufacturer,  using WAO, reduced the COD/BOD ratio from 3.7:1 to
1.2:1.   They  also  reported  that  cyanide,  in  concentrations
between 500 and 3,000 mg/1,  at an acrylonitrile plant in  Japan,
has  been  reduced by over 99.9 percent along with a 95+  percent
reduction in COD.  In general, they noted that a two-step process
of partial oxidation and detoxification by WAO,  followed by some
type  of  biological  process,   can  typically  result  in   cod
reductions from 55,000 to 300 mg/1.


Wilhelmi  and Ely (1976) and Randall and Knopp (1978) reported on
the destruction of phenols (more than 99.8 percent) by  WAO.   It
was  noted  that  during the oxidation process  higher  molecular
weight  compounds are preferentially oxidized to lower  molecular
weight intermediate products.   High oxidation temperatures,  and
the  use  of copper catalysts at lower  temperatures,  were  also
proven effective in phenol destruction.


Wilhelmi  and Knopp (1978) reported that the WAO system  used  at
the  Louisville,  Kentucky  sewage  plant to detoxify  spills  of
hexachlorocyclopentadiene  reducing the concentration from  6,000
mg/1 to 420 mg/1.   WAO tests (Wilhelmi,  1979) showed reductions
of  nitrosodipropylamine from 170 mg/1 to 2 to 3 mg/1 and for  N-
nitrosodimethylamine, reductions from 400 mg/1 to 50 ppb.


Zimpro,  Inc.  (1980)  reported on the destruction  of  pesticide
chemicals  by  WAO.    A  summary  of  the  pesticides  evaluated
(identified by structural group) follows:

A.   Destroyed at 200°C

*    Most of the amide and amide-type pesticides

*    Carbamate pesticides

*    Urea pesticides, monuron and siduron

*    Heterocyclic pesticides with nitrogen in the ring

*    The uracil pesticides, bromacil and terbacil

*    Phosphorothioate and phosphorodithioate pesticides
                            VI-44

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*     Most  of the halogenated aliphatic and aromatic  pesticides

(except trichlorobenzene, PCNB, dichlorobenzene, ortho, and para)


B.   Destroyed at 240°C to 275°C

*    All the tested pesticides in the nitro structural group

*    The triazines pesticides

*    Most of the urea pesticides (except monuron and siduron)

Zimpro,  Inc.  (1980) also reported that in pilot plant tests,  a
wastewater  composite of about 40 actual pesticides showed a  99+
percent  pesticide destruction,  and 85 percent COD reduction  by
WAO.


Solvent Extraction
The  use  of  solvent  extraction  as a unit process operation is
common in the pesticide  industry;  however,  it  is  not  widely
practiced for the removal of pollutants from waste effluents.  It
should  be  considered  as  a  potential treatment alternative to
steam stripping and adsorption  systems  with  product  recovery.
Solvent  extraction  is  most  effectively  applied to segregated
process streams as  a  roughing  treatment  for  the  removal  of
priority  pollutants  such  as  phenols,  cyanide,  and  volatile
aromatics.


Full-Scale  Systems—Plant 1  uses  solvent  extraction  for  the
removal of 2,4-dichlorophenol from pesticide process wastewaters.
As  a  result,  Plant  1  has reported that 2,4-dichlorophenol is
reduced by 98.9 percent, from 6,710 to 74.3 mg/1.


Treatability Studies—Phenol removal by  solvent  extraction  has
been  used  extensively  for  the  treatment of refinery and coke
byproduct waste (Mulligan, 1976).  Removals generally range  from
90  to  99.9  percent  with effluent levels of 1 to 4 mg/1 from a
feed of 1,500 mg/1 when high  distribution  coefficient  solvents
were used.


Solvent   extraction   removals   of   97  percent  for  benzene,
ethylbenzene, and TOD have been reported (Earhart, et al.,  1977)
using isobutylene as the solvent.
                                    VI-45

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Membrane Processes
Reverse  osmosis systems place wastewater under pressure  in  the
presence  of an osmotic membrane to remove solutes from solution.
Molecular size,  valency,  temperature, pH, suspended solids, and
pressure  may  affect  the  rejection  rate  for  the   membrane.
Membrane  materials used are cellulose acetate,  polymers such as
polyamides  and  polyureas,   dynamic  membrances  using  hydrous
zirconium oxide and polyacrylic acid,  and inorganic  membrances.
Ultrafilitration  systems achieve similar removal of solutes from
solution based primarily in molecular size.


Modern  ultrafiltration  membrances are made from  a  variety  of
noncellulosic  synthetic polymers such as nylon,  vinyl chloride-
acrylonirile copolymers, polysulfone, polyvinylidene, etc.


Although  no  membrane  processes  are  used  in  the   pesticide
industry,  their  application has been demonstrated in the  metal
industry for recovery of zinc and copper, in the textile industry
for  recovery  of polyvinyl alcohols and mineral oils as well  as
for  removal  of  dyes,  and  in the  pulp  and  paper  and  food
industries (Mulligan, 1976).


The  Development  Document  for the Coil  Coating  Industry  (EPA
440/1-82/071) reported the following data from full-scale systems
using  membrane  filtration  to remove precipitated  metals  from
wastewater.
                     Plant 1                      Plant 2
                             Percent                       Percent
Metal In (mg/1)  Out (mg/1)  Removal In (mg/1)   Out (mg/1) Removal

Copper    18.0      0.043      99.8      8.0       0.22      97.3
Zinc       2.09     0.046      97.6      5.0       0.051     98.9


CARRE  (1977) conducted screening tests on textile wastewater  to
review the rejection by membrane of various known toxic chemicals
and  indicators.   Eight  different  types of  membranes  and  14
parameters (BOD,  COD,  TOC,  dissolved solids,  volatile solids,
color,  phenol,mercury,  manganese, iron,  nickel, chromium, zinc,
copper)  were  investigated.   Rejection data for  some  specific
compounds by Selas Dynamic Zr(IV)-PAA membrane  follows:
                                   VI-46

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                     Percent         Concentration   No. of Data
Parameter    Rejection     (mg/1)        90-100%


  COD                71-99             1600-7100     27 out of 35
  BOD                74-99               25-2300     29 out of 38
  TOC                82-98              175-2000     26 out of 32
  Phenol             86-100            0.66-315       4 out of 7
  Zinc               94-99              2.1-18       13 out of 13
  Copper             92-99              1.5-5.5      14 out of 14
  Nickel             80-98              0.7-3.87      7 out of 10


Rejection  data for the cellulose acetate  membrane  demonstrated
good  removals  at high concentrations over wide fluctuations  in
pH.  These results agreed closely with available literature data.
Bench  tests,  and  an extensive literature seach  were  made  by
Cabassor  et al.   (1975) to determine the applicability of trace
organic   solutes   removal  from  drinking  water  by   membrane
separation.  The five membranes evaluated were cellulose acetate/
cellulose  acetate  butyrate,  ethyl  cellulose/  polyamide,  and
polyurea  (NS-1)  with the latter two being the  most  effective.
The  authors  concluded that treatment by  reverse  osmosis  with
further  treatment  by  an osmotic concentrator is  a  reasonable
approach,   and   that  high  water-solute  coupling  occurs   in
transport.


Hyperfiltration   treatability   studies  are   currently   being
conducted on pesticide wastewaters by EPA.


End-of-Pipe Treatment


Biological Treatment


Aerated  lagoon,  activated  sludge, and trickling filter systems
are widely used  throughout  the  pesticide  industry  to  remove
organic  pollutants  measured  by parameters such as BOD and COD.
As shown in Table  VI-16,  there  are:   (1)  14  aerated  lagoon
systems with detention times ranging from approximately 2 days to
95  days,  (2)  13  activated sludge systems with detention times
from 7.15 to 79 hours, and (3) 4 trickling filter systems.


Conventional and nonconventional  pollutant  operating  data  for
these systems are presented in Table VI-17.  BOD removals ranging
from  87.4  to  98.8  percent  were  achieved  at  major industry
biological  systems.  COD   removals   at   these   same   plants
ranged   from  60.5 to 89.7  percent.    Priority  pollutant  and
nonconventional  pollutant   pesticide  (manufactured  pesticide)
removal in biological systems is described below.   The mechanism
of  pollutant  removal  may  be  one  or  more  of the following:
                                 VI-47

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(1)  biological  degradation  of  the  pollutant,  (2) adsorption
of   the  pollutant  onto  sludge  which is separately  disposed,
or (3) volatilization of the pollutant into the air.


It is well documented that biological systems can  be  acclimated
to  wastewaters containing significant concentrations of phenols.
For example, Plant 21 operates an aerated lagoon system  removing
phenol  by  >93.8  percent  from  61.8  to  3.84 mg/1.   Plant 16
operates an aerated lagoon with hydrogen  peroxide  added,  which
reduces  phenol  by  99.8  percent  from 1,100 mg/1 to 2.03 mg/1.
Plant 5 reduces 4-nitrophenol by 94.7 percent from  203  mg/1  to
10.7  mg/1.   Plant 6 reduces 4-nitrophenol by >99.8  percent from
461 mg/1 to 1.0 mg/1.   Plant 2 reduces 2,4-dinitrophenol  by  95
percent from 7.91 mg/1 to 0.397 mg/1.  In such cases  as described
above,  biological  systems  achieve  priority  pollutant phenols
removal similar to that of activated  carbon,  resin   adsorption,
and chemical oxidation pretreatment systems.


The  fate  of  priority  pollutant phenols which reach biological
systems, after pretreatment, at approximately 1 mg/1  or below  is
a  phenomenon  of  importance  which  requires further study.  As
shown in Table VI-17, the following  actual  removals  have  been
observed in the pesticide industry:


                                        Percent Removal with
   Priority Pollutant                   Raw Load Below 1 mg/1

     Phenol                                    84.4-96.5
     2-Chlorophenol                            >83.9
     2,4-Dichlorophenol                        93.8-97.6
     2,4,6-Trichlorophenol                     4.5 or less
     Pentachlorophenol                         39.6-41.0

Data  from  wood  preserving  plants in the Timber Industry (ESE,
1978)  indicate  that  pentachlorophenol   is   removed   through
biological systems as follows:

                                                         Percent

Plant                Influent          Effluent          Removal

      33              158.0             0.907              99.4
      34                1.2             0.032              97.3
      35               22.3             0.21               99.1
      36                2.7             0.069              97.4
As  shown in Table VI-17, approximately 50 percent of the cyanide
at a 1 mg/1 concentration  entering  the  biological  systems  at
Plants  3  and  13 is removed.  Additional data from Plants 3, 7,
and 9 indicate that cyanide  removals  are  related  to  influent
concentration,   i.e.,   greater   than  50  percent  removal  is
                             VI-48

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experienced for raw wasteloads greater than 1 mg/1, and less than
50 percent for raw wasteloads less than 1 mg/1.


Air stripping  of  volatile  priority  pollutants  in  biological
systems  is  a  phenomenon  which  has  received  some  study  as
described  in  Section  VIII  (Nonwater  Quality  Aspects).    In
general,  these  pollutants  are  removed from above about 1 mg/1
down to their detection limits of 0.005 to 0.01   mg/1.    Actual
data  from  biological  systems treating pesticide wastewater are
summarized below from Table VI-17:
                                   Percent              Percent
    Pollutant Group             Removal Range        Removal Average

     Volatile Aromatics           56.5-99.9               94.6
     Halomethanes                 22.6-98.5               58.3
     Haloethers                   90.9                    90.9
     Chlorinated Ethanes and      9.1-96.3                63.0
       Ethylenes
     Polynuclear Aromatics        >84.8                  >84.8


Priority pollutant metals which can be traced to process  sources
in the pesticide industry are copper and zinc.  Table VI-17 shows
copper  and  zinc  removals  in biological systems to be about 50
percent at influent concentrations of  1  mg/1  or  less.   These
metals  are  adsorbed  onto sludge since they are not volatile or
biodegradable.


Priority pollutant dienes are not currently biologically  treated
in   the   pesticide  industry.   Due  to  their  relatively  low
solubility,  dienes  are  not  expected  to  be  biodegraded   or
volatilized (Strier, 1979), but rather like metals will adsorb on
sludge.


Pesticides  are removed in biological systems to varying degrees,
based  on the characteristics of the individual compound.   Table
VI-17 shows  that biological systems such as Plants  2,   7f  and
13   which   are   receiving   pesticides   at  approximately   1
mg/1,  are  achieving  removals in excess of 50 percent.


Results  from  bench  scale   treatability studies  performed  by
Plant  37  showed  that  a  pesticide  in concentrations  up   to
3,000   mg/1  did  not   inhibit   aerobic degradation of  sewage
at typical aerator food-to-mass ratios.


Plant 5 conducted bench-scale biological studies to determine the
removal of COD from pesticide wastewater.  An average COD removal
of  57  percent  was  achieved  in  an  aerated  lagoon  with  no
                               VI-49

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equalization   and  40  days  retention time.     A  pilot   plant
with  equalization   and   20 days  retention   time  achieved  an
average  COD removal of 56 percent.   An activated sludge   bench
unit   with   5  days  retention (no  equalization)  achieved  an
average  removal  of  44  percent.    Plant  5  determined   that
equalization  times of 5 to 10 days should  allow  the  activated
sludge  system  to  achieve  57  percent  COD    removal.    After
conducting  bench-scale  and   pilot-plant treatability  studies,
as  well  as  in-plant hydraulic/sampling surveys,  Plant 38  has
concluded   that   out  of  ten  alternative  schemes   including
ocean   disposal,   biological   treatment  of  selected  wastes,
coupled   with  evaporation  and  thermal   oxidation   of   high
strength wastes, have been selected.


Plant  39 reported that it will be replacing its activated carbon
treatment  system with biological oxidation for   the   treatment
of all plant wastes.  Startup was planned for  after June 1979.


Plant 16 reported phenol degradation with a strain of aspergillus
bacteria.
Plant  40  conducted  a  bench-scale  activated  sludge  study of
wastewater from a pesticide process.  Over 99 percent destruction
of this pesticide was achieved with effluent levels of less  than
1.8 ug/1.


Plant  28  has  conducted pilot-scale treatability studies on the
pesticide  consisting  of  a  20-gallon   aerated   lagoon   with
approximately   15   days   detention  time  along  with  gravity
clarification and flocculation.  COD removals of 83  percent  and
BOD removals of 97.5 percent was reported.


Plant 29 reported that spent pesticide fermentation beer,  sampled
in  March 1978, did not inhibit biological activity when added to
a bench scale activated sludge unit.


Monnig, et al. (1979) reported results of a bench-scale activated
sludge system where carbaryl wastewater  was  diluted  with  nine
parts  of  municipal wastewater.  Carbaryl, toluene, and COD were
all reduced by 90 percent or greater.  The influent concentration
of  the wastewater was:   Toluene,  160 mg/1;  COD,   4,100 mg/1;
Carbaryl,  4.3  mg/1;  and  NH3-N,  158 mg/1.  Carbaryl or alpha-
naphthal  (which  was  reported as the  hydrolysis  product   for
carbaryl)  was  not  detected  above  0.5  ug/1  in the test unit
effluent.  Data indicated that carbaryl is  readily  degraded  in
activated sludge systems.
                                  VI-50

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Saldick   (1975)   reported that cyanuric  acid is  removed  from
aqueous chemical plant wastes by treatment  of  the  wastes  with
active  bacteria,  under anaerobic conditions,  while holding  pH
between 5.0 and 8.5 at ambient temperature.
Petrasek, et al. (1981) conducted a pilot-plant study to evaluate
the  behavior,   and  fate  of  the  volatile  organic   priority
pollutants  in   a  conventional municipal  wastewater  treatment
plant.  It was determined that POTW removals of these  pollutants
were   greater  than or equal to 95 percent with effluent  levels
less  than 1 ug/1 in   most   cases.    Exceptions  were   1,1,2-
trichloroethane   (69  percent)  and  dibromochloromethane    (73
percent).     It    was   also  found   that   volatile   organic
priority  pollutants  do not generally  partition  strongly    to
the   sludge.    A   direct relationship   was  observed  between
a   compounds   tendency   to  partition to the  sludge  and  the
sludge's  octanol/water   partition  coefficient.     Significant
quantities   of  some of the compounds were also  found  in   the
off-gases   from   the  aeration   basin.  Removal   by   primary
clarification   and  activated  sludge  treatment  for   specific
compounds  to  be  regulated in the pesticide  industry  were  as
follows:
      Compound

     Benzene
     Chlorobenzene
     Toluene
     Carbon tetrachloride
     Chloroform
     Methylene chloride
     Tetrachloroethylene
                Percent Removal

                       99
                       99 +
                       95
                       99
                       97
                       99
                       93
Biological  treatment  studies  were  conducted  on a bench scale
(Kincannon, 1981) in order to observe  the  removal  of  specific
compounds  by  biodegradation  versus air stripping.  The results
indicated that overall removal of compounds to  be  regulated  in
the  pesticide  industry  ranged between 93 and 99.9 percent.  In
the case  of  1,2-dichloroethane  and  1,2-dichloropropane,  this
removal  is accomplished almost entirely by air stripping, rather
than by biodegradation as noted and were as follows:
    Parameter

  1,2-Dichloropropane
  Methylene chloride
  Benzene
  1,2-Dichloroethane
  Phenol
  Tetrachloroethane
  2,4-Dichlorophenol
    Percent
Overall Removal

    99.4-99.9
    99.5
    99.9
    98.5
    99.9 +
    93
    94
  Percent
Biodegraded

    0-11.2
    94.5
    84.5-85
    0
    99.9 +
    0
    94
  Percent
Air-Stripped

   88.3-99
   5.0
   15.4
   97.5-100+
   0
   93
   0
                                  VI-51

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Preliminary findings of a U.S.   EPA  program  (EPA 440/1-80/301)
to study  the  occurrence and fate of the 129 priority pollutants
in 40 POTWs show that,  based on the data for the first 20 of the
40 POTWs,  50 percent of secondary treatment plants which utilize
the  conventional  activated sludge process achieve at  least  76
percent reduction   of   total  priority  pollutant  metals,   85
percent reduction of total volatile priority pollutants,  and  70
percent reduction of total acid-base-neutral priority pollutants.
Median  secondary  removal  rates for specific pollutants  to  be
regulated in the pesticide industry are:


   Priority Pollutant                  Percent Removal

     Zinc                                    80
     Copper                                  82
     Cyanide                                 54
     Toluene                                 94
     Methylene chloride                      55
     Total phenols                           77
     BOD                                     91
     COD                                     83
     TSS                                     92
     Tetrachloroethylene                     86
     Benzene                                 95
     Chloroform                              79
Powdered Activated Carbon
Powdered activated carbon (PAC) is used in wastewater  facilities
to   adsorb   soluble   organic  materials,  to  enhance  aerobic
biological systems, and to aid in clarification.   Powdered carbon
can be fed to primary clarifiers, aeration basins, or to separate
sludge recirculation clarifiers.    The  du  Pont   PACT   process,
which  incorporates  PAC addition to the activated sludge system,
is the most widely used form  of   PAC  treatment   in  wastewater.
Spent carbon is removed with the  sludge and can then be discarded
or regenerated in a furnace or wet air oxidation  system.


Powdered  carbon  adsorption  has not been widely used on a full-
scale basis in the pesticide industry.  Plant 1 designed  a  PACT
system  but  switched  to  granular-activated  carbon  because it
experienced problems with regeneration by wet-air oxidation.


Plant  2  operates  three  batch   activated  carbon   units   for
wastewater from three pesticide processes.  Separation wash water
from  one  pesticide  is initially treated by extraction, gravity
separation, and stripping prior  to  entering  the  carbon  unit.
This unit is designed to remove phenol and pesticide.
                                   VI-52

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Prior to the reaction step in a second pesticide process at Plant
2,   wastewater  passes  through  solvent  extraction,  activated
carbon, hydrolysis, and ammonia stripping.  One to two percent by
weight  powdered carbon is mixed with waste from  this  pesticide
in  a batch vessel for one hour.  The compound 1,2-dichloroethane
is felt to be removed  by  activated  carbon;  however,  no  data
currently exist from this plant.


Wastewater from the reaction step of a third pesticide at Plant 2
is  treated  by batch slurry contact activated carbon adsorption.
The  system  is  preceded  by  wastewater   extraction,   gravity
separation,  stripping, and chemical oxidation.  Carbon treatment
was installed to reduce concentrations of pesticide and  phenols.
Following  carbon  treatment, wastewater from all three processes
is  combined  with  other  plant  wastes  in  the  general  waste
treatment   plant   prior  to  direct  discharge.   There  is  no
regeneration of spent carbon.


Advantages of the PACT  process  system  have  been  reported  by
DeJohn (1975) and Frohlich (1976).  Among possible benefits are:


1.  Improved organic pollutant removal (BOD, COD, and TOC).

2.  Protection of biological system against upsets by removal of
    toxic waste components.

3.  Greater proportions of nonbiodegradable materials are removed
    through direct adsorption.

4.  Improved operational stability.

5.  Nitrification in single-stage aeration systems.

6.  Control of foaming.

7.  Improved oxygen transfer.


Treatability Studies—DeJohn (1975) reported the  performance  of
four  full  scale  activated  sludge systems before and after the
addition of powdered carbon:

                Parameter             Before             After

     Plant 1    BOD Removal             23%             90 to 95%
     Plant 2    Effluent COD        1,800 mg/1          350 mg/1
     Plant 2    Effluent TOD      100-1,000 mg/1     less than 20 mg/
     Plant 3     TSS & COD               —          40% improvement
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Preliminary studies results (Sublette,  et al., 1980) showed that
PAC    effects   are  not  attributable  entirely   to   physical
adsorption,   but   involve  biological   enhancement.    Studies
involving  the  addition  of  phenol  to  reactors  showed   that
microcultures are apparently not affected by such toxins when the
toxins are adsorbed by the PAC.


Studies to determine the effect of PAC on biogradation of benzene
(Allen  and  Gloyna,  1980)  showed that PAC provided a system of
benzene uptake by adsorption and release through desorption  that
essentially   controlled   and  optimized  biological  oxidation.
Cumulative  oxygen uptakes as high as 95 percent of the TODC   of
the final benzene concentrations were observed.
Berndt  and  Polkowski  (1978)  reported  on  powdered  activated
carbon/wet  air  oxidation  pilot plant studies where removals of
pesticides and PCB's  were  more  than  90  percent  higher  than
removals  with  the  existing  full scale activated sludge plant.
Similarly, the PAC pilot plant effluent  residual  concentrations
of  arsenic,  phenol,  and  total cyanides were shown to be about
one-half of the values for the activated sludge system.  Effluent
concentrations of compounds are listed below:
     Parameter

     TOC mg/1
     COD mg/1
     Chlorinated pesticides ug/1
     Organo-sulfur pesticides ug/1
     Copper mg/1
     Zinc mg/1
     NH3-N mg/1
     PCBs ug/1
Activated
Sludge

  18.2
  50
   0.35
  15.0
   0.01
   0.08
  12.4
   0.131
  PAC/WAO
Pilot Plant

    8.3
   16
    0.017
    0
    0.008
    0.021
    0.17
    0.008
Flynn, et al. (1979) reported on the  operational  results  of  a
treatment  plant receiving organic chemical manufacturing wastes.
The plant, using PACT  in conjunction with neutralizers,  primary
and   secondary   clarifiers,    aerators,  and  a  waste  sludge
thickener  with  long sludge age,  achieves a  dissolved  organic
carbon  (DOC) reduction of approximately 80 percent.


Heath   (1980)  reports  on  (two years) operating data for a 40-
MGD    plant   using   PACT    process   to   provide    combined
secondary/tertiary  treatment  to  industrial  wastewater.    BOD
removals of over 96 percent were reported.  Other achievements of
this system are:


1.  The filtration rate of PACT  sludge increases with increasing
    carbon content.
                             VI-54

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2.  There  have  been  no  foaming  problems in the PACT  liquid
    train, even though the wastewater contains surfactants.


Data showed removal of  volatile  organics  to  be  generally  90
percent   with  effluent  concentrations  around  10  ug/1.   The
removal  of  phenol  was reported to be between,  94  and  an  98
percent  and  effluent concentration less than 40 ug/1.
Ford  and  Eckenfelder  (1979)  report  that  because many of the
organic  constituents  included  in  the  list  of  126  priority
pollutants  are amenable to carbon adsorption, the attractiveness
of the addition of  PAC  to  the  activated  sludge  process  for
effluent  quality  control  is  increasing.   Data  are presented
showing pilot plant performance with PAC addition as follows:
Parameter
Pilot Plant   25 mg/1 PAC   50 mg/1 PAC

 Influent      Addition     Addition
     NH3-N (mg/1)
     Phenolics (mg/1)
     Soluble COD (mg/1)
        19
         3.95
       294
 0.4
 0.006
50
 0.1
 0.002
27
Zinc Process for the Removal of Mercury
A  process  for the removal of mercury from wastewater  has  been
developed  and  is  currently  being used by  one  plant  in  the
metallo-organic  pesticide  category.    Zinc  is  added  to  the
wastewater and combines with mercury to form an insoluble complex
that precipitates out of solution under acid pH conditions.   The
waste  treatment system is a pilot scale operation that  operates
intermittently.   Influent mercury levels of 32000 ppm have  been
reduced  to  approximately 20 ppm;  a 99.99% removal  efficiency.
The effluent wastewater is neutralized and contains residual zinc
remaining  after  the  reaction  with  mercury.    Zinc  effluent
concentrations  averaged 65 ppm and were as low as  2.5  ppm.   A
second  neutralization step is anticipated to further reduce  the
zinc  levels  from  the  process  wastewater,  before  subsequent
discharge.
Equalization
Equalization  consists  of a wastewater holding vessel or a  pond
large  enough  to  dampen  flow  and/or  pollutant  concentration
variation  which  provides a nearly constant discharge  rate  and
wastewater  quality.   The  holding  tank  or  pond  capacity  is
determined by wastewater volume and composition variability.  The
                           VI-55

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equalization basin may be agitated or may utilize a baffle system
to prevent short circuiting.   Equalization is employed prior  to
wastewater treatment processes that are sensitive to fluctuations
in waste composition or flow.


Equalization  basins  of 12-hour detention are provided  for  raw
process  wastewater  as  it leaves the  plant,  and  for  24-hour
detention  before any biological treatment system.   Equalization
consists of two basins in parallel, each equipped with a floating
aerator providing 75 horsepower per million gallons of volume.


Neutralization
Neutralization is practiced in industry to raise or lower the  pH
of  a wastewater stream.   Alkaline wastewater may be neutralized
with hydrochloric acid,  carbon dioxide, sulfur dioxide, and most
commonly,   sulfuric acid.   Acidic wastewaters may be neutralized
with  limestone or lime slurries,  soda  ash,  caustic  soda,  or
anhydrous   ammonia.   Often a suitable pH can be achieved through
the mixing of acidic and alkaline process wastewaters.  Selection
of neutralizing agents is based on cost,  availability,  ease  of
use,  reaction  by-products,  reaction rates,  and quantities  of
sludge formed.


Neutralization  has  been provided prior to activated carbon  and
resin adsorption,  pesticide removal,  and/or prior to biological
treatment.
The  neutralization  basin is sized on the basis  of  an  average
detention   time   of  6  minutes.    Either  acid   or   caustic
neutralization  may  be  required.    For  the  purpose  of  cost
estimation,  caustic  neutralization was assumed since it is  the
most expensive.  The size of the caustic soda handling facilities
is  determined according to a 100 mg/1 feed rate.    Caustic soda
storage  is  provided based on 30 days'  capacity and  is  fed  by
positive  displacement  metering pumps.    Seventy horsepower  per
million gallons is provided for mixing.


Pump stations are required to bring the  process effluents to  the
treatment  plant,   and  before  any  carbon  adsorption,   resin
adsorption,  or  aeration basins;  and to recycle backwash  water
from  dual  media  filters  and carbon  or  resin  adsorptin  and
overflow  from  sludge thickener,  aerobic digester,  and  vacuum
filters.
Pump stations provide a wet well and three individual pumps which
will each handle 50 percent of the daily flow during eight  hours
of service time.  The pumping head is assumed to be 20 feet.
                            VI-S6

-------
               Table  VI-1A.  Applicability of  Treatment Technologies  to  Various Pollutant Groups
 l
en
T,.— T*»»lo»
Activjttt fctia &*•§ liolmkol MM Air Ha*f«r» IfciaU Solvent ChaMcal *tiv4*i ltertt«y
folliCMt Ck**4» CMbun MaocptMa ftrirpiq| %dnil|iii QuidMion OiMktian MTUCMMS •tptrtfion BitractMM feMhtM* Pilli«tiai Cwfaua CMtua
1k.l«,l« *,— *.
MtiMUuHn
Cy«nwt«a
lUlucthwr*
HMIW|«
Hiiro St^MUrf«d Aruutic*
HitrauMinw
OK^J^^MI <«*•)








1
1
*
1
•
1
1
1
nritticiAM III
DIMM 1 1 «
too i i •
2
2
















i


































































2
2
2
2
2
2





NltC«lt«MM ~ — — — _—___—— _..
             I • tommy rawai t«clmai
-------
Table VI-IB.  Principal  Types  of  Wastewater Treatment/Disposal
Type of Treatment/Dlspoal                         Number of Plants*
Biological Oxidation                                     32
Activated Carbon                                         17
Deep Well Injection                                      17
Incineration                                             13
Chemical Oxidation                                        9
Contract Hauling of All  Wastewater                         9
Hydrolysis                                                8
Steam Stripping                                           8
Multimedia Filtration                                     7
Evaporation                                               6
Resin Adsorption                                          4
Metals Separation                                         3
* There are a total of 119 plants  1n  Industry; however, many have more
  than one means of treatment/disposal.
                                        VI-58

-------
                                                    Table VI-IC
                                    Pollutants Removed  by Selected Technologies
    Model
  Treatment
  Technology

(1) Stean Stripping
(2) Activated Cartoon
(3) Resin Adsorption
 Priority
Pollutants

Carbon Tetrachloride
Chloroform
Methylene Chloride
Methyl Chloride
Methyl Bromide
1,3-Diehloropropene
8 i s(2-Chloroethyl)Ether
1,2,4-Tr ichlorobenzene
1,2-Dichlorobenzene
1,4-Dichlorobenzene

N-Nitroscdi-N-Propylanine
2,4-Dinitrophenol
2,4-Dichlorophenol
Pentachlorophenol
HexaehJorocyclopentadiene
BHC-Alpha
BHC-Beta
BHC-Delta
BHC-Garnraa
Endosulfan-Alpha
Endosulfan-Beta
Endrin
Heptachlor
Toxaphene
4-Nitrophenol
(4) Metals Separation   See Metals

(5) Chemical Oxidation


(6)  Hydrolysis
Non-Conventional
   Pesticides
Alachlor
Atrazine
Bremacil
Butachlor
Carbendazim
Benomyl Complex
Carbofuran
Dinoseb
Diuron
Linuron
Terbacil
Triazine
Bentazon
Chloropropham
Ferbam
Hancozeb
Niacide
PCP Salt
Swep
ZAC
Zineb
Silvex
Maneb

Benfluralin
Ethalfluralin
Flucmeturon
2,4-DB
2,4-D IBE
2,4-D IDE
2,4-DB IBE
2,4-DB IOE
2,4,5-T
Trifluralin
2,4-D

Simazine
Terbuthylazine
Terbutryn
Isopfopalin
Neburon
Profluralin
Pronetryn
Propazine
Propham
Propoxur
Pj.-opachlor

                               Methcmyl
                               Oxanyl

                               Azinphos Methyl
                               Daneton
                               Diazinon
                               Disulfoton
                               Fensulfothion
                               Fenthion
                               ;«tetribuzin
                               Parathion .Methyl
                               KN Methyl
   Busan 40
   Busan 85
   Carbatn-S
   Carbophenthion
   Chlorpyrifos
   Chlorpyrifos Methyl
   Counaphos
   DBCP
   Dioxation
KN Methyl
Metham
Naled
Ronnel
Stiofos
Trichloronate
Daneton-O
Daneton-S
Simetryn
Parathion
Bolstar
Phorate
Dichlovos
Ethion
Halathion
Prcraeton
Terbufos

-------
Table VI-2.  Plants Using Stripping for Pesticide Wastewaters*
Plant
Code
1



2


3









4
5
6
7
8


Product/
Process Code Type Stripper
A
B
C
D
E
F
G
H
I
J
K
L
M
N
0
P
Q
R
S
T
U
V
W
X
Vacuum
Steam
Steam
Steam
Steam
Steam
Steam
Steam
Steam
Steam
Steam
Steam
Steam
Steam
Steam
Steam
Steam
Steam
Steam
Steam
Steam
Steam & Vacuum
Steam & Vacuum
Steam & Vacuum
Flow (MGD)
NA
0.0165
NA
NA
0.01
0.05
0.06
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.072
0.09
0.0326
0.048
0.09
0.06
0.04
Stripped Material
Isobutyl alcohol
Methylene chloride
Xylene
Xylene
Chloroform/ hexane
Chloroform, hexane
Chloroform, hexane
Ethylene dichloride
NA
Methanol
Toluene
Toluene
Methanol
NA
NA
Toluene
NA
Ammonia, ethylamine
1 , 2-dichloroethane
Ammonia
Methylene chloride
Toluene
Toluene
Toluene
NA = Not Available
*  Proposal Data
                                           VI-60

-------
Table VI-3.  Stean Stripping Operating Data*
                           VDLATIIE ARDMATICS
Benzene

Plant
1
6
6
8



Influent
mg/1
<0.07
<0.050
ND
<0.299°



Effluent
mg/1
<0.04
<0.050
ND
<0.299°



Percent
Renoval
42.8
NA
NA
NA




Plant
1
6
6
8
8
8
8
Toluene
Influent
mg/1
<0.070
<0.20
ND
>99.5
686
1,570
528
Effluent
mg/1
<0.041
<0.20
ND
29.1
33.8
86.5
24.2
Percent
Removal
42.1
NA
NA
>70.7
95.1
94.5
95.4
Chlorobenzene
                               Influent Effluent    Percent
                       Plant    mg/1     mg/1      Renoval
                                 ND
ND
NA
                                   HALOCTHANES
Methylene chloride
Plant
1
6
6
Influent
mg/1
<159
0.005
<0.798
Effluent
mg/1
<0.01°
0.02
<0.645
Percent
Removal
99.9
+
19.2
Chloroform
Influent Effluent
Plant mg/1 mg/1
1 <0.0623
2 70.0*
6 <0.30
<0.0010°
<5.0*
<0.733
Percent
Renoval
98.4
>92.9
+
Carbon tetrachloride


Plant
Influent
mg/1
Effluent Percent
mg/1 Renoval


                               <0.0010     <0.0010
            NA
Footnotes at end of table.
                                         VI-61

-------
Table VI-3.  Steam Stripping Operating Data (Continued, Page 2 of 2)
                        CHLORINATED ETHANES AND ETHYLENES
                                  Trichloroethylene
                               Influent  Effluent   Percent
                       Plant    mg/1      rag/1      Removal
1
6
<0.070
NA
<0.04
0.01
42.9
MA
                                  AMMONIA
Armenia

Plant
4
6
6
Influent
mg/l
>50.0
2540
7890
Effluent
mg/1
5.00
95
98.0
Percent
Removal
>90.0
96.3
98.8
NA = Not available
ND = Not detected
 + = Concentration increased
 0 = Analysis not conducted per protocol
 * = Data from ccmingled waste stream
 1 = Preproposal Data
                                       VI-62

-------
Table VI-4.  Plants Using Chemical Oxidation for Pesticide Wastewaters*
Plant
Code
1




2
3

4
5

6

7
8


9
NA »
* n.
Pesticide
Code
A
B
C
D
B
F
G
H
I
J
K
L
M
N
0
P
0
R
Not Available
• r~i_i_i_ri_i.T_j~L_n i_"l T^.n_k T_
Pesticide Volume
Disposed (MGD)
NA
0.029
NA
NA
NA
0.0634
0.10
0.02
0.07
0.0005
0.0015
0.02
0.015
0.0003
0.01
0.01
0.01
0.0026



pH
NA
NA
NA
NA
NA
13-14
7-11
7-11
1
8
8
10-12
10-12
7-12
NA
NA
NA
NA



Chemical Oxidant
Hydrogen peroxide
Sodium hypochlorite
Hyd'rogen peroxide
Hydrogen peroxide
Hydrogen peroxide
Formaldehyde
Chlorine
Chlorine
Hydrogen peroxide
Hydrogen peroxide
Hydrogen peroxide
Chlorine
Chlorine
Sodium hypochlorite
NA
NA
NA
Coha I Lou s ch } or ide


                                          VI-63

-------
Table VI-5.  Chemical Oxidation Operating Data1
           CYANIDE
                                     PHENOLS

Plant
Cyanide
Influent Effluent
mg/1 mg/1
Phenols
Percent
Removal
Influent
Plant mg/1
Effluent
rag/1
Percent
Removal
        5503*
19.7
99.6
1100*
 2.03*
99.8
                               MANUFACTURED PESTICIDES
Pesticides
Pesticide
Code
F
S
S
T
G
V
H
H
U
I
K
J

Chlorobenzene

Plant
2
3
3
3
3
3
3
3
3
4
5
5
VOLATILE

Influent
mg/1
83.2
1.33
3.46
2.03
2.40
2.57
398
19.2
0.013
MA
MA
NA
AROMATICS

Effluent
rag/1
<0.145
<0.01
1.26
<0.01
0.229
1.19
0.187
3.19
0.299
NA
0.023*
0.023*


Percent
Removal
>99.8
>99.3
63.6
>99.5
90.5
54.4
99.9
83.4
+
98. 9t
NA
NA

Toluene
        Influent  Effluent   Percent             Influent  Effluent   Percent
Plant    mg/1      mg/1      Removal     Plant    mg/1      rag/1      Removal
          ND
 ND
 NA
<0.01
<0.01
   NA
Footnotes at the end of table.
                                      VI-64

-------
Table Vl-5.  Chemical Oxidation Operating Data (Continued Page 2 of 2)
                               HADCMETHANES
         Carbon tetrachloride
                     Methylene chloride
        Influent  Effluent   Percent             Influent  Effluent   Percent
Plant    rag/1      rag/1      Removal     Plant    mg/1      rog/1      Removal
        Trace     0.014°
 NA
         ND
ND
NA
                                    Chloroform
                                Influent  Effluent   Percent
                        Plant    mg/1      mg/1      Removal
                          3
                          3
0.0367
0.170°
1.50
1.90°
NA = Not available
ND = Not detected
 ° = Analysis not conducted per protocol
 * = Data from coningled waste stream
 t = Pilot plant data
 + = Concentration increased
 1 = Preproposal Data
                                          VI-65

-------
Table VI-6.  Plants Using Metals Separation for Pesticide Wastewatersl
Plant
Code
1
2
3
Pesticide
Code Flow (MGD)
A 0.06
B NA
C* 0.35
D*
Type of System
Hydrogen Sulf ide
Precipitation
Sodium Sulf ide
Precipitation
Ferric Sulf ate,
Lime Precipitation
Effluent
Concentration
(mg/1)
2.2-2.8 (Cu)
NA
0.2 (As)
0.11 (Zn)
 NA = Not Available
  * = Previously manufactured metallo-organics.
 As = Arsenic
 Cu » Copper
 Zn » Zinc
  1 - Prepropoeal Data
                                           VI-66

-------
Table VI-7.  Plants Using Granular Activated Carbon for Pesticide Wastewaters1
Plant Pesticide
Code Code
1 A
B
C
D
E
F
G
H
I
2 J
K
3* L
M
Nt
0
4 P
Q
5 R
S
T
6 U
V
W
Pesticide
Intermediate
Volume
Treated (MGD)
0.0451
0.0165
NA
MA
NA
NA
NA
NA
NA
0.00453
0.009
0.40°
0.40°
0.40°
0.40°
0.015
0.012
1.26°
1.26°
1.26°
0.050-0.075
NA
NA
0.025-0.030

Calculated
Empty Bed Carbon Usage
pH Contract Time (lb/1000 gal)
1.0-1.5
1.0-1.5
1.0-1.5
1.0-1.5
1.0-1.5
1.0-1.5
1.0-1.5
1.0-1.5
1.0-1.5
0.5-4.0
0.5-4.0
7.0
7.0
7.0
7.0
NA
NA
6-12
6-12
6-12
8.5-9.5 (A)
8.5-9.5 (A)
8.5-9.5 (A)
1.5 (N)

320 Min.
320 Min.
320 Min.
320 Min.
320 Min.
320 Min.
320 Min.
320 Min.
320 Min.
588 Min.
588 Min.
19.1 Min.
19.1 Min.
19.1 Min.
19.1 Min.
NA
NA
18-52 Min.
18-52 Min.
18-52 Min.
1000 Min. (A)
1000 Min. (A)
1000 Min. (A)
571 Min. (N)

26.0
26.0
26.0
26.0
26.0
26.0
26.0
26.0
26.0
81.5
81.5
3.9
3.9
3.9
3.9
NA
NA
20.0-33.5
20.0-33.5
20.0-33.5
136 (A)
136 (A)
136 (A)
NA (N)

Reactivation
Method
Off-site/Thermal
Off-site/Thermal
Off-site/Thermal
Off -site/Thermal
Off-site/Thermal
Off-site/Thermal
Off-site/Thermal
Off-site/Thermal
Off-site/Thermal
Off-site/Thermal
Off-site/Thermal
Off-site/Thermal
Off-site/Thermal
Off-site/Thermal
Off-site/Thermal
NA
NA
On-site/infrared furnace
On-site/infrared furnace
On-site/infrared furnace
Off-site/Thermal
Off-site/Thermal
Off-site/Thermal
Off-site/Thermal

 Fotenotes at end of Table.

-------
        Table VI-7.  Plants Using Granular Activated Carbon for Pesticide Wastewaters1  (Continued, Page 2 of. 2)
00
Plant
Code
7
8
9
10
11
12
13
14
15
16
17
Pesticide
Code
X
y
z
AA
BB
CC
DD
EE
FF
GG
HH
HH
II
II
JJ
KK
Volume
Treated (MGD)
0.046
0.047
0.16
0.07
0.02
0.001
0.0005
0.0028
0.010
0.00133
0.0275
0.0002
0.12
0.18
0.0005
0.0004
Calculated
Empty Bed
pH Contract Time
6-8
6-8
8-12
NA
5-9
NA
NA
NA
6
1
2.0
2.0
11.6-12.5
11.6-12.5
4.0-10.6
4.0-10.6
480 Min.
480 Min.
100 Min.
NA
250 Min.
NA
NA
NA
109 Min.
35 Min.
420 Min.
420 Min.
91.5 Min.
60.8 Min.
60 Min.
60 Min.
Carbon Usage Reactivation
(lb/1000 gal) Method
95.0
95.0
2.89
NA
69.3
NA
NA
NA
0.92
NA
451.0
451.0
71.6
47.7
2.0
2.0
Of f-s iteAhermal
Of f-s iteAhermal
Of f-s i teAherroal
NA
Of f-s iteAhermal
NA
NA
On-s i teAhermal
On-s i teAhermal
On-s i teAsopropanol
Of f-s i teAherroal
Off-siteAhermal
Of f-s iteAhermal
Off-siteAhermal
Off-siteAhermal
Of f-s iteAhermal
           0 = Combined pesticide flow.
           * = Utilized as tertiary treatment.
           t = Production discontinued.
         NA = Not Available
         (A) = Amination
         (N) = Nitration
           1 = Preproposal Data

-------
 Table VI-8.  Granular Activated Carbon  Operating Data^

                               MANUFACTURING  PESTICIDES
Pesticides
Pesticide
Code
B
B
A
A
C
K
K
0
0
M
M
L
L
P
Q
R.S.T
R,S,T
U
U
U
Y
X
Z
Z
BB
BB
FF
GG
HH
HH
HH
HH
HH
II
Plant
1
1
1
1
1
2
2
3
3
3
3
3
3
4
4
5
5
6
6
6
7
7
8
8
10
10
13
14
15
15
15
15
15
16
Influent
mg/1
7.83
<4.63
83.0
82.5
<0.01
0.465
15.5
NA
0.065t
10.4
10.9
40.7
18.1
9300
15
133*
45.7*
184
14.6
3.37
7.57
218
31.3
41.8
160.0
477
NA
17.2
7.75
3460
320
1780
4.2
<1420
Effluent
mg/1
<0.0084
<0.0147
0.0428
<0.0359
<0.01
<0.001
0.0182
0.0055
0.005
<0.92
<0.342
<5.84
0.680
1.7
0.01
4.7*
12.4*
2.82
0.0713
0.004
>0.01
1.26
<10.0
15.2
<0.025
3.37
0.00602
11.0
2.45
5.71
4.32
1.85
1.4
<314
Percent
Removal
>99.9
99.7
99.9
>99.9
NA
>99.8
99.9
NA
92.3
>91.2
>96.9
85.7
96.2
99.9
99.9
96.5
72.9
98.5
99.5
99.8
<99.9
99.4
>68.0
63.6
>99.9
99.3
NA
36.0
68.4
99.8
98.6
99.9
66.7
77.9
 * = Data from comingled waste  stream
 t = Analysis not conducted  per protocol
NA = Not Available
 1 = Preproposal  Data
                                             VI-69

-------
Table VI-8.
Granular Activated Carbon Operating Data
(Continued, Page 2 of 6)
                                      PHENOLS
Phenol

Plant
1
1
4
4
6
8
Influent
mg/1
44.1
<1.82*
0.92
280
<0.015t
ND
Effluent
mg/1
0.197*
<0.081*
<0.01
0.029
<0.01
ND
Percent
Removal
99.6
95.5
<98.9
99.9
33.3
NA

Plant
1
1
8
15


2 , 4-Dichlorophenol

Plant
1
1
1
1
4
Influent
mg/l
92.2*
NA
NA
53.7*
42,000
Effluent
mg/1
<0.0591*
0.482°
0.498°
<0.022*
0.82
Percent
Removal
>99.9
NA
NA
>99.9
99.9

Plant
1
1
4
8

Pentachlorophenol

Plant
2
6


Influent
mg/1
<1.0
<0.01


Effluent
mg/1
<0.10t
<0.01t


Percent
Removal
90.0
NA



Plant
1
1
2
3
2-Chlorophenol
Influent
mg/1
<5.09*
11.2*
ND
0.040


Effluent
mg/l
<0.0233*
<0.010*
ND
ND


Percent
Removal
99.5
>99.9
NA
NA


2 , 4^ 6-Trichlorophenol
Influent
mg/l
<3.69*
2.20*
8700
ND

Effluent
mg/l
<0.0493*
<0.010*
0.068
ND

Percent
Removal
98.7
>99.5
99.9
NA

Total jDhenol
Influent
mg/l
<145*
<79.6*
<0.0056
0.187
Effluent
mg/l
<0.329*
<0.143*
<0.001
0.118
Percent
Removal
99.8
99.8
82.1
36.9
NA = Not available
ND = Not detected
 t = Analysis not conducted per protocol
 0 = Reported as total phenol with 2,4-dichlorophenol principal constituent
 * = Data fron coningled waste stream
                                           VI-7G

-------
Table VI-8.  Granular Activated Carbon Operating Data
             (Continued/ Page 3 of 6)
                              NITROSAMINES
                         N-nitrosodi-n-propylamine
                     Plant
Influent
 mg/1
Effluent
 ma/1
Percent
Removal
                      6
                      6
                      6
                      8
 0.069
 0.123
  1.96
    ND
0.0067
0.0276
0.0041
    ND
  90.3
  77.6
  99.8
    NA
                            VOLATILE AROMATICS
Benzene

Plant
1
4
4
7
15
15



Influent
mg/l
<0.01*
NA
0.073
ND*
<0.050
0.02



Effluent
mg/l
<0.01*
<0.012
<0.01
NA
<0.050
ND



Percent
Removal
NA
NA
>86.3
NA
NA
NA




Plant
1
4
4
5
5
5
7
15
15
Toluene
Influent
mg/l
0.0162*
NA
0.03
5.80*
1.08
2.69*
0.137*
ND
<0.20°
Effluent
mg/l
0.0194*
<0.006
<0.01
<0.1*
NA
NA
<0.007*
ND
<0.20
Percent
Removal
+
NA
>66.7
>98.3
NA
NA
>94.9
NA
NA
NA = Not available
ND = Not detected
 + = Concentration increased
 * = Data from comingled waste stream
 0 = Analysis not conducted per protocol
                                            VI-71

-------
Table VI-8.  Granular Activated Carbon Operating Data
             (Continued, Page 4 of 6)
                            VOLATIIE ARQMATICS (continued)
          Chlorobenzene
                                 Hexachlorobenzene
        Influent  Effluent   Percent             Influent  Effluent   Percent
Plant    mg/1      mg/1      Removal     Plant    mg/1      mg/1      Removal
        <0.01
<0.01
NA
<0.008    <0.001
87.5
                             Dichlorobenzenet
                             Influent  E ffluent   Percent
                     Plant    ng/1      mg/1      Removal
                             <0.108    <0.0167
                                 84.5
                            HAEJOeTHANES
Methylene chloride
Plant
1
1
4
4
6
8
10
15
Influent
mg/1
3.54*
1.70*
0.88
NA
0.326
ND
12.7°
<0.10
Effluent
mg/1
<3.07*
1.49*
<0.01
1.43
<0.010
ND
<0.10°
<0.798
Percent
Removal
>13.3
12.5
>98.9
NA
>96.9
NA
>99.2
+
Plant
1
1
3
4
4
10


Chloroform
Influent
mg/1
<0.0689*
0.0189
0.623
<0.09
NA
<0.30°


Effluent
mg/1
<0.0119*
0.0231*
0.210
<0.01
<0.0233
<0.30°


Percent
Removal
82.7
+
66.3
88.9
NA
NA


NA = Not available
ND = Not detected
 t = Combined dichlorobenzenes: 1,2; 1,3? 1.4.
 0 = Analysis not conducted per protocol.
 * = Data froni oomingled waste stream
 + = Concentration increased
                                               VI-72

-------
Table VI-8.
Granular Activated Carbon Operating Data
(Continued, Page 5 of 6)
                            HALCEETHANES (continued)
                             Carbon tetrachloride
Plant
1
1
3
4
4
5
5
5
Influent
mg/1
<0.150*
<0.0010*
10.5*
NA
<0.91
0.39
0.168*
<0.16*
Effluent
ng/1
<0.0261*
<0.0010*
2.32*
<0.02
<0.01
MA
MA
<0.1*
Percent
Removal
82.6
MA
77.9
NA
98.9
NA
NA
37.5
                       CHLORINATED ETHANES AND ETHYLENES
                             1,2-Dichloroethane
                             Influent  Effluent    Percent
                     Plant    mg/1      mg/1      Removal
                      6
                      4
                 <0.022
                     NA
<0.012
 <0.01
45.5
  NA
NA = Not Available
ND = Not detected
 * = Data fro comingled waste stream
                                                  VI-73

-------
Table vi-8.
Granular Activated Carbon Operating Data
(Continued, Page 6 of 6)

               TRADITIONAL PARAMETERS


Plant
1
3
5
5
6
7
10
14
15





Plant
1
2
3
5
5
5
6
7
8
10
13
14
15
15
BOD
Influent
mg/l
5690*
137.0*
ND*
78.8
NA
NA
<103
45200
3331



TSS
Influent
mg/l
56.6*
235
35.0*
411*
178
253*
NA
68,6*
77.5
87.7
<97.0*
1460
4094
3000

Effluent
mg/l
4136*
319.0*
<20.0*
NA
316
889*
<1.92
37400
2397




Effluent
mg/l
185*
150
35.0*
25.7*
NA
NA
34.0
-•16.6*
32.>
<:s .00
<117*
2600
204
2000

Percent
Removal
27.3
+
+
NA
FA
f94.3
+
+
95.0
33.3


Plant
1
2
3
c
5
5
6
7
10
14
15
15


Plant
2
5
5
7
10
13
14
15
15
16





Influent
mg/l
8000*
1500
895.0*
353*
890
468*
5120
4750*
4880
148000
28021
75500

Influent
mg/l
430
585*
178*
1650*
2170
<344*
79800
28489
19500
523




COD
Effluent
mg/l
2580*
204
819.0*
<285*
NA
NA
2880
808*
31.2
109000
5340
60000
TOC
Effluent
mg/l
40.3
81.0*
NA
153*
15.4
<245*
66700
6538
3300
165





Percent
Removal
67.7
86.4
8.49
>19.3
NA
NA
43.7
83.0
99.4
26.3
80.9
20.5

Percent
Removal
90.6
86.2
NA
90.7
99.3
28.8
16.4
77.0
83.1
68.4




NA = Not available
 •f = Concentration increased
 * = Data from coningled waste stream
                                           VI-74

-------
        Table VI-9.  Plants Using Resin Adsorption for Pesticide Wastewaters1
en
Plant
Code
1
2
3
4
Pesticide
Code
A
B*
C
D
E
F
G
Volume Disposed
(MOD)
0.15
0.10
0.14
0.04
0.09
0.06
0.04
Flow Rate
(GPM/Ft2)
4.0
1.0
3.5
3.5
3.6
3.6
3.6
PH
6-8
4.5
3-4
3-4
1.5
1.5
1.5
Empty Bed
Contract Time
7.5 Min.
30 Min.
15 Min.
15 Min.
15 Min.
15 Min.
15 Min.
Regeneration
Solvent/Disposal
Methanol/Boiler fuel
Sodium hydroxide/Recycle
Isopropanol/Boiler fuel
Isoprcpanol/Boiler fuel
Methanol/Distilled-Reused
Methanol/Distilled-Reused
Methanol/Di s t i 1 led-Reused
        * = Production discontinued
        1 = Preproposal Data

-------
Table VI-10.  Resin Adsorption Operating Datal

                            MANUFACTURED PESTICIEES
                               Pesticides
Pesticide
Code
A
A
D
D
C
C
E
E
E
E
E
F
G
Plant
1
1
3
3
3
3
4
4
4
4
4
4
4
Influent
mg/1
0.154
0.142
0.095
0.320
0.518
<0.51
129
612
<331
260
248
<152
71.1
Effluent
mg/i
0.00067
0.00123
0.038
0.010
0.539
<0.015
24.0
18.6
<19.5
61.1
26.7
<18.3
<9.24
Percent
Removal
99.6
99.1
60.0
96.9
+
97.1
87.5*
97.0
94.1
76.5
89.2
88.0
>87.0
                                   PffiNOLS
          2-Chlorophenol
        Influent  Effluent   Percent
Plant    mg/1      mg/1      Removal
Plant
           2,4-Dichlorophenol
Influent
 mg/1
Effluent
 mg/1
Percent
Removal
  4      <0.152     <0.01    93.4
  4       0.162   <0.0314   >80.6
  4      <0.718    <0.069    90.4
        2,4,6-Trichlorophenol
Plant
4
4
4
Influent
mg/1
<0.348
0.378
<0.544
Effluent
mg/1
<0.163
<0.0892
<0.219
Percent
Removal
68.8*
>76.4
59.7
  4      5.76    0.523        93.9*
  4     <10.5    <4.32        58.9
  4      3.15   <0.462       >85.3
  4      5.46    <1.53       >72.0

             4-Nitrophenol
Plant
2
Influent
mg/1
lOOOt
Effluent
mg/1
l.OOt
Percent
Removal
99.9
NA - Not available
ND - Not detected
 * « Removal based on pollutant mass balance, not concentration
 t « Pilot scale data
ft » Reported at total phenol with 2,4-dichlorophenol as principal constituent
 + » Concentration increased
 1 » Preproposal data
                                          VI-76

-------
Table VI-10.  Resin Adsorption Operating Data (Continued,  Page 2 of 4)
                                   PHENOLS (Continued)
Phenol



Influent Effluent Percent
Plant mg/1 mg/1 Removal
4 3.82 1.15
4 0.955 0.518
69.8*
45.8


DIENES
HexachlorocyclojDentadiene
Influent Effluent Percent
Plant mg/1 mg/1 Removal Plant
3 0.827* 0.123* 85.1 3
3 0.435* 0.034* 92.2
Hexachlorobutadiene
Influent
mg/1
0.210*
Effluent
mg/1
0.01*
Percent
Removal
91.1*
VOLATILE AROMATICS
Benzene
Influent Effluent Percent
Plant mg/1 mg/1 Removal Plant
1 <0.053 <0.032 34.5** 3
4 <0.298 NA NA 4
4
4
4
4
Toluene
Influent
mg/1
2.10*
16.8
20.8
25.2
82.9
Effluent
mg/1
0.742*
8.76
<79.6
19.8
<16.4
NA
Percent
Removal
64.7
65.2**
53.5
63.1
>34.9
NA
NA = Not available
 * = Data from conringled waste stream
** = Removal based on pollutant mass balance,  not concentration
                                         VI-77

-------
Table VI-10.  Resin Adsorption Operating Data (Continued,  Page 3 of 4)
                               VOLATILE AROMATICS (Continued)
                             Chlorobenzene
                             InfluentEffluentPercent
                     Plant    mg/1       mg/1       Removal
                              0.577    0.151
39.2**
                                 HALOMETHANES
Chloroform
Influent Effluent Percent
Plant mg/1 mg/1 Removal
Chlorodibromomethane
Influent Effluent
Plant mg/1 mg/1
1 6.19 2.51 59.4 1 <0.0063 0.005
3 0.382* 0.339* 11.2
Carbon tetrachloride
Influent
Plant mg/1
1 8.07
3 67.9*
POLYNUCLEAR
Effluent Percent
mg/1 Removal
5.49 28.4**
44.5* 34.5
AROMATIC HYDROCARBONS
Percent
Removal
<13.8**

                               Naphthalene
                             InfluentEffluentPercent
                     Plant    mg/1      mg/1       Removal
                              1.06*    0.297*
72.0
 * = Data from comingled waste stream
** = Removal based on pollutant mass balance, not concentration
                                        VI-78

-------
Table VI-10.  Resin Adsorption Operating Data (Continued,  Page  4  of  4)
                          CHORINATED ETHANES  AND  ETHYLENES

                             Tetrachloroethylene	
                             InfluentEffluentPercent
                     Plant    mg/1       mg/1       Removal
1
3
0.054
0.467*
0.018
0.199*
55.3**
57.4
                             TRADITIONAL PARAMETERS

Plant
1
3
4
BOD
Influent
mg/1
55.0
331*
1906

Effluent
mg/1
55.0
278*
2104

Percent
Removal
0.0
16.0

Plant
1
3

Influent
mg/1
674
675*
COD
Effluent
mg/1
576
545*

Percent
Removal
17.9**
19.3


Plant
1
3

TSS
Influent
mg/1
23.0
208*


Effluent
mg/1
19.0
81.3*


Percent
Removal
25.0**
60.9



Plant
1
3
4

Influent
mg/1
62.0
342*
2670*
TOC
Effluent
mg/1
59.0
301*
2590

Percent
Removal
3.85**
12.0
3.0
 * = Data from comlngled waste stream
** = Removal  based on pollutant mass balance,  not  concentration
 + = Concentration Increased
                                        VI-79

-------
          Table VI-11.  Plants Using Hydrolysis for Petsicide Wastewaters*
CO
o
Plant
Code
1
2
3
4

5










6





7

8
Pesticide
Code
A
B
C
D
E
F
G
H
I
J
K
L
M
N
0
P
0
R
S
T
U
V
w,x
w,x
Y
Pesticide Volume
Disposed (MGD)
0.00451
0.056
0.025
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.0634
0.006
0.015
0.025
0.007
0.013
0.02-0.015
0.02-0.015
0.010
PH
>9.0
<1.0
12.7
<10
<10
11-12
8-12
8-12
12+
8-12
12+
12+
13+
8-12
12+
12+
NA
12-14
12-14
12-14
12-14
12-14
10-12
4-6
9
Detention
Time
>108 Hrs.
264 Hrs.
3 Hrs.
120 Hrs.
120 Hrs.
Variable
Variable
Variable
Variable
Variable
Variable
Variable
Variable
Variable
Variable
Variable
NA
12 Hrs.
12 Hrs.
12 Hrs.
12 Hrs.
12 Hrs.
80 Min.
50-60 Min.
19 Hrs.
Temperature
Ambient
Ambient
46.1°C
NA
NA
30°-40°C
65°-100°C
65°-100°C
100°C
65°-100°C
100 °C
100°C
30°-35°C
65°-100°C
100 °C
100°C
NA
43.3°C
43.3°C
43.3°C
43.3°C
43.3°C
104 °C
104 °C
75°C
Type System
Batch
Continuous
Batch
Continuous
Continuous
Continuous
Batch
Batch
Continuous
Batch
Continuous
Continuous
Continuous
Batch
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
Continuous
          NA = Not avialable

           * = Preprcposal data

-------
Table VI-12.  Hydrolysis  Operating  Data1





                            Pesticides
Pesticide
Code
A
B
C
C
E
D
G
F
J
N
L
H
K
P
0
I
M
Q
V
u
T
S
R
X
W
Y
NA = Not analyzed
ND = Not detected
* = Sampling has demonstrated
average varies based on pH
t = Design basis
** = Hydrolysis and biological
1 = Preproposal Data
Influent Effluent
Plant
1
2
3
3
4
4
5
5
5
5
5
5
5
5
5
5
5
6
6
6
6
6
6
7
7
8


that cited
mg/1
3300
57
27.0
26.8
12.2**
12.2**
20
50
50
60
60
60
104
150
200
300
1000
NA
NA
NA
NA
NA
NA
NA
55
720


effluent
, temperature, and

oxidation


treatment

mg/1
5.49
0.049
0.56
1.7
<0.01**
<0.01**
<1.0*
<1.0*
<1.0*
<1.0*
<1.0*
<1.0*
4.0
<2.0*
1.0*
<1.0*
<2.0*
NA
<0.01
<0.1
<0.1
<0.01
<0.5
NDt
<0.001
90.8


removal is
Percent
Removal
99.8
99.9
97.9
93.7
>99.9
>99.9
>95.0
>98.0
>98.0
>98.3
>98.3
>98.3
96.1
>98.7
99.5
>99.7
>99.8
>95.0t
NA
NA
NA
NA
NA
NA
>99.9
87.4


achievable;
detention time.

combi ned




                                    VI-81

-------
Table VI-13.  Plant 10 Hydrolysis Data for Thiocarbamate Pesticides*
Pesticide
Code
Z

M and BB








CC




DD





pH
10

3


6


9


3

6

9
4
4
8

8

Temp
(°C)
20

20
35
50
20
35
50
20
35
50
20

20

20
30
60
30

60

Half-Life
(Hours)
Less than
one hour
1.0
0.45
0.27
2.7
2.7
5.0
12.9
8.0
6.0
Greater than
40 days
Greater than
40 days
72
120
50
Less than
24 hours
Less than
24 hours
* = Preproposal Data

-------
Table VI-14.   Hydrolysis Data—Triazine Pesticides*
Pesticide
Atrazine







Cyanazine
Prometryn
Ametryne


Met ri buz in



Cyprazine

Simazine

Atratone



PH
13
0.5
1
1
3
12
14
16
1.55
1.0
11
1
0.5
11
11
1
1
1
1
1
1
11
11
1
1
Temp
(°C)
25
40
25
80
25
25
25
80
25
25
41
41
41
23
41
23
41
23
41
23
41
23
41
23
41
Half-Life
(Hours)
48
3.3
80
4.7
331
295
4.5
0.27
30
22
133
22
10
270
236
19
9
43
8
33
8
420
290
176
48
Reference
Armstrong,
Lowenbach,
Little, et
Little, et
Little, et
Little, et
Little, et
Little, et
Brown, et
Kearney,
LAI, 1977
LAI, 1977
LAI, 1977
LAI, 1977
LAI, 1977
LAI, 1977
LAI, 1977
LAI, 1977
LAI, 1977
LAI, 1977
LAI, 1977
LAI, 1977
LAI, 1977
LAI, 1977
LAI, 1977
et al
1977
al.
al.
al.
al.
al.
al.
., 1967

1980
1980
1980
1980
1980
1980
al., 1972
et al .















, 1969















* = Preproposal  Data
                                      VI-83

-------
   Table VI-15.  Plants Using Incinceration* for Pesticide Wastewaters1
CO
Plant
Code
1
2





3



4





5




6
Pesticide
Code
A
B
C
D
E
F
G
H
I
J
K
L
M
N
0
P
Q
R
S
T
U
V
W
Pesticide Volume
Incinerated (MGD)
0.000234
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.0028
0.0013
0.0033
NA
NA
0.002
0.05
0.0005
NA
0.002
Incinerator Capacity
30-35 x 106
36.0 x 106
36.0 x 106
36.0 x 106
36.0 x 106
36.0 x 106
36.0 x 106
8.7 x 106
8.7 x 106
8.7 x 106
20.0 x 106
35.0 x 106 and 70.0 x
35.0 x 106 and 70.0 x
35.0 x 106 and 70.0 x
35.0 x 106 and 70.0 x
35.0 x 106 and 70.0 x
35.0 x 106 and 70.0 x
3000 BTU/lb feed
3000 BTU/lb feed
3000 BTU/lb feed
3000 BTU/lb feed
3000 BTU/lb feed
10 x 106
(BTU/HR)











106
106
106
106
106
106






Percent Devoted
to Pesticide
5.7
60
60
60
60
60
60
100
100
100
100
NA
NA
NA
0.55
4.68
NA
100
100
100
100
100
NA
   Footnotes at end of table,

-------
     Table VI-15.  Plants Using Inclneeration* for Pesticide Wastewaters  (Continued,  Page 2 of 2)
oo
en
Plant
Code
7








8
9

10
11
12
13


14
Pesticide
Code
X
Y
Z
AA
BB
X
CC
DD
EE
FF
GG
HH
II
JJ
KK
LL
MM
LL
NN
Pesticide Volume
Incinerated (MGD)
NA
NA
NA
NA
NA
NA
NA
NA
NA
0.0010
0.039
0.001
0.024
0.0029
NA
0.0000111
0.000105
0.0000076
0.115
Incinerator Capacity
20.0 x 106
9.0 x 106 and 12.0 x
9.0 x 106 and 12.0 x
9.0 x 106 and 12.0 x
9.0 x 106 and 12.0 x
9.0 x 106 and 12.0 x
9.0 x 106 and 12.0 x
9.0 x 106 and 12.0 x
9.0 x 106 and 12.0 x
5.0 x 106
76.7 x 106
76.7 x 106
48.0 x 106
12.0 x 106
NA
14.0 x 106
10.0 x 106
10.0 x 106
9.5 x 106
(BTU/HR)

106
106
106
106
106
106
106
106










Percent Devoted
to Pesticide
NA
NA
NA
NA
NA
NA
NA
NA
NA
NA
100
100
100
100
NA
NA
NA
NA
100
      * = Refers to the disposal of gaseous and organic liquid streams by specific incinceration

          facilities, not as a supplemental fuel in boilers.

      1 = Preproposal Data

     NA = Not available

-------
    Table VI-16.  Plants Using Biological Treatment  for Pesticide Wastewaters*
00
Plant
Code
1
2
3
4
5
6
7
8

9

10
11
12
13
14
15
16
17
Products
Manufactured
Pest,
Pest,
Pest,
Pest,
Pest,
Pest
Pest,
Pest,

Pest,

Pest,
Pest,
Pest,
Pest,
Pest,
Pest,
Pest,
Pest,
Inter
Inter
Inter
Inter
Inter

Inter
Inter

Inter

Inter
Form
Other
Inter
Inter
Inter
Inter
Inter
, Form,
Other
, Form,
, Form,


, Form,
, Form,

, Form,

, Other


, Form,
, Other
, Form,
, Form
, Form,
Other

Other
Other


Other
Other

Other




Other

Other

Other
Type of
System
AL
TF
AL;AL
AS;TF
AL
AS
AS
AS;AL
AL
AL
AS
AL
AS
AS
AL ;AS
AS
AL
AL;TF
AS
Detention
Time (Hours)
96
NA
240;120
5
2,280
139
7.15
79
367
2,160
55
NA
79
NA
51.1
60
288
192
NA
Activated Sludge
MLSS
(mg/1 )
M ^
--
—
2,000
—
35,000
6,000
>3,000
—
—
2,000
--
8,720
NA
NA
NA
—
—
NA
    Footnotes at end of table.

-------
     Table VI-16.  Plants Using Biological  Treatment for Pesticide Wastewaters*
                  (Continued, page 2 of 2)
CD
Activated Sludge
Plant
Code
18
19
20
21
22
23
24
25
26
27
28
29
30
31
32
Pest
Inter
Form
MA
AS
AL
TF
MLSS
Other
*
Products
Manufactured
Pest, Inter, Form, Other
Pest, Other
Pest, Inter, Form
Pest, Other
Pest, Other
Pest, Inter, Other
Pest, Other
Pest, Inter, Form, Other
Pest, Inter, Form, Other
Pest, Inter, Other
Pest, Other
Pest, Inter, Other
Pest, Inter, Form, Other
Pest, Inter, Other
Pest
= Pesticides
= Pesticide Intermediate
= Pesticide Formulations
= Not Available
= Activated Sludge
= Aerated Lagoon
= Trickling Filter
= Mixed-Liquor Suspended Solids
= Manufacture of other chemical
= Preproposal Data
Type of
System
AS
AL
AL
AL
AL
AS
AS
AL
AS
AL;AS
AL
AS
AL
AS
AS;TF








products

Detention
Time (Hours)
NA
NA
NA
206
NA
NA
NA
NA
24
NA
420
NA
NA
NA
3.2










MLSS
(mg/1 )
NA
—
—
—
—
NA
NA
—
NA
NA
—
NA
—
NA
NA











-------
Table VI-17.  Biological  Treatment  Operating  Preproposal Data
                           CONVENTIONAL  POLLUTANTS

Plant
1
1
3
3
4
5
6
7
9
9
11
13
15
16
18
20
20
20
26
28
29

BOD
Influent
mg/1
92.0*
179*
1940*
2082*
120*
4320
NA
928*
19.0*
675
694*
610*
1131*
NA
572*
NA
1000
2000
905*
2000*
7200*

TSS
Effluent
mg/1
39.0*
15.3*
96.5*
122*
8.0*
1820
12.7*
73.6*
<1.0*
29.6
12.2*
7.0*
NA
253
NA
74.3
NA
NA
114*
50.0*
NA

Percent
Removal
57.6
91.4
95.0
94.1
93.3
57.9
NA
92.1
>94.7
95.6
98.3
98.8
NA
NA
NA
NA
NA
NA
87.4
97.5
NA

Plant
1
1
3
3
4
5
5
6
7
8
9
9
11
13
15
18
20
20
20
26
26
28
Influent
mg/1
NA
NA
269*
375*
59.0*
NA
360
NA
595
5320*
38.7
47.6*
39.2*
3.0*
1394*
350*
NA
100
300
140*
340*
<100*
Effluent
mg/1
18.0*
22.8*
50.1*
66.8*
39.0*
501
NA
20.8*
62.5
NA
101
35.0*
28.4*
1.8*
NA
NA
81.2
NA
NA
27.3*
64.0*
92.0*
Percent
Removal
NA
NA
81.4
82.2
33.9
NA
NA
NA
89.5
NA
+
26.5
27.5
40.0
NA
NA
NA
NA
NA
80.5
81.2
<8.00
NA = Not available
 * = Data from comingled waste stream
 + = Concentration increased
                                      VI-88

-------
Table VI-17.  Biological  Treatment Operating Preproposal  Data (Continued,
Page 2 of 13)
                        NONCONVENTIONAL POLLUTANTS

Plant
1
3
5
6
7
8
9
9
11
13
15
18
20
20
20
21
22
26
26
28
29
COD
Influent
mg/1
429
5870*
9740
436*
4290*
5250*
137*
1480
1550*
1600*
2382*
5800*
NA
2450
4900
2191*
5250
2630*
2830*
4500*
14000*

Effluent
mg/1
299
2320*
3390
127*
1280*
NA
60.3*
537
160*
290*
NA
NA
515
NA
NA
394*
NA
519*
336*
770*
NA

Percent
Removal
30.3
60.5
65.2
70.9
70.2
NA
56.0
63.7
89.7
81.9
NA
NA
NA
NA
NA
82.0
NA
80.3
88.1
82.9
NA

Plant
1
1
3
8
26
26






Plant


3
13





Influent
ng/1
110*
122*
1810*
3230*
900*
3680*





Influent
mg/1


7430
NA




TOC
Effluent
mg/1
104*
NA
621*
NA
100*
136*




TOD
Effluent
mg/1


3094*
408*





Percent
Removal
5.45
NA
65.7
NA
88.9
96.3





Percent
Removal


58.4
NA




NA = Not available
 * = Data for comingled waste stream
                                        VI-89

-------
Table VI-17.  Biological  Treatment  Operating Preproposal Data  (Continued,
Page 3 of 13)


                        MANUFACTURED PESTICIDES


Plant
1
1
2
2
3
3
3
3
3
3
3
3
3
3
3
3
3
3
4
4
4
4
4
4
4
5
5
6
6
7
7

NA •
ND "
+ •
* .
t •
Pesticides
Influent Effluent Percent
mg/1 mg/1 Removal
NA 0.0452 NA
NA 0.0452 NA
1.56 0.101 93.5
12.2 <0. 00183 >99.9
0.00213 0.00175 17.8
0.00846 0.00149 82.4
0.615 0.0554 91.0
<0.684 0.533 22.1
<3.67 <1.62 55.9
<4.93 <4.17 15.4
<6.32 <4.19 33.7
<6.64 <4.31 35.1
<7.67 <4.67 39.1
<8.51 <5.37 36.9
<15.8 <14.5 8.23
<17.7 <18.4 +
<23.5 <27.0 +
45.9 0.184 99.6
0.023 <0.01 >56.5
0.120 0.05 58.3
0.20 <0.0001 >99.9
0.470 <0.010 >97.9
0.240 <0.0001 >99.9
1.11 0.011 99.0
3.00 <0.010 >99.7
0.084 0.0093 88.9
0.0507 0.0169 66.7
12.2t <0.01t >99.9
12. 2t <0.01t >99.9
<0.010 <0.010 NA
0.019 0.027 +

Not avlalable
Not detected
Concentration Increased
Data from comlngled waste stream
Hydrolysis and biological oxidation
Pesticides (Continued)
Influent Effluent
Plant
7
7
7
7
7
7
7
7
7
7
7
8
9
9
9
9
9
11
11
11
11
11
11
13
13
13
13
13
13
13
13
13




mg/1
<0.0336
0.0817
0.0918
0.189
0.439
0.753
<0.820
<0.850
1.03
3.02
3.58
1100
NA
NA
NA
NA
<0.10
3.56
13.8
18.0
30.3
104
136
0.207
1.48*
1.48*
19.9
29.0
180
6.84
2.80
26.2




mg/1
<0.0394
0.067
0.0197
0.148
0.0836
0.0946
<0.254
<0.105
<0.129
0.0685
0.49
114
<0.012
<0.011
<0.5
<0.01
<0.10
2.08
10.3
0.012
NA
NA
NA
0.164
0.783*
0.783*
3.20
<1.0
1.67
<0.279
0.255
15.3




Percent
Removal
+
18.0
78.5
21.7
81.0
87.4
69.0
87.6
87.5
97.7
86.3
89.6
NA
NA
NA
NA
NA
41.6
25.3
99.9
NA
NA
NA
20.8
47.1
47.1
83.9
>96.5
99.1
>95.9
90.9
41.6




treatment combined
                                        VI-90

-------
Table VI-17.  Biological  Treatment  Operating  Preproposal Data  (Continued,
Page 4 of 13)
                        MANUFACTURED  PESTICIDES  (Continued)
Pesticides (Continued)
Plant
13
13
16
16
20
20
20
21
22
26
26
26
26
26
26
26
28
Influent
mg/1
292
326
MA
NA
NA
NA
NA
0.58*
NA
3.63
3.05*
3.05*
0.979*
0.979*
9.40*
5.90*
16.0
Effluent
mg/1
1.40
<2.0
0.023
0.023
<0.05
<0.05
<0.2
0.35*
<1.0
0.88
0.378*
0.378*
0.362*
0.362*
0.170*
0.080*
10.0
Percent
Removal
99.5
>99.4
NA
NA
NA
NA
NA
39.6
NA
75.7
87.6
87.6
63.0
63.0
98.0
98.6
37.5
NA = Not available
ND = Not detected
 * = Data from comingled waste stream
                                                VI-91

-------
Table VI-17.  Biological  Treatment  Operating  Preproposal Data  (Continued,
Page 5 of 13)


                          VOLATILE  AROMATICS
Benzene

Plant
3
4
4
6
7
26
26



Tnf Tuent
mg/1
2.68*
0.220*
52.0*
0.07
0.057*
<0.050
0.005*



Effluent
mg/1
<0.01*
<0.01*
NA
0.005
0.16*
<0.050
ND*



Percent
Removal
>99.6
>95.4
NA
92.9
+
NA
NA




Plant
3
4
6
7
10
13
13
25
26
26
Chlorobenzene

Plant
4
4
4
6
9
13
13
26
Influent
mg/1
<0.005*
3.0*
135.0*
0.3*
ND*
3.80*
5.0*
ND*
Effluent
mg/1
NA
<0.01*
NA
0.76*
ND*
<0.01*
<0.02*
ND*
Percent
Removal
NA
>99.7*
NA
+
NA
>99.7
>99.6
NA

Plant
4
10
13





Toluene
Influent
mg/1
15.3*
5.40*
0.10*
0.21*
0.00103*
1.4*
7.42*
<69.3
<0.20*
0.150*
Effluent
ing /I
<0.01*
<0.01*
0.009*
0.021*
0.0347*
ND
<0.01*
<9.6
<0.20*
0.005*
Percent
Removal
>99.9
>99.8
91.0
90.0
+
NA
>99.9
86.1
NA
96.7
Ethyl benzene
Influent
mg/1
7.90*
<0.001*
0.20





Effluent
mg/1
ND
<0.001*
<0.01





Percent
Removal
NA
NA
>95.0





NA = Not available
ND = Not detected
 * = Data from comlngled waste stream
 + = Concentration increased
                                        VI-92

-------
Table VI-17.  Biological Treatment Operating Preproposal  Data (Continued,
Page 6 of 13)
                          VOLATILE AROMATICS
         1,2-Dichlorobenzene
                     1,3-Dichlorobenzene
        InfluentEffluentPercent             InfluentEffluentPercent
Plant    mg/1      mg/1      Removal     Plant    mg/1       mg/1       Removal
        0.023*    <0.01*t
>56.5
0.410*    0.013*
96.8
                                 1,4-Dichlorobenzene
                                InfluentEffluentPercent
                        Plant    mg/1       mg/1       Removal
                                 0.470*
              <0.01*t    >97.9
                                 HALOMETHANES


Plant
6
9






NA =
ND =
* =
+ =
o _
Methyl chloride
Influent Effluent Percent
mg/1 mg/1 Removal
ND ND NA
ND° ND° NA






Not available
Not detected
Data from comingled waste stream
Concentration increased
Anal v/ cio n r\1* r* r\r\f\\\ r^ &/\ r\c*r* r\ ^/\^ /\/* r\
Methyl ene chloride

Plant
4
7
9
10
11
13
26
26



i
Influent
mg/1
0.260*
0.55*
<0.464*
<0.001*
0.017*
76.0*°
0.030*
<0.25*




Effluent
mg/1
0.190*
0.24*
<0.10*
0.172*
0.020*
<1.1*
0.010*
0.100*




Percent
Removal
26.9
56.4
78.4
+
+
>98.5
66.7
60.0




     Data from combined dichlorobenzenes:  1,2; 1,3; 1,4,
                                        VI-93

-------
Table VI-17.  Biological  Treatment  Operating  Preproposal Data  (Continued,
Page 7 of 13)
                          HALOMETHANES  (Continued)
Chloroform

Plant
3
4
4
4
6
7
7
9
10
13
13
26
26
Influent
mg/1
0.0149*
0.022*
0.120*
2.8
0.017
0.04*
0.20*
<0.571*°
<0.001*
0.455*
0.867*
0.080*
<0.80
Effluent
mg/1
<0.01*
NA
0.032*
NA
<0.01
0.06*
NA
ND*
<0.001*
<0.01*
<0.01*
0.020*
<0.30
Percent
Removal
>32.9
NA
73.3
NA
>41.2
+
NA
NA
NA
>97.8
>98.8
75.0
62.5
Carbon tetrachloride
Influent Effluent Percent
Plant mg/1 mg/1 Removal
4 1.00* 0.270* 73.0
13 Trace Trace NA











                                   CYANIDE
Cyanide

Plant
3
3
3
7
9
13
Influent
mg/1
1.22*
2.16*
5.04
0.067*
0.0959
0.92*0
Effluent
mg/1
0.682*
0.337*
NA
0.065*
0.071
0.404*°
Percent
Removal
44.1
84.4
NA
2.98
26.0
56.1
NA = Not available
ND = Not detected
 * = Data from comingled waste stream
 + = Concentration increased
 0 = Analysis not conducted per protocol
                                         VI-94

-------
Table VI-17.  Biological Treatment Operating Preproposal  Data  (Continued,
Page 8 of 13)
                                   HALOETHERS
                      Plant
                             B1s(2-ch1oroethy1)  ether
Influent
 mg/1
Effluent
 mg/1
Percent
Removal
                                0.582    0.0527
                        90.9
                                  PHENOLS
Phenol
Plant
1
1
4
4
4
4
4
16
21
28
Influent
mg/1
NA
0.058*
0.290*
16.0
16.0
47.0*
0.270*
1100*
61.8*
0.01*
Effluent
mg/1
0.004*
4.0*
<0.01*
NA
NA
NA
0.042*
2.03*
<3.84*
0.09*
Percent
Removal
NA
+
>96.5
NA
NA
NA
84.4
99.8
>93.8
+
2-Chlorophenol
Influent Effluent Percent
Plant mg/1 mg/1 Removal
4 0.062* <0.01* >83.9
4 <0.5* NA NA








NA • Not available
 * • Data from comlngled waste stream
 + • Concentration Increased
                                         VI-95

-------
Table VI-17.  Biological Treatment Operating Preproposal Data  (Continued,
Page 9 of 13)

	PHENOLS (Continued)	
           2,4-Dichlorophenol
                                         2,4,6-Trichlorophenol
Plant
Influent
mg/1
Effluent
mg/1
Percent
Removal
Plant
Influent
mg/1
Effluent
mg/1
Percent
Removal
  4
  4
  4
  4
  7
  7
0.290*
 <5.0
 15.0*
>1000
0.002*
0.042*
 0.018*
    NA
    NA
    NA
    NA
<0.001*
 93.8
   NA
   NA
   NA
   NA
>97.6
4
4
4
4
7
0.110*
  3.0*
 <5.0
 <100
0.022*
0.180*
   NA
   NA
   NA
0.021*
   NA
   NA
   NA
 4.54
Pentrachlorophenol
Plant
Influent
mg/1
Effluent
mg/1
Percent
Removal
4-Nitrophenol
Influent
Plant mg/1
Effluent
mg/1
Percent
Removal
  4
  4
  4
 21
0.390*
  1.0*
>1000
 0.58*
 0.230*
    NA
    NA
  0.35*
 41.0
   NA
   NA
 39.6
4
5
5
6
 NO
203
174
461t
<0.01*
 10.7
<7.84
 <1.0t
   NA
 94.7
>95.5
>99.8
2,4-Dinitrophenol
Plant
Influent
mg/1
Effluent
mg/1
Percent
Removal
                                      7.91
                                       0.397
                                          95.0
NA = Not available
ND = Not detected
 * = Data from comingled waste stream
 + = Concentration increased
 0 = Analysis not conducted per protocol
 t = Hydrolysis and biological oxidation treatment combined
                                             VI-96

-------
Table VI-17.  Biological  Treatment Operating Preproposal  Data (Continued,
Page 10 of 13)

                      POLYNUCLEAR AROMATIC HYDROCARBONS
                                   Naphthalene
                               Influent  Effluent    Percent
                       Plant    mg/1       mg/1       Removal
                               0.066*
<0.01*
>84.8
                                    METALS
Copper

Plant
3
4
7
9
9
10
13
Influent
mg/1
0.204*
0.510
0.05*
0.0575
0.093*
0.065
0.53
Effluent
mg/1
0.114*
0.110*
0.06*
0.112
0.088
1.66*
0.30
Percent
Removal
44.1
78.4
+
+
5.38
+
43.4

Plant
4
7
10
13



Cadmium

Plant
3
4
7
26
26



Influent
mg/1
0.00723
0.0021
0.2
0.0003
<0. 00120



Effluent
mg/1
0.0046
0.0017
0.25
0.0001
<0. 00080



Percent
Removal
36.4
19.0
+
66.7
33.3




Plant
3
4
7
10
13
26
26
26
Influent
mg/1
0.450*
0.06
<0.0257
0.530



Zinc
Effluent
mg/1
0.400
0.13
0.187
0.120




Percent
Removal
11.1
+
+
77.4



Chromium
Influent
mg/1
0.0647
0.240*
1.0
0.060
0.280
0.041
0.048*
0.059
Effluent
mg/1
0.044
0.049*
1.1
0.033*
0.120
0.007
0.008*
0.0075
Percent
Removal
32.0
79.6
+
45.0
57.1
82.9
83.3
>87.3
* = Data from comingled waste stream
+ = Concentration increased
                                         VI-97

-------
Table VI-17.  Biological  Treatment  Operating Preproposal Data  (Continued,
Page 11 of 13)

                                   METALS  (Continued)
Lead

Plant
3
4
7
7
13
26
26






Influent
mg/1
0.0489
0.032*
0.003
0.065
0.011*
0.024
0.0243






Effluent
mg/1
0.0683
0.0038*
0.003
0.018
0.0048*
<0.001
<0.001


Plant
3
7
13
Percent
Removal Plant
+ 13
88.1
0.0
72.3
56.4
>95.8
>95.9
Nickel
Influent Effluent
mg/1 mg/1
0.331 0.286
0.45 0.45
0.140 0.024
Mercury
Influent Effluent
mg/1 mg/1
0.0008 <0.0004







Percent
Removal
13.6
0.0
82.8

Percent
Removal
>50.0












CHLORINATED ETHANES AND ETHYLENES


Plant
4
7
10
1,2-01 chl
Influent
mg/1
1.40*
0.37*
<0.0117*
oroethane
Effluent
mg/1
0.580*
0.18*
<0.069*
1,1,1-TM chl oroethane
Percent
Removal Plant
58.6 4
51.3

Influent Effluent
mg/1 mg/1
0.430* 0.022*


Percent
Removal
94.9


    Data from comlngled waste stream
    Concentration Increased
                                               VI-98

-------
Table VI-17.  Biological Treatment Operating Preproposal Data (Continued,
Page 12 of 13)

    	CHLORINATED ETHANES AND ETHYLENES (Continued)	
            Vinyl chloride
        Influent  Effluent   Percent
Plant    mg/1      mg/1      Removal
                                1,1-Dlchloroethylene
                               Influent  Effluent   Percent
                       Plant    mg/1       mg/1       Removal
        0.023*    <0.01*
           >56.5
                    1.10*
          0.041*
96.3
	l,2-trans-D1ch1oroethy1ene
        InfluentEffluent   Percent
Plant    mg/1      mg/1      Removal
                                Trlchloroethylene
                               InfluentEffluentPercent
                       Plant    mg/1       mg/1       Removal
  4     0.011*
  7      0.17*
<0.01*
 0.54*
>9.09*
0.034*    <0.01*
>70.6
                                Tet rach1oroethy1ene
                               InfluentEffluentPercent
                       Plant    mg/1      mg/1      Removal
                         4
                         7
                         7
              0.330*
               2.47*
               0.37*
             0.037*
              1.45*
               6.9*
    88.8
    41.3
                                  PHTHALATES
                             B1s(2-ethy1hexyl) phthalate
                               InfluentEffluentPercent
                       Plant    mg/1      mg/1      Removal
                                <0.01*    0.028*
    Data from comlngled waste stream
    Concentration Increased
                                        VI-99

-------
Table VI-17.  Biological Treatment Operating Preproposal  Data (Continued,
Page 13 of 13)
                                    AMMONIA	

                                Tet rach1oroethy1ene
                               InfluentEffluentPercent
                       Plant    mg/1       mg/1       Removal
                                7.24        4.4       39.2
                                       VI-100

-------
Table VI-18.  Plants Disposing All Pesticide Wastewaters by Contract Hauling*
Plant
Code
1


2
3


4
5

6

7

8
9







Pesticide
Code
A
B
C
D
E
F
G
H
I

J

K-

L
M
M
N
0
P
0
R
R
Volume
Disposed
(MGD)
0.01
0.05
0.06
0.0163
0.00055
0.00130
0.00130
0.0000154
0.000086

Nil

0.0068

0.000252
0.0001
NA
0.0009
0.0002
0.005
NA
0.0002
NA
Pretreatment
NE,GS,KS,SP
NE,GS,SK,SP
MS,NE,GS,SK,SP
NO
NE
NE
NE
NE
NE

NO

EQ,NE

NO
NE
NO
NO
NO
NO
NO
NO
NO
Disposal Site/Method
City evaporation pond
City evaporation pond
City evaporation pond
Sanitary landfill
Hazardous waste landfill
Hazardous waste landfill
Hazardous waste landfill
Sanitary landfill
Sanitary landfill
deep well injection
Sanitary landfill
deep well injection
Private waste treatment
plant
Contract incinceration
Contract incineration
Contract incineration
Contract incineration
Contract incineration
Contract incineration
Contract incineration
Contract incineration
Contract incineration
EQ = Equalization
GS = Garvity Separation
MS = Metal Separation
NA = Not Available
NE = Neutralization
NO = None
SK = Skimming
SP = Stripping
 * = Proposal Data
                                       VI-101

-------
Table VI-19.  Plants  Using Evaporation Ponds for Pesticide Wastewaters*
Volume
Plant Pesticide Disposed
Code
1

2

3
4
5
6
+
AL
CO
EQ
GS
HD
NA
NE
NO
SK
1
Code (MGD)
A 0.02
B 0.015
C 0.01
0 0.001
E 0.0072
F 0.091
6 0.002
H 0.001
* Indicates precipitation 1s
= Aerated Lagoon
= Chemical Oxidation
= Equalization
- Gravity Separation
= Hydrolysis
- Not Available
a Neutralization
= None
= Skimming
= Preproposal Data
Net
Evaporation Supplementary
(Inches/Yr) Design Pretreatment
-12 Heat HD, NE, CO, EQ
-12 Heat HD, NE, CO, EQ
-12 Aeration AL
-12 Aeration AL
-2 None GS, NE
+13 Heat SK, AL
+20 NA NO
+69 NA NE
less than evaporation











-------
Table VI-20.  Plants Disposing Pesticide Wastewaters  by  Ocean  Discharge*
Plant
Code
1





Pesticide
Code
A
B
C
D
E
F

Flow (MGD)
0.01009
0.012
0.005
0.012
0.008
0.005

Pretreatment
None
None
None
None
None
None
* = Preproposal  Data
                                     VI-103

-------
Table VI-21.  Plants Using Deep well Injection for Pesticide Wastewates*
Plant
Code
1


2

















3

4
5

6

7
8

Pesticide
Code
A
B
C
D
D, H, I, and Q Combined
Pesticide Processes
E
F
G
H
I
J
K
L
G, J, 0, and P Combined
Pesticide Processes
M
N
0
P
0
R
Pesticide intermediate
S
T
U
V
w
X
Y

Volume
Injected (MGD)
0.0072
0.0086
0.0720
MA

0.013
0.041
0.032
NA
NA
NA
NA
0.025
0.0029

0.036
NA
0.010
NA
NA
NA
Nil
0.010
NA
0.0072
0.0072
0.07
0.08
0.30
0.01

Pretreatment
NO
NO
NO
GS

GS
SE
SB
NE
GS
GS
NE
GS,NE
PF

NE;
NA
NO
NE;
NS
GS
GS,MS,GS
GS,MS,GS
NO
NE
NE
NE,PF
NE,PF
NE,PF
NE,CA,SK,GS,PF
EQ
Footnote at end of table
                                       VI-104

-------
Table Vl-21.
Plants Using Deep Well Injection for Pesticide Wastewates*
(Continued, Page 2 of 2)
Plant Pesticide
Code Code
9 Z
AA
BB
CC
DD
EE
FF
GG
HH
10 II
JJ
KK
11 LL
12 M*
13 NN
14 00

15 PP
QQ
16 RR
17 SS
TT
AP = API Type Separator
CA = Coagulation
EQ = Equalization
GS = Gravity Separation
MF = Multimedia Filtration
NA = Not Available
1C = Neutralization
NO = None
PF = Pressure Leaf Filter
SE = Solvent Extraction
SK = Skimning
* = Preproposal Data
Volume
Injected (MGD)
0.01
0.04
0.04
0.04
0.01
0.04
0.04
0.01
0.04
0.0015
0.015
0.005
0.328
0.0072
0.00125
0.014

0.073
0.0095
0.0533
NA
NA













Pretreatment
SK,GS,PF
SK,GS,PF,GS
SF,GS,PF,GS
SK,GS,PF,GS
SF,NE,GS,PF
SK,GS,PF,GS
SK,GS,PF,GS
SK,NE,GS,PF,GS
SK,GS,PF,GS
AP
AP
AP
PF
NO
NO
NE,GS,SE,GS,NE
PF
GS,PF
NE,GS,PF
GS,SK
NO
NO












                                          VI-105

-------
Table VI-22.  Treatment Technology  Selected as  Best  Performance*

                                         Number of Plant with Treatment
Treatment Unit                               BPT                BAT

Biological Oxidation1                        13                32
Chemical Oxidation1                           -                  9
Granular Activated Carbon1                     9                17
Hydrolysis1                                   5                  8
Metals Separation1                            -                  3
Resin Adsorption1                             -                  4
Steam Stripping1                              -                  8
Ion Exchange2
Membrane Processes2
Powdered Activated Carbon2                     -                  1
Solvent Extraction2                           -                  1
Ultraviolet Photolysis2
Wet Air Oxidation2
Note:  1 = Selected as best performance
       2 = Not selected as best performance
       * = Preproposal Data
                                      VI-106

-------
Table  VI-23.  Total Plants with Data and Best Performance Plants*
Treatment          Plants with Data              Priority Pollutants

Activated Carbon        13                                9
Biological Oxidation    18                               12
Chemical Oxidation       1                                0
Hydrolysis               8                                6
Metals Separation        2                                2
Resin Adsorption         4                                4
Steam Stripping          5                                3
             Total      51                               36

  = Preproposal Data.
                                        VI-107

-------
Table VI-24.  Best Performance Removal Systems for Nonconventional Pesticides by
              Treatment Technology*
Treatment
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Activated Carbon
Acitvated Carbon
Activated Carbon
Activated Carbon
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Plant Criteria
006 295% Removal or <1 mg/1
008 295% Removal or <1 mg/1
022 295% Removal or <1 mg/1
022 295% Removal or <1 mg/1
006 2.95% Removal or <1 mg/1
206 >^95% Removal or <1 mg/1
050 295% Removal or <1 mg/1
045 295% Removal or <1 mg/1
039 295% Removal or <1 mg/1
018 295% Removal or <1 mg/1
036 295% Removal or <1 mg/1
022 295% Removal or <1 mg/1
046 295% Removal or <1 mg/1
049 295% Removal or <1 mg/1
203 295% Removal or <1 mg/1
006 >95% Removal or <1 mg/1
198 295% Removal or <4 mg/1
021 2.95% Removal or <1 mg/1
028 295% Removal or <1 mg/1
028 295% Removal or <1 mg/1
148 295% Removal or <1 mg/1
Pollutant BP Average Used
2,4-D
PCNB
2,4-D
Propachlor
2,4-DB
Carbendazim/
Benomyl
Carbofuran
Deet
Trifuralin
Dinoseb
Triazines
Atrazine
Atrazine
Bentazon
Dicofol
2,4-DCE
Dioxathion
Diazinon
Parathion Methyl
Parathion Ethyl
Ethoprop
Y >99.9%
Y >99.9%
Y 99.9%
Y 99.6%
Y >99.8%
Y 99.6%
Y >99.6%
Y 99.4%
Y 99.3%
Y 96.9%
Y 96.5%
Y 96.2%
Y 68% and
<12.6 mg/1
N 47% and
166 mg/1
N 36% and
N N/A
N N/A
Y 99.9%
Y >99.9%
Y >99.9%
Y >99.9%
   Preproposal
                                           VI-108

-------
Table VI-24.  Best Performance Removal
              Treatment Technology1
                    Systems for Nonconventional Pesticides by
Treatment
Plant Criteria
Pollutant
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Hydrolysis
Resin Adsorption
Activated Carbon
Activated Carbon
Activated Carbon
032 >95% Removal or <
032 295% Removal or <
032 >95% Removal or <
032 2.95% Removal or <
032 2.95% Removal or <
032 2.95% Removal or <
032 295% Removal or <
032 295% Removal or <
027 2?5% Removal or <
032 2.95% Removal or <
034 2.95% Removal or <
198 2.95% Removal or <
034 2.95% Removal or <
034 >95% Removal or <
034 295% Removal or <
034 2.95% Removal or <
034 2.95% Removal or <
148 2?5% Removal or <
229 2?5% Removal or <
006 299% Removal or <
022 2.99% Removal or <
039 2.99% Removal or <
1 mg/1
1 mg/1
1 mg/1
1 rag/1
1 mg/1
1 mg/1
1 mg/1
1 mg/1
1 mg/1
1 mg/1
1 mg/1
1 mg/1
1 mg/1
1 mg/1
1 mg/1
1 mg/1
1 mg/1
lmg/1
1 mg/1
1 mg/1
1 mg/1
1 mg/1
Metribu:
Fensulf(
Phorate
Fenthioi
Coumaph<
Demeton
Azinpho!
Disulfoi
Parathi<
Bolstar
Cyanazii
Didxath
DBCP
Mevinph*
Naled
Stirofo!
Dichlop
Merphos
2,4-D
2,4-Did
2,4-Dicl
N-Nitroi
Activated Carbon   008 2?9% Removal or <1 mg/1

Activated Carbon   039 2?9% Removal or <1 mg/1
                               Propylamine

                               PCP

                               Phenol
 BP Average Used

      Y >99.8%

      Y >99.7%

      Y 99.5%

      Y >98.3%

      Y >98.3%

      Y >98.0%

^1    Y >98.0%

      Y >96.1%

lyl   Y >95.8%

      Y >95.0%

      N >95.0%

      N 87.4%

      N N/A

      N N/A

      N N/A

      N N/A

      N N/A

      N N/A

      Y 97.0%

tienol Y >99.9%

henol Y >99.9%

      Y 99.8%


      N 90.0%

      N 33.3%
                                        VI-109

-------
Table VI-24.  Best Performance Removal Systems for Nonconventional Pesticides by
              Treatment Technology1
Treatment
                   Plant Criteria
                             Pollutant
Activated Carbon   039 299% Removal or <1 mg/1    PCP

Activated Carbon   046 >99.0% Removal or <1 mg/1  N-Nitroso-Di-N
                                                  Propylamine

Activated Carbon   046 ^99.0% Removal or 99.0% Removal or <1 mg/1  Toxaphene
BP Average Used

     N <0.01 mg/1

     N ND


     N ND

     Y 99.3%
Resin Adsorption   023 299.0% Removal or <1 mg/1  Hexachloro-
                                                  cyclopentadiene

Resin Adsorption   023 >99.0% Removal or 99.0% Removal or 99.0% Removal or <1 mg/1  Cyanide

                                                  Copper
Metals Separation  010 295.0% Removal or £0.50
                                          mg/1

Metals Separation  050 295.0% Removal or <0.50
                                          mg/1
                                                  Zinc
Steam Stripping

Steam Stripping

Steam Stripping

Steam Stripping


Steam Stripping

Steam Stripping

Steam Stripping

Steam Stripping
                   049 290-0% Removal or <5 mg/1  Dichlorobenzene

                   229 290.0% Removal or <5 mg/1  Toluene

                   010 2.90.0% Removal or <5 mg/1  Chloroform

                   006 2.90.0% Removal or £5 mg/1  Benzene


                   006 2^0.0% Removal or <5 mg/1  Toluene
                                                  N 96.6%

                                                  Y 99.9%


                                                  Y (63.8%)
                                                  <0.12 MS

                                                  Y 97.8%

                                                  Y 95.0%

                                                  Y >92.9%

                                                  Y (42.8%)
                                                  <0.04 mg/1
                                                  Y (42.1%)
                                                  <0.04 mg/1
006 >90.0% Removal or <5 mg/1  Methylene Chloride N 99.9%
                   006 >90.0% Removal or <5 mg/1  Chloroform

                   006 290.0% Removal or <5 mg/1  Carbon Tetra-
                                                  chloride
Steam Stripping    034 290.0% Removal or <5 mg/1  Ammonia
                                                  N 98.4%

                                                  N <0.001 mg/1


                                                  N N/A
                                         VI-110

-------
Table VI-24.  Best Performance Removal Systems for Nonconventional Pesticides by
              Treatment Technology1
Treatment
                   Plant Criteria
                             Pollutant
Steam Stripping    206 >90.0% Removal or £5 mg/1  Ammonia

Steam Stripping    229 >9Q.Q% Removal or £50 mg/1 Benzene

                   048 >95% Removal or £ 50 mg/1  BOD
Biological
  Oxidation

Biological
  Oxidation

Biological
  Oxidation

Biological
  Oxidation

Biological
  Oxidation

Biological
  Oxidation

Biological
  Oxidation

Biological
  Oxidation
Biological
  Oxidation

Biological
  Oxidation
Biological
  Oxidation
Biological
  Oxidation

Biological
  Oxidation

Biological
  Oxidation

Biological
  Oxidation
041 >95% Removal or £50 mg/1   BOD


034 >95% Removal or £50 mg/1   BOD


021 >95% Removal or £50 mg/1   BOD


019 >95% Removal or £50 mg/1   BOD


022 >95% Removal or £50 mg/1   BOD


028 >95% Removal or £50 mg/1   BOD


206 X70% Removal or £586 mg/1  ODD



180 X70% Removal or £586 mg/1  ODD


032 X70% Removal or £586 mg/1  ODD



027 >95% Removal or £50 mg/1   BOD



146 >95% Removal or £50 mg/1   BOD


020 >95% Removal or £50 mg/1   BOD


039 >95% Removal or £50 mg/1   BOD


200 >95% Removal or £50 mg/1   BOD
BP Average Used

     N N/A

     N <0.299 mg/1

     Y 98.8%


     Y 98.3%


     Y >95.6%


     Y 95.0%
                                                                     Y (91.4%)
                                                                     27.1 mg/1

                                                                     Y (93.3)
                                                                     8.0 mg/1

                                                                     Y 12.7 mg/1
     Y (87.4%, 114
     mg/1 BOD)
     84.2% ODD

     Y 82%
                                                                     Y (92.1%,  73.8 mg/1
                                                                       BOD)  70.0%
                                                                       ODD

                                                                     N 57.9% 1820 mg/1
                                                                       BOD 65.2%,
                                                                       3340 mg/1 ODD

                                                                     253 mg/1


                                                                     N N/A


                                                                     N N/A


                                                                     N N/A
                                      VI-111

-------
r\3
                 t.B- •
                O.I- -

               0 001 - -
               00001
              O.OOOOt
                         ACTIVATED SLUDGE
                       AND AERATED LAGOON
 METALS  -T-
SEPAHATION f
 STEAM
STRIPPING.
                                                                              CHEMICAL
                                                                              OXIDATION
                                                                    EVAPORATION
                                        INCINERATION
                                  CONTRACT
                                   HAULING
                                                                                    PESTICIDE
                                                                                    REMOVAL
                                                                                             • - 8.11
                                             • - 0.001
                                                                                             • -0.0001
                                                                                              •.ami
                                              TYPE OF TREATMENT/DISPOSAL
              FIGURE VI-1     RANGE  OF FLOWS FOR PESTICIDE TREATMENT/DISPOSAL

-------
    FLOW DIAGRAM
          STORAGE
           DRUM
       PREHEATER
 INFLUENT
 EFFLUENT
J
HEAT
 STORAGE DRUM
                                       OVERHEAD
                                       CONDENSER
                                     SEPARATOR
                                       DRUM
                                 PUMP
                                   TO
                                   JNCINERAT10N
                                   OR RECYCLE
                                                  STEAM
                             STRIPPING
                             COLUMN
    Figure VI- 2   RECOMMENDED BAT TECHNOLOGY
                  STEAM STRIPPING
                           VI-113

-------
   FLOW DIAGRAM
CAUSTIC STORAGE
         CHEMICAL
    POLYMER
                POLYMER STORAGE
INFLUENT
               MIXING TANKS
                                             HOLDING TANK
    Figure VI- 3
RECOMMENDED BAT TECHNOLOGY
METALS SEPARATION
                         VI-114

-------
FLOW DIAGRAM
           MIXING
           TANK
INFLUENT	*
           7
CAUSTIC    CHEMICAL
STORAGE
                               STEAM
                            I * +  I I  I  I
EFFLUENT
                            HYDROLYSIS BASINS
Figure VI-
              RECOMMENDED BAT TECHNOLOGY
              PESTICIDE HYDROLYSIS
                           V1-115

-------
    FLOW DIAGRAM
        INFLUENT
                      CARBON COLUMNS
 BACKWASHED WATER
TO EQUALIZATION BASIN
                                   1
                                           BACKWASH PUMP
    Figure VI- 5   RECOMMENDED BAT TECHNOLOGY
                 CARBON ADSORPTION
                         VI-116

-------
FLOW DIAGRAM
    NEW CARBON
                                          WASH WATER
                        TO ADSORBERS
   MAKE-UP TANK   WASH TANK
  FROM ADSORBERS
JL
      DEWATERINQ
 SLURRY   TANK
 PUMPS
                FURNACE
         QUENCH
          TANK"
WASH TANK
                                 TO ADSORBERS
Figure VI- 6  RECOMMENDED BAT TECHNOLOGY
             CARBON REGENERATION
                   VI-117

-------
FLOW DIAGRAM
INFLUENl


r
i
r






	 »» BACKW ASHED WATER-*—
TO EQUALIZATION BASIN
RESIN COLUMN

i
BACKW
RESIN COLUMN
i
b-
ASH PUMPS
1
r




EF


FLUENT
Figure VI- 7   RECOMMENDED BAT TECHNOLOGY
            RESIN ADSORPTION
                     VI-118

-------
FLOW DIAGRAM
INFLUENT-
-EFFLUENT
                   AERATION BASINS
Figure V!- 8   RECOMMENDED BAT TECHNOLOGY
             AERATION BASIN
                     V1-119

-------
   FLOW DIAGRAM
INFLUENT


POLYMER
FEEDERS


POLYMER
STORAGE

i
\
H
;/
EFFLUENT
   Figure VI- 9  RECOMMENDED BAT TECHNOLOGY
               CLARIFICATION
                         VI-120

-------
  FLOW DIAGRAM
     STORAGE
INFLUENT
 VENTURI
SCRUBBER FJNAL
       SCRUBBER
AIR-*/)     _^
    FUEL STORAGE

     CAUSTIC/LIME
        STORAGE
               pH ADJUSTMENT
  Figure VI-10  RECOMMENDED BAT TECHNOLOGY
                INCINERATION
                           M1-121

-------

-------
                           SECTION VII

                  INDUSTRIAL SUBCATEGORIZATION
INTRODUCTION

The primary purpose of industry subcategorization is to establish
groupings within the Pesticides Chemicals Category such that each
group  (subcategory)  has a uniform set of effluent  limitations.
This requires that the elements of each group be capable of using
similar   treatment   technologies  to   achieve   the   effluent
limitations.   Thus,  the  same wastewater treatment and  control
technology  is  applicable  within a subcategory  and  a  uniform
treated  effluent  results  from the application  of  a  specific
treatment  and  control technology.   This section  presents  the
subcategorization   established  for  the  Pesticides   Chemicals
Category and explains the selection rationale.


Proper  industry  subcategorization  defines  groups  within   an
industrial  category whose wastewater discharges can be contolled
by  the  same  concentration  or  mass  based  limitations.   The
subsections  which follow deal with these considerations as  they
apply to the Pesticides Chemicals Category.


CATEGORIZATION BASIS

The  following aspects of the Pesticides Chemicals Category  were
considered for the bases of establishing subcategories:

     1.   Product type
     2.   Manufacturing process
     3.   Raw materials
     4.   Dominant Product
     5.   Geographic location
     6.   Plant size
     7.   Plant age
     8.   Non-water quality characteristics
     9.   Treatment cost
    10.   Energy cost


After  examination of the potential categorization  bases,  three
pesticides subcategories were established.  These are:

     Subcategory 1 - Organic pesticide chemical manufacturers

     Subcategory 2 - Metallo-organic pesticide chemical
                     manufacturers of mercury, cadmium, copper,
                     and arsenic - based products
                               VII-1

-------
     Subcategory 3 - Formulator/packagers of pesticide chemicals


The  primary  bases for subcategorizing plants in  this  industry
were found to be dominant product type,  manufacturing processes,
and raw materials used.


Product Type


Product  type is the primary difference between organic pesticide
manufacturers  and metallo-organic pesticide  manufacturers.   In
the  manufacture  of organic pesticides,  metals may be  used  as
catalysts  but  are not a component of the  end  product.   Metal
atoms  are significant components of metallo-organic  pesticides.
Because of the product difference,  raw waste characteristics are
also  different,  because  the process wastewater  from  metallo-
organics  pesticide chemicals would contain large  concentrations
of metals,  whereas the process wastewater from organic pesticide
chemicals would not.
Manufacturing Process


Typically,   organic  pesticide  chemicals  and   metallo-organic
pesticide  chemicals are manufactured for captive or merchant use
in  four  or  more  chemical reaction  steps  starting  from  raw
material to final product.  Two or more different products  might
use  the  same process but then the raw materials  used,  process
sequence,  control,  recycle  potential,  handling,  and  quality
control will vary, producing wastes of different quality.


Pesticide  chemicals  formulating  and packaging  is  a  physical
mixing  of a finished pesticide active ingredient with  an  inert
material  and the subsequent packaging of that mixture for  sale.
Any chemical reaction that might occur are coincidental.   Hence,
pesticide   chemicals   formulating  and  packaging  process   is
significantly  different  from the  organic  and  metallo-organic
chemicals  manufacturing  processes.    Therefore,  manufacturing
process is used as a basis for subcategorization.


Raw Materials
The different products are produced from different raw materials,
but  the  primary  difference is that  metallo-organic  pesticide
chemicals  have  metallic compounds  as  raw  materials,  whereas
organic  pesticide  chemicals do not.   This difference leads  to
differences  is raw waste characteristics,  and is essentially  a
consequence of the different product types.
                               VII-2

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Geographical Location


Pesticide chemical plants exist in all parts of the United States
but   subcategorization  on  this  basis  is   not   appropriate.
Geographical  location is important in analyzing the  feasibility
of   various  treatment  alternatives.    Evaporation  ponds  are
functional  only  in areas where  evaporation  exceeds  rainfall.
Ocean dumping and deep well disposal are possible only in certain
areas, and must be consistent with local, state and federal laws.
The  possibility  of ground water contamination may preclude  the
use of unlined holding and settling ponds in many locations.


In the northern regions,  climatic conditions may necessitate the
inclusion of special provisions to prevent freezing of  treatment
system  components,   particularly  biological  oxidation  units,
clarifiers,  ponds,  and  open collection systems.   The costs of
utilizing  waste  heat  sources from  the  process  or  providing
various types of thermal protection, such as insulation or burial
of  pipes  and tanks and building structural  shelters,  may  add
considerably  to  the  capital  and O&M cost  associated  with  a
treatment technology.


Thus,  the influence of geography,  climate,  geology,  etc.,  is
reflected in wastewater treatment modifications and is  primarily
manifested in the cost of treatment.   This,  of itself, is not a
good basis for subcategorization.


Dominant Product
Subcategorization  by  chemical  name of  the  dominant  chemical
produced  involves the least ambiguity in applying standards to a
given  point  source.   There is great variety  of  product  mix,
manufacturing  processes,   wastewater  constituents,  and  other
factors at existing plants.  Subcategorization by product becomes
less useful as product mix increases in complexity because multi-
product wastewater also becomes more complex and less susceptible
to simple uniform treatment.


A  subcategory  established on the basis of product  manufactured
might have two or more different processes but,  in the  majority
of  cases,  the  characteristics  of the  wastewaters  should  be
similar  and  the  same treatment technology can be  applied  for
different  process  wastewaters.    In  the  pesticide  chemicals
category, there are a very large number of products produced, but
most   are  produced  at  only  one  or   two   plants.    Hence,
subcategorization  based on product would yield a large number of
subcategories, most with only one or two plants.  This would be a
very complex regulatory approach.


                               VII-3

-------
The Agency,  at proposal,  attempted an alternate approach  where
the  dominant  products  were grouped together based  on  similar
pollutants in the untreated wastewater.   However,  this approach
was  found to be needlessly complicated and  unnecessary  because
the  Agency  found  that  it could apply a  uniform  approach  to
developing regulations based on a general model treatment  system
for  each  product  type (organic or  metallo-organic  pesticide)
while  incorporating  the flexibility needed  for  the  different
dominant   products  within  each  product  type.    Hence,   the
subcategorization is not based on dominent product.


Plant Size
Plant  size and production capacity were not found to affect  the
characteristics of the wastewater produced.   Although plant size
can  affect  treatment cost,  this variability can  be  expressed
graphically  or  mathematically  without  the  need  for  further
segmentation of the category.


Plant Age


Plant age can have an important bearing on wastewater volume  and
quality  and is,  therefore,  a significant factor to consider in
evaluating  the  applicability  of  treatment  technologies   and
assessing  the  relative costs of treatment for plants of  widely
differing  age  producing  the  same  or  similar  products.    A
particular  problem  with  older plants  is  that  their  present
patterns of water use may have evolved over a long period of time
with  little consideration for the principles of efficient  waste
segregation,  collection,  and  treatment.   To a limited degree,
plant  modernization  can correct or at least  mitigate  some  of
these  shortcomings in older facilities,  however,  only a  small
proportion  of  the  cost of revamping collection systems  or  of
converting  from  contact to noncontact cooling  systems  can  be
offset  by  the resulting lower cost of treatment.   In  general,
older  plants,  even after considerable  modernization,  normally
have a higher volume of wastewater flow and higher waste loadings
(although  pollutant  concentrations  may be lower  due  to  poor
segregation from noncontact sources) in comparison to  relatively
new plants.  Pollution control requirements could impose a severe
treatment  cost  penalty  on  older plants due to  the  need  for
backfitting and replumbing of outdated collection systems.   Land
availability and land use restrictions are also factors which may
translate into higher treatment costs for older facilities  which
find  themselves  surrounded by highly developed  industrial  and
residential areas.
                               VII-4

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Unfortunately,  plant  age  does  not readily lend itself  to  an
unambiguous definition where a series of plant modifications  has
taken  place.   The  extent of modifications also varies  greatly
among plants within the same product industry.  For those  plants
that  have been enlarged or modified from their original  status,
plant  age is not unambiguously calculable and therefore is not a
reasonable basis for subcategorization.


Non-Water-Quality Characteristics


Airborne  emissions  from manufacturing operations  can  be  kept
within  air  quality control limits through the use of  cyclones,
wet scrubbers and other methods.  The nature of the air pollution
is related to the product(s) manufactured and/or the raw material
used.   As  discussed  in  Chapter  VI,  most  metals,  including
arsenic,  cadmium,  and copper, can be incinerated with the metal
bearing ash safely collected,  because neither the metal nor  its
metal  oxide  incineration products  are  volatile.   Hence,  the
metal-bearing ash is collected by scrubbers,  cyclones,  or other
air pollution control device.  By contrast, mercury is a volatile
metal,  hence  incineration  of process wastewater from  mercury-
organic  pesticide manufacturing could result in release  of  the
mecury  to  the  environment  through  the  incinerator  exhaust.
Therefore,  the  metallo-organic pesticide chemicals  subcategory
was further subdivided into two segments.


The  pretreatment  standard  for the  mercury  organic  pesticide
chemical  manufacturing  segment is different from the  standards
for  the  arsenic,  cadmium,  copper organic  pesticide  chemical
segment.   Although the Agency did not subcategorize on the basis
of  non-water-quality  characteristics,   the  non-water  quality
characteristics   are  reflected  in  the  varying   pretreatment
standards.
Treatment Cost


From   a  technical  viewpoint,   subcategorization   by   common
technological  requirements for treatment processes could provide
a  logical  basis  for selecting one or more  unit  processes  to
accomplish the same treatment function,  regardless of the source
of   the  wastewater.     This  "building  block"  concept   could
conceivably  result  in selecting various  combinations  of  unit
processes  to  meet the treatment  requirements.   However,  this
method  of  subcategorization crosses product lines  and  product
types.   Even  if the  unit operation is commonly  applicable  for
treating  wastewater  flows of different products,  the  cost  of
treatment  will  fluctuate  because of variations  in  wastewater
quality,  loading  and flow rates,  and subcategorization on  the
basis of treatment cost is not recommended.
                               VII-5

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Energy Cost
The  energy costs for treatment are related to the  product  type
and  treatment  costs.    Manufacturing processes in  the  organic
pesticide   chemicals   industry  typically  have  large   energy
requirements.     In  contrast,    wastewater  treatment  processes
consume a small fraction of the total energy used.  There appears
to  be  no  major energy requirements  for  wastewater  treatment
facilities.    By  contrast,   in  the  metallo-organic  pesticide
chemical (except mercury organic pesticide chemicals segment) and
pesticide chemicals formulating and packaging subcategories,  the
cheapest  technology  for  most plants in  contract  hauling  and
incineration  which  does involve energy  costs.   When  balanced
against other  costs, however,  these costs are less than the costs
of any other treatment  technology.    Therefore,  subcategorization
on the basis of energy  cost is  not  justified.
                               VII-6

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                          SECTION VIII

           COST, ENERGY, AND NONWATER QUALITY ASPECTS


The  purpose of this section is to document the cost, energy, and
nonwater quality  aspects  of  recommended  treatment  technology
presented in Section VI.


COST AND ENERGY


Pesticide Manufacturers

The costs presented in this section are estimates of the capital,
annual,  and  energy expenses which could potentially be incurred
to  meet the design effluent levels presented in Sections XI  and
XIII for pesticide manufacturers.  These estimates are  therefore
the  incremental costs above and beyond BPT.


The general costing analysis methodology is outlined as follows:

     a.   Development of treatment technology cost curves

     b.   Evaluation of the characteristics of each individual
          waste stream for each manufacturing plant

     c.   Determination of pollutants removal percent
          requirements based upon effluent monitoring data and
          the proposed effluent long-term average limitations

     d.   Selection of treatment technologies

     e.   Determination of treatment technology costs

     f.   Determination of monitoring costs

     g.   Determination of compliance costs associated with
          Resource Conservation and Recovery Act (RCRA)
          requirements.

The  costs   presented here represent  the   expenditures   which
would   be  required  to treat detected and  indicated  priority,
conventional, and nonconventional pollutants.  The plant-by-plant
treatment cost estimates were based on the following criteria.


1.   For those plants with effluent data exceeding BAT levels for
priority  pollutants  and for pesticides projected  treatment  to
bring  the plant into compliance with the appropriate  regulation
was costed.
                              VIII-1

-------
2.    For those plants without effluent data,   it was assumed that
pollutants  germane  to each process exist at  effluent levels  in
excess of the design levels and appropriate treatment was  costed
accordingly.


3,    Plant waste streams requiring similar treatment were assumed
to use common treatment units.
4.    Pesticide   costs   were  based  on  individual   pesticide
wastestream  flow  data.   Where individual wastestream  flow was
unavailable, the total plant flow was assumed for costing.


It  should  be noted that treatment cost estimates  may  in  some
cases be overestimated due to such factors as:
1.    Treatment costs for large activated  carbon facilities were
based  on  the  purchase  of  the  activated  carbon  system  and
regeneration facilities.  This is more expensive than the leasing
of activaed carbon systems which is prevalent inthe industry.


2.    Contract hauling has been costed to handle hazardous waste.
Disposal  costs  may  be cheaper if wastes are determined  to  be
nonhazardous.
The  Agency does not require that these recommended BAT  or  PSES
technologies  be installed at any plant  location;   however,  the
application of these technologies will attain the design effluent
levels.   Individual  plants have the option of utilizing process
modifications,  in-plant controls, alternate methods of disposal,
alternate end-of-pipe treatment units,  or any combination of the
above in order to achieve equivalent effluent levels.   A  plant-
by-plant cost analysis has  been conducted in order to assess the
potential economic impact of installing the recommended treatment
to  meet design effluent levels.   This analysis is  confidential
and is in a separate section of the record.   The procedure is in
Economic  Impact Analysis of Effluent Limitations Guidelines  and
Standards for the Pesticide Cher.lcal Industry,  EPA-440/2-85-027,
September 1985.


The  cost estimates for pesticides manufacturers are presented on
a plant-by-plant basis.  They show the costs potentially incurred
by  model  plants  of  various  flows  and  differing   pesticide
treatability.  They were derived in he following manner:


1.    Costs  were generated for each treatment unit  specified in
Section  VI based on August 1983 dollars and corresponding  to  a
Marshall  and Swift Index value of 592.   The capital and  annual


                              VIII-2

-------
cost  assumptions for these computations are presented in  Tables
VIII-1 and VIII-2.  The basis for these assumptions is documented
in  Supplement B to the Administrative Recrod for the regulation.
The  total  construction costs for each unit were  prepared  from
equipment manufacturers' estimates which were compared to  actual
plant data when available.   The total construction costs include
the   treatment   unit   cost,    land,    electrical,    piping,
instrumentation,  site preparation,  engineering, and contingency
fees.  Annual and energy costs were calculated in accordance with
the assumptions specified.  Cost curves were prepared for dollars
versus volume treated, and each of the components included in the
individual treatment units was specified.   These cost curves are
presented graphically in Figures VIII-1 through VIII-19.


2.    A  summary of the plant-by-plant treatment technology costs
is presented in Table VIII-3.   The total capital,  land,  annual
and energy costs for each plant were derived by summing the costs
for individual treatment units that are specified for each  level
of control recommended in Sections XI thru XIV.
Each  plant in subcategory one has been costed and evaluated  for
their  ability  to incur incremental monitoring costs  associated
with these regulations.   The Agency assumed plants would monitor
for  priority pollutants and nonconventional pesticides  one  per
week  as   a cost of $1,125.   The annual cost for monitoring  is
$54,000 per plant.   However,  the summary costs for  subcategory
one  only  include  the monitoring costs for the  42  direct  and
indirect  plants incurring other treatments costs as a result  of
this regulation.   In addition,  nine subcategory one plants were
costed  based on the requirements under the Resource Conservation
and Recovery Act (RCRA).


                   Summary  Cost

                            Annual        Capital

Treatment Costs              49.712      105.18

RCRA Costs                     .453

Monitoring Costs              2.189
    Total Costs              52.354      105.18

The  cost of compliance with the regulation also includes  plant-
by-plant   costs  for  monitoring  and  costs   associated   with
requirements  under  the Resource Conservation and  Recovery  Act
(RCRA).
                              VIII-3

-------
Metallo-Organic Pesticide Manufacturers


For  the Metallo-Organic Pesticide manufacturers,  the Agency  is
promulgating  a  no  discharge of pollutants  standard  for  PSES
except   for   manufacturers  of  mercury-based   metallo-organic
pesticides.   The pretreatment standard for mercury would  affect
one facility that manufactures mercury metallo-organic compounds.
This  one facility has a discharge of approximately 3,000 gallons
per day of untreated process wastewater containing an average  of
approximately 2,000 mg/1 of mercury.  This facility currently has
a  pilot plant pretreatment system using zinc oxide precipitation
that  is  demonstrating 99.99 percent  removal.   The  Agency  is
basing the regulation for mercury on this plants treatment system
(see  Section VI).  The estimated capital,  annual O&M and  total
annual  costs for mercury waste treatment for this specific plant
are approximately $47,000,  $119,550 and $129,800,  respectively.
Although residual zinc may appear in the effluent,  the Agency is
excluding  zinc  from regulation under paragraph 8(a)(i)  of  the
Settlement Agreement because only one facility is affected.


For  the  plants  that are required to achieve  no  discharge  of
detectable   amounts   of   pollutants   contract   hauling   and
incineration,  is recommended.   Typical cost ranges for contract
hauling are presented in Table VIII-4.


Pesticide Formulator/Packagers


The costs presented in this section are estimates of the  capital
and  annual expenses which could potentially be incurred to  meet
the no discharge requirements for pesticide formulator/packagers.
Plant-by-plant  costs  were  developed  for  a  set  of  randomly
selected    formulator/packagers.     These   costs   were   then
extrapolated     to    the    estimated    total    number     of
formulating/packaging plants.   Discussed here are (1) costs  for
low  flow  plants,  (2)  costs for high flow plants and  (3)  the
extrapolation of costs to the universe of formulator/packagers.


1.    EPA  received  40 questionnaires from  the  industry  which
contained   sufficient   information  to  provide  a   means   of
correlating  specific  information  with flow  data.   This  data
included  plants that were not randomly selected but  volunteered
information to EPA.   Several of the 40 plants were contacted  by
EPA  so  that site-specific anomalies could be  evaluated.   Four
plants  discharge  wastewater volumes that  were  over  1,000,000
gallons  per year while the remaining plants typically  discharge
less than 200,000 gallons per year.  The high flow plants tend to
use proportionally more water as a solvent,  produce more product
lines,  and  operate more weeks per year.   Lack of economies  of
scale  favor  contract  hauling as the method of  achieving  zero
regulated  pesticide pollutant discharge at the low flow  plants.


                              VIII-4

-------
Wastewater  treatment  and  reuse  is  a  demonstrated  means  of
achieving zero discharge at both low and high flow plants.


Compliance   costs   were   calculated  for  each   of   the   40
formulator/packagers  that  submitted  a  questionnaire  and   is
currently   an  indirect  discharger.    Plants  that  discharged
pesticide-bearing  waste  streams less than 200,000  gallons  per
year  were  costed differently than the 4 plants  that  discharge
higher   flows.    Contract  hauling  and  incineration  was  the
technology selected for the low flow plants.   Capital and annual
costs  are  based  on  the  cost  of  low  volume  waste   stream
segregation,    collection,   storage,   contract   hauling   and
segregation,    collection,   storage,   contract   hauling   and
incineration.   Segregation,  collection,  and  storage costs are
estimated below for a typical low flow formulator/packager.  This
system would be installed in addition to existing  systems.   The
existing  systems  would be used to collected  unregulated  waste
streams,  such  as sanitary wastes.   Piping costs are tripled to
reflect  the  cost of retrofit.   Unit costs are based  on  Means
Construction Cost Data, 1982.  System cost are as follows:

                                Installed
           Item             Unit Cost       Total Cost

250 Feet of 2-inch, schedule
 40  galvanized steel pipe      $10.80/foot    $8.100 ($2,700  x 3)

6-Sewage ejector pumps, cast
 iron 110 gallon per minute,
 1/2 horsepower                 $l,200/each         $7,200

1-5000 Gallon steel storage     $3,850/each         $3,850
                                           Total = $19,150

The  total installed cost of $19,150 is equivalent to $19,700  in
1985  dollars  based  on Engineering  News  Record   indices  for
chemical  engineering plant costs.   A rounded,  capital cost  of
$20,000 per plant is conservatively estimated for segregating and
collecting  formulator/packager wastestreams at low flow  plants.
The  annualized  cost is $4,360 if a 0.218 factor is used for  10
year period at a 13 percent interest rate.


Several plants exhibit flows less than 2,500 gallons per year (10
gallons  per  day).   Manual  collection methods  would  be  more
appropriate at these plants.   For these very low flow plants the
following assumptions can be made:   One 55 gallon drum could  be
manually  filled  at  a cost of $14 per drum  for  labor;  and  a
storage   shelter   (3'x9'x8<),   for  the  drums,   would   cost
approximately $2,000 based on Means Construction cost Data, 1982.
The annualized cost is $436, if a factor of 0.218 is used.
                              VIII-5

-------
In  response  to the June  13,   1984,   Federal  Register  notice,
commenters  reported  a  range  of contract  hauling  costs.   The
Chemical  Specialities Manufacturers Associated (CSMA) reports  a
$2  to $3 per gallon cost for the contract hauling  of  hazardous
liquid waste.  The Small Business Administration reports a $2 per
gallon  incineration  cost.    Several  plants estimated  that  the
contract  hauling could approach $3 to $4 per  gallon.   However,
plants  that  currently incinerate  pesticide-bearing  wastewater
state  that their operating  and investment costs are less than $1
per  gallon.   A  $2.50 per  gallon contract  hauling  cost  which
includes incineration in a RCRA approved incinerator is judged to
be  a  reasonable estimate of an industry-wide cost for the  year
1985.   Plant-by-plant  capital  and annual costs are  listed  in
Table VIII-5.


2.    The four high flow plants have either demonstrated or  said
they  would use the reduction and reuse technologies utilized for
this regulation.  A large percentage of the discharged wastewater
can  be  treated  to  acceptable  levels  for  reuse.   Treatment
technologies  have  been  evaluated  and costed  by  EPA  in  the
proposed Development Document.    Table VIII-8 and VIII-9 of  that
document  list  unit  operations  associated  with  the  proposed
manufacturer's Subcategory Two,  Level One treatment costs.   The
unit   operations   listed   are  typical  of   reuse   treatment
technologies.   Included  are unit processes for the disposal  of
treatment  wastes  from filtration and  carbon  regeneration.   A
range of costs is given for  treating the respective 0.01 MGD  and
0.1 MGD design flows.  For estimates prepared here, the high cost
value  is assumed to apply.    Use of the high value accounts  for
any  inflation cost indexing necessary to adjust 1979 dollars  to
1985  dollars.   A  contract hauling cost of $2.50 is applies  to
those  internal wastestreams that plant personnel state  are  not
suitable  for reuse.   The cost of segregating and collecting PFP
wastestreams  is  $1,4000,000  which  is  based  on   information
supplied by plant No. 7.


In  addition  to  the  segregation  and  collection  system  cost
reported by plant No. 7,  the cost of  returning treated water for
reuse must be considered.   The following costs apply for treated
water storage and return:


                            Installed                 Total

       Unit                 Unit Cost                 Cost

1500 feet, 2 inch schedule
40, galvanized steel pipe    $10.80/ft               $16,200

400 feet, 4 inch, schedule
40, galvanized steel pipe    $24/ft                  $ 9,600

50,000 gallon tank (5,000


                              VIII-6

-------
gal = $3,850;                estimate                $25,000
210,000 gal = $57,000)

Foundation Mat (100 cubic
yards)                       $15/C.Y.                $ 1,500

Ground Slab (6" thick, 500
sq. ft.)                      1.93/S.P.              $   965
                                                     $53,265


This  total installed cost corresponds to a $55,000 cost in  1984
dollars.   Therefore,  the  total  capital cost  of  segregation,
collection and return piping and storage systems is $1,455,000.


Since a typical high flow plant uses about 7,000,000 gallons  per
year,  some  cost  savings will result if recycled water is  used
instead of city water.   Based on a city water cost of $0.005 per
gallon,  an average savings of $35,000 is realized.  Table VIII-6
is a breakdown of costs for the 4 high flow plants.


3.     The   cost  of  achieving  zero  discharge  at   the   169
formulator/packager  plants  may be extrapolated from the  random
sample of 28 plants.  Since costs are available for the 12 plants
which volunteered information,  these are subtracted from 169  to
yield  157.   The  subtotal annual and capital costs for  the  28
plants  is  multiplied by the ratio 157/28,  below,  to yield  an
extrapolated  cost.    The  cost  for  the  12  plants  is   then
conservatively  added  to the extrapolated cost to provide  total
capital and annual costs.


                              Annual Cost       Capital Cost

1.  28 Randomly Selected
     Plants                   $2,456,000          $ 2,818,000

2.  Extropolated Cost         13,775,365           15,800,929

3.  12 Non-randomly
     Selected Plants           3,187,973            6,759,000
4.  Sum of Items 2 and 3     $16,963,338          $22,559,929


The  Agency  continued  their  solicitation  of  information   by
requesting additional information in the January 24,  1985 Notice
of Availability.   The Agency stated,  at that time,  that it was
considering  setting  formulator/packager  regulations  equal  to
manufacturer's  pretreatment  standards.   The industry  did  not
submit sufficient data or information to support this alternative


                              VIII-7

-------
on   a  technological  or  economic  basis.    If   manufacturers
pretreatment  standards  were  established  for  PFP  plants,  96
percent  of  the  169  indirect discharge plants  would  find  it
cheaper  to  comply  with  the  regulation  by  contract  hauling
followed by incineration,  rather than build a separate treatment
system  for  the  PFP flow to  meet  the  pretreatment  standard.
Consequently,  those  plants  would  achieve  zero  discharge  of
process  wastewater pollutants.   Some of remaining 4 percent  of
the  163  indirect  dischargers  with high flows  would  find  it
cheaper  to recycle and reuse the treated wastewater rather  than
discharge  because  for  those plants the savings  in  water  and
monitoring  costs would outweigh the costs for  additional  pumps
and  piping  to recirculate the treated water for  reuse.     The
other  high  flow  plants  may find it  cheaper  to  treat  their
wastewater  using  the technology upon  which  the  manufacturers
pretreatment  standards are based and then discharge rather  than
recycle   the  treated  wastewater  to  meet  a  zero   discharge
requirement.


NONWATER QUALITY ASPECTS


The potential contamination of gaseous,  liquid, and solid wastes
will be   restricted   to   those   areas  directly  affected  by
the  implementation of technology recommendations  contained   in
this report.


Air Quality


Incineration  has  been  recommended  as a means for disposing of
organic  liquids and nonrecoverable  solvents.    The incinerator
design    recommended    in   this  study  is  a  RCRA   approved
incinerator  which provides for the scrubbing of  off-gases  with
caustic  or lime,  should there be hydrogen chloride gas present,
or  with  water in cases where nonchlorinated liquid  wastes  are
being fed to the incinerator.   Given the proper temperature  and
dwell  time in the combustion chamber,  greater than 99.9 percent
removal  of pesticide active ingredients can be  maintained  (See
Section  VI)  so  that a potential air pollution problem  is  not
created.   Incineration,  if properly designed with air pollution
control  device,  can  be  an affective means  for  disposing  of
organic  solvent and pesticides.   However,  incineration is  not
applicable  to  organic  pesticides wastewaters  containing  high
levels of mercury.


Gaudy and Kincannon (1982) studied the treatment compatability of
municipal waste and 24 biologically hazardous compounds to assess
the effects of priority pollutants on the performance of open and
closed  activated sludge treatment systems.   Based on  the  data
from  the  three  types of open reactor  studies,  Strier  (1985)
concluded  that  fourteen  compounds are removed  mostly  by  air


                              VIII-8

-------
stripping,  four  are  removed mostly by sorption,  and  six  are
mostly biodegraded.


Specifically,  in batch reactor studies, naphthalene was found to
be  highly biodegradable and listed as being  highly  strippable,
indicating  both  are  significant concurrent  removal  pathways.
Toluene  biodegraded rapidly but appeared to air strip even  more
rapidly.  Hexachlorobenzene is too insoluble to indicate anything
but  sorption  on the MLSS (mixed-liquor  suspended  solids)  and
MLVSS   (mixed-liquor   volatile  suspended   solids).    Benzene
biodegrades  but  appears to air-strip even more rapidly  as  was
found  for  toluene.   Phenol biodegrades readily  but  manifests
insignificant   air  stripping.    Pentachlorophenol   manifested
minimal biochemical oxidation and no air stripping.  Nitrobenzene
showed some evidence of biological activity of 2-chlorophenol was
unclear, except for some evidence of biodegradation; however, its
air stripping characteristics were minimal, if any at all.


Anthrancene may have been sorbed and/or metabolozed by the sewage
sludge,  but  showed no air  stripping  tendencies.   Nitrophenol
showed biological activity and/or chemical activity; however, its
air stripping activity is only slight.  Hexachloroethane appeared
essentially   inert  in  these  tests  and  was  not  tested  for
stripping.   Fluorene seemed to show no activity in these  tests,
except possibly for some sorption.  There was no evidence for any
stripping.   Methylene  chloride  appeared to be air stripped  at
rates far  greater than any possible biological activity.  Carbon
tetrachloride and chloroform both were stripped out of the system
rapidly  at  rates  resembling that of  methylene  chloride  with
little if any evidence of biological activity.  Trichloroethylene
is  rapidly  stripped and shows some evidence for  adsorption  on
suspended solids.  Chlorobenzene was found to be rapidly stripped
from  the  system  with  very  little  evidence  for   biological
activity.   Tetrachloroethylene is rapidly air stripped but showed
no   evidence   for   biodegradation.     4-Chloro-3-methylphenol
biodegrades   but   does   not  air   strip.    Ethylbenzene   is
predominately    air   stripped   with   little   evidence    for
biodegradation.    1,2-Dichloroethane   is  air   stripped   with
essentially    no    evidence   for    biodegradation.     1,1,2-
Trichloroethane   gives  no  evidence  of  biodegration  but   is
essentially completely air stripped.  Therefore, air stripping of
volatile   organics  from  biological  oxidation  systems  is   a
potential air pollution problem.  As a result, this regulation is
based  on  the use of steam stripping of volatile organics  as  a
pretreatment  step  before  biological  oxidation,  in  order  to
eliminate this air pollution problem.


Air  stripping  of  volatile organic  compounds  from  biological
treatment  systems  may create potential  air  quality  problems.
This  regulation  is  based on the use of steam  stripping  (with
recovery  of the stripped organic material) prior  to  biological
treatment.   However,  the Agency has not regulated five volatile


                              VIII-9

-------
organic  compounds for PSES and is concerned about resulting  air
quality  impacts.   The Agency intends to gather additional  data
and  propose  additional  regulations  for  there  pollutants  in
calendar year 1986.


Both  solar and spray evaporation were recommended as alternative
methods   for   disposal  of  low  volumes  of   wastewater   for
formulators/packagers.   However,  based  on public comments  the
Agency is no longer recommending these methods.   The practicality
of  using  solar  and spray evaporation  in  northern  latitudes,
during winter months, was questioned by several  plants.


Also, the use of evaporation ponds, unless they  are appropriately
lined present problems of potential ground water contamination.

              i
On-site regeneration of activated carbon has been recommended  as
an   alternative   for   the   removal  of  pesticides,   phenols,
nitrosamines, and  chlorinated  dienes.   The  furnace  which  is
utilized  in this system has been provided with  an afterburner to
control obnoxious gases and a wet scrubber  for   dust  collection
and cooling of gases.


In  a  study conducted by Wagner, et al. (1979)  it was determined
that the  conditions  necessary  to  safely  incinerate  granular
activated  carbon  reactivation  off-gases were  within the normal
operating range of a typical afterburner.  Of the eight compounds
selected five were not present in  their  original  form  in  the
furnace   off-gases  (two  of  these  five  were  the  pesticides
malathion and 2,4-D).  The residual levels  of  the  other  three
compounds,  and  the  hydrocarbon decomposition  products from all
eight compounds, were reduced by  at  least  98   percent  in  the
afterburner.


Solid Waste Considerations


Many  liquid and solid wastes generated in the pesticide industry
have been classified as  "hazardous"  by  regulations  under  the
Resource  Conservation and Recovery Act (RCRA) 40 CFR,  Part 261,
May 19, 1980. Under the RCRA regulations, disposal of wastes off-
site  would  require  preparation  of a  manifest  to  track  the
movement  of  the  waste  from  the  generator's  premises  to  a
permanent  off-site  treatment,  storage,  or disposal  facility.
Specific  waste  streams  within  specific  processes  have  been
designated  as  hazardous,  as  well as specific products and raw
materials.    The   cost  of   compliance   with  existing   RCRA
regulations   were reviewed  in  order to assess  the   potential
impact   of  these  regulations.    RCRA  management  costs  were
estimated  using procedures described in the "EPA Guidance Manual
for  Estimating  RCRA Subtitle C Compliance Costs."    The  costs


                              VIII-10

-------
include: (1) runoff collection and treatment  system, (2) closure
plan,  (3)  off-site management,  (4) administration,  (5) record-
keeping,  (6)  monitoring   and   testing,  (7)   training,   (8)
contingency   plan,   and (9) closure and post closure  financial
responsibilities as applicable to each type  of  facility.    The
RCRA   management  costs  associated  with  these  BAT  and  PSES
regulations   are   estimated   to  be  $453,000   annually   for
subcategory  one  plants.   PFP plants were costed  for  contract
hauling and incinerating hazardous wastes at $2.50 a gallon.


Metal separation systems have been recommended for the removal of
copper  and  zinc.  Adjustment of pH using sodium  hydroxide   in
these   systems   will  create   zinc   and   copper    hydroxide
sludges.  The quantities of sludge generated are estimated to be:

                         Cubic Yards of Sludge
                       Generated Per Year Per MGD
                          Copper     Zinc

                           102,000    5,540

Protection of_ Ground Water


Deep well injection is practiced at 17 plants  in  the  pesticide
industry.  Since this method of disposal has not been recommended
by this study, its potential impact on groundwater pollution will
not be addressed.
Spray  irrigation  of  process  wastewaters is practiced at three
plants  in  the  industry.   Since  this  is  not  a   technology
recommended  in  this  study,  its potential for pollution of the
ground water will not be addressed.
                              VIII-11

-------
   Table VIII-1.  Basis for Capital Costs Computations
                  (August 1983 Dollars)
   Item
 Capital Cost
Land

Excavation

Materials

 Reinforced Concrete

 Machined Steel

 Epoxy Coating

 Liner

 Sitework, electrical, piping
   and instrumentation

 Engineering

 Contingency
$32,700 per ace

$6.78 per cubic yard



$345 per cubic yard

$2.64 per pound

$2.50 per square foot

$0.77 per square foot


48% of total equipment cost

15% of construction cost

15% of construction cost
                          VIII-12

-------
      Table VIII-2.  Basis of Annual Cost Computations
                     (August 1983 Dollars)
  Item
     Capital Cost
Capital Recovery

Taxes and Insurance

Manpower

  Labor


  Supervision
10 years at 13% (0.218)

2% of capital cost
$24,500 per worker per year
   including fringe benefits

$35,600 per worker per year
  including fringe benefits
Maintenance Materials

Sludge Disposal


Water

Activated Carbon

Chemical Consumed

  Caustic Soda (50%)
  Chlorine
  Ferric Chloride
  Lime
  Methanol

Chemicals Recovered

  Methylene Chloride
  Pesticides

Energy Consumed

  Electricity
  Gas

  Steam

Energy Recovered

  Thermal

Contract Haul
4% of capital costs

$25 per cubic yard (non hazardous)
$200 per cubic yard (hazardous)

$0.60 per thousand gallons

$0.77 per pound delivered
$0.08 per dry pound delivered
$0.18 per pound delivered
$0.37 per pound delivered
$80 per ton delivered
$2.08 per gallon delivered
$0.37 per pound
$2.50 per pound
$0.08 per kilowatt-hour
$6.71 per one thousand
   cubic feet
$11.86 per thousand pounds
$6.08 per million BTU

$2.50 per gallon (hazardous)
$0.30 per gallon (non hazardous)
                            VIII-13

-------
Table VIII-3
Treatment Technology Cost Summary for Direct
Dischargers for Feticide Manufacturing

Plant #
1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22A
22B
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
Discharge
Status
I
I
D
D
D
D
I
I
I
D
I
D
D
D
D
D
D
I
D
D
D
D
I
I
I
D
I
I
D
I
I
D
D
I
I
D
I
I
I
I
I
D
and Indirect
Plants
Plant Costs $(1000)
Capital
14274
195
668
817
20210
540
1179
918
2074
439
814
4297
1623
17620
470
9460
263
3590
280
7536
462
722
967
1045
0
596
445
1007
257
264
274
148
259
656
6298
0
511
394
418
1046
0
377
Land
173
34
16
14
161
19
28
21
28
12
27
62
22
294
14
76
6
69
7
90
12
24
35
38
0
16
16
34
8
7
7
4
7
16
98
0
21
10
18
25
0
10
Annual
7262
591
175
456
9109
378
505
254
1227
119
448
3398
759
10496
109
3824
70
1687
73
2752
223
355
533
299
16
191
116
283
133
61
79
55
77
632
2454
182
166
90
119
287
1
172
Energy
788
3
1
224
528
200
119
2
622
53
209
1131
193
1027
5
156
46
274
14
431
134
49
10
155
0
42
9
7
88
16
15
1
16
316
97
0
0
72
1
248
0
74
TOTAL
$105,176   $1,579  $50,216
$7,377
                     VIII-14

-------
                          Table VIII-4
 PSES Costs for Indirect Discharge Metallo-Organic Manufacturers


                          Average Flow (gallons per day)

         5,000                   500                     50
Capital  Annual  Energy  Capital Annual Energy  Capital  Annual Energ
Contract Hauling1


 Hazardous^


       3,250,000   ~      —    $325,000  ~      ~      $32,500  -


 Nonhazardous^


         390,000   —      ~      39,000  —      —        3,900  -



•^260 operating days per year

T
^$2.50 per gallon to contract haul hazardous waste


^$0.30 per gallon to contract haul nonhazardous waste
                              VIII-15

-------
Table VIII-5.  Summary of Annual and Capital Costs for Formulator/Packagers

                                   (1985 dollars)

Plant
No.
1*
2*
3*
4*
5*
6
7
8*
9*
10*
11*
12*
13*
14*
15*
16*
17*
18*
19*
20
21*
22*
23*
24
25
26
27
28
29*
30*
31*
32*
33*
34
35*
36
37*
38*
39
40
Regulated PFP
Wastewater Volume
(gallon/year)
1,240
400
3,600
45
840
2,500
1,512,000
1,600
71,510
6,400
12,000
100,000
6,000
4,000
30
14,310
40,000
950
27,800
172,000
50,200
5,000
2,500
300
19,500
3,200
4,832,000
28,000
25,800
10,600
188,000
11,000
4,000
101,000
520
14,716,800
55
15,860
300

Contract
Hauling
Cost ($)
3,100
1,000
9,000
113
2,100
6,250
44,360
4,000
178,775
16,000
30,000
250,000
15,000
10,000
75
35,775
100,000
2,375
69,500
430,000
125,500
12,500
6,250
750
48,750
8,000
74,360
70,000
64,500
26,500
470,000
27,500
10,000
252,500
1,300
0
138
39,650
750
0
Annualized
Capital Costs
($)
910
670
4,360
570
790
1,280
770,000
1,000
4,360
4,360
4,360
4,360
4,360
4,360
570
4,360
4,360
820
4,360
4,360
4,360
4,360
1,280
640
4,360
4,360
1,092,000
4,360
4,360
4,360
4,360
4,360
4,360
4,360
710
1,092,000
570
4,360
640
157,600
Water
Savings
($)
0
0
0
0
0
0
(35,000)
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
(35,000)
0
0
0
0
0
0
0
0
(35,000)
0
0
0
0
Total
Annual
Cost
4,010
1,670
99,360
680
2,890
7,530
779,360
5,000
183,130
20,360
34,360
254,360
19,360
14,360
650
40,130
140,360
3,200
73,860
434,360
129,860
16,860
7,530
1,390
53,110
12,360
1,313,360
74,360
68,860
30,860
474,360
31,860
14,360
256,860
2,010
1,057,000
710
44,010
1,390
157,600
Capital
Cost
($)
2,000
2,000
20,000
2,000
2,000
2,000
2,440,000
2,000
20,000
20,000
20,000
20,000
20,000
20,000
2,000
20,000
20,000
2,000
20,000
20,000
20,000
20,000
2,000
2,000
20,000
20,000
3,098,000
20,000
20,000
20,000
20,000
20,000
20,000
20,000
2,000
3,098,000
2,000
20,000
2,000
455,000
         Subtotal Cost (28 randomly selected plants)
         Subtotal Cost (12 not- randomly selected plants)

Note:  Asterisk (*) indicates a randomly selected plant.
$2,456,000 $2,818,000
$3,187,000 $6,759,000
                                 VIII-16

-------
                                                  Table VIII - 6

                           Wastewater Recycle Oosts for High Flow Formulator/Packagers
   CONTRACT HAULING
WASTESTREAM
SEGREGATION (2)
TREATMENT OF SEGREGATED STREAMS (3)
Plant
36
7
27
40(5)
Flow
(gallons/
year)
0
16,000(1)
28,000
0
Annual
Cost $
0
44,360
74,360
0
Capital
Cost $
1,455,000
1,455,000
1,455,000
0
Annual
Cost $
317,000
317,000
317,000
0
Flow
(gallons/
year)
14,716,800
1,476,000
4,804,000
5,400,000
Capital
Cost $
1,643,000
985,000
1,643,000
455,000
Annual
Cost $
775,000
453,000
775,000
—
water (4)
Use
Savings
(35,000)
(35,000)
(35,000)
—
Total
Annual
Cost
1,057,000
779,360
1,131,360
157,600
Notes: (1)  Plant No. 7 reported a contract hauling flow of 36,000 gallons per year.  However, 16,000 gallons per
            year is used here since it is the average contract hauling flow for the 4 high flow plants.  Plant No.
            7 is the cnly randomly selected high flow plant.  Since data is available for 4 of the plants, this
            correction is judged reasonable.

       (2)  Based on costs supplied by plant No. 7

       (3)  Based on proposed Efeveloprant Document Tables VIII - 8 and 9 (November 1982).

       (4)  Based on an average high flow plant wastestream of 7,000,000 gallons per year
            and a water cost of $0.005 per gallon.

       (5)  Based on actual plant data for an existing system.

-------
COMPONENTS INCLUDED
               WET WELL
               PUMPS
               50 FT. OF PIPING
   CAPITAL COST
ANNUAL COST
   I PUMP STATION
    •CAPITAL
    •LAND
 ANNUAL. OtrM. ENERGY COSTS
     PUMP STATION
                             Q
                             8,0
                                       TOTAL ANNUAL >
         9.1
        FLOW (MODI
       o.t
     FLOW (MODI
Figure VIII-1 TREATMENT COST CURVES
             PUMP STATION
                     VIII-18

-------
COMPONENTS INCLUDED
              EQUALIZATION BASINS
              AERATORS/MIXERS
    CAPITAL COST
  ANNUAL COST
  EQUALISATION i24 HRi
    CAPITAL
    LAND
EQUALIZATION 124 HRI
  ANNUAL
   O6M
  ENERGY
                                 0.01    001 0.1
                                   FLOW IMQDI
Figure VIII-2 TREATMENT COST CURVES
             EQUALIZATION
                     VIII-19

-------
COMPONENTS INCLUDED
              FEED STORAGE DRUM
              FEED PREHEATER
              FEED PUMPS
              STRIPPING COLUMN
              OVERHEAD CONDENSER
              SEPARATOR DRUM
              HEAT EXCHANGER
              EFFLUENT STORAGE DRUM
   CAPITAL COST
    GRAPH OF CAPITAL COST v. FLOW
ANNUAL COST
                            GRAPH OF OfrM COST n. FLOW
             • HIGH
             • MEDIUM
             • LOW
                               TOTAL ANNUAL
         1C
        FLOW (MODI
     .10
   FLOW (MODI
Figure VIII-3 TREATMENT COST CURVES
            STEAM STRIPPING
                       VIII-20

-------
COMPONENTS INCLUDED
             FEED PUMPS
             REACTOR VESSELS
             RECIRCULATION PUMPS
             CAUSTIC STORAGE
             CHEMICAL FEEDERS
             CHLORINE STORAGE
             CHLORINATORS
   CAPITAL COST
ANNUAL COST
                               TOTAl AIMUtL 0»M. MO IMDOT
                                CHIWIOAL OIIWTTO*
       CAHUl COITi
       CHIMWAL CWIMTPO«
Figure VIII-4 TREATMENT COST CURVES
            CHEMICAL OXIDATION
                     VIII-21

-------
COMPONENTS INCLUDED
                FEED PUMPS
                MIXING TANK
                FILTER PRESS
                HOLDING TANK
                CAUSTIC STORAGE
                CHEMICAL FEEDERS
                POLYMER STORAGE
                POLYMER FEEDERS
    CAPITAL COST
                        ANNUAL COST
    CAPITAL AND LAND COSTS
     METAL SEPARATION
    (MAX AND MIN CONCENTHATIONI
     COPPER AND ZINC
          UPDATED CURVES
i »
            ZINC IMIN.)
            COPPER IMIN I
COPPER AND ZINC
LAND COSTS
                       ANNUAL. ENERQY. OtrM COSTS
                         METAL SEPARATION
                         IMAJt CONCINTIIATKMI
                                  OftM -
                                           COPPER
                                           ZINC
                                     ZN
         0-01
       PLOW IMGDI
                             0.01
                           FLOW (MODI
Figure VIII-5 TREATMENT COST CURVES
              METALS SEPARATION
                       VIII-22

-------
    COMPONENTS INCLUDED
                  CAUSTIC STORAGE TANK
                  CHEMICAL FEEDER
                  MIXING TANK
                  HYDROLYSIS BASINS WITH COVERS
                  TEMPERATURE CONTROL
                  STEAM DELIVERY AND CONTROL
       CAPITAL COST
ANNUAL COST
            pcsncfoe «ronotr»i»
             CAPITAL COSTS
                         HYDROLYSIS
                                        ANNUAL COSTS
I.-,"
c
           M.MO MIN. OCT. TIME
           tt.M MIN. DCT. TIME
           4.NO MIN. OCT. TIME
           400 MIN. DET. TIME
    Figure VIII-6 TREATMENT COST CURVES
                 PESTICIDE HYDROLYSIS
                        Mill-*3

-------
COMPONENTS INCLUDED
              CAUSTIC STORAGE TANK
              CHEMICAL FEEDER
              MIXING TANK
    CAPITAL COST
  ANNUAL COST
 NEUTRALIZATION
   CAPITAL
   LAND
NEUTRALIZATION
 ANNUAL
  O&M
 ENERGY
001    OMt O.*l
        FLOW (MOD)
                                   FLOW (MOD)
Figure VIII-7 TREATMENT COST CURVES
             NEUTRALIZATION
                      VIII-24

-------
 COMPONENTS INCLUDED
               FEED PUMPS
               FILTERS
               BACKWASH PUMPS
    CAPITAL COST
  ANNUAL COST
       CAPITAL COSTS
     DUAL MEDIA FILTRATION
       FLOW IMOOI
TOTAL ANNUAL AND OPERATING COST
   DUAL MEDIA FILTRATION
                                          ENERGY
                                 FLOW (MOD)
Figure VIII-8 TREATMENT COST CURVES
             DUAL MEDIA PRESSURE FILTRATION
                      VIII-25

-------
COMPONENTS INCLUDED
               CARBON COLUMNS
               BACKWASH PUMPS
   CAPITAL COST
ANNUAL COST
   PRIMARY CARBON ADSORPTION
       CAPITAL COSTS
               2nd EDITION
    TOTAL ANNUAL COITI
   PRIMARY GABION AD*.
   	U«JATtO t. MtU	
                              CNEROY COtT
                              IAU omimoN TIMIII
Figure VIII-9 TREATMENT COST CURVES
             CARBON ADSORPTION
                     VIII-26

-------
COMPONENTS INCLUDED
             CARBON MAKE-UP TANK
             MAKE-UP CARBON WASH TANK
             SLURRY PUMPS
             SPENT CARBON DEWATERING TANK
             FURNACE
             QUENCH TANK
             REGENERATED CARBON WASH TANK
             WASH WATER PUMPS
             AFTER BURNER
             SCRUBBER
 CAPITAL COST
ANNUAL COST
                                   ANNUAL COST
      CAPITAL COST
 8 1 000-
       FLOW (MODI
                                   FLOW (MODI
  Figure VIII-10 TREATMENT COST CURVES
              CARBON REGENERATION
                      VIII-27

-------
COMPONENTS INCLUDED
               RESIN COLUMNS
               BACKWASH PUMPS
   CAPITAL COST
ANNUAL COST
   CAPITAL COtT CURVI: MIIN ADSORPTION
                              ANNUAL COSTI CUMVII: KMIN ADIOPUTION
    tm  u    11  1.1
     nan IMOOI  »
    MTII UNO eofr ran AU OAHI n turn
  tm 1.1    (.1 1.1
  now IMOOI -
Figure VIII-11 TREATMENT COST CURVES
              RESIN ADSORPTION
                        VIII-28

-------
COMPONENTS INCLUDED
               METHANOL STORAGE
               PUMP
               BATCH DISTILLATION COLUMN
               OVERHEAD CONDENSER
               REFLUX DRUM
    CAPITAL COST
ANNUAL COST
      (CAPITAL - LANOI C01T
      :MIIN MQINIRATION:
       CAPITAL
         LAND
       01       10
        FLOW (MODI
ANNUAL COW: RUIN MQINIKATION
   INIHOY IPOWI* • ITUMI
                                   FLOW (MODI
Figure VIII-12 TREATMENT COST CURVES
              RESIN REGENERATION
                      VIII-29

-------
COMPONENTS INCLUDED
              PHOSPHORIC ACID STORAGE
              ANHYDROUS AMMONIA STORAGE
              CHEMICAL FEED PUMPS
   CAPITAL COST
  ANNUAL COST
NUTRIENT ADDITION
  CAPITAL
   LAND
NUTRIENT_AODITION
  ANNUAL
   ObM
  ENERGY
             CAPITAL
      001   001 01
       FLOW IMGD1
Figure VI11-13 TREATMENT COST CURVES
              NUTRIENT ADDITION
                    viir-30

-------
COMPONENTS INCLUDED
             AERATION BASINS
             AERATORS
   CAPITAL COST
ANNUAL COST
      Ml   t« 1.1
       FLOW IMOOI
Figure VIII-14 TREATMENT COST CURVES
            AERATION BASIN
                  VIII-31

-------
COMPONENTS INCLUDED
               CLARIFIER
               SLUDGE RECYCLE PUMPS
               POLYMER STORAGE AND FEEDER
     CAPITAL COST
                               ANNUAL COST
 PURIFICATION
   CAPITAL
   LAND
CLARIHCATIOM
 ANNUAL
  OfrM
 ENERGY
              CAPITAL
     0.0» 0.01    0.01 0.1    0.1  10
        FLOW (MODI
      0.01    0 01

        FLOW (MODI
Figure VIII-15 TREATMENT COST CURVES
              CLARIFICATION
                        VIII-32

-------
COMPONENTS INCLUDED
              AIR FLOTATION TANK AND MECHANISM
              SLUDGE RECYCLE PUMPS
    CAPITAL COST
 ANNUAL COST
 SLUDGE THICKENING
   CAPITAL
    LAND
SLUDGE THICKENING
  ANNUAL
   06M
  ENERGY
              CAPITAL
               LAND
    O.OOi 0.01    O.di 0-1
        FLOW (MODI
Figure VIII-16 TREATMENT COST CURVES
              SLUDGE THICKENER
                         VIII-33

-------
COMPONENTS INCLUDED
              DIGESTION CHAMBER
              AERATORS
    CAPITAL COST
  ANNUAL COST
  AEROBIC DIGESTION  CAPITAL & LAND COSTS
  O&M
ENERGY COSTS
TOTAL ANNUAL
                               CM O.H    001 01

                                   FLOW IMOOI
     ooet 001   ooi 01
        FLOW IMOD)
Figure VIII-17 TREATMENT COST CURVES
              AEROBIC DIGESTION
                       VIII-34

-------
COMPONENTS INCLUDED
              VACUUM FILTER
              CHEMICAL FEEDERS
              CHEMICAL STORAGE
    CAPITAL COST
  VACUUM FILTRATION
    CAPITAL
        CAPITAL
 ANNUAL COST
VACUUM FILTRATION
  ANNUAL
   OttM
  ENERGY
    O.Mi 001    ooi e.i
        FLOW (MOO)
Figure VIII-18 TREATMENT COST CURVES
              VACUUM FILTRATION
                      VIII-35

-------
COMPONENTS INCLUDED
               LINED PONDS
     CAPITAL COST
ANNUAL COST
1000
 300
 100'
 30'
 10
          NI-MTIW^OMATON
  0.1    0.3     1    3

        FLOWIGPD x 1000)
                        1000
                     10   01
   1.0      10

   FLOWIGPD x 1000)
       Vlll-19. TREATMENT COST CURVES
              SOLAR EVAPORATION
                       VII1-36

-------
                           SECTION IX
  SELECTION OF POLLUTANT PARAMETERS RECOMMENDED TO BE REGULATED
INTRODUCTION
The  purpose  of  this  section  is  to  define  the   pollutants
regulated  in the Pesticide Chemicals Industry and to provide the
rationale  for  their regulation.   EPA's objective  was to limit
the  number  of pollutants regulated to the minimum  required  to
ensure  proper  application and operation of  wastewater  control
technologies.   The priority,  nonconventional,  and conventional
pollutants    in   the  scope  of  this  study   were  segregated
into the three groups  defined  below,  as  listed  in Tables IX-
1 through IX-3:


1.   Pollutants of primary significance are those regulated;


2.    Pollutants   of  dual   significance  are  regulated   only
where   they   are  the manufactured product;  where they  are  a
wastewater constituent  of  other  pesticide  products they are a
pollutant of secondary significance; and


3.   Pollutants  of  secondary  significance  are  not  currently
regulated but are controlled by regulation of associated priority
pollutants.


A   detailed  process  chemistry  evaluation  was  conducted   to
determine pollutants of primary and secondary significance.   The
nonconfidential analysis for the proposal is in volume 44 of  the
administrative record.  The final analysis is in Section II B2 of
the final promulgated record.  These reports detail the decisions
made, on a pollutant-by-pollutant basis, using actual plant data,
process chemistry evaluations, and technology transfer.


This section summarizes these data,  as well as the environmental
effects and the conclusions of the process chemistry evaluations.
Data  to  support  the assumptions and conclusions are  found  in
Section V of this report.
                               IX-1

-------
The rationale for assigning pollutants into  these  three  groups
was  based  on factors such as raw waste load level and presence,
treatability,  and analytical methods  availability.  Information
used  to  evaluate  these  factors is either  referenced  in  the
bibliography and/or found in the Public Record.


Priority  pollutants  were  initially  categorized  as  being  of
primary or secondary significance, as shown in  Tables  IX-1  and
IX-3, according to the rationale described below.


Priority  pollutants  detected or indicated to be  present in each
pesticide wastestream were examined by group as  shown in  Section
V,  as  was  the  raw waste load level.  Priority  pollutants were
initially classified as of primary significance  if:


1.  They are shown  to  exist  independently  of  other  priority
pollutants in that group, or


2.   They  are  shown to exist in combination with other priority
pollutants in that group; but because they may be  raw  materials,
solvents,   or  products,  they  are  normally  found  in  higher
concentrations     than    other  priority     pollutants      of
secondary significance.


Priority  pollutants  were  initially  classified  as of secondary
significance  because:


1.  They were detected or are indicated to exist predominantly in
conjunction with pollutants of primary significance, or


2.   They  may  be  impurities or reaction  byproducts  that  are
normally  found  in lower concentrations than priority pollutants
of primary significance.


As  an example of the process described above  benzene,  toluene,
and  chlorobenzene  were selected as   priority    pollutants   of
primary significance   in   the   volatile   aromatic   pollutant
group.   Ethylbenzene   was   considered  to  be   of   secondary
significance  since  it predominantly exists as  an  impurity   in
benzene  or  toluene. Hexachlorobenzene  and  1,3-dichlorobenzene
were  considered  to be of secondary  significance   since   they
predominantly   exist  in conjunction with,  and at lower  levels
than, chlorobenzene.
                               IX-2

-------
Once  the  presence  and  levels  of priority pollutants had been
initially evaluated, the relative treatability of  each  priority
pollutant  was  examined.   The  purpose  of  this  review was to
identify any  priority  pollutants  initially  classified  as  of
secondary  significance,  which  because  of  a  lesser degree of
treatability could  not  achieve  the  same  effluent  levels  as
priority pollutants of primary significance in the same pollutant
group.   Upon completion of this review it was concluded that the
pollutants  of  primary significance adequately represented   the
treatability  of  each  group  of priority pollutants and that no
further additions were required.


Analytical methods availability was  examined  for  the  priority
pollutants  initially  designated as of primary significance.  It
was  judged  that  no  modifications  were  required   based   on
analytical methodology.


All   nonconventional  pesticide  pollutants   with   promulgated
analytical  procedures,  per  40  CFR Parts  136  and  455,  were
categorized  as  of  primary   significance.    These  pollutants
are      identified      in     Sections     XIV     and      XV.
Nonconventional  pesticide   pollutants   which   lack   approved
analytical   procedures   were   categorized   as   of  secondary
significance  and are not regulated  at  this  time  pending  the
development  of  analytical  methods  and the  collection  of  an
adequate data base.   The pollutants  ammonia and manganese  have
been  detected  in segments   of  the  pesticide   industry   but
were not prevalent in any one subcategory,  therefore,  they were
classified    as   of   secondary  significance   and    national
limitations    and   standards   are  not   promulgated.    Other
nonconventional  pollutants were not considered for regulation in
the Pesticide Industry.


POLLUTANTS OF PRIMARY, DUAL, OR SECONDARY SIGNIFICANCE


Based  upon  the  factors discussed above,  the pollutants listed
in  Table  IX-1  are considered  of  primary significance in  the
Pesticide  Chemicals  Industry.  The   34   priority   pollutants
listed   in  Table  IX-1  will  not necessarily be found  in  any
one  pesticide  plant's   wastewater.   The    specific  priority
pollutants    (of    primary   significance)   recommended    for
regulation (monitoring) as a result of this study are listed with
the  associated manufactured pesticide in Section XX-Appendix  6.
Whenever  a  plant  manufactures  a  specific   pesticide  active
ingredient,  that  discharger must meet the effluent  limitations
and standards for the specific priority pollutants identified  in
Table II-l.


The 5 priority pollutants listed in Table IX-2 are considered  of
dual   significance   in   the   Pesticide   Chemicals  Industry.


                               IX-3

-------
These   pollutants   (1,2-dichlorobenzene,   1,4-dichlorobenzene,
1,2,4-trichlorobenzene,   bis   (2-chloroethyl)  ether,  and  1,3-
dichloropropene)   are   classified  as  pollutants  of   primary
significance  if  they   are   manufactured   as   a    pesticide
product.   If  these  pollutants  are detected or indicated to be
present in other pesticide  processes,  they  are  classified  as
pollutants of secondary significance.


The  priority  pollutants listed in Table IX-3 are considered  of
secondary  significance  in the  Pesticide   Chemicals  Industry.
Priority  pollutants  of  secondary   significance   which    are
excluded  from regulation under paragraph 8 of the consent decree
(NRDC  v.   Train)  include  pollutants  which  were   previously
regulated,  not currently produced and unlikely to be produced in
the  future  because  their use is banned in  this  country,  not
suspected  in  the industry,  not  present in treatable amounts or
are  judged to   be  adequately  controlled  if  the   pollutants
of   primary significance are  reduced  to  recommended   levels.
Nonconventional  pesticide pollutants of  secondary  significance
are  those  for  which  no  promulgated  analytical  methods  are
available.  However, some pesticides for which analytical methods
do  exist  are  not covered under  regulations  for  manufacturers
because  technical  data  is  not   adequate.    Reasons  for  the
exclusion  of  these pesticides from the regulation  for  organic
pesticide  chemicals manufacturers is discussed in  Section  XIV.
The  Agency is,  however,  encouraging permit writers and control
authorities to consider these and  other pollutants which,  on the
basis  of  actual monitoring data  or other  information,  may  be
present   in  a  particular  plants  effluent.      Table    IX-3
identifies  pollutants  which  are  excluded from regulation.  An
affidavit  has been filed with the Court of Appeals defining  the
reasons for paragraph 8 selection.  See Section XX-Appendix 10.


A detailed discussion of the  selection  rationale  for  priority
pollutants,    nonconventional  pollutants,   and   conventional
pollutants follows.


PRIORITY POLLUTANTS


Priority  pollutants  recommmended  as  of  primary,   dual,   or
secondary  significance are discussed by pollutant group in order
of their approximate frequency of  occurrence as follows.


Volatile Aromatics


There are nine compounds which represent  the  volatile  aromatic
priority  pollutant  group.   Benzene, chlorobenzene, and toluene
were chosen as pollutants of primary significance since they  are
used  as    raw   materials   and   solvents  and  are  found   in
                               IX-4

-------
higher   concentrations   than  the   other   volatile   aromatic
compounds.


Primary Significance—In the pesticide industry, benzene is  used
as   a  raw  material in the production of seven pesticides.   It
is used as  a solvent in at least 11 pesticide processes,  and  it
is  indicated   to  be  present in  an  additional  96  processes
(primarily  as an impurity in the solvent toluene).   It has  been
detected  in raw  waste  loads  at  concentrations  up to 180,000
mg/1.   While  benzene in treated effluents has been observed for
the most  part to  be  less  than  1  mg/1,  this level may  have
been   achieved  by  volatilization   in   biological    systems,
thereby   creating   a potential air pollution problem.


In the pesticide industry, chlorobenzene is detected or indicated
to  be  present  in  32  pesticide  processes  as  a solvent, raw
material, impurity, or final product.  Of 21 processes monitored,
chlorobenzene has been measured in raw waste loads at  levels  up
to 979 mg/1.


In the pesticide industry, toluene is detected or indicated to be
present in  108 pesticide processes as a solvent, raw material, or
impurity.   Of  35 processes monitored, toluene concentrations in
raw waste loads ranged from not detected to 294,000 mg/1.


Dual Significance—In the pesticide industry, 1,2-dichlorobenzene
is  detected or indicated to be present in 26 pesticide processes
as a final  product, raw material impurity, solvent impurity, or a
reaction   byproduct.    Raw   waste   concentrations   of   1,2-
dichlorobenzene    have    ranged    up  to   127   mg/1.    1,2-
Dichlorobenzene  is  regulated as a priority pollutant only if it
is  manufactured  as a  product.    In other  processes   it   is
adequately   controlled by regulation of the  priority   pollutant
of  primary  significance, chlorobenzene.


In  the  pesticide  industry,  1,4-dichlorobenzene is detected or
indicated to be present in 26  pesticide  processes  as  a  final
product,  raw  material  impurity, or as a solvent impurity.  Raw
waste load  concentrations of 1,4-dichlorobenzene have  ranged  up
to   85.0   mg/1.    1,4-Dichlorobenzene  is   regulated   as   a
priority  pollutant  only  if  it  is  manufactured as a product.
In   other   processes   it   is   adequately    controlled     by
regulation   of  the  priority  pollutant of primary significance,
chlorobenzene.
In the pesticide industry, 1,2,4-trichlorobenzene is detected  or
indicated  to  be present in 25  pesticide processes as a reaction
byproduct, raw material impurity, or a  stripper  impurity.   Raw
waste  load  concentrations of 1,2,4-trichlorobenzene have ranged
                               IX-5

-------
up  to  36.0  mg/1.    1,2,4-Trichlorobenzene is regulated  as  a
priority pollutant only if it is manufactured as a  product.   In
other  processes it is adequately controlled  by  regulation   of
the priority pollutant of primary significance, chlorobenzene.


Secondary   Significance—In   the   pesticide   industry,   1,3-
dichlorobenzene  is  detected  or  indicated  to be present in 26
pesticide processes as a raw material impurity, solvent impurity,
or a reaction byproduct.  Raw waste load concentrations  of  1,3-
dichlorobenzene  have ranged up to 127 mg/1.  1,3-Dichlorobenzene
is  adequately   controlled   by  regulation   of   the  priority
pollutant of primary significance, chlorobenzene.


In  the pesticide industry, ethylbenzene is detected or indicated
to be present in 103  pesticide  processes  as  a  raw  material,
solvent  impurity,  or  a  raw material impurity.  Raw waste load
concentrations  of  ethylbenzene  have  ranged up  to  7.9  mg/1.
Ethylbenzene  is  be  adequately  controlled  by  regulation   of
the   priority  pollutants of primary significance,  benzene  and
toluene.
In the  pesticide  industry,  hexachlorobenzene  is  detected  or
indicated  to  be  present  in 16 pesticide processes as reaction
byproducts, solvent impurity,   or  raw  material  impurity.   Raw
waste load concentrations of hexachlorobenzene have been detected
at   levels   less  than   0.008   mg/1.    Hexachlorobenzene  is
adequately controlled  by  regulation  of  the priority pollutant
of primary significance, chlorobenzene.


Halomethanes-


There  are  eight  compounds  which  represent  the   halomethane
priority  pollutant  group.    Carbon tetrachloride,  chloroform,
methyl  bromide,  methyl  chloride,  and methylene chloride  were
chosen  as pollutants  of  primary  significance  since they  are
used  as  raw  materials  and solvents and are  found  in  higher
concentration than the other halomethane compounds.


Primary   Significance—In   the   pesticide   industry,   carbon
tetrachloride is detected  or  indicated  to  be  present  in  46
pesticide  processes  as  a  solvent,  organic  stripper solvent,
solvent impurity, reaction byproduct, or raw  material  impurity.
Carbon  tetrachloride concentrations in raw waste loads have been
detected at levels up  to  121  mg/1.


In the  pesticide  industry,  methyl  bromide  (bromomethane)  is
detected  or  indicated to be present in four pesticide processes
as a final product, raw material, a  reaction  byproduct,  or  an


                               IX-6

-------
impurity.   Raw
to 2,600 mg/1.
waste load concentrations have been monitored up
In  the  pesticide  industry,  methyl  chloride  is  detected  or
indicated to be present in 49 pesticide processes  as  a  solvent
and  organic  stripper  solvent, or as raw material, raw material
impurity,  or  reaction  byproduct.   Methyl  chloride  has  been
monitored   in   only  nine  pesticide process  raw  wastes  with
concentrations measured less than 1.0 mg/1.


In the pesticide industry,  methylene  chloride  is  detected  or
indicated  to  be present in 52 pesticide processes as a solvent,
impurity, or reaction  byproduct.   Of  17  processes  monitored,
methylene   chloride   was   detected   in  raw  waste  loads  at
concentrations equal  to  or  less  than  31,000  mg/1.


Secondary  Significance—In  the  pesticide  industry,  bromoform
(tribromomethane)  is detected or indicated to be present in  six
pesticide processes as either  a  reaction  byproduct  or  as  an
impurity.   Only trace levels were detected in the four processes
monitored.   Bromoform is adequately controlled by  regulation of
the priority pollutant of primary significance, methyl bromide.


In the pesticide industry, chlorodibromomethane is  indicated  to
be present in two pesticide process as a reaction byproduct.  Raw
waste   load   concentrations  of  chlorodibromomethane  are  not
available  in  the pesticide industry.   Chlorodibromomethane  is
adequately controlled  by  regulation  of the priority pollutants
of primary significance, methylene chloride and methyl bromide.


In the pesticide industry, dichlorobromomethane  is  detected  or
indicated  to be present in two pesticide processes as a reaction
byproduct.    Dichlorobromomethane   is  adequately controlled by
regulation of the priority  pollutants  of  primary significance,
methylene chloride and methyl bromide.
Cyanide
Cyanide    represents   a   priority   pollutant   group. Cyanide
was  chosen as a pollutant of  primary  significance   since   it
is   a  unique  compound  in the pesticide industry where  it  is
used   as  a  raw  material   and   is   found   in   significant
concentrations  in pesticide  raw  waste  loads.
                               IX-7

-------
Primary  Significance—In  the  pesticide  industry,  cyanide  is
detected or indicated to be present  in 42   pesticide  processes
as a raw material,  impurity,  or reaction byproduct.  Of the  17
pesticide   processes  monitored,   cyanide was present in levels
ranging up to 5,503 mg/1  in  raw  waste  loads.


Haloethers—There   are   six  compounds  which   represent   the
haloether  priority   pollutant   group.    Haloethers  were  not
selected as pollutants of  primary significance,  since they were
not   found  above  detectable   levels.      However,     bis(2-
chloroethyl)    ether  has  been classified as a   pollutant   of
dual   significance  since  it  is manufactured as a product  and
has zero wastewater discharge.


Dual  Significance—In  the pesticide industry, bis(2-chlorethyl)
ether (BCEE) is  detected  or  indicated  to  be  present  in  12
pesticide  processes  as  a final product, reaction byproduct, or
raw material impurity.   BCEE  has  been  detected  in  only  one
process  raw waste load and was found at a concentration of 0.582
mg/1.   Bis(2-chloroethyl)  ether  is  regulated  as  a  priority
pollutant  only if it is manufactured as a product.


Secondary   Significance—In   the   pesticide  industry,  bis(2-
chloroethoxy)  methane  is  indicated  to  be   present   in   11
pesticide processes as a reaction byproduct or an impurity.  This
compound  has not been detected in raw waste loads monitored.


In   the  pesticide  industry,  bis(2-chloroisopropyl)  ether  is
indicated to be present in 14 pesticide processes as  a  reaction
byproduct or an impurity.  This compound has not been detected in
monitored  raw  waste  loads.


In   the   pesticide  industry,  4-bromophenyl  phenyl  ether  is
indicated to be present in one pesticide process  as  a  reaction
byproduct.   This  compound  has not been detected in  the  waste
streams monitored in the pesticide industry.


In the pesticide industry, 2-chloroethyl vinyl ether is indicated
to  be  present in 14 pesticide processes as a reaction byproduct
or as an impurity.  This compound has not been  detected  in  the
pesticide  industry.


In  the  pesticide  industry,  4-chlorophenyl  phenyl  ether   is
indicated  to  be present in 20 pesticide processes as a reaction
byproduct.   This  compound has not been  detected in   monitored
waste streams.
                               IX-8

-------
Phenols-There   are  11  compounds  which  represent  the  phenol
priority    pollutant    group.       2,4-Dichlorophenol,    2,4-
dinitrophebnol,  4-nitrophenol,   pentachlorophenol,  and  phenol
were    chosen   as pollutants  of  primary  significance   since
they are used as raw materials or produced as final products, and
are  found  in  higher concentrations  than  the  other  phenolic
compounds.


Primary    Significance—In    the   pesticide   industry,   2,4-
dichlorophenol is detected or  indicated  to  be  present  in  23
pesticide  processes as a raw material, raw material impurity, or
reaction byproduct.  Of the 15 process raw waste loads monitored,
the concentration of 2,4-dichlorophenol ranged from 0.042 mg/1 to
42,000 mg/1.


In the  pesticide  industry,  2,4-dinitrophenol  is  detected  or
indicated  to  be  present  in three pesticide processes as a raw
material   or   raw   material    impurity.     2,4-Dinitrophenol
concentrations  in  raw waste loads have been detected  at levels
up to 7.91 mg/1.


In the pesticide industry, 4-nitrophenol is detected or indicated
to be present in four pesticide processes as a  raw  material  or
reaction  byproduct.   Of  the  three  process  raw  waste  loads
monitored, 4-nitrophenol has been detected in raw  waste  streams
with concentrations ranging from 0.002 mg/1 to 461 mg/1.


In  the  pesticide  industry,  pentachlorophenol  is  detected or
indicated to be present in seven pesticide processes as  a  final
product  or  reaction  byproduct.   Of  two  processes monitored,
pentachlorophenol concentrations in raw waste loads  ranged  from
1.0  mg/1 to greater than 1,000 mg/1.


In the pesticide industry, phenol is detected or indicated to  be
present in 26 pesticide processes as a raw material, impurity, or
reaction  byproduct.  There have been ten processes monitored for
phenol with concentrations ranging from 0.27 mg/1 to 1,100  mg/1.


Secondary Significance—In the pesticide industry, 2-chlorophenol
is detected or indicated to be present in 18 pesticide  processes
as   a  reaction  byproduct  or  an  impurity.   Raw  waste  load
concentrations of 2-chlorophenol have  been  detected  at  levels
up   to  1,000  mg/1  and  at  30.5  mg/1.    2-Chlorophenol   is
adequately controlled  by  regulation  of  the priority pollutant
of primary significance, 2,4-dichlorophenol.


In the pesticide industry, 2,4-dimethylphenol is indicated to  be
present  in three pesticide processes as a reaction byproduct  or


                               IX-9

-------
an  impurity.   This   compound  has not  been  detected  in  the
waste  stream  monitored   in   the  pesticide  industry.    2,4-
Dimethylphenol is adequately  controlled  by  regulation  of  the
priority  pollutants  of primary significance, 2,4-dichlorophenol
and phenol.


The compound 4,6-dinitro-o-cresol is not indicated to be  present
in   the  pesticide industry.   The  presence  of  4,6-dinitro-o-
cresol,  if any,   would be adequately controlled by regulation of
the   priority   pollutants   of   primary   significance,   2,4-
dichlorophenol and phenol.


In  the  pesticide  industry,  2-nitrophenol  is  indicated to be
present  in  two  pesticide processes as   an   impurity.    This
compound  has not  been  detected in the waste streams  monitored
in   the  pesticide  industry.    2-Nitrophenol  is    adequately
controlled  by  regulation of the priority pollutant  of  primary
significance,  4-nitrophenol.


In  the  pesticide  industry,  parachlorometacresol  (4-chloro-m-
cresol)  is   indicated   to  be  present   in   three  pesticide
processes as a reaction byproduct or an impurity.  This  compound
has   not   been  detected in the waste  streams  monitored   the
pesticide  industry.    The   presence  of  4-chloro-m-cresol  is
adequately controlled by regulation of the priority pollutants of
primary significance, 2,4-dichlorophenol and phenol.


In the pesticide industry, 2,4,6-trichlorophenol is  detected  or
indicated  to be present in 18 pesticide processes as a  reaction
byproduct or as an impurity.  Of the  nine  processes  monitored,
2,4,6-trichlorophenol  concentrations  in  raw waste loads ranged
from   0.022  mg/1  to  8,700  mg/1.    2,4,6-Trichlorophenol  is
adequately  controlled  by  the  regulation   of   the   priority
pollutant of primary significance, 2,4-dichlorophenol.


Nitrosubstituted   Aromatics-There   are  three  compounds  which
represent the nitrosubstituted aromatic priority pollutant group.
There are  no  pollutants  of  primary significance in this group
since 2,4-dinitrotoluene,  2,6-dinitrotoluene,  and  nitrobenzene
are adequately  controlled  by  the regulation of a pollutant  of
primary significance.


Secondary   Significance—In   the   pesticide   industry,   2,4-
dinitrotoluene is indicated  to  be  present  in  five  pesticide
processes  as  a  reaction byproduct.  This compound has not been
detected   in  the  waste  streams  monitored  in  the  pesticide
industry.   The  presence  of  2,4-dinitrotoluene  is  adequately
controlled  by  regulation  of  the priority pollutant of primary
significance, toluene.


                               rx-io

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In the pesticide industry, 2,6-dinitrotoluene is indicated to  be
present in five pesticide processes as a reaction byproduct.  The
nitrosubstituted  aromatic  2,6-dinitrotoluene  is  predominantly
used  as  a  mixture  with  2,4-dinitrotoluene.    This  compound
has  not  been  detected in the waste streams  monitored  in  the
pesticide  industry.   The  presence  of  2,6-dinitrotoluene   is
expected  to  be  adequately  controlled  by  regulation  of  the
priority pollutant of primary significance, toluene.


In the pesticide industry, nitrobenzene is detected or  indicated
to  be  present in 42 pesticide processes as a reaction byproduct
or an impurity.  Raw waste load concentrations of  this  compound
have  been  detected in monitored waste streams at less than 0.01
mg/1.    The presence of nitrobenzene is adequately controlled by
regulation  of the priority pollutant  of  primary  significance,
benzene.
Polynuclear  Aromatic  Hydrocarbons-There  are 17 compounds which
represent the polynuclear  aromatic  hydrocarbon  (PAH)  priority
pollutant    group.     The PAHs are not detected or indicated to
be present in the pesticide  industry.


Secondary Significance—In the pesticide industry, acenaphthylene
is  indicated  to  be  present  in  six pesticide processes as an
impurity. Raw waste load concentrations of this compound have not
been detected in  monitored  waste  streams.
In the  pesticide  industry,  acenaphthene  is  indicated  to  be
present  in  six  pesticide  processes as an impurity.  Raw waste
load concentrations of this compound have not  been  detected  in
monitored  waste  streams.
In  the pesticide industry, anthracene is indicated to be present
in six pesticide  processes  as  an  impurity.   Raw  waste  load
concentrations  of  this  compound  have  not  been  detected  in
monitored waste  streams.


Benzo(a)anthracene  is not detected or indicated to be present in
the pesticide industry.


Benzo(a)pyrene is not detected or indicated to be present in  the
pesticide  industry.


3,4-Benzofluoranthene is not detected or indicated to be  present
in the pesticide industry.


                               IX-11

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Benzo(ghi)perylene  is not detected or indicated to be present in
the pesticide industry.


In the pesticide industry,  2-chloronaphthalene  is  detected  or
indicated  to  be present in 18 pesticide processes as a reaction
byproduct  or  an impurity.   Raw waste  concentrations   of   2-
chloronaphthalene have been reported at less than 0.01 mg/1.


Chrysene is not detected  or  indicated  to  be  present  in  the
pesticide industry.


Dibenzo(a,h)anthracene is not detected or indicated to be present
in  the pesticide industry.


In  the  pesticide  industry,  fluoranthene  is  indicated  to be
present in six pesticide processes as  an  impurity.   Raw  waste
concentrations   of   this  compound have not  been  detected  in
monitored waste streams.


Indeno(l,2,3-cd)pyrene is not detected or indicated to be present
in the pesticide industry.


In  the  pesticide industry, naphthalene is detected or indicated
to be present in 25 pesticide processes as a  reaction  byproduct
or    as   an   impurity.   Napthalene is  also  associated  with
manufacture  of  biphenyl  and  1,8-napthalic  anhydride;   these
pesticides  are  unregulated at this time pending development  of
data   and  an  analytical  test  method  for   the   pesticides.
Manufacture  of  biphenyl  was discontinued in  1978.   Since  no
limitation  for  napthalene  was  proposed  and  the  number   of
manufacturers  is  now  small  this  priority  pollutant  is  not
regulated.


In  the  pesticide  industry,  phenanthrene  is  indicated  to be
present  in  six  pesticide processes as   an   impurity.    This
compound has not  been detected in monitored waste streams.


Pyrene is  not  detected  or  indicated  to  be  present  in  the
pesticide  industry.
                               IX-12

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Metals-There are 13 compounds which represent the metals priority
pollutant    group.     Copper,  mercury and zinc were chosen  as
pollutants of primary significance since they  are  detected   or
indicated   to  exist   in  significant  concentrations  and  are
independent of other priority pollutants in this group.


Primary   Significance—In  the  pesticide  industry,  copper  is
detected or indicated to be present in 11 pesticide processes  as
a  raw  material or catalyst.  Of six pesticide process raw waste
loads monitored, copper was present at levels  ranging  from  not
detected  to  59,000  mg/1.


Mercury  is detected to be present in one pesticide manufacturing
processes  as a raw material.   Raw waste load  concentration  of
32,000 mg/1 have been measured.


In the pesticide industry, zinc is detected or  indicated  to  be
present in 11 pesticide processes as a raw material, catalyst, or
as  an impurity.  Of two processes monitored, zinc concentrations
were detected in raw waste  streams  at  a  level  of  247  mg/1.
Secondary  Significance—Antimony is not detected or indicated to
be present in the pesticide industry in concentrations  over  the
treatability  level  of  0.1  mg/1.  In the  pesticide  industry,
arsenic  is  detected  or  indicated to  be  present  in  several
pesticide processes as a raw material impurity.  Arsenic has been
detected  in  significant concentrations  in  treated   effluent.


Beryllium is not detected or  indicated  to  be  present  in  the
pesticide   industry   in concentrations  over  the  treatability
level of  0.05  mg/1.


Cadmium  is  not  detected  or indicated to  be  present  in  the
pesticide industry over treatability levels of 0.1  g/1.


Chromium is not detected  or  indicated  to  be  present  in  the
pesticide   industry   in concentrations above  the  treatability
level of 0.1 mg/1.


Lead is not detected or indicated to be present in the  pesticide
industry   in  concentrations  over the treatability level of 0.1
mg/1.


In the pesticide industry, nickel is indicated to be  present  in
one    pesticide   process   as   a   catalyst.    Nickel is  not
indicated   to   be   present  in    concentrations   over    the
treatability level  of 0.1 mg/1.
                               IX-13

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Selenium is not detected  or  indicated  to  be  present  in  the
pesticide   industry   in concentrations  over  the  treatability
level of 0.1 mg/1.


Silver  is  not  detected  or indicated to be   present  in   the
pesticide   industry   in concentrations  over  the  treatability
level of 0.1 mg/1.


Thallium is not detected  or  indicated  to  be  present  in  the
pesticide   industry   in  concentrations over  the  treatability
level of 0.1 mg/1.


Chlorinated Ethanes and Ethylenes-There are  12  compounds  which
represent   the   chlorinatedethanes  and  ethylenes  priority
pollutant  group.


Primary Significance—1,2-Dichloroethane and  tetrachloroethylene
were  chosen as pollutants of primary significance since they are
used as  solvents  in  the  industry  and  are  found  in  higher
concentrations   than the other compounds in this group.  In  the
pesticide    industry,    1,2-dichloroethane   is   detected   or
indicated  to be present in 30 pesticide processes as a  solvent,
reaction byproduct, or  as  an  impurity. Of  the six process raw
waste  loads monitored,  1,2-dichloroethane  concentrations  were
detected  up  to  10,000 mg/1.    In  the   pesticide   industry,
tetrachloroethylene is detected or indicated to be present in  17
pesticide  processes  as  an  impurity,  reaction  byproduct,  or
solvent.   Of  the four processes monitored,  tetrachloroethylene
concentrations  in raw waste loads ranged from 0.37 mg/1 to  less
than 98.0 mg/1.


Secondary Significance—In the pesticide  industry,  chloroethane
is   indicated  to  be  present  in  30 pesticide  processes as a
reaction  byproduct  or  as  an   impurity. This compound was not
detected   in   monitored  waste  streams.    The   presence   of
chloroethane  is  adequately  controlled  by  regulation  of  the
priority pollutant of primary significance, 1,2-dichloroethane.


In the pesticide industry, 1,1-dichloroethane is indicated to  be
present  in  30 pesticide processes as a reaction byproduct or an
impurity.    This  compound  has not  been  detected in monitored
waste streams.   1,1-Dichloroethane  is  adequately controlled by
the regulation of the priority pollutant of primary significance,
1,2-dichloroethane.


In  the  pesticide industry, 1,1-dichloroethylene is indicated to
be present in 19 pesticide processes as a reaction  byproduct  or
                               IX-14

-------
an   impurity.     This  compound  has   not   been  detected  in
monitored   waste   streams.    The   priority   pollutant   1,1-
dichloroethylene  is  adequately  controlled  by  regulation   of
the    priority    pollutant  of   primary   significance,   1,2-
dichloroethane.


In the pesticide industry, hexachloroethane is  indicated  to  be
present  in  11    pesticide processes as a reaction byproduct or
an impurity.  This compound  has not  been  detected in monitored
waste  streams.   Hexachloroethane is adequately  controlled   by
regulation   of  the priority pollutant of primary  significance,
1,2-dichloroethane.


In  the pesticide industry, 1,1,2,2-tetrachloroethane is detected
or indicated to  be  present  in  30  pesticide  processes  as  a
reaction  byproduct or an impurity.   Raw waste concentrations of
this   compound   have  been detected at 1.70 mg/1  in  monitored
waste  streams.    This  compound  is  adequately controlled   by
regulation   of  the priority pollutant of primary  significance,
1,2-dichloroethane.


In  the   pesticide   industry,   1,2-trans-dichloroethylene   is
indicated  to  be  present  in  19  pesticide  processes as a raw
material or an impurity.   This compound has not been    detected
in   monitored   waste   streams.       This compound is expected
to  be  adequately controlled by regulation of  the      priority
pollutant     of    primary    significance, tetrachloroethylene.


In the pesticide industry, 1,1,1-trichloroethane is indicated  to
be  present  in  30   pesticide processes as a reaction byproduct.
This  compound has not been detected in monitored waste  streams.
The  presence  of 1,1,1-trichloroethane is adequately  controlled
by   regulation    of   the   priority   pollutant   of   primary
significance, 1,2-dichloroethane.


In the pesticide industry, 1,1,2-trichloroethane is  detected  or
indicated  to  be present in 30 pesticide processes as a reaction
byproduct  or an impurity.   This compound  has been detected  in
concentrations  up  to  0.02 mg/1  in  monitored  waste  streams.
1,1,2-Trichloroethane  is adequately controlled by regulation  of
the   priority   pollutant    of   primary   significance,   1,2-
dichloroethane.
                               IX-15

-------
In  the  pesticide  industry,  trichloroethylene  is  detected or
indicated to be present in 19 pesticide processes as  a  reaction
byproduct   or   an  impurity.    Raw waste  concentrations  have
ranged  up  to  0.052 mg/1 in monitored raw  wastewater  streams.
The  presence  of  trichloroethylene  is  adequately   controlled
by    regulation    of    the  priority  pollutant   of   primary
significance, tetrachloroethylene.


In the pesticide industry, vinyl  chloride  is  indicated  to  be
present  in  18  pesticide  processes as a raw material, reaction
byproduct,  or  as  an  impurity.    This compound  has  not  been
detected  in   monitored  waste   streams.  Vinyl   chloride   is
adequately    controlled    by   regulation   of   the   priority
pollutant of primary significance, tetrachloroethylene.


Nitrosamines-There   are  three  compounds  which  represent  the
nitrosamine    priority    pollutant    group.     N-nitrosodi-n-
propylamine  was  chosen as a pollutant of  primary  significance
since it  is  found in  higher  concentrations  than  the   other
priority   pollutant  nitrosamines   and controlling   it    will
adequately      control     N-nitrosodimethylamine     and     N-
nitrosodiphenylamine.


Primary  Significance—In  the pesticide industry, N-nitrosodi-n-
propylamine is detected or indicated to be present as a  reaction
byproduct   in  ten processes.   One process has  been  monitored
showing a maximum raw waste concentration of 1.85 mg/1.


Secondary   Significance—In   the   pesticide    industry,    N-
nitrosodimethylamine  is  detected  or indicated to be present in
ten pesticide processes as a reaction byproduct.  Raw waste  load
concentrations  of this compound have been monitored at less than
0.00005 mg/1.   N-nitrosodimethylamine is adequately   controlled
by  regulation of the priority pollutant of primary significance,
N-nitrosodi-n-propylamine.


In the pesticide industry, N-nitrosodiphenylamine is indicated to
be present in two pesticide processes as  a  reaction  byproduct.
This  compound  has  not  been  detected  in  the  waste  streams
monitored in the  pesticide  indudstry.    The    presence     of
N-nitrosodiphenylamine  is adequately  controlled  by  regulation
of the priority pollutant of primary significance, N-nitrosodi-n-
propylamine.


Phthalate Esters-There are  six  compounds  which  represent  the
phthalate  ester priority pollutant group.   Two phthalate esters
are  not detected  or  indicated  to be present in the  pesticide
industry.
                               IX-16

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Secondary  Significance—Bis(2-ethylhexyl)   phthalate   is   not
expected  to  be  present  in  the  pesticide industry.


In the pesticide industry, butyl benzyl phthalate is indicated to
be present in 15  pesticide processes as a reaction byproduct  or
as   an   impurity.   This compound has not been detected in  the
waste streams monitored in the pesticide industry.


In the pesticide industry, dimethyl phthalate is indicated to  be
present  in  12   pesticide processes as a raw material, reaction
byproduct,  or as an impurity.   Dimethyl phthalate is considered
insignificant  since it was detected in the effluent from only  a
small number of sources and is uniquely related to those sources.


In  the  pesticide industry, diethyl phthalate is indicated to be
present in 15  pesticide processes as a reaction byproduct or  an
impurity.   This compound has only been detected in trace amounts
in the pesticide  industry.


In the pesticide industry, di-n-butyl phthalate is  indicated  to
be  present in 15  pesticide processes as a reaction byproduct or
an  impurity.   This  compound has only been  detected  in  trace
amounts in  the  pesticide  industry.


Dichloropropane and Dichloropropene-There are two compounds which
represent   the   cfichloropropane  and  dichloropropene  priority
pollutant  group.    Dichloropropane and dichloropropene were not
selected   as     pollutants    of     primary     significance.,
however,    1,3-dichloropropene   has   been  classified   as   a
pollutant   of  dual significance since it is manufactured  as  a
final product and  has zero  wastewater  discharge.


Dual Significance—In the pesticide industry, 1,3-dichloropropene
is indicated to be present in 17 pesticide  processes  as  a  raw
material,   solvent,   reaction  byproduct,  or  impurity.   This
compound has not been detected in either of the two pesticide raw
waste loads monitored.   1,3-Dichloropropene  is regulated  as  a
priority  pollutant  only  if  it is  manufactured  as  a   final
product.   The  geometric  isomers,  cis-l,3-dichloropropene  and
trans-l,3-dichloropropene,  are  regulated in formulator/packager
wastesteams as pesticides but are not regulated in  manufacturing
wastestreams.
                               IX-17

-------
Secondary   Significance—In   the   pesticide   industry,   1,2-
dichloropropane is  indicated  to  be  present  in  18  pesticide
processes  as  a  raw  material,  solvent, reaction byproduct, or
impurity. 1,2-Dichloropropane was not detected in either  of  the
two  raw  waste loads monitored.


Priority  Pollutant  Pesticides-There  are  18  compounds   which
represent  thepriority  pollutant  pesticide group.  BHC-alpha,
BHC-beta,    BHC-delta,    endosulfan-alpha,     endosulfan-beta,
endrin,  heptachlor,   lindane  (BHC-gamma),   and toxaphene were
chosen  as  pollutants  of primary significance  since  they  are
produced as  final  products.


Primary Significance—In the  pesticide  industry,  BHC-alpha  is
indicated  to  be  present  in  3  pesticide processes as a final
product or a reaction byproduct.  This  compound  has  not   been
detected  in waste streams monitored  in  the pesticide industry.
BHC  was   previously  regulated  under BPT   (direct  discharge)
only.


In the pesticide industry, BHC-beta is indicated to be present in
five  pesticide  processes  as  a  final  product  or  a reaction
byproduct.   This   compound   has not  been  detected  in  waste
streams monitored in the pesticide industry.   BHC was previously
regulated under BPT (direct discharge) only.


In the pesticide industry, BHC-delta is indicated to  be  present
in  five  pesticide  processes  as  a final product or a reaction
byproduct.   This   compound  has not  been detected in the waste
streams  monitored in the pesticide industry.  BHC was previously
regulated under BPT (direct discharge) only.


In  the  pesticide  industry, endosulfan-alpha is indicated to be
present  in  one  pesticide process as  a  final  product.   This
compound has not been detected in the waste streams monitored  in
the  pesticide  industry.   Endosulfan was  previously  regulated
under BPT  (direct discharge) only.


In  the  pesticide  industry,  endosulfan-beta is indicated to be
present  in  one  pesticide process as a  final  product.    This
compound  has not  been  detected in the waste streams  monitored
in the pesticide industry.   Endosulfan was previously  regulated
under BPT (direct discharge) only.
                               IX-18

-------
In  the  pesticide industry, endrin is used as a final product in
one pesticide process.  It has been monitored in  the  raw  waste
load  at  a  level  which  is declared proprietary.   Endrin  was
previously regulated by effluent standards and prohibitions at 40
CFR 129.


In the pesticide industry, heptachlor is detected or indicated to
be  present  in  two  pesticide  processes  as a final product or
reaction  by-product.   Raw  waste concentrations of   heptachlor
have  ranged up to a declared proprietary level.  Heptachlor  was
previously regulated under BPT (dirct discharge) only.


In the pesticide industry, lindane (BHC-gamma) is indicated to be
present  in  two  pesticide  processes  as  a  final product or a
reaction   byproduct.    This compound  has  not been detected in
the waste streams monitored in the pesticide  industry.   Lindane
was  previously  regulated under BPT (direct discharge) only.


In the pesticide industry, toxaphene is used as a  final  product
in  one pesticide process.  Toxaphene concentrations in raw waste
loads  have  been  detected  at   levels   which   are   declared
proprietary.   Toxaphene  was  previously regulated  by  effluent
limitations and prohibitions at 40 CFR. 129.


Secondary    Significance—Priority   pollutant   pesticides   of
secondary  significance are generally not covered by  regulations
for   the   manufacturing  subcategory  1  but  are  covered   by
regulations for the formulator/packager subcategory 3.


In  the  pesticide  industry,  aldrin is detected or indicated to
be present in one pesticide process as a reaction byproduct.  Raw
waste  concentrations  of aldrin have been monitored at  a  level
which  is  declared  proprietary.    Aldrin  is  expected  to  be
adequately  controlled by regulation of the  priority   pollutant
endrin   since   it   is   a  reaction   byproduct   of   endrin.
Additionally,   the  pesticide  aldrin  was  previously regulated
by the effluent limitations and prohibitions at 40 CFR 129.


In   the   pesticide  industry,   chlordane  is predicted  to  be
present  in two pesticide  processes  as  a  final product  or  a
reaction byproduct.  Chlordane was previously regulated under BPT
(direct discharge)  only.


In the pesticide industry, dieldrin is detected or  indicated  to
be present in one pesticide process as a reaction byproduct.  Raw
waste  concentrations  of  this compound have been  monitored  at
levels    which   are   declared    proprietary.    Dieldrin   is
adequately   controlled    by   regulation   of   the    priority


                               IX-19

-------
pollutant   endrin.   Additionally,   the pesticide  dieldrin   was
previously    regulated   by   the    effluent   limitations   and
prohibitions at 40 CFR 129.


In the pesticide industry, 4,4'-DDD is detected or  indicated  to
be  present  in  five pesticide processes as a final product or a
reaction byproduct.    Raw waste concentrations  of  4,4'-ODD have
been monitored at levels which are  declared  proprietary.     The
presence    of    4,4'-ODD   is  adequately     controlled     by
regulation    of    the     pesticide  methoxychlor,      at  the
only    plant where  is currently   manufactured.   Additionally,
4,4'-ODD was previously regulated by the effluent limitations and
prohibitions at 40 CFR 129.


In  the  pesticide industry, 4,4'-DDE is detected or indicated to
be present in five pesticide processes as a final  product  or  a
reaction  byproduct.    Raw  waste concentrations of 4,4'-DDE have
been monitored at levels  which  are  declared  proprietary.  The
presence   of   this   compound is  adequately    controlled    by
regulation    of    the     pesticide  methoxychlor,      at  the
only   plant where it is currently    manufactured.  Additionally,
4,4'-DDE was previously regulated by the effluent limitations and
prohibitions at 40 CFR 129.


In   the  pesticide  industry,  4,4'-DDT  (DDT)  is  detected  or
indicated to be present in five pesticide processes  as  a  final
product, raw material,  or reaction  byproduct.  DDT concentrations
in  solid  wastes  being  contract   hauled have been monitored at
levels  which are declared  proprietary.  Additionally,  DDT  was
previously  regulated by the flluent limitations and prohibitions
at 40 CFR 129.
In  the pesticide industry,  endosulfan sulfate is indicated to be
present  in  one  pesticide  process as  a   reaction   byproduct.
This compound has not been detected in waste streams monitored in
the   pesticide   industry.     Endosulfan sulfate  is  adequately
controlled   by   the  regulation  of  the   priority  pollutant,
endosulfan.


In  the  pesticide  industry,  endrin aldehyde is indicated to be
present in one pesticide process as a  reaction  byproduct.   Raw
waste concentrations of this compound have been monitored in  the
pesticide industry at levels which are declared proprietary.  The
presence   of   endrin  aldehyde   is adequately  controlled   by
regulation  of  the priority pollutant, endrin.


In the pesticide industry, heptachlor epoxide is indicated to  be
present  in two pesticide processes as a reaction byproduct.  Raw
waste  concentrations  have  been monitored in  waste  streams  at
                               IX-20

-------
levels  which are declared  proprietary.    Heptachlor epoxide is
adequately  controlled by regulation of the priority pollutant of
primary significance, heptachlor.


Dienes-There are two compounds which represent the diene priority
pollutant  group.   Hexachlorocyclopentadiene  was  chosen  as  a
pollutant  of  primary  significance  since  it  is used as a raw
material   and   is   found   in   higher   concentrations   than
hexachlorobutadiene.
Primary     Significance—In     the     pesticide      industry,
hexachlorocyclopentadiene  ("HEX") is detected or indicated to be
present in six pesticide processes  as  a  raw   material.    HEX
concentrations  in raw waste loads range from 0.435 mg/1 to 2,500
mg/1.


Secondary     Significance—In     the     pesticide    industry,
hexachlorobutadiene is detected or indicated  to  be  present  in
eight pesticide processes as a solvent, reaction byproduct, or an
impurity.   Raw waste load concentrations have ranged up to 0.191
mg/1.     Hexachlorobutadiene   is    adequately  controlled   by
regulation   of  the priority pollutant of primary  significance,
hexachlorocyclopentadiene.


TCDD-2,3,7,8-tetrachlorodibenzo-p-dioxin  (TCDD)  represents    a
priority    pollutant   group.   In   the   pesticide   industry,
2,3,7,8-tetrachlorodibenzo-p-dioxin   (TCDD)   is   detected   or
indicated to be present  in 11 pesticide processes as a  reaction
byproduct.     TCDD    was    chosen   as   a    pollutant     of
secondary significance  since significant efforts to control this
compound have been undertaken in past years and the Agency is  in
the  process  of completing a study to determine the  sources  of
remaining environmental releases,  if any,  or the sources of any
existing contamination.


Miscellaneous Priority Pollutants-There are five compounds  which
represent  the miscellaneous priority pollutant group.   All five
compounds   have   been  chosen  as  pollutants   of    secondary
significance  since they  lack  adequate  monitoring data or they
are not detected or indicated to be present in this industry.


Secondary  Significance—The compound acrolein is not detected or
indicated to be present in the pesticide industry.   The compound
acrylonitrile  is detected or indicated  to  be present  in  only
one pesticide process.


In  the pesticide industry, asbestos is detected to be present in
72   pesticide/nonpesticide   wastewaters.    Raw   waste    load


                               IX-21

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concentrations  have ranged from nondetectable limits to 0.3 mg/1
(total    calculated     mass    chrysotile     fibers     only).
Asbestos  is  not used in this industry,  and  is  therefore  not
regulated   as   a   pollutant   of  primary  significance.    In
addition, there is no promulgated method for asbestos analysis.


The  compound  1,2-diphenylhydrazine is not detected or indicated
to be present in the pesticide industry.


The compound isophorone  is  not  detected  or  indicated  to  be
present in the pesticide industry.


Polychlorinated  Biphenyls-Seven polychlorinated biphenyls (PCBs)
represent a  priority  pollutant  group.   PCBs  were  chosen  as
pollutants    of  secondary   significance  since  they  are  not
currently indicated to be present in the pesticide industry.


Secondary  Significance—In  the  pesticide  industry,  PCBs  are
indicated  to  be  present  in  one pesticide process as reaction
byproducts. No data are available on the concentration of PCBs in
the raw waste  loads  of  this  pesticide  process.   Since  this
pesticide is not currently manufactured, PCBs are not recommended
for regulation as a pollutant of primary significance.


Benzidines-There  are two compounds which represent the benzidine
priority pollutant group.    Benzidine and 3,3'-dichlorobenzidine
were  chosen as pollutants of secondary significance  since  they
are not indicated to be present in the pesticide industry.


Secondary Significance—The compound benzidine is  not  indicated
to  be present in the pesticide industry.


The  compound  3,3'-dichlorobenzidine  is  not  indicated  to  be
present in the pesticide industry.


All  other  priority  pollutants not discussed  above  have  been
excluded  under  Sections  of Paragraph 8 of the  consent  decree
(NRDC  v.  Train).   These pollutants are listed along  with  the
Paragraph 8 rationale in Appendix 6.


Nonconventional Pesticide Pullutants


Nonconventional pesticide pollutants considered for regulation at
this  time  are listed in Table 11-3 and include those for  which
EPA  approved promulgated analytical methods  are  available.   A


                               IX-22

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general discussion of these pesticides,  their properties, use in
the  industry  and  some information on  production  follows  and
provides  the basis for their selection as pollutants of  primary
significance.   The  availability  or absence of an EPA  approved
analytical  method  for analysis of the pesticide  in  wastewater
effluents  was the primary consideration and  controlling  factor
which   limits  the  main  nonconventional  pesticide  pollutants
regulated     in    the    Pesticides    Effluent     Guidelines.
Formulator/packager wastestreams are limited to zero discharge of
priority  pollutants and the pesticide active ingredients  listed
in  Appendix D of the regulation in process wastewater  generated
by formulating and packaging of the pesticide active  ingredients
in  Appendix  D.   The  pesticide active  ingredients  listed  in
Appendix D are those for which the Agency has approved analytical
methods.  Manufacturing  wastestreams  are  subject  to  effluent
limitations  for only 89 of the pesticides described  here.   The
rationale for exclusion of the other  pesticides from the organic
pesticide  chemicals  manufacturers  regulation is  discussed  in
Section X.
Primary   Significance—Alachlor  is  used  as  a   pre-emergence
herbicide (Martin and Worthing,  1977).   Inhibition of growth in
the  shoots and roots  of  germinating  seedlings  is known    to
occur  in  the  presence  of  alachlor  (McEwen  and  Stephenson,
1979).   Alachlor  has  a residual action lasting 10 weeks to  12
weeks (Martin and Worthing,  1977).  Alachlor has a melting point
of 40°C to 41°C.  Its solubility in water is 240 mg/1  at
23°C (Martin and Worthing,  1977).  An analytizal test method
is available at 40 CFR 455.
Ametryne   is  used  as  a  pre-  and   post-emergence  selective
herbicide   for  the control of broad-leaved and grassy weeds  in
pineapple,  sugar cane,  banana, citrus, corn, and  coffee crops.
Ametryne  forms colorless crystals with a melting point of 84  to
86°C  and  has a very low vapor pressure  at  20°C.   Its
solubility  in  water  is  185 mg/1  at  20°C   (Martin   and
Worthing,  1977).   An analytical test method is available at  40
CFR 136.
Aminocarb  is   a  nonsystemic  insecticide with  acaricidal  and
molluscicidal  activity.   It  is  used against  biting  insects,
mites,  and  slugs.  Aminocarb is a white crystalline solid with a
melting point of 93°C  to  94°C,   and  is only  slightly
soluble in water (Martin and Worthing, 1977).  An analytical test
method is available  at 40 CFR 136.
(AOP)    is  a trade name for the diammonium salt of Nabam in   a
4-percent solution  (Martin  and  Worthing,  1977) Raw waste load
concentrations  of  AOP  have  been  monitored  at levels   which
are   declared   proprietary.    AOP  is a  protective  fungicide
which,  when  applied  to  the soil,  has  systemic  action.   An


                               IX-23

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analytical teat method for AOP is available at 40 CFR 455.


Atraton is a herbicide with the chemical name 2-(ethylamino),  4-
(isoproylamino),   6-methoxyf  s-triazine.    An  analytical  test
method is available at 40 CFR 136.


Atrazine is used as a selective pre- and post-emergence herbicide
on   a  variety  of  crops   including   maize,  sorghum,   sugar
cane,   and   pineapple.    It   is   used   in   water  treatment
against  algae  and  submerged  plants   (Martin   and  Worthing,
1977).   Atrazine  is a colorless crystal with a melting point of
175  C° to 177° C and a very low vapor pressure of 3.0  x
10-7  torr at  20° C.   Its solubility in water is 28 mg/1 at
20°C (Martin and Worthing, 1977).  The half-life for atrazine
in  soil  is  26  weeks  to  78  weeks  (Little,    1980),    and
it    may  be   absorbed   by  clays   such   as  montmorillonite
(Little,  1980).   The  LD50 for fish is considered to  be  12.6
mg/1 (Little,  1980).  It showed low toxicity in tests on rainbow
trout and bluegills (Martin and Worthing,  1977). The general use
and  persistent  nature  of  atrazine  present   the  possibility
for  contamination  of  ground  waters that  are  drinking  water
sources  for  much  of the rural population  of   North   America
(McEwen  and  Stephenson,  1979).   Traces   of atrazine have been
found in finished water in Iowa  cities  obtaining  their  supply
from  wells  and  in higher levels in those supplied from surface
waters (McEwen and Stephenson,  1979).  An  analytical test method
is available at 40 CFR 136.


Azinphos   methyl  is  a  nonsystemic insecticide  and  acaricide
(Martin and  Worthing,   1977).    It  is used  against  foliage-
feeding   insects   and  has  broad spectrum effects (McEwen  and
Stephenson,   1979).    Azinphos   methyl  is  a  white   crystal
with   a   melting   point   of   73°C   to  74°C.    Its
solubility in water is  33  mg/1  at  room   temperature.   It  is
rapidly  hydrolyzed by cold alkali and acid (Martin and Worthing,
1977).  Persistence in the environment is long, lasting 2 or more
weeks (McEwen and Stephenson, 1979). An analytical test method is
available at 40 CFR 136.


Barban  is  a  selective post-emergence herbicide  used  for  the
control   of   wild  oats.    It is a crystalline  solid  with  a
melting  point of 75°C to 76°C.   Its solubility in water
is  11 mg/1 at  25°C  (Martin   and  Worthing,   1977).   The
acute  oral LD50 for rats and mice is 1,300 mg/kg to 1,500 mg/kg,
and the  dermal  LD50  for  rats  is  1,600 mg/kg.  An analytical
test method is available at 40 CFR 136.


Benfluralin  acts as a pre-emergence herbicide for the control of
annual grasses and  broad-leaved  weeds in  lettuce,  tobacco, and
other  forage crops when  incorporated  into  the   soil  (Martin


                               IX-24

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and Worthing, 1977).  Benfluralin is a yellow-orange  crystalline
solid   with   a  melting  point  of  65   to  66.5°C.    Its
solubility  in water is less than 1 mg/1 at 25°C.    It is of
low  to moderate persistence in  the  environment   (Martin   and
Worthing,  1977).


An analytical test method is available at 40 CFR 455.


Benomyl  is  a protective and eradicant fungicide  with  systemic
activity  used  on  a  wide range of  fungi   in   fruit-.^.  nn*-o
vegetables,   and  ornamentals.   It is a white crystalline SOJ..L-U
with a faint acrid odor.   At 20°C its solubility  in   water
is   3.8   mg/1   (Martin   and   Worthing,    1977).   Benomyl's
fungicidal   action   is  effected  by  adsorption   to   spindle
fibers  involved  in  cell division. An analytical test method  is
available at 40 CFR 455.
Bentazon,    a  contact  herbicide,   is  used  for  control   of
Matricaria,  Anthemis  spp.,   and  other  plants in  winter  and
spring  cereals.   It is ineffective as a pre-emergence herbicide
since it is absorbed by leaves,  and  it has  little  effect   on
germinating   seeds (Martin and Worthing,  1977).   Bentazon is a
white odorless crystalline  powder  with  a melting  point of 137
C to 139°C.   Its solubility in water is 500 mg/L (Martin and
Worthing,  1977).    An analytical test method is available at 40
CFR 455.
Bolstar   is  an  insecticide.   An  analytical  test  method  is
available at 40 CFR 455.


Bromacil is recommended for general weed control on noncrop  land
such  as railroad rights-of-way.   It is a nonselective inhibitor
of photosynthesis and  is absorbed  mainly  through roots.  It is
also used for annual weed control  in  established  citrus    and
pineapple    plantations.  Bromacil is a white crystalline  solid
with a melting point of 158°C  to 159°C.   Its solubility
in  water  is 815 mg/1 at 25°C (Martin and  Worthing,  1977).
The  average   half-life   in the environment  of   bromacil   is
several  months,  and  moderate  mobility in the  soil  has  been
observed   (McEwen  and  Stephenson,  1979).  An analytical  test
method is available at 40 CFR 455.
Busan   40   is  a  fungicide.   An  analytical  test  method  is
available at 40 CFR 455. Busan 85 a fungicide. An analytical test
method is available at 40 CFR 455.
Butachlor  is  a pre-emergence herbicide used in the  control  of
annual grasses and certain broad-leaved  weeds  in rice.   It  is
                               IX-25

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a  light  yellow  oil with a  boiling  point  of  196°C.  Its
solubility in water is 20 mg/1 at 20°C (Martin and  Worthing,
1977). An analytical test method is available at 40 CFR 455.


Captan  is  a  nonsystemic  fungicide  used  mainly  for  foliage
protection.   The technical product is an amorphous solid,  white
to beige in  color with a pungent odor.  Its melting point is 160
°C to 170°C (Martin and Worthing,  1977).  The acute oral
LD50  is  9,000  mg/kg for  rats.  In  the   environment,  captan
decomposition produces hydrochloric acid and its rapid hydrolysis
can  lead  to  toxic effects  on  sensitive  plants  (McEwen  and
Stephenson,  1979).   Under alkaline conditions, captan  produces
hydrogen  sulfide gas.   Captan is of relatively long persistence
in  the  environment  (Vettorazzi,   1979).   An analytical  test
method is available at 40 CFR 136.
Carbam-S   is   a soil fungicide.   An analytical test method  is
available at 40 CFR 455.


Carbaryl  is  a   broad   spectrum   contact   insecticide   with
slight   systemic properties.    Carbaryl  is  used   extensively
for foliar pests in agriculture, pests in home gardens and lawns,
and   ectoparasites  (fleas  and  ticks)  on livestock  and  pets
(McEwen,  1979;  Martin, 1977).  Carbaryl is a white  crystalline
solid   with  a  melting point  of  142"C.    Its  solubility
in water is 40 mg/L at 30&C (Martin and Worthing,  1977).  An
analytical test method is aailable at 40 CFR 136.


Carbendazim  is  a  broad-spectrum  systemic  fungicide  and   is
absorbed  by  the  roots and the green tissue of plants.  It is a
light  grey powder with a solubility  in  water  of  5.8 mg/L  at
20°C (Martin and Worthing,  1977).  An analytical test method
is available at 40 CFR 455.


Carbofuran is a broad-spectrum,  systemic insecticide, acaricide,
and nematicide.   It is a white, odorless, crystalline solid with
a  solubility   in  water of  700  mg/L  at 25°C (Martin  and
Worthing,  1977).   The  half  life  of  carbofuran  in the  soil
ranges from 30 days to 80 days (McEwen and Stephenson, 1979).  An
analytical test method is available.


Carbophenothion      is    a  nonsystemic     insecticide     and
acaricide   used   for  preharvest treatments  on  deciduous  and
citrus fruits.  It is  also  used  as seed  dressing  for  cereal
grains (Vettorazzi,  1979).   It is an off-white to amber-colored
liquid  with  a  mild  mercaptan-like odor.   Its  boiling  point
is  82°C  and it is soluble in water at the rate of  40  mg/L
(Martin  and  Worthing,  1977).  An  analytical  test  method  is
available at 40 CFR 136.
                               IX-26

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Chlorobenzilate   is   a  nonsystemic   acaricide,    of   little
insecticidal action,  used for the control of mites on citrus and
deciduous fruit.   It is a pale yellow solid with a melting point
of  35°C to 37°C and  a  boiling point  of  156°C  to
158°C.   The  technical  product  is  a  brownish  liquid  of
approximately 96  percent  purity  and  is  practically insoluble
in  water (Martin and Worthing,  1977). An analytical test method
is available at 40 CFR 455.


Chlorpropham  is a selective pre-emergence herbicide and  mitotic
poison.   It has been generally used to prevent potato  sprouting
(Martin   and  Worthing,  1977).   Its  solubility  in  water  at
25°C is 89 mg/L,  and its melting point is from 38.5°C to
40°C. An analytical test method is available at 40 CFR 136.


Chlorpyrifos   is  a broad spectrum insecticide and is  effective
by  contact/  ingestion,   and  vapor  action.   It  is  used for
the control of larvae and adult mosquitos, soils, and foliar crop
pests,  and  for ectoparasites on sheep and cattle  (Martin   and
Worthing,   1977;  McEwen  and  Stephenson,  1979).  Chlorpyrifos
persists   in  the soil for 2 to 4 months (Martin  and  Worthing,
1977). An analytical test method is available at 40 CFR 455.


Chlorpyrifos   methyl  has  a  broad range  of  activity  against
insects  and is   effective   by    contact,    ingestion,    and
vapor   action.  Chlorpyrifos  methyl  is used on  stored  grains
foliar  crop  pests. Its  form  is  white  crystals with a slight
mercaptan  odor and a melting point of 45.5°C to  46.5°C.
Its  solubility  in water is  4 mg/L  at   25°C  (Martin  and
Worthing, 1977). An analytical test method is available at 40 CFR
455.
Coumaphos  is a contact and systemic insecticide used on animals,
including poultry.    Application  is made by dipping,  spraying,
adding  to  feed,  and dusting.   An analytical  test  method  is
available at 40 CFR 455.


Cyanazine is a pre- and post-emergence herbicide used for general
weed  control.   It  is   a white  crystalline   solid   with   a
melting  point of 166.5°C and solubility in water of 171 mg/L
(Martin  and  Worthing,  1977).   An  analytical test  method  is
available at 40 CFR 455.
2,4-D  along with its salts and esters (2,4-D isobutyl ester  and
2,4-D  isocotyl  ester)  are systemic  herbicides  used  for  the
weeding  of cereals  and  other  crops.  2,4-D is  a white powder
with a slight phenolic odor.  2,4-D has a melting point of  140.5


                               IX-27

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°C,  and  its solubility  in  water  is  620 mg/L at 25°C
(Martin and Worthing,  1977).    2,4-D persists in the soil for at
least  1 month (Martin and Worthing,  1977).   An analytical test
method  for 2,4-D and its salts and esters is available at 40 CFR
136.
2,4-DB  and its esters (2,4-DB isobutyl ester and 2,4-DB  isoctyl
ester) are translocatable herbicides similar to 2,4-D.    They are
more  selective  because  their activity depends on oxidation  to
2,4-D  by  the plant.    It  is  used   on   lucerne,    undersown
cereals,   and grasslands.   An analytical test method  for 2,4-DB
and its esters is available at 40 CFR 455.
DBCP   (dibromochloropropane)    is a soil fumigant  used  in  the
control of nematodes.  It is an amber to dark brown liquid with a
mildly  pungent  odor  and  a  boiling point of  196°C.   Its
solubility  in water is 1000 mg/L at room temperature (Martin and
Worthing,   1977).   DBCP  is persistent  in  the  soil,  thereby
requiring  a  long aeration time before planting such  crops   as
potatoes and tobacco (Martin and Worthing,  1977).  An analytical
test method is available at 40 CFR 455.
DCNA (dichloran) is a protectant fungicide  which  is  used   for
foliar  application   and   soil treatment.     During  preharvest
it  is  used  on  vegetables and cotton,  while at post harvest it
is  used  as  a  dip  for   peaches,  nectarines,   and   carrots
(Vetbtorazzi,   1979).    It   is a yellow  odorless  crystalline
solid  with a melting point of 195°C.     DCNA is  practically
insoluble  in water (Martin and Worthing,  1977).   An analytical
test method for dichloran is available at 40 CFR 136.
Deet   is   an  insect repellent  which  is   effective   against
mosquitoes.    It  is  a colorless to amber liquid with a boiling
point  of  111°C.   Deet is practically  insoluble  in  water
(Martin and Worthing,  1977).  An analytical test method for deet
is available at 40 CFR 455.


Demeton  is a systemic insecticide and acaricide which has   some
fumigant   action.    It  rapidly   penetrates   plants   and  is
effective  against sap-feeding insects and mites.   Demeton is  a
colorless   oil   with  a  boiling point   of   123°C.    Its
solubility   in water is 60 mg/L at room temperature (Martin  and
Worthing, 1977).  Analytical test methods for demeton, demeton-o,
and demeton-s are available at 40 CFR 136.


Demeton-o is a systemic insecticide and acaricide which has  some
fumigant  action.  It  is a colorless oil with a boiling point of
123°C.    Its  solubility  in  water  is  60  mg/L  at   room
temperature.


                               IX-28

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Demeton-s  is a systemic insecticide and acaricide which has some
fumigant action. It is a colorless oil with a  boiling  point  of
128°C.    Its   solubility   in  water is 2000 mg/L  at  room
temperature.


Diazinon  is a nonsystemic insecticide  and  acaricide  used   on
rice,   sugar  cane,  corn, tobacco,  and potatoes.  It is a pale
to  dark  brown liquid with a solubility in water  of  40   mg/L.
Diazinon  persists  on plants  for  7 days to 10 days (McEwen and
Stephenson,  1979).  An  analytical test method for  diazimon  is
available at 40 CFR 136.


Dicamba  is a post-emergence,  translocateable herbicide used for
weed  control  in  cereals.    The  pure  compound  is  a   white
crystalline solid with a melting point of 114  to 116°C.  Its
solubility  in water is 4500 mg/L at  25°C.   The   technical
acid  is  a  pale  buff  crystalline  solid  of  about 83 percent
to 97 percent purity (Martin and Worthing,  1977).  An analytical
test method is available at 40 CFR 136.
Dichlofenthion is a nonsystemic insecticide and nematicide  which
is  applied to the soil.  It is a colorless liquid with a boiling
point  of 120  to 123°C.   Its solubility in water  is  0.245
mg/L  at 25°C.   The technical product is 95 percent  to   97
percent  pure (Martin  and  Worthing,   1977). An analytical test
method is available at 40 CFR 136.
Cis-l,3-dichloropropene    and   trans-l,3-dichloropropene    are
geometric  isomers  of  1,3-dichloropropene which  was  discussed
under priority pollutants.  Analytical test methods for  priority
pollutants are available at 40 CFR 136.


Dichlorophen     salt    is    the   sodium    salt    form    of
dichlorophen.  Dichlorophen is a fungicide and  bactericide  used
in  the protection of materials from molds and algae.  It is also
employed in combating tapeworm infestation in man and animals  as
well  as being a component in an athlete's foot preparation.  Its
solubility  in  water  is 30 mg/L at 25° C  and  its  melting
point  is at  least  164°C.  There is no available analytical
test method for dichlorophen or dichlorophen salt.
                               IX-29

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Dichlorvos  is  a  contact  and  stomach  insecticide  which  has
penetrant and  fumigant action.   Dichlorvos  is  used  on  crops
and as a household and public health fumigant.   It is a colorless
to amber  liquid  with an  aromatic  odor and has a boiling point
of  35°C  and is soluble in water at room temperature at  the
rate of 10000 mg/L  (Martin  and Worthing,  1977).  An analytical
test method is available at 40 CFR 455.
Dicofol   is   a   nonsystemic  acaricide    which   has   little
insecticidal  activity.   It  is used to control mites on a  wide
range  of crops.   The technical product is a brown  viscous  oil
which    is   practically   insoluble   in   water  (Martin   and
Worthing, 1977).  Because  dicofol  is practically  insoluble  in
water  and  unaffected  by  light  or moisture  it  persists   in
the environment.  In the soil, dicofol persists for more than one
year (McEwen  and  Stephenson,   1979). An analytical test method
is available at 40 CFR 136.
Dinoseb   is   a  contact herbicide  used  as   a  post-emergence
annual  weed  control on peas and cereals.    Ammonium  and  amine
salts  are the most  widely  used form  of   dinoseb.     It  is an
orange-brown  liquid  with a melting point  of  30   to  40°C.
Dinoseb  is  soluble in water at a  rate  of 100   mg/L   (Martin
and  Worthing,   1977). An analytical test  method is  available at
40 CFR 455.


Dioxathion   is  a nonsystemic  insecticide  and  acaricide  used
on   livestock for external parasites and  on  fruit   trees   and
ornamentals.   The technical  product  is a brown liquid which is
insoluble in water (Martin and Worthing,  1977).   An  analytical
test method is available at 40 CFR 136.


Disulfoton   is a systemic insecticide and  acaricide  for use   in
protecting   seeds and  seedlings.    It is applied as a seed  or
soil  treatment.   The technical product is a dark yellowish  oil
with   a   solubility   in water of 25 mg/L at  room  temperature
(Martin and Worthing,  1977). When applied  in the  granular form,
disulfoton is taken up by plants over an extended period of time.
An analytical test method is available at 40 CFR 136.


Diuron is a herbicide used for general weed control on crops such
as sugar cane,  citrus,  pineapple,  and cotton.    Diuron  kills
weeds   by   inhibiting   photosynthesis.    It   is    a   white,
odorless  solid  with a melting  point  of   158   to   159°C.
Its  solubility  in  water  at  25°C is 42  mg/L  (Martin  and
Worthing, 1977).  Diuron is persistent and  immobile in  the  soil
since  it  is  stable  to  oxidation  and  moisture  (McEwen  and
Stephenon,  1979).   An analytical test method is available at 40
CFR 136.
                               IX-30

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Ethalfluralin is a pre-plant herbicide  which  kills  germinating
weeds;  however,  weeds  which  are established are tolerant.  In
soil, ethalfluralin  has  residual  action  on  broad-leaved  and
annual  grass weeds in cotton, dry beans, and soybeans.  The pure
compound is a yellow-orange  crystalline  solid  with  a  melting
point  of  55  to 56°C,  its solubility in water is 0.2  mg/L
(Martin  and   Worthing,   1977).  An analytical test  method  is
available at 40 CFR 455.
Ethion  is  a nonsystemic insecticide and   acaricide   used   on
both  plants  and  animals. Specifically,  it  is  used  on  such
crops  as  citrus,  deciduous fruit,  tea,  and  some  vegetables
(Vettorazzi, 1979).  Ethion is  a white  to  amber-colored liquid
which  is  only slightly soluble in water (Martin  and  Worthing,
1977).    Ethion   is   persistent  in  the  soil   for   several
months (McEwen and Stephenson,  1979).  An analytical test method
is available at 40 CFR 136.
Ethoprop   is   a nonsystemic,   nonfumigant nematicide and  soil
insecticide  used  on many crops.   It is a  clear,  pale  yellow
liquid  with  a  boiling point  of 86  to 91°C.   Ethoprop is
soluble  in  water  at a rate of 750 mg/L (Martin  and  Worthing,
1977).  There is no analytical test method available for ethoprop,


Etridiazole is a fungicide used for control  of  some  soil-borne
diseases  of  turf  and  ornamentals.   It is also used as a seed
treatment for pre- and post-emergence cotton  seedling  diseases.
The   technical  product  is  a  reddish-brown  liquid  which  is
practically  insoluble in water.   An analytical test  method  is
available at 40 CFR 455.


Fensulfothion  is  an  insecticide and nematicide applied to soil
and  has   long   persistence   and   some   systemic   activity.
Fensulfothion  can  penetrate plant tissue.  It is an oily yellow
liquid with a boiling point of 138  to 141°C.   Fensulfothion
is only  slightly  soluble  in  water with a rate of 1500 mg/L at
25 °C (Martin and Worthing,  1977).    Fensulfothion persists
in  the  soil for months.  An analytical test method is available
at 40 CFR 455.


Fenthion is a contact and stomach  insecticide  with  penetrating
action used against fruit flies,  leaf hoppers,  and cereal bugs.
The technical product is a brown,  oily liquid with a weak garlic
odor.   Fenthion is  soluble in  water  at  room  temperature  at
a  rate  of  54  mg/L to 56 mg/L  (Martin  and  Worthing,  1977).
Fenthion persists in the  soil  for  several months  (Vettorazzi,
1979). An analytical test method is available at 40 CFR 455.
                               IX-31

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Fenuron  is  a herbicide which is absorbed through roots and acts
by inhibiting photosynthesis.  It is  used  especially  on  woody
plants.   Fenuron  is  a white, odorless crystalline solid with a
melting point of 133  to 134°C.   Its solubility in water  is
3850 mg/L  at  25°C.   An analytical test method is available
at 40 CFR 136.
Fenuron-TCA is a mixture of the two herbicides, fenuron and  TCA.
It  is  recommended  for  the  control of woody plants on noncrop
areas.  Fenuron-TCA is a white, odorless crystalline solid with a
melting  point  of 65  to 68°C.   Its solubility in water  is
4800  mg/L  at room temperature.   An analytical test  method  is
available at 40 CFR 136.


Ferbam  is  a  fungicide used mainly  for   the   protection   of
foliage  by spraying.   It is a black powder with a solubility in
water  of  130 mg/L  at room temperature  (Martin  and  Worthing,
1977). An analytical test method is available at 40 CFR 455.


Fluometuron is a herbicide with weak foliar activity which can be
absorbed  through roots.   It is used for control of broad-leaved
and  grass  weeds.  Fluometuron is in the form of white  crystals
with a melting point of  163  to 164.5°C.   Its solubility in
water  at 20°C is 105 mg/L (Martin and Worthing,  1977).   An
analytical test method is aailable at 40 CFR 455.


Glyphosate  is a relatively nonselective, post-emergent herbicide
used   on  annual and  perennial   grasses/  sedges,  and  broad-
leaved   weeds.    It  is  a  white   solid   that   melts   with
decomposition   at  230°C.    Its solubility  in   water   is
12000   mg/L   at  25°C  (Martin  and  Worthing,  1977).   An
analytical test method is available at 40 CFR 455.


Hexazinone  is a  post-emergence  contact  herbicide used against
many  annual,  biennial,  and perennial weeds.   It is  a  white,
odorless, crystalline  solid with  a melting point of 115  to 117
°C.   Hexazinone  is soluble in water at a rate of 33000 mg/L
at 25 °C (Martin and  Worthing,   1977).   An analytical test
method is available at 40 CFR 455.


Isodrin  a  diene-organochlorine insecticide which is  stable  in
soil  and  relatively  stable  to  the  ultra  violet  action  of
sunlight.   It's  chemistry  and uses are similar  to  chlordane,
aldrin,  dieldrin and heptachlor.   An analytical test method  is
available at 40 CFR 136.


Isopropalin is a pre-plant herbicide incorporated in the soil for
direct  seeded  tomatoes.   It  is  a  red-orange  liquid  with a


                               IX-32

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solubility  in water of 0.1 mg/L.
available at 40 CFR 455.
   An analytical test method  is
KN  methyl   is   a  fungicide.
available at 40 CFR 455.
An  analytical  test  method  is
Linuron  is   a  selective  pre-  and  post-emergence   herbicide
which  inhibits photosynthesis.   It is used on soybeans, cotton,
potatoes,  carrots,   and   winter  wheat.  Linuron  is  a  white
odorless   crystalline  solid  with a melting  point  of  93   to
94°C.  Its solubility in water is 75 mg/L at 25°C (Martin
and  Worthing,   1977).    Linuron  decomposes  slowly  in  soil,
persisting  up  to 4 months (Martin  and   Worthing,  1977).   An
analytical test method is available at 40 CFR 136.


Malathion   is   a nonsystemic  insecticide  and  acaricide.   It
can  be  phytotoxic  to  cucumber,   string  bean,   and  squash.
Malathion  has  a  wide  range of  uses  including  agricultural,
horticultural,  and   household  pest.  It  is   a  clear,  amber
liquid with a boiling point of 156  to 157°C.  Its solubility
in  water   is   145  mg/L  at  room   temperature  (Martin   and
Worthing,   1977).   An analytical test method is available at 40
CFR 136.


Mancozeb  is  a protective fungicide used against a wide range of
foliage  diseases.  It  is  a  greyish-yellow   powder   and   is
practically  insoluble in water (Martin and Worthing, 1977).
An analytical test method is available at 40 CFR 455.
Maneb  is  a  protective  fungicide  used  against  many  foliage
diseases  in potatoes and tomatoes.   It is a yellow  crystalline
solid  which  is  only  slightly soluble  in  water  (Martin  and
Worthing, 1977). An analytical test method is available at 40 CFR
455.
Mephosfolan  is  a  contact   and   stomach   insecticide   which
demonstrates    systemic  activity  following  root   or   foliar
absorption.   It is used on such crops  as  cotton,   vegetables,
fruit,  and field crops.  It is a yellow  to  amber  liquid  with
a   boiling   point  of   120°C.  Mephosfolan  is  moderately
soluble in water (Martin and Worthing, 1977).  An analytical test
method is available at 40 CFR 455.
Metham is a soil fungicide,  nematicide, and  herbicide which has
fumigant  action.   It decomposes to the active component  methyl
isothiocyanate.    Metham is phytotoxic and is persistent in  soil
                               IX-33

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for  approximately  two  weeks.   It is a white,  crystalline solid
with  a  solubility in water of  722000 mg/L at 20°C   (Martin
and Worthing,   1977).  An analytical test method is available at
40 CPR 455.
Methiocarb  is  a  nonsystemic  insecticide  and acaricide with a
broad range of action which  includes  effectiveness  in  killing
snails.   It  is  also used as a bird repellent by seed dressing.
Methiocarb is a white crystalline powder with a melting point  of
117    to 118°C.   It is practically insoluble in  water.  An
analytical test method is available at 40 CFR 136.


Methomyl   is   used  for control  of  many   insects  by  foliar
application  and  has  systemic action when incorporated  in  the
soil.  It is a white  crystalline solid  with a slight sulphurous
odor.   The melting point is 78 to 79°C.  Methomyl is soluble
in water at a rate of 58 g/1 at  25°C (Martin  and  Worthing,
1977).  An analytical test method is available at 40 CFR 455.


Methoxychlor    is    a  nonsystemic    contact    and    stomach
insecticide.   It  has  been recommended for fly control in dairy
barns,  and  is  used   on  many crops    near    harvest    time
(McEwen   and  Stephenson,   1979).  Methoxychlor  is   a   grey,
flaky   powder   which   is   practically  insoluble   in   water
(Martin  and  Worthing,  1977).   An  analytical test  method  is
available at 40 CFR 136.
Metribuzin   is   a  herbicide   used  in   soybeans,   potatoes,
tomatoes,  and  other  crops.   The technical product is white  to
yellowish and crystalline,    and its  solubility in water is 1200
mg/1 at 20°C (Martin and Worthing, 1977).  An analytical test
methods is available at 40  CFR 455.


Mevinphos  is  a  volatile   contact   and systemic insecticide and
acaricide used against sap-feeding insects, mites,   beetles,  and
caterpillars.   The  technical product is a pale yellow to orange
liquid  with  a  mild  odor.  The boiling   point   is   99    to
103°C.   Mevinphos   is   soluble  in   water   (Martin   and
Worthing,  1977).   An analytical test method is available at  40
CFR 455.


Mexacarbate  is  used as a  molluscicide and has a solubility   of
100  mg/L   at   25°C.     Its  melting  point  is    85°C
(Windholz,  1976).  An  analytical test method is available at 40
CFR 136.


Mirex  is  a stomach insecticide with  little  contact  activity.
Its   widest use  has been  against fire ants.   Mirex is a  white


                               IX-34

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solid  which  is practically insoluble  in  water   (Martin   and
Worthing,   1977).  An  analytical test metnod is available at 40
CFR 136.


Monuron  is  a  herbicide  which  is  absorbed by roots and is an
inhibitor of photosynthesis.  It is used on noncrop land such  as
rights-of-way,  industrial  sites, and drainage ditches.  Monuron
is a white odorless crystalline solid with a melting point of 174
to  175°C.    Its  solubility  in  water  is  230   mg/L   at
25°C.   An analytical test method is available at 40 CFR 136.


Monuron-TCA is a general herbicide used for total weed control in
uncropped  areas  such  as  rights-of-way,  industrial sites, and
drainage ditches.  Monuron-TCA is  a  crystalline  solid  with  a
melting  point  of  78   to 81°C.  Its solubility in water is
918  mg/L  at room temperature.   An analytical  test  method  is
available at 40 CFR 136.
Nabam is a  protective  fungicide  which,   when  applied  to the
soil,  has  systemic action.   Nabam  is  too  phytotoxic  to  be
applied   to  foliage.    It  exists in  the  form  of  colorless
crystals.   Nabam  is very soluble in water  and  forms  a yellow
solution  (Martin and Worthing,  1977). An analytical test method
is available at 40 CFR 455.


Naled  is  a  fast-acting   nonsystemic   contact   and   stomach
insecticide   and   acaricide   with   fumigant  action.   It  is
recommended for use in greenhouses, mushroom houses, and  against
adult  mosquitoes  and  flies on crops.  Naled is a yellow liquid
with  a slightly pungent odor and a boiling point  of  110°C.
It is practically insoluble in water (Martin and Worthing, 1977).
An analytical test method is available at 40 CFR 455.


Neburon  is  a  pre-emergence herbicide which is absorbed through
roots and acts by inhibiting photosynthesis.  It  is  recommended
for  control  of annual weeds and grasses in wheat, strawberries,
and nursery plantings of certain woody ornamentals.  Neburon is a
white,  odorless,  crystalline  solid  with  a melting  point  of
102°C to  103°C.    Its  solubility in water is 4.8  mg/L
at  24°C.   An analytical test method is available at 40  CFR
136.
Niacide  is  a fungicide.  An analytical test method is available
at 40 CFR 455.


Oxamyl  is a  contact-type  insecticide  with  residual   action.
It   is  applied   to   foliage  and  soil.   In  plants,  oxamyl
translocates in both an upward and downward direction.   Oxamyl is


                               IX-35

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applied to soil to control nematodes and to  foliage  to  control
a   variety   of insects.    Oxamyl  is  a   white,   crystalline
solid  with  a  slight sulphurous odor.   Its  melting  point  is
100°C  to  102°C  and  is soluble  in  water  at  a  rate
of   280,000 mg/L  at 25°C (Martin and  Worthing,  1977).  An
analytical test method is available at 40 CFR 455.


Parathion ethyl and Parathion methyl are nonsystemic contact  and
stomach  insecticides which have some  fumigant   action.    They
are  used  as a household spray for ants and cockroaches  (McEwen
and Stephenson,  1979).   Parathion methyl is a white-crystalline
powder with a melting point of 35   to  36°C.   Approximately
60  mg/L  of parathion methyl is  soluble  in water at  25°C.
The  technical product is a light  to  dark  tan  liquid  (Martin
and Worthing,   1977). Analytical test methods for both parathion
ethyl and parathion methyl are available at 40 CFR 136.


PCNB  (pentachloronitrobenzene) is a fungicide used for seed  and
soil  treatment.   It  exists in the form of   colorless  needles
with   a   melting  point  of  146°C.   PCNB  is  practically
insoluble in water (Martin and  Worthing,   1977).  An analytical
test method is available at 40 CFR 136.


PCP  salt exists in the form of buff flakes with a solubility  in
water of  330,000 mg/L at 25°C (Martin and  Worthing,   1977).
An analytical test method is available at 40 CFR 136.


Perthane is a nonsystemic insecticide with specific applications.
It is recommended for use against pear psylla, leaf hoppers,  and
various  larvae  on  vegetable  crops.   Perthane is also used to
control clothes moths and carpet beetles.  The technical  product
is   a   wax  with  a  melting  point above 40°C and  is  .pa
practically   insoluble  in  water.    Perthane  is  of  moderate
persistence in soil.

An analytical test method is available at 40 CFR 136.


Phorate is a systemic and contact insecticide and acaricide  used
to  protect crops  such  as root  and  field crops,  cotton,  and
coffee.   It is also used as a soil insecticide on corn and sugar
beets.    Phorate   is  a  clear liquid  with a boiling point  of
118   to 120°C.   Its solubility in water is 50 mg/L at  room
temperature  (Martin  and  Worthing,   1977).   Phorate  is  very
persistent  in  the   environment.  It  has   been   shown   that
carrots  are capable of taking up and storing large quantities of
phorate  (Vettorazzi,   1979).   An  analytical  test  method  is
available at 40 CFR 455.
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Profluralin  is  a  preplant herbicide  applied  to   soil.    It
is  used  to  control annual and perennial weeds and  grasses  in
cotton,   soybeans,  and  other  crops.  It  is  a  yellow-orange
crystalline  solid  with  a  melting  point  of  32°C.    Its
solubility in water is 0.1 mg/L at 20°C.   An analytical test
method is available at 40 CFR 136.


Prometon  is  a  nonselective herbicide for the control of annual
and   perennial  broad-leaved and  grass  weeds.   Prometon is  a
white  crystalline  solid  with  a melting  point  of  91   to 92
°C.   Its  solubility in water is 750 mg/L at  20°C.   An
analytical test method is available at 40 CFR 136.


Prometryn  is  a  pre-  and  post-emergence  herbicide  which  is
used for selective weed control in cotton, peas, carrots, celery,
and   potatoes.    It   is  a  white crystalline  solid  with   a
melting  point  of  118   to  120°C.  Prometryn is soluble in
water  at  a rate of 48 mg/L at  20°C.   An  analytical  test
method is available at 40 CFR 136.
Propachlor is  a  pre-emergence  herbicide  used  against  annual
grasses    and  certain  broad-leaved  weeds  in  corn,   cotton,
soybeans, and  several  other vegetable crops.  It is a light tan
solid with a melting point of 67   to  76°C.    Propachlor is
soluble in water at a rate of 700 mg/L at  20°C.   Propachlor
persists  in  the  soil  from  4 to 6 weeks (Martin and Worthing,
1977). An analytical test method is available at 40 CFR 455.


Propazine   is   a  pre-emergence  herbicide used against  broad-
leaved and grass weeds in millet and carrots.   It is in the form
of colorless crystals with a melting point of 212  to  214°C.
Propazine  is soluble  in  water at  a  rate  of  8.6  mg/L at 20
°C. An analytical test method is available at 40 CFR 136.


Propham is a selective  pre-planting,  pre-emergence,  and  post-
emergence  herbicide  used mainly for the control of annual grass
weeds in peas and beets.  It is absorbed by  roots  and  acts  by
inhibiting  cell  mitosis  (Vettorazzi,  1979).   It exists in the
form  of  white  crystals  with  a  melting  point  of   87    to
87.6°C.  Prophams'  solubility in water has been reported  at
various rates including 32 mg/L,  100 mg/L,  and  250  mg/L  from
20    to  25°C (Martin  and Worthing,  1977).   An analytical
test method is available at 40 CFR 136.
Propoxur  is   a nonsystemic  insecticide with  rapid  knock-down
power.    It  is  used extensively on  field  crops,  fruits,  and
vegetables,    and   in   the  household   against   flies    and
cockroaches.    Propoxur  has some systemic action in plants.  It
is  a  white crystalline powder with a faint odor and  a  melting


                               IX-37

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point  of 84  to  87°C.   Propoxur  is soluble in water at  a
rate  of  2000  mg/L at 20°C  (Martin  and  Worthing,  1977).
Propoxur  has  residual activity for several weeks  when  applied
indoors   (McEwen  and  Stephenson,  1979).   An analytical  test
method is available at 40 CFR 136.
Ronnel  is  a  systemic insecticide which is used as  a  residual
spray for flies and other household pests.    It is also used as a
spray   for control  of  ectoparasites  of    livestock,  poultry,
and household pets.  Ronnel is a white, crystalline powder with a
melting point of 40  to 42°C.    Its solubility in water is 40
mg/L  (Martin  and Worthing,   1977).    An  analytical test method
is available at 40 CFR 455.
Secbumeton  is  a  herbicide.    It is a colorless powder  with  a
melting point of 86°C.   Its solubility in water  is 600 mg/L
at  20"C.   It is taken up by leaves and roots  and  controls
mono- and  di-cotyledonous  weeds.  An analytical test method  is
available at 40 CFR 136.
Siduron  is  a  selective  herbicide  which  is  used  to control
crabgrass and annual weed grasses.    It  is  a  white,  odorless,
crystalline,   solid   with   a   melting  point   of   133    to
138°C.
Siduron  is soluble in water at a rate of 18 mg/L  at
An analytical test method is available at 40 CFR 136.
25°C.
Silvex are  hormone-type herbicides  which are absorbed by leaves
and  stems and demonstrate translocation properties.     They  are
used   for  control  of  brush submergent  and  emergent  aquatic
weeds,   and  weed control for certain crops.    Silvex is a white
powder  which  is  soluble  in water  at a rate of 140 mg/L at 25
°C.  An  analytical test method for silvex and its salts  and
esters is available at 40 CFR 136.
Simazine   is  a pre-emergence herbicide used for   the   control
of  broad-leaved  and grassy  weeds  in  deep-rooted  crops  such
as  citrus,  deciduous  fruits,  and  olives.   It is   a   white
crystalline  solid  with  a melting  point of 225  to  227°C.
Simazine  is  soluble  in  water at a rate of 5 mg/L  at  20   to
22°C.

An analytical test method is available at 40 CFR 136.


Simetryne  is a herbicide which is used in combination with  S-4-
chlorobenzyl  diethyldithiocarbamate to  control woodleafed weeds
in  rice.   It  is in the form of white crystals with  a  melting
                               IX-38

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point of  82   to  83°C.   Simetryne  is soluble  in water at
a rate of 450 mg/L at room temperature. An analytical test method
is available at 40 CFR 455.
Stirofos  is  a  selective  insecticide  used  to kill insects on
fruit, rice, cotton, corn, and other vegetables.   The  technical
product  is  a white crystalline solid with a solubility in water
of 11 mg/L at 20°C.   An analytical test method is  available
at 40 CFR 40 CFR 455.
Strobane   is   a   poly-chloroterpene   insecticide   which   is
semipersistent  in soil and disappears from the surfaces of  most
plant  tissue  within  3 to 4 weeks.   Its chemistry and  use  is
similar to toxaphene.   An analytical test method is available at
40 CFR 136.
SWEP  is a pre-  and  post-emergence  herbicide used  to  control
seedlings  of  annual weeds and grasses in rice and  large-seeded
legumes.   It  is a white solid with a melting point of  112   to
114°C.     SWEP   is  practically  insoluble  in  water.   An
analytical test method is available at 40 CFR 136.
2,4,5-T is a
as a  foliage
application
2,4,5-T  acid
solubility in
water soluble
(Martin  and
2,4,5-T, its
herbicide used to kill woody plants.   It is applied
    dormant shoot,   or  bark spray.  Two methods of
of 2,4,5-T are girdling and direct plant  injection.
  exists  in   the form  of white  crystals  with  a
 water of 278 mg/L at 25°C.   2,4,5-T salts  are
   however, esters of 2,4,5-T are insoluble in water
 Worthing,  1977).   An analytical test  method  for
salts and esters, is available at 40 CFR 136.
Terbacil   is   a   herbicide  which  acts  as  an  inhibitor  of
photosynthesis.  It is absorbed  by  roots  and  translocates  to
leaves.   Terbacil  is  used  for control of many annual and some
perennial weeds in crops such as  sugar  cane,  apples,  peaches,
citrus,  and  mint.   It  is  a  white  crystalline  solid with a
solubility  in  water  of  710 mg/L  at  25°C.   Terbacil  is
persistent in the soil and has an  average  half-life of  several
months  (McEwen and Stephenson, 1979).  An analytical test method
is available at 40 CFR 455.
Terbufos  is  a  soil-applied  insecticide with residual  action.
It  is used on cotton,  sugar beets,  cabbage,  and onions.   The
technical  product  is  a clear,   colorless to pale yellow liquid
with a boiling point of 69°C.    Terbufos is soluble in water
at  a  rate  of  10 mg/L to  15  mg/L  at  room  temperature.  An
analytical test method is available at 40 CFR 455.
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Terbuthylazine is a herbicide which is  taken  up  by  roots  and
controls  a  wide  range of weeds.  It is used as a pre-emergence
herbicide in sorghum and for  selective  weed  control  in  corn,
vineyards,  and  citrus. Terbuthylazine is a white solid which is
soluble  in  water  at  a  rate of  8.5  mg/L  at  20°C.   An
analytical test method is available at 40 CFR 136.


Terbutryn  is  a  selective pre- and post-emergence herbicide for
use on winter cereals, sunflowers, potatoes, and peas.  It  is  a
white  powder  with  a  melting  point  of  104   to   105°C.
Terbutryn  is  soluble  in  water  at  a  rate  of  58   mg/L  at
20°C (Martin and Worthing,  1977).  An analytical test method
is available at 40 CFR 455.
Triademefon is a systemic fungicide which has protective  action.
It  is  used  against  mildew  and  rusts on vegetables, cereals,
coffee, and grapes.  Triademefon is  a  colorless  solid  with  a
melting   point  of 83.3°C.   Its solubility in water is  250
mg/L  at 20 C (Martin and Worthing,  1977).   An analytical  test
method is available at 40 CFR 455.


Tributyltin  benzoate is a fungicide used mainly on  leather  and
textiles (Packer,  1975).   An analytical test method for  tin is
available at 40 CFR 136.


Tributyltin oxide is a fungicide used in lumber, paint, plastics,
and fabrics (Packer,  1975).   An analytical test method  for tin
is available at 40 CFR 136.


Trichloronate  is a nonsystemic insecticide.   An analytical test
method is available at 40 CFR 455.


Tricyclazole is a fungicide used on rice for the control of blast
disease.  It is a crystalline solid with a melting point  of  187
to   188°C.   Tricyclazole is soluble in water at a  rate  of
1600 mg/L at 25°C (Martin and Worthing, 1977).  An analytical
test method is available at 40 CFR 455.


Trifluralin  is  a  pre-emergence   herbicide  with  some   post-
emergence   activity  when incorporated in the soil (Martin   and
Worthing,   1977).    It  is absorbed  by  penetrating shoots and
roots  of  young  seedlings and inhibits  growth  in  the  entire
seedling,   especially  in  lateral root  formation  (McEwen  and
Stephenson,  1979).  It is used to control broad-leaved weeds and
annual  grasses in cotton  legumes,  beans,   and  orange  trees.
Trifluralin is an orange,  crystalline solid with a melting point
of 48.5  to 49°C.   Its  solubility  in water  is  less  than
1  mg/L at 27°C (Martin and Worthing,  1977).  Trifluralin is


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very persistent in the environment due to its immobility in  soil
caused  by  its low solubility in water and tendency to absorb to
soil particles (McEwen and  Stephenson,  1979).   Trifluralin  is
persistent in soil up to 1 year (Martin and Worthing,  1977).  An
analytical test method is available at 40 CFR 455.


Vancide  51Z  and Vancide 51Z dispersions  are  fungicides  which
contain zinc.  An analytical test method for zinc is available at
40 CFR 136.
ZAC   is   a
application.
455.
 nonsystemic  fungicide    used     for     foliage
An  analytical test method is available at  40  CFR
Zineb  is  a fungicide used to protect foliage and is  phytotoxic
to   zinc-sensitive  plants.  Zineb  is  a  light-colored  powder
which  is  soluble  in  water  at a  rate  of  10  mg/L  at  room
temperature  (Martin  and Worthing,   1977).  An analytical  test
method is available at 40 CFR 455.
Ziram is a protective fungicide used on fruit and vegetable crops
and  is phytotoxic  to zinc-sensitive plants.   Ziram is a white,
odorless  powder  with  a  melting  point  of   240°C.    Its
solubility  in water is 65 mg/L at 25°C (Martin and Worthing,
1977).   The  acute  oral  LD50 for  rats  is  1,400
analytical test method is available at 40 CFR 455.
                                        mg/kg.   An
                               IX-41

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Table IX-1.  Pollutants of Primary Significance
                              Nonconventional         Conventional
Priority Pollutants             Pollutants             Pollutants
Volatile Arenatics            Nonconventional              BOD
  Benzene                       pesticides listed in       TSS
  Chlorobenzene                 Tables XIII-3 and          pH
  Toluene                       are designated noncon-
Halomethanes                    ventional pollutants of
  Carbon tetrachloride          primary significance
  Chloroform                  COD
  Methyl bromide
  Methyl chloride
  Methylene chloride
Cyanides
  Cyanides
Phenols
  2,4-Dichlorcphenol
  2,4-Dinitrophenol
  4-Nitrophenol
  Phenol
Metals
  (Arsenic Cadmium)
  Copper
  Mercury
  Zinc
Chlorinated Ethanes
  1,2-Di chloroethane
  Tetrachloroethane
Nitrosamines
  N-nitrosodi-n-prcpylamine
Pesticides
  BHC-alpha
  BHC-beta
  BHC-delta
  Endosulfan-alpha
  Endosulfan-beta
  Endrin
  Heptachlor
  Lindane (BBC-gamma)
  Toxaphene
Dienes
  Hexachlorocyclopentadiene
                                  IX-42

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 Table IX-2.  Pollutants of Dual Significance
                               Nonconventional         Conventional
 Priority Pollutants             Pollutants             Pollutants
 Volatile Arcmatics            None                        None
   1,2-Dichlorobenzene*
   1,4-Dichlorobenzene*
   1,2,4-Trichlorobenzene*

 Haloethers
   Bis (2-chloroethyl) ethert

Dichloropropane and Dichloropropene
   1,3-Dichlorcprcpenet
    Classified as a priority pollutant of primary significance and proposed
    for regulation only if it is manufactured as a final product.  Classified
    as a priority pollutant of secondary significance in other processes
    and proposed to be excluded from regulation since it is controlled by
    regulation of chlorobenzene.

    Classified as a priority pollutant of primary significance and proposed
    for regulation only if it is manufactured as a final product and has
    zero discharge.  Classified as a priority pollutant of secondary
    significance in other processes and proposed to be excluded from
    regulation due to a lack of adequate monitoring and control data.
                                  IX-43

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Table IX-3.  Pollutants of Secondary Significance
                              Nonconventional         Conventional
Priority Pollutants             Pollutants             Pollutants
Volatile Arena tics            Nonconventional             None
  1,3-Dichlorobenzene           pesticides for which
  Ethylbenzene                  approved analytical
  Hexachlorobenzene             procedures and/or
Halcmethanes                    adequate technical
  Bromoform                     and economic data are
  Chlorodibromcmethane          not available
  Dichlorobromomethane        Ammonia
Haloethers                    Manganese
  Bis(2-chloroethoxy) methane
  B is(2-chloroi sopropy1) ether
  4-Bromophenyl phenyl ether
  2-Chloroethyl vinyl ether
  4-Chlorophenyl phenyl ether
Phenols
  2-Chlorophenol
  2,4-Dimethylphenol
  4,6-Dinitro-o-cresol
  2-Nitrcphenol
  Parachlorcmetacresol
  2,4,6-Trichlorophenol
Nitrosubstitued Aromatics
  2,4-Dinitrotoluene
  2,6-Dinitrotoluene
  Nitrobenzene
Polynuclear Aronatic Hydrocarbons
  Acenaphthylene
  Acenaphthene
  Anthracene
  Benzo(a)anthracene
  Benzo(a)pyrene
  3,4-Benzofluoranthene
  Benzo(ghi)perylene
  Benzo(k)fluoranthene
  2-Chloronaphthalene
  Chrysene
  Dibenzo(a,h)anthracene
  Fluoranthene
  Ideno(1,2,3-cd)pyrene
  Naphthalene
  Phenanthrene
  Pyrene
                                   IX-44

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Table IX-3.  Pollutants of Secondary Significance (Continued, Page 2 of 2)
Priority Pollutants
Priority Pollutants
Metals
  Antimony
  Beryllium
  Chromium
  Lead
  Nickel
  Selenium
  Silver
  Thallium
Chlorinated Ethanes and Ethylenes
  Chloroethane
  1,1-Dichloroethane
  1,1-Dichloroethylene
  Hexacnloroethane
  1,1,2,2-Tetrachloroethane
  1,2-Trans-dichloroethylene
  1,1,1-Trichloroethane
  1,1,2-Trichlorothane
  Trichloroethylene
  Vinyl chloride
Nitros amines
  N-ni trosodimethy lami ne
  N-nitrosodiphenylamine
Phthalate Esters
  Bis(2-ethylhexyl) phthalate
  Butyl benzyl phthalate
  Diethyl phthalate
  Dimethyl phthalate
  Di-n-butyl phthalate
  Di-n-octyl phthalate
Pesticides
  Aldrin
  Chlordene
  Dieldrin
  4,4'-ODD
  4,4'-DEE
  4,4'-DDT
  Endosulfan sulfate
  Endrin aldehyde
Dienes
  Hexachlorobutadi ene
TOO
  TCDD
Miscellaneous
  Acrolein
  Acrylonitrile
  Asbestos
  1,2-Diphenylhydrazine
  Isophorone
Polychlorinated Biphenyls
  PCB-1242
  PCB-1254
  PCB-1221
  PCB-1232
  PCB-1248
  PCB-1260
  PCB-1016
Benzidines
  Benzidine
  3,3'-Dichlorobenzidine
Dichloropropane and
  Dichloropropene
  1,2-Dichloropropane
                                    IX-45

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                            SECTION X



                     ANALYTICAL TEST METHODS
BACKGROUND
Section  304(h)  of  the Clean Water Act directs  the  Agency  to
approve analytical methods for the analysis of pollutants.  These
methods  are  used  for  compliance  monitoring  and  for  filing
applications  for  the NPDES program under 40 CFR  122.60(c)  and
122.60(i)  and  the pretreatment program under 40  CFR  403.7(d).
Without  these methods,  there would be no universally applicable
procedure for determining the presence and concentration of thec-
pollutants in wastewater.


During  the  initial  data gathering phase  in  developing  these
regulations,   analytical   test   methods  had   been   approved
(promulgated) by the Agency for the conventional pollutants, some
priority  pollutants (all metals and some  chlorinated  organics)
and   some  nonconventional  pesticide  pollutants,   principally
chlorinated  organic  pesticides.    The  Agency  also  developed
analytical  test methods for all organic priority pollutants  and
proposed those methods for public review and comment on  December
3, 1979 (44 FR 69464).  However, in November 1982, the Agency did
not  have proposed or promulgated analytical test methods for  85
nonconventional  pesticide pollutants ("NCPs") for which effluent
limitations and standards were proposed.


The  Agency had acquired data on the presence and  concentrations
of these pollutants in wastewater at organic pesticide  chemicals
manufacturing  facilities,  and  data for 24 of the NCPs with  no
proposed  or  promulgated analytical method were used  to  derive
effluent  limitations and standards (See Table X-l for a list  of
these 24 NCPs).   Data on these and other NCPs were submitted  by
the industry; to more fully understand these data, the Agency, in
1982,  requested  industry to provide the analytical test methods
used by industry to generate the data.
                           X-l.

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                            TABLE X-l

NCPs  Where  Data Was Used to Develop  Effluent  Limitations  and
Standards But Which Had No Promulgated Method in November 1982


Alachlor                 Carbendazim              Benomyl
Butachlor                Dichlorvos               KN Methyl
Propachlor               Femsulfothion            DBCP
Hexazinon                Fenthion                 Maneb
Profluralin              Glyphosate               Naled
Bolstar                  Methomyl                 2,4-DB
Bromacil                 Metribuzin               Stirofos
Carbofuran               Meximphos                Dinoseb


Screening  and verification sampling was conducted by the  Agency
and its contractors at organic pesticide chemicals  manufacturing
facilities   in  1979  and  1980  to  acquire  data  to  identify
pollutants   of   concern   and   verify   their   presence   and
concentrations  in raw (untreated) and  treated  wastewater.   At
that  time,  only a limited number of analytical test methods for
NCPs  were  available.   Accordingly,  the  Agency  directed  its
contractor,  Environmental  Science  and  Engineering,  Inc.,  to
develop  test methods for those NCPs expected at  the  facilities
scheduled  for sampling.    None of the data resulting from use of
the  contractor  developed test methods was  used  in  developing
effluent limitations guidelines and standards, but it was used to
identify NCPs of concern at individual organic pesticide chemical
manufacturing facilities.


The   Agency  has  assigned  the  principle  responsibility   for
developing new analytical methods to its Environmental Monitoring
and Support Laboratory at Cincinnati ("EMSL").  During the period
1980-1982,  EMSL  developed analytical test methods for 55  NCPs.
These  test  methods  were,  with a few  exceptions,  tested  and
validated  in  at  least two  matrices,  usually  reagent  water,
pesticides   manufacturing  industry  wastewater,   and/or   POTW
wastewater.   POTW  wastewater  typically is  more  complex  than
either reagent water or treated industry wastewater.

The   EMSL  methods  were  not  available  during  screening  and
verification sampling,  consequently,  none of the EMSL developed
methods  generated  data  which  was  used  to  develop  effluent
limitations and standards.   However,  the principle  differences
between   the  EMSL  developed  methods  and  the  industry   and
contractor  methods are (1) the EMSL methods contain more  detail
about the specific steps to follow,  particularly with respect to
elimination  of possible and unknown interferences,  whereas  the
industry  and  contractor methods include steps to eliminate  the
known  interferences encountered in the wastewater at  the  plant
which submitted the method;  (2) the EMSL methods were tested and
validated  in  at least two different  wastewaters,  whereas  the
                               X-2

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industry  and  contractor  methods  were validated  only  in  the
treated  industry wastewater;  and (3) the EMSL  methods  include
precision and accuracy (P&A) statements, and the method detection
limit  ("MDL") is determined in at least one matrix as defined at
40 CFR Part 136,  whereas the industry and contractor methods may
not  have  much of a P&A statement,  and the detection  limit  is
usually estimated based on instrument conditions.  In other words
the differences are in the amount of detail in the method  rather
than the chemistry of the methods.   Many of the industry methods
are  very similar to the EMSL methods and the EMSL methods,  when
applied to the specific industry wastewaters,  would not need the
clean-up  steps  necessary  to  remove  interferences  when   the
interferences  are not present in the industrial wastewater,  or,
alternatively,  could incorporate a specific cleanup step as part
of  the normal method.   In either case,  the EMSL  method  could
become essentially identical to the industry method.  Recognizing
the  variety of wastewaters which could be encountered,  the EMSL
methods   allow   flexibility  for  the   analyst   to   exercise
professional  judgment to simplify or make minor modifications to
the methods to address individual wastewater matrices, so long as
the  modified methods meet performance criteria  incorporated  in
the methods.
PROPOSED ANALYTICAL TEST METHODS


In  response  to  the  Agency's request,  in  1982  the  industry
submitted 45 analytical test methods for the analysis of 53 NCPs.
No  industry methods were submitted for the analysis of  Carbam-S
(Dibromochloropropane);  Nabam;  Niacide;  PCP  salt  (sodium  or
potassium  pentachlorophenate);   Ronnel;   or  Terbutryn.    The
industry methods typically included analysis for only one or  two
NCPs  (only  one method,  number 109,  included as many  as  five
pollutants).  There were generally two industry methods submitted
for  each pollutant,  although in several cases only one industry
method  was  submitted and in some cases three  industry  methods
were submitted.    See Table X-2 for the list of industry  methods
submitted  and  pollutants which can be analyzed by each  method.
Note  that the industry method for Ethion is very similar to  the
method the Agency promulgated for Ethion December 1,  1976 (41 FR
52780).
                          X-3

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                            TABLE X-2
             Industry Methods Proposed February 1983
Method         Pollutants

101        Alachlor, Butachlor, Propachlor
102        Alachlor, Butaehlor, Propachlor
103        AOP, Zineb, Ziram, ZAC
104        Benfluralin, Ethalfluralin,
           Isopropalin
105        Benomyl, Carbendazim
106        Benomyl, Carbendazim
107        Bentazon
108        Bolstar
109        Bromacil, Hexazinone, Oxamyl,
           Methomyl, Terbacil
110        Busan 40, Busan 85, KN-Methyl

111        Carbofuran
112        Chlorobenzilate
113        Chlorpyrrfos, Chlorpyrifos Methyl

114        Couniaphos
115        Cyanazine
116        Cyanazine, Stirofos
117        2,4-DB

118        Deet
119        Mevinphos, Dichlorvos, Naled,
           Stirofos
120        Mevinphos, Dichlorvos, Naled,
           Stirofos
121        Dinoseb
122        Dinoseb

123        Ethion
124        Etridiazole
125        Fensulfothion
126        Fenthion
127        Glyphosate
128        Mancozeb
129        Maneb

130        Mephosfolam, Phorate, Terbufos

131        Metham
    Developed By

Monsanto, No Date
Monsanto, 1979
FMC, No Date
Eli Lilly,
No Date
E.I. duPont, 1981
E.I. duPont, No Date
BASF, 1974
Mobay, No Date
E.I. duPont, 1980

Buckman Laboratories
No Date
FMC, No Date
Ciba-Geigy, 1977
Dow Chemical
No Date
Mobay, No Date
Ciba-Geigy, 1977
Shell, No Date
Rhodia, Inc.
No Date
US EPA, 1973
(Method Not
 Promulgated)
Shell, No Date

Shell, No Date

Dow, 1973
Vicksburg Chem.
Co., No Date
FMC, No Date
Olin, No Date
Mobay, No Date
Mobay, No Date
Monsanto, No Date
Rohm & Haas, 1978
E.I. duPont,
No Date
American Cyanamid,
No Date
Stauffer,
No Date

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                       TABLE X-2 continued
                           page 2 of 2
Method         Pollutants                           Developed By

132        Methomyl                             Shell, No Date
133        Methomyl                             Vertac, No Date
134        Mevirphos                            Amyac, No Date
135        Profluralin                          Ciba-Geigy, 1977
136        Simetryn                             Ciba-Geigy, 1977
137        Triademefon                          Mobay, No Date
138        Trichloromate                        Mobay, No Date
139        Tricyclazole                         Eli Lilly, No Date
140        Glyphosate                           Monsanto, 1980
141        Hexazinome, Terbacil,                E.I. duPont, 1980
           Bromacil
142        Ziram                                Fike Chemicals,
                                                1982
143        Propachlor                           Dow, No Date
144        Fluometuron                          Ciba-Geigy, 1982
145        Metribuzin                           Mobay, No Date
                                X-5

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                           TABLE X-III
            Contractor Methods Proposed February 1983


Method                   Pesticide

401                            AOP
401                            Perbam
401                            Niacide
401                            ZAC
401                            Zineb
401                            Ziram
402                            Benomyl
402                            Carbendazim
403                            Carbofuran
404                            Chlorobenzilate
404                            Terbutyrn
404                            Profluralin
405                            2,4-DB
405                            2,4-DB isobutyl Ester (2,4-DB IBE)
405                            2,4-DB Isoctyl Ester (2,4-DB IOE)
406                            Dinoseb
407                            Dinoseb
408                            Methomyl
409                            Cyanazine
                                 X-6

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The  Agency's contractor developed nine analytical  test  methods
for the analysis of 18 NCPs.   All but five of these 18 NCPs also
had  industry  methods.   (Contractor methods,  but not  industry
methods  were  available for  Ferbam,  Niacide,  2,4-DB  isobutyl
ester;  2,4-DB isooctyl ester;  and terbutryn).   Most contractor
methods included only one NCP,  but Method 401 included six NCPs,
all of which are dithiocarbamates.  The analytical method for all
six  is  based on the reaction of each with caustic  to  generate
carbon disulfide ("CS2) which is then detected and the amount
generated   is  determined  as  a  measure  of  the   amount   of
dithiocarbamate  in  the  sample.   See Table X-3 for a  list  of
contractor  methods  submitted and the pollutants of  which  were
analyzed by each method.


EMSL developed 15 analytical test methods for the analysis of  59
NCPs.   Most of the 59 NCPs were also included in the industry or
contractor  methods;  however,  no EMSL methods are available for
five  NCPs,  (Alachlor,  Butachlor,  Bentazone,  Glyphosate,  and
Terbufos)  and  there  no industry  or  contractor  methods  were
submitted  for  the  analysis  of seven  NCPs  (PCP  salt,  DBCP,
Carbophenothion,   Ronnel,   Carbarn   S,   Dichloofenthion,   and
Dioxathion.    Of  these  seven,   analytical  methods  had  been
promulgated for Carbophenothion, Dichlorofenthion, and Dioxathion
in December 1976.   The promulgated methods were essentially  the
same as those received from EMSL in 1982).


The  Agency  proposed  all  69 analytical test  methods  for  the
analysis of 66 NCPs on February 10,  1983 (48 FR 6250).   In  its
proposal, the Agency stated that in some cases analytical methods
from three sources (industry, contractor, and EMSL) were proposed
for  one NCP.   The Agency stated that it presented all available
methods  for  public comment and that it intended to  select  the
most appropriate method or methods for promulgation.   The Agency
did  not intend to propose analytical test methods for  NCPs  for
which  an  Agency approved method had already  been  promulgated.
However, four test methods were proposed which included only NCPs
with promulgated analytical test methods (Methods 123 and 614 for
Ethion;  Methods 617 and 701 for Carbophenothion;  and Method 701
for Dioxathion and Dichlofenthion).


During  the  comment period for the proposed analytical  methods,
industry  submitted  25  additional analytical  methods  for  the
Agency's consideration,  several of which were to be in place  of
methods previously submitted by the industry (104A,  105A,  107A,
116A and B, and 140A), three (102A, 107B, and 107C) were to be in
addition  to  the methods previously submitted,  and  eight  were
methods for NCPs not included in the methods previously submitted
by  industry.   The rest of the methods submitted by industry are
the 800 series of methods listed below and in Table X-4.
                                X-7

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In its June 1984 NOA (49 FR 24492,   June 13,   1984)f  the  Agency
stated that it was considering promulgating one or more of the 18
"800" series methods submitted by industry (see Table X-4);  five
of  those 800 series methods were rejected by the Agency and were
not  included in the June 1984 NOA.    Those five methods and  the
reasons they were rejected are:
(a) Method 812        -     A thin-layer chromatography method
(Prometon)                  with poor precision and lack of
                            quantitative and qualitative accurcy

(b) Method 813        -     The method is non-selective for
(Triazines,                 specific triazine compounds, and has
Total)                      no clean-up step even though it is
                            susceptible to interferences

(c) Method 814        -     This method is a preliminary write-up
(Atrazine, Simazine,        of method 409; the full procedure was
Propazine)                  proposed in February 1983

(d) Method 816 and    -     Information submitted was insufficient
and   Method  818           for  evaluation.  No complete analytical
                            procedures were presented.  The available
                            material consisted of letters and other
                            correspondance with a few general
                            experimental details.


Of  the  revised methods submitted by industry (the "A"  and  "B"
methods such as 104A,  etc.) only method 107B was included in the
June 1984 NOA as method 817.


                            TABLE X-4

                   Methods Proposed June 1984

        Method                        Pollutant

        801                           2f4-D
        802                           Demeton
        803                           Azinphos methyl
        804                           Disulfoton
        805                           Diazinon
        806                           Parathion methyl
        807                           Parathion methyl,
                                      Parathion ethyl
        808                           Atrazine
        809                           Ethoprop
        810                           2f4-D
        811                           Dicofol
        815                           Trifluralin
        817                           Bentazone  (Same as 107B)
                                  X-8

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Selection of Analytical Methods for Promulgation


The  Agency  evaluated  all 82  analytical  methods  proposed  in
February  1983  and  June  1984 and  each  of  the  modifications
received  in  comments,  but the Agency did not evaluate  methods
812,  813,  814,  816,  and 818.   Key factors evaluated were (1)
instrumentation  required  for  the  method;   (2)   multianalyte
capability;    (3)    clean-up   procedures;    (4)   performance
characteristics  (including detection limit,  recovery of  spikes
from   samples,   precision,   interferences,   and   calibration
methodology)  (5) holding time and sample preservation;  and  (6)
miscellaneous  characteristics  including complexity  of  method,
safety hazards,  and cost considerations).   Each of the  methods
was  reviewed  and  evaluated  by  each  of  several  experienced
analytical  chemists  who  assigned  points to each  of  the  key
factors  for each method,  based on their professional  judgment.
The point scores for each key factor were then averaged for  each
reviewer  for  each  method reviewed and then  totaled  for  each
method.   The total score for each  method was tabulated, and the
complete  table was placed in the public record for the June 1984
NOA.   In making its final selection of methods for promulgation,
the Agency has used the numerical scores of the evaluation of the
methods as a guide to identify items of major deficiencies within
each  method  but has not used the numerical score  itself  as  a
selecting  criterion.   Thus,  while most of the selected methods
received  total scores of 800 or more,  whether or not  a  method
received  a  score of 800 was neither necessary nor a  sufficient
requirement for selection.   The Agency considered the  following
factors of major importance, for the reasons given following each
factor.
First, the analytical methods must be used by pesticide chemicals
manufacturers,  by pesticide chemicals formulators and packagers,
by POTWs,  and by State and Federal regulatory agencies.   Sample
types  would  include treated pesticide  chemicals  manufacturing
wastewater,  treated  or untreated wastewater from PFP facilities
most  of which formulate and package a variety  of  non-pesticide
materials,  and both untreated and treated municipal wastewaters,
which again would arise from a variety of sources, including many
non-pesticide sources.  Therefore, the methods must be capable of
analyzing  accurately a variety of wastewater types ("matrices").
Ideally,  the method should include detailed procedures to reduce
or   eliminate  any  interferences  which  may  be   encountered.
Alternatively,  the method should include at least information or
guidance  for  reduction  or elimination  of  the  most  commonly
expected  interferences,  and the flexibility for the analyst  to
use professional judgment for the analysis of complex matrices.


Second, the effluent limitations and standards applicable to much
of  the  pesticide  industry require no  discharge  of  pesticide
                                  X-9

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active ingredients;  the facilities so regulated,  however, could
discharge  wastewater,  so long as they can demonstrate that  the
wastewater   contains  no  pesticide  active  ingredient.    That
demonstration    would   involve   the   analysis   of    samples
representative  of  the discharge for the presence  of  pesticide
active  ingredients.   Accordingly,  the  methods should  have  a
statement  of  the method detection limit ("MDL")  determined  in
several  wastewaters.   The  MDL is defined at 40  CFR  Part  136
Appendix B.  The MDL is defined as the minimum concentration of a
substance  that  can  be measured and reported  with  99  percent
confidence  that the analyte concentration is greater than  zero.
The MDL is determined from analysis of a sample in a given matrix
containing the analyte.  A method that has a statement of the MDL
even  if the MDL was only determined in reagent  water,  contains
some confidence that an analytical result of "not detected" means
the  pollutant  is not present in the wastewater,  at  least  not
above the MDL.
Third, the method should not only contain a statement of the MDL,
but  should  also have a "low" MDL,  that is,  where two  methods
exist  for the same pollutant,  and both have a statement of  the
MDL,  the  method  with the lowest MDL was considered to  be  the
better method.
Fourth,  the method should have a statement of the precision  and
accuracy  (standard  deviation of duplicate analysis and  percent
recovery  of spiked samples) for the analytes,  in a  variety  of
wastewaters.  Using this information, an analyst can determine if
the  method  is being applied properly.   Additionally,  in  some
cases  modifications to the methods may be necessary to adapt  to
specific matrices.   The analyst needs to have a statement of the
precision  and accuracy for the unmodified method for  comparison
to the precision and accuracy found for the method as modified to
judge whether the results obtained are adequate.


Finally,  the method should be written clearly and completely, so
the method may be readily used by analysts who are not  dedicated
solely  to pesticides analyses.   The method should have at least
general information on safety precautions, reagents and glassware
necessary,  and calculations needed to generate the final  result
to be reported.  Each of these is important for analysts starting
to  use  an unfamiliar method,  but may be easily  overlooked  in
methods   normally  used  for  analysis  of  only  one  type   of
wastewater.


Considering  all of these factors,  the Agency has promulgated 14
analytical test methods for NCPs.  These 14 methods are presented
in  Table X-5.   Ten of the 14 analytical test methods are  EMSL-
developed methods.   When compared to the other methods proposed,
the  EMSL  methods  were  generally  more  complete,   containing
detailed  sections  on  safety,   reagents  and  glassware,   and
                                X-10

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calculations.   The EMSL methods contained a statement of the MDL
in  at least one wastewater,  the precision and accuracy  for  at
least one wastewater,  and were the most sensitive, that is, they
have the lowest MDL,  when a contractor or industry method had an
MDL  (usually,  neither  the contractor nor the  industry  method
provided an MDL).   The EMSL methods also provided information on
clean-up   and   separation  procedures  for  the  reduction   or
elimination of interferences.  In most cases,such information was
absent  or  extremely  brief  for  the  industry  and  contractor
developed   methods.    Four  industry  developed   methods   are
promulgated.   They are methods 102, 107A, 130, and 140A.  In all
four  cases,  no  EMSL-developed  method was  available  for  the
pollutants  analyzed by the methods,  hence the industry  methods
were  promulgated  even  though there were some  deficiencies  in
information, so that a method would be available.


RATIONALE FOR SELECTION/REJECTION OF EACH METHOD


This  section  describes briefly the reason(s) for  selecting  or
rejecting each method.


1.    Methods 101,  102,  102A, and 143 for analysis of Alachlor,
Butachlor,  and  Propachlor (Method 143 is for propachlor  only).
All three methods were submitted by Monsanto.   Method 101 is  an
early  version  of method 102,  which is more complete  and  more
recent  than  method 101.   Method 102A is a method submitted  by
Monsanto  in  its comments on  the  proposed  methods.   Monsanto
requested  that method 102A be in addition to method 102,  method
102A is not a revision of method 102 but is an entirely different
method.   Method 102A is more experimental than method 102, hence
the  Agency  did  not propose method 102A in the  June  1984  NOA
because  method 102 is believed to be  adequate,  validated,  and
with adequate precision,  accuracy,  and detection limit.  Method
143  uses  a flame ionization detection ("FID") which is  not  as
sensitive  to  chlorinated  herbicides as  the  electron  capture
detection  ("BCD") used by method 102.   Hence,  method  102  was
selected and the other three methods were rejected.


2.    Methods 103,  110, 128, 129, 131, 142, 401, and 630 for the
analysis of AOP, Busan 40, Busan 85, Carbam-S, Ferbam, KN Methyl,
Mancozeb,  Maneb,  Metham, Nabam, Niacide, ZAC, Zineb, and Ziram:
these  pesticides are all metal dithiocarbamates.   Methods  103,
129,  142,  401,  and  630  all hydrolyze the dithiocarbamate  to
CS2 and measure the amount of CS2 evolved as a measure of
the  amount  of  pesticide in  the  wastewater.   The  analytical
procedures described in each of those 5 methods is  similar,  but
method  630 clearly applies to all 14  dithiocarbamates,  whereas
each of the other 4 names only some of the 14 pesticides.  Hence,
method  630 is the best of the five.   Method 110 is a thin-layer
chromatography method with poorly defined precision and accuracy,
a  detection limit of one part per million (ppm) compared to  the


                                x-n

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0.025 ppm MDL obtained by method 630.   Moreover,  method 110  is
very incomplete;  the method does not even describe what reagents
to use.  Methods 128 and 131 are gas chromatographic (GC) methods
for specific dithiocarbamates, one (method 128)  uses GC to detect
the  CS2  evolved during hydrolysis while the  other  (method
131)   uses  GC  to  detect  methyisothiocyanate  evolved  during
hydrolysis.   Neither  method provides sufficient information  on
clean-up  and separation  procedures,  likely  interferences,  or
precision and accuracy.   Hence,  method 630 was selected and the
other seven methods were rejected.


3.    Methods 104,  104A,  135,  404, and 627 for the analysis of
Benfluralin,  Ethalfluralin,  and  Isopropalin  (methods 104  and
627), and Profluralin (methods 135, 404, and 627).


Method  135  is  a  thin-layer  chromatography  method  which  is
insensitive   (detection  limit  of  6  ppm).    Method  404   is
imcomplete,   with  no  information  on  interferences,  clean-up
procedures,  and  calculations,  and insufficient information  on
calibration procedures and quality control.   Methods 104,  104A,
and  627  appear to be similar but method 627 has  more  complete
information   on  interferences  and  procedures  to  reduce   or
eliminate the interference, and more complete information on MDL,
precision and accuracy.   In addition,  method 627 includes  four
analytes,  method  104 and 104A only three analytes.   Therefore,
method 627 was promulgated.


4.    Methods  105,  105A,  106,  402,  and 631 for  Benomyl  and
Carbendazim:   All  five  methods  are  high  performance  liquid
chromatography ("HPLC") methods.   Method 106 is an early version
of  method  105 which is used at one industrial facility but  has
not been demonstrated in other wastewaters.  Method 402 reports a
detection  limit of 0.10 ppm and does not contain information  on
interferences,  calibration, quality control, or calculations and
therefore  must be considered too incomplete and insensitive  for
general use.   Method 105 has a reported detection limit of  0.08
ppm   but  has  no  information  on  interferences  and  clean-up
procedures.   Method  631  has  a MDL of .009  ppm  and  includes
information  on  interferences  and  clean-up  procedures.    The
precision  and  accuracy  were  determined  in  two  wastewaters.
Therefore,  method 631 was promulgated, and methods 105, 106, and
402 were withdrawn.
5.    Methods 107, 107A, 107B, and 817 for Bentazon.  Method 107A
adds  more detail to method 107 including some revisions  to  the
procedures to eliminate some interferences.   BASF, the submitter
of all four methods, requested 107 be withdrawn and replaced with
method  107A.   BASF  also  requested  methods 107B  and  817  be
promulgated.   Method 817 is significantly different from  method
107,  and 107A, and 107B and is considerably less sensitive, with
a  detection  limit  of 1 ppm.   Method 107B is an  extension  of
                                X-12

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methods  107 and 107A in that it uses GC/MS rather than  GC  with
FID,  but  method 107B does not have complete information on  the
precision  and accuracy that can be obtained whereas method  107A
is  very similar to method 107 and can be expected to yield equal
or better results than those reported for method 107.  Therefore,
method  107A is promulgated because method 107 was  withdrawn  by
the submitter, method 107B needs more information, and method 817
is insensitive.


6.     Methods   108(Bolstar),   113(Chlorpyrifos,   Chlorpyrifos
Methyl),     114(Coumaphos),    116(Stirofos),    116A(Stirofos),
119(Dichlorvos,   Naled,  Mevinphos,  Stirofos),  120(Dichlorvos,
Naled,  Mevinphos,  Stirofos), 125(Fensulfothion), 126(Fenthion),
134(Mevinphos),    138(Trichloronate),    and    622    (Bolstar,
Chlorpyrifos,   Chlorpyrifos  methyl,    Coumaphos,   Dichlorvos,
Fensulfothion,   Fenthion,  Mevinphos,  Naled,  Phosate,  Ronnel,
Stirofos,  and  Trichloronate).   All  of  these  pesticides  are
organo-phosphorus pesticides.  Method 116 is an HPLC method which
was  withdrawn  by the submitter and replaced with  Method  116A.
Method  116A  provides an estimated detection limit of 0.010  ppm
for  stirofos whereas method 622 has an MDL of 0.005 ppm  and  is
applicable to 13 organophosphorus pesticides while method 116A is
applicable to only Stirofos.   Methods 108,  114,  120, 125, 126,
134  and  138 have no information on precision and  accuracy  and
contain  other information deficiencies as well.   Method 113  is
incomplete  because it does not have information on interferences
and  has no clean-up and separation procedures.   Method 119  has
detection limits of .002 to .010 ppm whereas method 622 has  MDLs
of .0001 to .005 ppm.  Accordingly, method 622 is promulgated and
methods 108,  113, 114, 116, 119, 120, 125, 126, 134, and 138 are
withdrawn.


7.     Methods  109  (Oxamyl,   Methomyl,  Bromacil,  Hexazinone,
Terbacil), 111 (Carbofuran), 118 (DEET), 132 and 132A (Methomyl),
133  (Methomyl),   137  (Triadimefon),  139  (Tricyclazole),  141
(Bromacil,   Hexazinone,   Terbacil),   144  (Fluometurom),   145
(Metribuzin),  403 (Carbofuran), 408 (Methomyl), 632 (Carbofuran,
Fluometuron,   Methomyl,    Oxomyl)  and   633  (Bromacil,  DEET,
Hexazinone, Metribuzin, Terbacil, Triadimefon, Tricyclazole).


These   pesticides   contain  nitrogen  and  are  of   borderline
volatility  for  analysis  by GC,  thus  the  wide  variation  in
methods.  Methods 137 for Triadimefon and 144 for Fluometuron are
thin-layer  chromatography ("TLC")  methods which are  insensitive
and  imprecise.   Method  111  for  Carbofuran  does  not  provide
information on interferences,  clean-up and separation, detection
limit,  precision or accuracy.  Method 403 for Carbofuran reports
a  detection  limit of 0.025 ppm whereas method 632 has a MDL  of
0.004 ppm for Carbofuran.   Hence,   the Agency promulgated method
632 for Carbofuram,  Fluormeturon,   Methomyl and Oxamyl.   Method
109 does not report detection limits,  precision or accuracy  for
any  of the pesticides.   Methods 132,  132A,  133,  and 408  for
                                X-13

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Methomyl have detection limits that are too high (0.10 ppm, 0.010
ppm   0.10  ppm,  and  1 ppm respectively)   and  have  incomplete
information on interferences clean-up and separation procedures.


Method  118  for  DEBT  is incomplete because it  does  not  have
information   on   interferences,   calibration,   clean-up   and
separation, calculations, detection limit,  precision or accuracy.
Method 139 does not have information on interferences and  clean-
up  and  separation procedures,  and has been tested in only  one
wastewater.   Method  141  also  does  not   have  information  on
interferences,  clean-up and separation procedures,  and each  of
the  three  pesticides requires different instrument  conditions.
Method  145  for metribuzin does not  provide  detection  limits,
precision  or accuracy information.   Method 633 has MOL of 0.004
ppm  or less and has been tested by EPA in  two  wastewaters.   In
addition,   one  commenter  tested  the  method  extensively  and
reported excellant,  reproducable results.    Accordingly,  Method
633 is promulgated.   Methods 109,  111, 118, 132, 133, 137, 139,
141, 144, 145, 403 and 408 are withdrawn.


8.     Methods  112  (chlorobenzilate),  124  (Etridiazole),  404
(Chlorobenzilate,   Terbutryn,   and  Profluralin),   and   608.1
(Chlorobenzilate, Etridiazole, Propachlor,  and DBCP).  Method 112
is  a TLC method that is insensitive and imprecise.   Method  124
has  no  information on interferences,  clean-up and  separation,
detection limit,  or precision and accuracy.   Method 404 has  no
information  on interferences,  precision or accuracy,  and has a
detection limit of 0.2 ppm.   Method 608.1  has a MDL of 0.001 ppm
or less.  Therefore, method 608.1 is promulgated and methods 112,
124,  and  404  are withdrawn.   (Note that method  102  is  also
promulgated for the analysis of propachlor).


9.    Methods 115, 116, 116A, 409, and 629  for Cyanazine.  Method
115  is  a  TLC  method that is too  insensitive  and  imprecise.
Method 116 was withdrawn by the submitter and replaced by  method
116A.  Method 116A has a detection limit of 0.050 ppm, Method 409
has  a detection limit of 0.14 ppm,  whereas Method 629 has a MDL
of  0.006 ppm and has been tested in four different  wastewaters.
Therefore,  the Agency is promulgating method 629 and withdrawing
methods 115, 116, and 409.


10.  Method 117(2,4-DB), 121(Dinoseb), 122(Dinoseb), 405 (2,4-DB,
2,4-DB isobutyl ester,  2,4-DB isoctyl ester),  406(Dinoseb), 407
(Dinoseb) and 615 (2,4-DB,  2,4-DB esters,   and Dinoseb).   These
chlorinated  herbicides are best determined by  GC/ECD  (electron
captive  detectors).  Methods  117,  122,  406,  and 407 are  too
insensitive,  with detection limits of 1 ppm,  0.1 ppm,  0.2 ppm,
and  0.2  ppm,   respectively.    Method  121  does  not  include
information on interferences,  clean-up and separation, detection
limit,  or  precision  and accuracy.   Method 615  includes  that
information and has MDLs of 0.001 ppm or  less.   Therefore,  the
                                 X-14

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Agency  is  promulgating method 615 and withdrawing methods  117,
121, 122, 405, 406, and 407.
11.   Methods 123(Ethion),  614 (Ethion),  617 (Carbophenothion),
701 (Dichlofenthion,  Dioxathion,  Carbophenothion), 801 (2,4-D),
802(Demeton),   803  (Azinphos  Methyl),  804  (Disulfoton),  805
(Oiazinon),   806(Parathion  Methyl),   807  (Parathion   Methyl,
Parathion Ethyl), 808 (Strobane), 810 (2,4-D), 811 (Dicofol), and
815  (Trifluralin).    All  these methods include only  NCPs  for
which  analytical test methods were promulgated in December 1976.
The  Agency  had not intended to propose  alternate  methods  for
those methods.   Therefore,  the Agency is withdrawing them under
40 CFR Part 455.
12.   Methods 127, 140, and 140A - Glyphosate.  All three methods
were  developed by Monsanto.   Method 127 is an early version  of
method  140.   Monsanto  developed method 140 using  a  synthetic
wastewater.   Monsanto  reported in its comments on the  proposed
analytical  methods that the use of method 140 on actual  treated
wastewater  did not give reproducible results because a  clean-up
step  was  necessary  to eliminate  interferences.   Method  140A
includes  this  clean-up  step.    Accordingly,   the  Agency  is
promulgating method 140A because it supercedes method 140,  which
Monsanto determined could not be applied to real wastewater,  and
the  Agency  is also withdrawing method 127 because it  also  has
been superceded by method 140A.


13.  Method 130 (Mephosfolan, Phorate, and Terbufos)


There are no other methods available for Mephosfolan or Terbufos,
and Method 130 includes information on interferences and  reports
a  detection  limit  of .005 to 0.025 ppm using  an  aklaki-flame
ionization detector.   The method does not include precision  and
accuracy   information,   however;   good  quality  control   and
maintenance  of records is essential.   Note that method 622  has
also been promulgated for analysis for Phorate.
                                X-15

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14.   Methods  136  (Simetryne)  and 619  (Simetryne,  Terbutryn).
Method  136  is a TLC method that is insensitive  and  imprecise.
Method 619 has a MDL of 0.00007  ppm or less,   and has been tested
in two wastewaters.  Therefore,  the Agency is promulgating method
619 and withdrawing method 136.


15.   Method 809-Ethoprop.  This method is not a water method but
instead is a method for determining the purity of the  pesticide.
The method uses a 1 gram sample, which is about 1 milliter.  That
small a volume cannot be accurately analyzed  for trace quantities
by the method as written.


16.   Method  604 and 625 for PCP salt.   These two methods  were
promulgated as part of 40 CFR Part 136 on October 26, 1984 (49 FR
43234).   Therefore,  they  are  not promulgated as part of 40 CFR
Part 455.


The  analytical test methods promulgated at 40 CFR 455 are  shown
in Table X-5.  Table X-6 presents the analytical test methods for
NCPs  promulgated  at 40 CFR 136.   Table X-7  presents  priority
pollutant pesticides,  all of which have analytical test  methods
promulgated at 40 CFR 136.

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                            TABLE X-5
        Analytical Test Methods Promulgated at 40 CPR 455
Method

102

107A

130

140A

608.1


615


619

622
627


629

630
631

632


633
Pollutants

 Alachlor, Butachlor, Propachlor

 Bentazon

 Mephosfolan, Phorate, Terbufos

 Glyphosate

 Chlorobenzilate, Etridiazole,
 Propachlor, DBCP

 2,4-DB; 2,4-DB isobutyl ester;
 2,4-DB isooctyl ester; Dinoseb

 Simetryn, Terbutryn

 Bolstar, Chlorpyrifos, Chlorpyrifos
 Methyl, Coumaphos, Dichlorvos,
 Fensulfothion, Fenthion, Mevinphos,
 Naled, Phorate, Ronnel, Stirofos,
 Trichloronate

 Benfluralin, Ethalfluralin,
 Isopropalin, Profluralin

 Cyanazine

 AOP, Busan 40, Busan 85, Carbam-S,
 Ferbam, KN Methyl, Mancozeb, Maneb,
 Metham, Nabam, Niacide, ZAC, Zineb,
 Ziram

 Benomyl, Carbendazim

 Carbofuran, Fluometuron, Methomyl
 Oxamyl

 Bromacil, Deet, Hexazinone,
 Metribuzin, Terbacil, Triadimefon,
 Tricyclazole

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                            TABLE X-6

                NCPs With Analytical Test Methods
                    Promulgated at 40 CPR 136
 1.  Ametryn                      28.
 2.  Aminocarb                    29.
 3.  Atraton                      30.
 4.  Atrazine                     31.
 5.  Azinphos methyl              32.
 6.  Barban                       33.
 7.  Captan                       34.
 8.  Carbaryl                     35.
 9.  Carbophenothion              36.
10.  Chloropropham                37.
11.  2,4-D and its esters & salts 38.
12.  Demeton-O                    39.
13.  Demeton-S                    40.
14.  Oiazinon                     41.
15.  Dicamba                      42.
16.  Dichlofenthion               43.
17.  Dichloram                    44.
18.  Dicofol                      45.
19.  Dioxathion                   46.
20.  Disulfoton                   47.
21.  Diuron                       48.
22.  Ethion                       49.
23.  Penuron                      50.
24.  Fenuron-TCA
25.  Isodrin                      51.
26.  Linuron                      52.
27.  Malathion
Methiocarb
Methoxychlor
Mexacarbate
Mirex
Monuron
Monuron-TCA
Neburon
Parathion methyl
Parathion ethyl
PCNB
Perthane
Prometon
Prometryn
Propazine
Propham
Propoxur
Secbumeton
Siduron
Simazine
Strobane
Swep
2,4,5-T and its esters and salt
2,4,5-TP(Silvex) and its esters
and salts
Terbuthylazine
Trifluralin
                                 X-18

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                            TABLE X-7
                  Priority Pollutant Pesticides
               Analytical Test Methods Promulgated
                          at 40 CFR 136
1.   Aldrin
2.   alpha-BHC
3.   beta-BHC
4.   delta-BHC
5.   gamma-BHC (Lindane)
6.   4,4'-ODD
7.   4,4'-DDE
8.   4,4'-DDT
9.   Dieldrin
10.  Endosulfan I
11.  Endosulfan II
12.  Endosulfan Sulfate
13.  Endrin
14.  Endrin Aldehyde
15.  Heptachlor
16.  Heptachlor epoxide
17.  Toxaphene
18.  Chlordane
19.  Bis(2-chloroethyl)ether
20.  Chlorobenzene
21.  1,2-Dichlorobenzene
22.  1,4-Dichlorobenzene
23.  1,2-Dichloropropane
24.  cis-l,3-Dichloropropene
25.  trans-l,3-Dichloropropene
26.  1,3-Dichloropropene
27.  Dimethyl Phthalate
28.  Hexachlorobenzene
29.  Methylbromide
30.  Napthalene
31.  Pentachlorophenol ("PCP")
     and its salts
32.  Trichlorobenzene

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                           SECTION XI

                    BEST AVAILABLE TECHNOLOGY
                     ECONOMICALLY ACHIEVABLE
INTRODUCTION

This section describes the best available technology economically
achievable  (BAT)  for  the  treatment  and  control  of  process
wastewater  generated  within the Pesticides Chemicals  Category.
BAT   represents  the  best  existing   economically   achievable
performance of plants of various ages,  sizes, processes or other
shared characteristics.


The Federal Water Pollution Control Act of 1972 required that BAT
represent   reasonable  further  progress  (beyond  BPT)   toward
eliminating   the   discharge  of  all  pollutants.    In   fact,
elimination  of  discharge  of  all  pollutants  is  required  if
technologically and economically achievable.  The Clean Water Act
of  1977  specifically defined both the  conventional  and  toxic
pollutants  that  must  be  regulated (See  Section  IX  of  this
document   for  identification  of  these  pollutants)  and  also
established a class of nonconventional pollutants for regulation.


BAT  has  been  further  defined as the  very  best  control  and
treatment   technology  within  a  subcategory  or   a   superior
technology  transferred  from other industrial  subcategories  or
categories.    This   definition  encompasses  in-plant   process
improvements as well as more effective end-of-pipe treatment.


IDENTIFICATION OF BAT
The   BAT  technologies  for  the  organic  pesticide   chemicals
manufacturing  subcategory of physical chemical treatment  (steam
stripping,  pesticide  removal,  chemical oxidation and/or metals
separation)  followed  by biological treatment are  discussed  in
Section VI of this document.   For the 23 priority pollutants and
50  nonconventional  pesticides listed in  Table  XI-1,  the  BAT
technology  is physical/chemical treatment followed by biological
treatment.   For the 9 priority pollutants and 33 nonconventional
pesticides   listed  in  Table  XI-1,   the  BAT  technology   is
physical/chemical  treatment.   As discussed in Section  VI,  the
recommended physical/chemical treatment varies depending upon the
specific  pollutants  associated with a  pesticide  manufacturing
process.   Plants  manufacturing two priority pollutant  and  six
nonconventional   pollutant  pesticides  do  not  discharge   any
wastewaters.   The  plants manufacturing the six  nonconventional
pollutant  pesticides do not generate any  wastewater,  therefore


                               XI-1

-------
there   is  no  treatment  technology  required.    One  priority
pollutant manufacturer does not generate wastewater and the other
employs total evaporation to eliminate a point source  wastewater
discharge.


The BAT treatment systems (defined in Section VI) are adequate to
achieve the BAT effluent limitations.  However, a plant may elect
to supplement this system with other equipment or use an entirely
different   treatment  technique  in  order  to  attain  the  BAT
limitations.   Alternative technologies (both end-of-pipe and in-
process) are described in Section VI of this document.


RATIONALE FOR SELECTION OF BAT
The  BAT  treatment  system identified  previously  was  selected
because  it has been proven in pesticides plants to  represent  a
well  demonstrated,  reliable  technology which achieves  a  high
degree  of toxic and nonconventional pesticide pollutant removal.
This  is demonstrated by the BAT system performance described  in
Section VI.
Although  demonstration of BAT at a single plant is adequate  for
its selection, the selected BAT technologies are employed at many
pesticides   plants.    Twenty  plants  currently  employ   steam
stripping,  chemical oxidation or metals separation.  Twenty-nine
plants  currently employ adsorption or   hydrolysis.   Thirty-two
plants employ biological treatment.    Adsorption onto  activated
carbon  have  been  demonstrated to be effective  at  17  plants,
although   far   less   frequently  than   the   identified   BAT
technologies.


The  costs  and nonwater quality environmental aspects  of  these
technologies are presented in Section VIII.


The  BAT  effluent limitations guidelines for subcategory  1  are
presented in Section XIV.


The  development  of these effluent limitations from  performance
measurements of existing BAT systems is described in Section XIV.
The statistical rationale used in developing these limitations is
presented  in  Section  XIV and  expanded in  a  separate  report
entitled "Limitations and Standards Methodology for the Pesticide
Chemicals Industry, August 10, 1985.


The  Agency  is  not promulgating  BAT  for  the  metallo-organic
pesticide  chemicals  manufacturing  or the  pesticide  chemicals
formulating and packaging subcategories but instead is  excluding


                               XI-2

-------
these  two  subcategories  from further national  BAT  regulation
development under paragraph 8(a)(i) of the NRDC y_^  Train consent
decree because effluent limitations guidelines no more  stringent
than  BPT  could  be established.   BPT  for  both  subcategories
requires no discharge of process wastewater pollutants.


BENEFITS OF BAT IMPLEMENTATION
The  estimated  environmental benefits of the application of  the
selected  BAT  model technology is the removal  of  0.74  million
kg/yr  (1.63 million Ib/yr) of pollutants from current discharge,
including  0.42  million kg/yr (0.92 million Ib/yr)  of  priority
pollutants.
                               XI-3

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                                                             TABUB XI-1
               Treatment
               Technology

               (1) Ethical/Chemical
                   Treatment Technology
x
M
I
(2)  Physical/Chenical
     Plus Bio Treatment
     Technology
      MODEL

 Priority
Pollutants
                                                                 TEOWaUOfflf FOR BAT
1,2-Dichlorobenzene
1,4-Dichlorobenzene
1,2,4-Trichlorobenzene
Methyl bromide
Carbon tetrachloride
Chloroform
Methyl chloride
Hethylene chloride
Cyanide
2,4-Dichlorophenol
2,4-Dinitrophenol
4-Nitrophenol
Pentachlorophenol
Copper
Zinc
N-Ni trosodi-n-prcpylwii ne
Bexachlorocyclopentadiene
Benzene
Chlorobenzene
Toluene
Phenol
1,2-Dichloroethane
Tetrachloroethylene
                                                                **Non-Conventional
                                                                     Pesticides
Busan 40
Busan 85
Carbam-S
Carbophenthion
Chlorpropham
Chlorpyrifos
Chlorpyrifos-mBthyl
Coumaphos
CBCP
Dioxathion
Ferbam
KN-methyl
Mancozeb
Maneb
Methatn
Niacide
Alachlor
Atrazine
Azinphos methyl
Benfluralin
Benonyl
Bolstar
Bromacil
Butachlor
Carbendazim
Carbofuran
Dematon-0
Dematon-S
Dene ton
Diaz iron
Dichlofenthion
Dichlorvos
Dinoseb
Disulfoton
Diuron
Ethalfluralin
Ethion
Fensulfothion
Fenthion
Fluonsturon
Glyphosate
Isopropalin
Linuron
FOB
POP salt
Ronnel
Silvex
Stirofos
Swep
Trichloronate
ZAC
Zineb
2,4-D
2,4-D IB ester
2,4-D IO ester
2,4-DB
2,4-DB IB ester
2,4-DB 10 ester
2,4, W
Halathion
Hethonyl
Netribuzin
Hevinphos
Neburon
Oxanyl
Parathion ethyl
Parath'ion methyl
Pnorate
Profluralin
Proraeton
Pnanetryn
Propachlor
Propazine
Propham
Propoxur
Siraazine
Siraetryn
Terbacil
TerbuCos
Terbuthylazine
Terbutryn
Trifluralin




                23 Priority Pollutants **ere BST  = P/C  & Bio
                 2 Priority Pollutants where BKT  » No discharge
                  (1,3-Dichloropropene and Bis {2-Chloroethyl Ether)
              ** 6 NCP's where BKT - No discharge (Barban,  SilveK isooctylester,
                  Silvex salt, Tributyltin benzoate,  Vancide 512,  Vancide 512 dispersion)

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                           SECTION XII

             NEW SOURCE PERFORMANCE STANDARDS (NSPS)
INTRODUCTION
This  section  describes  the new  source  performance  standards
(NSPS)  for  the  treatment and control  of  process  wastewaters
generated  within the Pesticides  Manufacturing  Category.   NSPS
reflects    existing   treatment   and   control   practices   or
demonstrations that are not necessarily in common practice.


The  Federal  Water Pollution Control Act of 1972  required  that
NSPS   represent   the  best   available   demonstrated   control
technology, processes, and operating methods.  Where practicable,
no pollutant discharge at all is to be allowed.   Where pollutant
discharge  is unavoidable,  these standards are to represent  the
greatest degree of effluent reduction achievable.   They apply to
new  sources,  which  are  defined as  any  building,  structure,
facility, or installation that discharge pollutants and for which
construction is started after promulgation of the standards.


New  direct discharge organic pesticide chemicals  manufacturers,
and   pesticide   chemicals   formulator/packagers,    have   the
opportunity  to  design  the best and  most  efficient  pesticide
processes  and  wastewater  treatment  technologies.   Therefore,
Congress  directed EPA to consider the best demonstrated  process
changes,    in-plant   controls,    and   end-of-pipe   treatment
technologies  which  reduce  pollution  to  the  maximum   extent
feasible.
NSPS  for  organic pesticide chemicals manufacturers includes  89
nonconventional  pesticide and 34 priority  pollutants  regulated
under  BAT,  and the conventional pollutants BOD,  TSS and pH and
COD  regulated under BPT.   For subcategory 2 the Agency  is  not
promulgating  a NSPS pending further analysis of appropriate NSPS
technologies.    For  subcategory  3,  NSPS  applies  to  process
wastewaters  resulting from formulating and packaging of the  147
organic  pesticide chemicals which have an  available  analytical
method  plus vancide 51Z,  vancide 51Z dispersion (which  contain
zinc),   and   metallo-organic  pesticide  chemicals   containing
arsenic,  cadmium,  copper,  mercury and tin, where the pesticide
may be detected by analyzing for the metal.
                               XII-i

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IDENTIFICATION OF NEW SOURCE PERFORMANCE STANDARDS TECHNOLOGY


Data  from  existing  organic pesticide  chemicals  manufacturing
plants  were  used  to  define  a  model  direct  discharger  for
subcategory 1.  Average subcategory production and discharge flow
rates  were used to define the model plant.   For subcategory  3,
two  model  new  source plants were defined,  one  based  on  the
average  of existing high flow plants and the other based on  the
average of existing low flow plants.


The   technology   basis   for  NSPS   for   subcategory   1   is
physical/chemical  treatment followed by biological treatment for
23   priority   pollutants  and  49   nonconvenitonal   pesticide
pollutants and physical/chemical treatment alone for 11  priority
pollutants  and 34 nonconventional pesticide  pollutants.   These
technologies  are  identical  to those  selected  for  BAT.   The
rationale for selection of these technologies is given in Section
IX.  The Agency is promulgating effluent limitations based on the
BAT  technology  because no additional technology  which  removes
significant  additional quantities of pollutants is  known.   The
NSPS  effluent limitations for subcategory 1 are given in Section
XIV.
The  technology  basis  for NSPS for subcategory  3  is  contract
hauling  and incineration for all plants except those  where  the
wastewater flows are high enough that physical/chemical treatment
and  recycle/reuse,  with  contract hauling and  incineration  of
treatment  system  residues,  is  less  expensive  than  contract
hauling.   This technology is the same as the technology selected
for  PSES (See Section XIII for the rationale for selecting  that
technology).


The  Agency  is  promulgating NSPS based on the  PSES  technology
because  no  additional  technology  which  removes   significant
additional  quantities of pollutants is known.    The NSPS require
no   discharge  of  process  wastewater  pollutants  in   process
wastewaters  resulting from the formulating and packaging of  any
of  147 organic pesticide chemicals,  Vancide  51Z,  Vancide  51Z
dispersion,   and  metallo-organic pesticide chemicals  containing
arsenic,  cadmium,  copper,  mercury, and tin.   (See Section XIII
for a list of the 147 organic pesticide chemicals).
                               XII-2

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                           SECTION XIII


                     PRETREATMENT STANDARDS
INTRODUCTION


This  section  describes the pretreatment standards for  existing
sources  (PSES)  and the pretreatment standards for  new  sources
(PSNS) for the treatment of process wastewaters generated  within
the  Pesticide Chemical Subcategories and discharged to  publicly
owned  treatment works (POTW).   These standards are intended  to
provide  an equivalent degree of toxic organic  pollutant,  toxic
metal pollutants, and nonconventional pesticide pollutant removal
as provided by direct discharge limitations.


The  Federal Water Pollution Control Act of 1972 stated that  the
pretreatment  standards shall prevent the discharge to a POTW  of
any pollutant that may interfere with, pass through, or otherwise
be incompatible with the POTW.  The Clean Water Act Amendments of
1977  further  stipulated  that industrial  discharges  must  not
interfere with use and disposal of municipal sludges  and further
that  the  discharge from the POTW must not be greater  than  the
direct  discharge  limitations .   In accordance with  the  Clean
Water Act,  individual POTWs may specify more stringent standards
or  (after  meeting specified criteria) may relax  the  standards
presented here.


IDENTIFICATION OF PRETREATMENT TECHNOLOGY
The  pretreatment technology for PSES for the  Organic  Pesticide
Chemicals  Manufacturing  is presented in Table XIII-1  for  each
regulated  pollutant.   The pretreatment technology for PSES  for
the   Metallo-Organic   Pesticide  Chemicals  Manufacturing   and
Pesticide Chemicals Formulgating and Packaging subcategories  are
given in Table XIII-2.


RATIONALE FOR SELECTION OF PRETREATMENT TECHNOLOGY


Toxic organic,  metals,  and nonconventional pesticide pollutants
may  pass  through a POTW or they may contaminate the  sludge  or
they may interfere with the treatment process.   These pollutants
must  therefore  be controlled by pretreatment.   (See Section  V
B(3) of the preamble to the regulation).
                               XIII-1

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PRETREATMENT STANDARDS
Pretreatment standards for existing (PSES)  and new sources (PSNS)
for the organic pesticide chemicals manufacturing subcategory are
the same as BAT for all pollutants except six priority pollutants
which  are not regulated.  A detailed discussion as to why  these
pollutants  were  not regulated is in the preamble to  the  final
regulation. These standards are given in Section XIV.


The  pretreatment  standards for  the  metallo-organic  pesticide
manufacturing   subcategory  are  the same as  the  existing  BPT
limitation  of no discharge of process wastewater pollutants from
the   manufacture   of  metallo-organic   pesticides   containing
cadmium,  arsenic  or copper.  A discharge standard based on zinc
precipitation  is  specified  for  the  manufacture  of   mercury
metallo-organic  pesticides products.   These standards are given
in Section XV.
The   pretreatment   standards  for   the   pesticide   chemicals
formulating   and  packaging  subcategory  are  no  discharge  of
priority pollutants or the pesticide active ingredients listed in
Appendix D of the regulation in process wastewater resulting from
the  formulating  and packaging of any of  the  pesticide  active
ingredients  listed in Appendix D of the regulation.   Appendix D
lists  147 organic pesticide chemicals with available  analytical
test  methods  and the zinc  metal-containing  organic  pesticide
chemicals  Vancide  51Z and Vancide 51Z dispersion.    Appendix  D
also includes all metallo-organic pesticide chemicals  containing
arsenic, cadmium, copper,  mercury, or tin.


The  Agency is not setting new source pretreatment standards  for
metallo-organic  pesticide  producers under paragraph 8(b)(2)  of
the EPA v.  Train Consent  Decree.  Pretreatment standards for new
sources  for  formulator packagers are the  same  as   pretreatment
standards for existing sources.
BENEFITS OF IMPLEMENTATION


The estimated environmental benefits of implementing pretreatment
standards  for this category are summarized in Section   XIV  and
detailed   in  a  report  entitled  "Limitations  and   Standards
Methodology for the Pesticide Chemical Industry."  Implementation
of  PSES will remove annually an estimated 150,000 kg/yr (330,000
Ib/yr)  of  pollutants included 93,200 kg/yr (205,000  Ib/yr)  of
priority pollutants.
                               XIII-2

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                                              TABLE  XIII-1
                                   MXEL TREATMENT TEOWOLOGY FOR PSES
                               FOR THB PESTICIDE  MANUFACTURING SUBCATEOORY
Treatment
Technology

(1) Physical/Chemical
    Treatment Technology
* Priority
 Pollutants

 cl,2-Oi chlorobenzene
 cl,4-Dichlorobenzene
 cl, 2,4-Tr ichlorobenzene
 CMethyl bromide
 ccarbon tetrachloride
 °Chloroform
 CMethyl chloride
 CMethylene chloride
 °2,4-Dichlorophenol
 c4-Nitrophenol
 cpentachlorophenol
 °Copper
 "Zinc
 "N-NitroBodi-n-prcpylamine
 CHexachlorocyclopentadiene
 ba-BRC-Alpha
 bb-BHC-Beta
 bd-BHC-Delta
 bg-BHC-Orana
 ba-Endosulfan-Alpha
 bd-Endosulfan-Beta
 "Endrin
 *Heptachlor
 *Toxaphene
     Non-Conventional
        Pesticides
Busan 40
Busan 85
Carbam-S
Carbophenthion
Chlorpropham
Chlorpyrifos
Chlorpyrifoe-methyl
Counaphos
CBCP
Dioxathion
Ferbam
KN-methyl
Mancozeb
Haneb
He than
Haled
Niacide
PCNB
PCP Salt
Ronnel
Si1vex
Stirofos
Swap
Triazines
Trichloronate
ZAC
Zineb
2,4-D
2,4-D IB ester
2,4-D IO ester

2,4-EB
2,4-EB IB ester
2,4-EB IO ester
2,4,5-T
 (2)  Physical/Cheniical
     Plus Biological
     Treatment Technology
 Cyanide
 2,4-Di nitrophenol
2Alachlor
2Atrazine
 Azi nphos-methyl
 Benfluralin
 Bolstar
 Bronacil
 Butachlor
 Carbendazinv/Benomyl complex
 Carbofuran
 Dematon-O
 Dematon-S
 Dene ton
 diazinon
 Dichlofenthion
2Dichlorvos
 Dnoseb
 Disulfoton
 Diuron
 Ethalfluralin
                                                               Fensulfothion
                                                               Penthion
                                                               Flucroeturon
                                                               Glyphosate
            Iscpropalin
            Linuron
            Malathion
            Methonyl
            Hetribuzin
          2Mevinphos
            Neburon
            Oxamyl
          2Parathion ethyl
          2Parathion methyl
            Phorate
            Profluralin
            Prcneton
            Pronetryn
            Propachlor
            Propazine
            Prophara
            Propoxur
            Simazine
            Siraetryn
            Terbacil
            Terbufos
            Terbuthylazine
            Terbutryn
            Trifluralin

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                                                   TABLE XIII-1

                                        MOCEL TFEATrcNT TECHNOLOGY FOR PSES
                                     FDR THE PESTICIDE MANUFACTURING SUBCATEGORY  (Continued, Page 2 of 2)


     1.  24 priority pollutants where PSES = P/C

         a.  Five of these pollutants have demonstrated PSES = P/C in pesticide data base
         b.  Six of these pollutants were confirmed using technology transfer from pesticide data base.
         c.  Thirteen of these confirmed by organic P/C (using technology transfer)

         Two pollutants not confirmed

         2,4 Dinitrophenol:  PSES should be P/C + Bio

M          Two plants affected:
M
M
 ^         1 indirect - meet limit
 *"         1 direct - has Bio, costed P/C originally

          Cyanide:

          Affects 7 directs/4 indirects
          NOA said BAT limit based on P/C + Bio.
          Limit actually based on plants with Bio and P/C + Bio (8 plants).
          The 1 pesticide plant with high CN meets limit with P/C + Bio (proprietary P/C system).

          Two priority pollutant where PSES = No discharge

          0  1,3 - Dichloropropene
          0  Bis (2-Chloroethyl) ether

     2.  7 of the 50 Cat. 1 NCPS discharged by 5 Indirect discharges (Plant Nos. 5, 28, 31, 46, and 182).
         All the remaining indirect dischargers only discharged Cat. 2 NCPs.  For the 5 indirects, 1
         plant has bio.  (costed P/C only for parathion ethyl & parathion methyl) and 4 plants costed
         P/C and bio.

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                           TABLE XII1-2


               Model Treatment Technology for PSES



Metallo-organic Pesticide Producers

o    Cadmium,  copper, arsenic

          Contract haul and Incineration

o    Mercury

          Zinc Precipitation


Pesticide Formulator Packagers

          Contract haul and Incineration
          Recycle/Reuse
                              XIII-5

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                           SECTION XIV
        DERIVATION OF EFFLUENT LIMITATIONS AND STANDARDS
 FOR THE ORGANIC PESTICIDE CHEMICALS MANUFACTURING SUBCATEGORY
INTRODUCTION


This section describes the selection of the recommended treatment
technologies,  the  data base and the methodology for determining
the effluent limitations and standards for the Organic  Pesticide
Chemicals Manufacturing Subcategory.


SELECTION OF RECOMMENDED TREATMENT TECHNOLOGIES
In  selecting the type of best performance treatment technologies
recommended   for  organic  pesticide   chemicals   manufacturing
wastestreams,  the Agency evaluated such factors as the technical
feasibility of the treatment to remove pollutants of concern, the
capital,   annual   and  energy  costs  of  the  treatment,   the
reliability of the technology, the availability of the technology
on a full-scale basis,   the compatibility of the technology with
other  treatment units and the versatility of treatment in  terms
of  the types and levels of pollutants which may be  treated.   A
significant  important  factor  in  the  Agency's  selection   of
treatment  technologies  was  whether or not the  technology  was
being used in the pesticide industry.  Table XIV-1 presents seven
technologies selected by the Agency as the basis for the effluent
limitations  guidelines and standards.   These  technologies  are
currently  operated  on a full-scale basis within  the  pesticide
manufacturing industry.   Table XIV-1 also shows six technologies
that the Agency did not recommend as best performance since their
use  had  not  been  adequately  demonstrated  in  the  pesticide
industry.


Selection  of  the  Data  Base Used to  Develop  Limitations  and
Standards
As  discussed previously,  based upon the available data for  the
pesticides industry as set forth in Section VI of this  Document,
the  Agency has selected treatment technologies for each specific
pesticide process.   Once these technologies were  selected,  the
Agency  also  evaluated the performance of these technologies  on
wastewaters  in  the organic chemicals,  plastics  and  synthetic
fibers  ("OCPSF")   and  Pharmaceuticals  industries  for  several
pollutants.
                               XIV-1

-------
Specifically,  the Agency transferred performance data from steam
strippers for methylene chloride from the pharmaceutical industry
and performance data from steam strippers for  benzene,  toluene,
chloroform,   dichloromethane,   carbon   tetrachloride  and  1-2
dichloroethane from the OCPSF industry.  The specific removals of
these   pollutants   by  steam  stripping  in   the   OCPSF   and
pharmaceutical  industry has been previously discussed in Section
VI of the Development Document.   The Agency believes that it  is
reasonable  to transfer steam stripping data for these pollutants
to  the pesticide industry because the raw waste load  data  into
the  steam  stripper for these pollutants in the  pesticide  data
base is similar or lower than to the raw waste load data into the
steam   strippers   for  these  pollutants  in  the   OCPSF   and
pharmaceutical data base.   See August 28, 1985 memorandum to the
record,  Section II.B.I.  Moreover, since the pollutants at issue
are  used  as solvents or raw materials in  the  Pharmaceuticals,
OCPSF and pesticide industry,  the process step for manufacturing
these pollutants is similar.   (see,  for example,  The Pesticide
Manual,  Kirk  and Othmer,  and the information listed in Section
XX-Appendix  6 of this report).   Given these  two  factors,  the
Agency   believes  that  the  removal  efficiency  of  the  steam
strippers  for  methylene  chloride  will  be  the  same  in  the
pesticides and Pharmaceuticals industry and for benzene, toluene,
chloroform,   dichloromethane,   carbon  tetrachloride  and  1,2-
dichloroethane  will  be the same in the OCPSF industry  and  the
pesticides industry.


The  Agency assembled the treatment technology  performance  data
from  pesticides  industry  and  the  OCPSF  and  Pharmaceuticals
industry  (for  the  above referenced pollutants) into  one  data
base.
The  Agency  edited the data base to remove plant  data  for  the
following reasons:


1.    The  Agency  edited  the data base to remove all  data  for
nonregulated pollutants.


2.    Data  for which adequate analytical methods did  not  exist
(i.e.,  those  with  minimal  quality  assurance/quality  control
specifications) were deleted.


3.    The  Agency  deleted  effluent  data for which  we  had  no
corresponding  influent  level  data or the  influent  data  into
the  biological  system  was at less than  85  ppb.   These  data
were  eliminated  because the Agency was unable  to  assure  that
the   effluent  values  at  the  end  of  the  treatment   system
reflected  the  actual  treatment  of pollutants  as  opposed  to
low   levels   of  raw  waste  concentrations  which   were   not
                               XIV-2

-------
removed  by  the  treatment system.   Use of  this  editing  rule
is   conservative   because  it  avoids   the   promulgation   of
effluent  limitations  guidelines  which do  not  reflect  actual
treatment.


4.    Three data pairs were eliminated because the effluent level
was higher than the corresponding influent level.


5.     Two   data  points  for  nonconventional  pollutants  were
eliminated because they were identified as outliers.


After editing the data base,  the Agency evaluated the  remaining
data base to identify "best performance" treatment systems.


The  Agency  evaluated each individual treatment system  at  each
plant  to identify best performance systems.   In order to select
best  performance  plants,   the  Agency  developed   performance
criteria  for  each  treatment  system.    The  best  performance
criteria are presented in Table XIV-2.  These criteria were based
on  engineering  evaluations of removal  efficiencies,  detention
time,  loading  rates and other design criteria.   The data  upon
which  these  performance criteria are based were  identified  in
Section  VI  of the 1982  Pesticide  Development  Document.   The
application of this data to the selection of the best performance
criteria  is found in Section II.B.I  of the Record.   (Refer  to
December 21, 1984 ESE letter).


Table  1  in the June 13,  1984 NOA sets forth two  criteria  for
selection  of best performance treatment data percent removal  of
the  treatment  system and treated effluent  concentration.   The
primary  criterion  evaluated by the Agency was  percent  removal
which best establishes treatment system performance.   If a plant
did  not meet the established percent removal,  the  plant  could
still  be considered "best performance" if it met the established
effluent concentrations.


A  treatment  system  was defined as "best  performance"  if  the
system  met the treatment performance criteria for any  regulated
pollutant for which the treatment system was designed.   In order
to determine for which pollutant a treatment system was designed,
the Agency reviewed the raw waste load data at each plant.   If a
pollutant  was  demonstrated to be in a significant amount  in  a
plant's  raw waste load,  the Agency assumed that  the  treatment
system  was  designed for that pollutant (i.e.,  steam  stripping
units  were  examined   for  volatile   organics,   not  phenolic
pollutants).
                               XIV-3

-------
The  Agency  arrayed  the data base for  each  plant  by  average
percent  removal  for each treatment system.    The  Agency  found
large disparities in average removals and effluent concentrations
in the arrayed data base.  The majority of the plants had removal
efficiencies  and  effluent  concentrations clustered  around  or
above  the  best performance value;  the plant  or  plants  whose
removal  efficiency  or effluent concentration was  significantly
different  correlated  with the "non best performance"  plant  in
terms of the engineering criteria.


As a result of this best performance analysis, the Agency deleted
four  treatment  systems for nonconventional  pollutants  and  one
treatment  system  for  priority pollutants  because  the  system
failed the best performance criteria.


For  those treatment systems which  did not meet  the  performance
criteria,   the   Agency  identified  specific  reasons  why  the
performance  of these systems is inadequate to be considered  BAT
treatment.  Typical examples are that the system is too small for
the treated flows or that the carbon usage rate is too low.


Methodology for Determining the Limitations and Standards


In developing effluent limitations  and standards the Agency  used
the  data base and model treatment  technologies described  above.
The methodology for developing these limitations and standards is
described  below.   The  model treatment technology for  BAT  and
pretreatment for each regulated pollutant is  given in  Table XI-1
XIII-1.  The  limitations  and  standards are given in Table II-l
and   II-2.   In calculating these  limitations and standards  the
Agency  used  a delta lognormal statistical  distribution.   This
analysis is described in detail in  the record to this  rulemaking
in "Limitations and Standards Methodology for Pesticide Chemicals
Industry," August 30, 1985.


BAT Effluent Limitations Guidelines for Priority Pollutant


To  derive BAT effluent limitations,  the Agency first  evaluated
the  removal  of  priority pollutants by plants which  have  well
operated biological treatment units.   The Agency used data  from
best  performance  biological  treatment systems to  calculate  a
long-term  average  effluent value  for each  priority  pollutant.
The  long-term average values are estimates of average  pollutant
levels  expected  to  be found in  treated  effluent  from  well-
operated   biological  systems  with  varying  influent  priority
pollutant levels.   These long-term average values are the  basis
for   the   BAT  effluent  limitations  guidelines.    For   most
pollutants, data from more than one best performance system for a
specific priority pollutant were used to calculate the  long-term


                               XIV-4

-------
average.   For nine  priority  pollutants, biological performance
data were not available.  In these cases the Agency determined in
its  technology  transfer analysis,  whether a  sufficient  basis
existed   for   transferring   the   biological   removals   from
structurally   similar  compounds.    (The  Agency's   technology
transfer  methodology  is discussed fully in the record  to  this
regulation and Section V of the preamble to the regulation).   In
cases  where  the Agency decided that there was  an  insufficient
basis  for transferring biological removal from other  compounds,
the BAT limitations and standards are based on the performance of
physical/chemical treatment only.


The  Agency then examined the average influent concentration  for
each priority pollutant in each of the best performing biological
systems  to determine the highest average influent  concentration
associated  with  an average treated effluent concentration  less
than  or  equal  to  the  long  term  average  for  the  priority
pollutant.   These  influent values are termed "trigger  values."
The  trigger value is the highest influent level  treatable  with
biological  treatment  alone.   If a plant had an influent  value
higher than the trigger value,  then physical/chemical  treatment
prior  to biological treatment is recommended and coated as  part
of   the  model  treatment  technology.    The  physical/chemical
treatment should reduce the priority pollutant below the  trigger
value.  For pollutants for which there were no biological removal
data and for which transfer of data was not supportable,  the BAT
effluent  limitation  was  based on the performance  of  physical
chemical treatment only.


Pretreatment Standards for Priority Pollutants


Pretreatment  standards are established to prevent the  discharge
of  any pollutant through publicly owned treatment works  (POTWs)
which interfers with or passes through the POTW.  To identify the
pollutants  which  pass through a POTW the  Agency  compared  the
average  percent  removal  of  the BAT treatment  system  to  the
average   percent  removal  obtained  by  well  operated   POTWs
achieving  secondary treatment.   Pollutants for which  the  POTW
removal  is lower than the BAT removal pass through the POTW  and
are  designated  as  incompatable  pollutants.   In  making  this
comparison,  the Agency found that six priority pollutants do not
pass  through  the  POTW (five of these are  volatile  pollutants
which  may cause subsequent air pollution problems on POTW safety
problems).


The  pretreatment standards for the 28 priority pollutants  which
are  incompatible with the operation of POTW's are equal  to  the
BAT  limitations  for  these  pollutants.   The  model  treatment
technology  for  26  of  these pollutants  is  physical  chemical
treatment  only.    For  two  pollutants,   the  model  treatment
technology is physical/chemical followed by biological treatment.


                               XIV-5

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BAT Limitations for Nonconventional Pesticide Pollutants


The  Agency  developed limitations for  specific  nonconventional
pesticides  by  using a  two-step  process.   First,  the  Agency
calculated  the long-term average physical/chemical effluent  for
each  pesticide for which it had a valid analytical  method.   In
cases  where  the  Agency  did not have  appropriate  data  on  a
specific  pesticide,  the  Agency  determined  whether  it  could
transfer  data from a similar compound within the same structural
group  (the  structural  groups,  their basis  and  the  transfer
methodology  are  discussed in the Agency's  technology  transfer
analysis,   "Technical   Document  of  Technology  Transfer   for
Nonconventional  Pesticides,"  August 1985).    If  no  data  were
available  and  it  was  not appropriate to  transfer  data  from
another compound, the pesticide was not regulated.


The second step in establishing limitations and standards was  to
determine  average percent removal of best performing  biological
treatment  for  each pesticide where biological removal data  was
not  available.   The  Agency determined whether  data  could  be
transferred  from another pesticide in the same structural group.
For  pesticides where biological removal data were  available  or
could  be  transferred,  the BAT limitations and  standards  were
determined  by multiplying the physical/chemical effluent by  the
biological percent removal.   Where no biological data existed or
could  be  transferred,  the BAT limitations and  standards  were
based on the physical/chemical treatment effluent.


Pretreatment Standards for Nonconventional Pesticide Pollutants
The  Agency determined that nonconventional pesticide  pollutants
could interfere with, upset, and pass through POTWs.  Accordingly
the   Agency  established  pretreatment  standards  for  all  the
nonconventional   pesticides  for  which  BAT  limitations   were
established.   The  pretreatment standards are equal to  the  BAT
limitations and are based on the same technology.


Confirmatory Data


The  Agency  used  data from the Organic Chemicals  Plastics  and
Synthetic   Fibers  Industry  to  confirm  the   performance   of
physical/chemical  treatment  systems  which form the  basis  for
pretreatment  standards for the priority pollutants.   This  data
was obtained by EPA through a sampling program carried out by the
Agency at 12 OCPSF plants.    This data (Table XIV-3) shows  that
physical/chemical  treatment  (steam  stripping)  is  capable  of
removing  various  volatile and semi-volatile  organic  compounds


                               XIV-6

-------
down  to detection limit values.   These data were not  available
until  after the June 13,  1984 NOA and were used to confirm  the
performance levels specified by the methodology set forth above.
                               XIV-7

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                           Table XIV-1
       Treatment Technology Selected as Best Performance*

                                Number of Plants with Treatment
Treatment Unit                        BPT             BAT

Biological Oxidation-*-                 13             32
Chemical Oxidation1                    -              9
Granular Activated Carbon1             9             17
Hydrolysis1                            5              8
Metals Separation1                     -              3
Resin Adsorption1                      -              4
Steam Stripping1                       -              8
Ion Exchange2
Membrane Processes2
Powdered Activated Carbon2             -              1
Solvent Extraction2                    -              1
Ultraviolet Photolysis2
Wet Air Oxidation2
Note:  l=Selected as best performance
       2=Not selected as best performance
       *=Preproposal Data
                               XIV-8

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                           TABLE XIV-2

    Criteria for Best Performance Treatment Technologies1

                                    CRITERIA
                        Nonconventic
Treatment
   Nonconventional
     Pollutant
Priority or Pollutants
Activated Carbon
Hydrolysis
Resin Adsorption
Steam Stripping
>95% Removal          >99% Removal
or < 1 mg/1 effluent  or < lmg/1 effluent

> 95% Removal
or < 1 mg/1 effluent

> 95% Removal         > 99% Removal
or < 1 mg/1 effluent  or< 1 mg/1 effluent

                      > 90% Removal
                      or  99.6% Removal
                      or <0.04 mg/1 effuent
Metal Separation
Biological Oxidation   > 70% Removal
                       < 586 mg/1 COD
                         effluent
                      > 95% Removal
                      or 0.5 mg/1 effluent
                       > 95% Removal
                       or < 50 mg/1 BOD
1  Preproposal Data
                               XIV-9

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Table XIV-3.  Physical/Chemical Confirmatory Treatment Data fron OCPSF Industry
                                0.1
                                0.1
                               49.0
    Volatile
Priority Pollutants

Benzene
Toluene
Chlorobenzene
1,4 - Dichlorobenzene
Methyl Chloride
Methyl Bromide
Carbon Tetrachloride
Tetrachloroethylene
Chloroform
1,2 - Dichlorobenzene
1,2,4 - Trichlorobenzene
Methylene Chloride
1,2 - Dichloroethane
1,3 - Dichloropropene
Bis (2-Chloroethyl) Ether
H:  High Strippability Compound
M:  Medium Strippability Compound
L:  Low Strippability Compound
                               Actual Steam Strippers
                           Effluent Concentration (mg/1)
                             Pesticides         OCPSF
                               13.37
                                6.96
0.016 (H)
                                                 ND (H)
0.010 (H)
0.010 (M)
0.015 (M)
                      Data Trasferred
                      From OCPSF (mg/1)
0.013 (H)
0.013 (H)
0.013 (H)

0.013 (H)
0.013 (H)
0.013 (H)

0.0125 (M)
0.0125 (M)
                                                                         0.0125 (M)
                                                                         1.064  (L)

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                          SECTION XV
              DERIVATION OF EFFLUENT LIMITATIONS AND
           STANDARDS FOR THE METALLO-ORGANIC PESTICIDE
                MANUFACTURING SUBCATEGORY AND THE
                FORMULATING/PACKAGING SUBCATEGORY
INTRODUCTION

This section describes the selection of the recommended treatment
technologies  and  the methodology for determining  the  effluent
limitations  and  standards  for  the  Metallo-organic  Pesticide
Manufacturing Subcategory and the Pesticide Formulating/Packaging
Subcategory.


SELECTION OF RECOMMENDED TREATMENT TECHNOLOGIES
In  selecting the type of treatment technologies recommended  for
metallo-organic pesticide manufacturing and formulating/packaging
wastestreams,  the Agency evaluated such factors as the technical
feasibility of the treatment to remove pollutants of concern, the
capital, annual and energy costs to the treatment, the ability of
the treatment to perform to levels of concern, the reliability of
the  technology,  the  availability of the technology on a  full-
scale  basis,  the  compatibility of the  technology  with  other
treatment  units and the versatility of treatment in terms of the
types  and levels of pollutants which may be treated.   The  most
important   factors  in  the  Agency's  selection  of   treatment
technologies was whether or not the technology was being used  in
the  pesticide industry.   Table XII-2 presents the  technologies
selected  by the Agency as the basis for the effluent limitations
guidelines  and  standards for these  two  subcategories.   These
technologies are currently operated on a full-scale basis in  the
pesticide industry.


Metallo-orqanic Manufacturers


The  Agency is unaware of any existing metallo-organic  pesticide
manufacturer  discharging  arsenic,  cadmium or copper to a POTW.
Therefore,  the Agency has not developed plant-by-plant costs for
these  indirect dischargers.   However,  PSES are promulgated for
these  pollutants  to  control any  existing  direct  discharging
facilities  which  changes to an indirect  by  discharging  these
pollutants  to  a POTW.   Since the Agency costed  treatment  for
these   facilities  under  BPT,   the  costs  of  installing  the
recommended  treatment  technology  to  achieve  zero   pollutant
discharge  have not been calculated by the Agency.   Accordingly,
PSES  for  metallo-organic  pesticide  manufacturers  discharging


                              XV-1

-------
arsenic,  cadmium  or  copper is  economically  achievable.   The
recommended    zero   discharge   treatment   technologies    for
manufacturers  of  arsenic,   cadmium  or  copper  metallo-organic
pesticides   are  contract  hauling  and   incineration.     These
technologies  are described  in Section  VI.   Factors  associated
with  the  feasibility  of  implementing  these  technologies  to
achieve  zero  discharge  is  discussed  in  this  section  under
formulator/packagers.  Only  one metallo-organic facility is known
to  indirectly  discharge process  wastewater.    That  facility
alleged  that it could not achieve zero discharge and recommended
that the Agency base PSES for mercury organic pesticides on  zinc
precipitation.   In response to this comment,  the Agency, in the
June  13,  1984  NOA,  announced  that it  was  considering  zinc
precipitation  treatment  technology or other  similar  treatment
technology  for  control of  mercury followed by discharge of  the
treated  wastewater as an alternative to the previously  proposed
zero   discharge  standards.    The  Agency  requested   specific
information  and  data on the wastewater  treatment  technologies
used by this segment of the  industry.


The  Agency  received  additional  comments  from  the   indirect
discharging  facility alleging that a zero discharge standard for
mercury  was  neither  environmentally  sound  nor   economically
achievable.   In  response  to this comment,  the  Agency  sought
additional  treatment  technology and wastewater data  from  this
facility.


As  a  result  of its evaluation of  this  additional  data,  the
numerical limit for mercury  is 0.45 mg/1 (daily maximum)  and 0.27
rag/1  (monthly  average) for indirect  discharge  metallo-organic
plants  discharging  mercury.   This  pretreatment  standard  for
mercury is based upon the zinc precipitation treatment technology
discussed  in  Section VI.   The Agency believes that it is  more
environmentally  sound to require zinc precipitation followed  by
discharge of the treated wastewater because zero discharge  based
on  incineration  or  evaporation  could  produce  air  pollution
associated  with the volatilization of mercury.   The Clean Water
Act requires EPA to consider the non-water quality  environmental
impacts  of  the effluent limitations guidelines  and  standards.
Volitilization   of   mercury  in  an  incinerater  could   cause
violations  of  the hazardous air  pollutant  emission  standards
established  under  the  Clean Air Act for mercury and  as  such,
could  create  serious non-water  quality  evironmental  impacts.
Zero  discharge  based  on recycle/reuse is  not  technologically
achievable for such manufactures.  Therefore, the Agency believes
that  zinc  precipitation is an appropriate technology  for  this
process and is preferable to other available treatent methods.
                              XV-2

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Pesticide Formulator/Packagers


The  Agency proposed PSES which would require zero  discharge  of
process  wastewater pollutants.   The treatment technology  bases
for pesticide formulating/packaging subcategory were:

     1.   Contract hauling

     2.   Spray Evaporation


The   Agency   believes   that  the  pollutants   discharged   by
formulating/packaging  facilities pass through the  POTW  because
the  BPT  treatment technology achieves no discharge  of  process
wastewater  pollutants which is complete removal.   Since a  POTW
cannot  achieve this removal for the priority and nonconventional
pollutants,  the Agency is establishing PSES for these pollutants
based on pass through.


Commenters  pointed  out  that  evaporation,  particularly  spray
evaporation,  can  lead  to  air-pollution  and  other  non-water
quality environmental impacts.   Commenters also pointed out that
contract  hauling must be combined with incineration,  not  land-
filling,  to  be effective in disposing of the pollutants  rather
than possibly creating future environmental problems.  Commenters
additionally  suggested that treatment technology,  such  as  the
physical/chemical   treatment   technology  used   by   pesticide
manufacturers,  could  achieve low levels of priority  pollutants
and pesticides in the treated water.


In response to these comments,  the Agency revised the technology
basis  for the promulgated PSES for this subcategory,  to combine
contract hauling with incineration, to eliminate evaporation, and
to   add   physical/chemical   treatment   followed   by    water
recycle/reuse.   Hence,  the technology bases for the promulgated
pretreatment standards are:

1.   Contact hauling and incineration

2.   Physical/chemical treatment with water recycle/
     reuse and contract hauling followed by incinera-
     tion for treatment system waste concentrates and
     any wastewater that cannot be treated and recycled.
                              XV-3

-------
Zero    discharge    of   process   wastewater   pollutants    is
technologically  feasible  and economically achievable  based  on
supporting  data  submitted  to the  Agency  through  the  random
telephone  survey,   follow-up  contacts,    and  public  comments
submitted  in  response  to the Federal  Register  notices.   The
technological feasibility of the standard is demonstrated by  the
fact  that an estimated 87 percent of the industry currently does
not discharge wastewater pollutants.


Plant-by-plant  application  of the recommended  technologies  is
related   to  flow  and  cost.    While  contract   hauling   and
incineration  is  less  expensive  then treatment  for  low  flow
plants,  treatment  and recycle/reuse will be less expensive  for
high  flow  plants.   The  Agency  assumes  that  96  percent  of
discharging  PFP  plants have flows small  enough  that  contract
hauling and incineration will be the chosen technology while four
percent  of  the  PFP plants with larger flows would  choose  the
treatment and recycle technology.


The  Agency  believes  that incineration will  be  the  treatment
technology   practiced   by  contract   haulers.    The   report,
"Evaluation of Regulatory Options and the Development of PSES and
NSPS compliance costs for the Pesticide Formulating and Packaging
Industry," dated August 30,  1985, found that incineration is the
favored  waste  treatment method among  pesticide  manufacturers.
Incineration,  under  proper operating  conditions,  can  destroy
virtually  all  of the active ingredients of organic  pesticides.
Therefore,  incineration under ideal conditions will result in no
solid  or liquid discharges.   Additionally,  for all  pollutants
except mercury,  incineration will not create harmful  discharges
to the air.   For mercury,  the Agency believes that incineration
of  the  low  concentrations  of mercury  which  are  present  in
formulator/packager   wastewaters   (as  opposed  to   the   high
concentrations  present  in metallo-organic wastewater) will  not
present  an air quality problem.   The report concludes  that  no
adverse   environmental   impacts  will  be  developed   by   the
implementation  of incineration technology.   The Agency believes
that  the  benefits  derived from eliminating  the  highly  toxic
wastewater generated will far outweigh any possible risks  caused
during  handling  and disposal of  pesticide-bearing  wastewater.
Also,  waste  must  be  transported and disposed  of  under  RCRA
requirements.   Any potential impact associated with the handling
of  pesticide-bearing wastewaters is believed to be significantly
less than associated with the handling of pesticide raw  material
and products.


Several commenters to the June 13,  1984 NOA stated that there is
nothing  stopping  a contract hauler from discharging waste to  a
POTW or to navigable waters.  However, this regulation covers all
wastestreams  that contain the  regulated  pollutants.   Contract
haulers  are  subject to the effluent limitations  and  standards
that  apply to pesticide manufacturers and  formulator/packagers.


                              XV-4

-------
They  would  be  direct or indirect  discharging  facilities  and
subject to permit requirements.


Information  acquired through the 308 questionnaires  and follow-
up  contacts  confirm  that  contract  hauling  is  preferred  by
formulator/packagers  that  discharge  low  volumes  of   process
wastewater.   In  estimating costs for compliance with PSES,  the
Agency assumed plants would contract haul and incinerate unless a
plant  stated  it  could recycle/reuse  the  treated  wastewater.
Based on these statements, the Agency costed contract hauling and
incineration for 96 percent of the discharging PFP plants.


For  the  remaining discharging plants  with  larger  flows,  the
Agency  assumed  that  physical/chemical  treatment  followed  by
recycle/reuse  would  be  the  technology  chosen.    The  Agency
evaluated  treatment and recycle technology for four plants  that
discharge   high  volumes  of  formulating/packaging  wastewater.
These four plants confirmed that treatment and recycle technology
is  a  feasible means of achieving PSES.   The  four  plants  did
identify  selected production processes that are not amenable  to
reuse.   These  processes  demand  high purity  source  water  to
guarantee  product integrity.   The water volume requirements  of
these processes is low, therefore  wastewater flows which can not
be  recycled after physical/chemical treatment would be  contract
hauled and incinerated.   One of the four plants presently treats
and reuses 75 percent of its treated wastestream as vent scrubber
wash  water.   A  second plant incinerates  formulating/packaging
process  waste and discharges incinerator blowdown that  contains
levels  of pesticides measured as not  detected.   An  additional
plant,  a  low  flow plant,  presently treats its wastewater  and
discharges no detectable process wastewater pollutants.


The wastewater treatment and recycle scheme confirmed as feasible
by the four high flow plants includes the following elements;


1.   Formulating/packaging wastestream segregation, collection;

2.   Wastewater treatment to include,

     a.   Equalization
     b.   Steam stripping
     c.   Neutralization
     d.   Dual media filtration
     e.   Carbon adsorption and carbon regeneration
     f.   Incineration.

3.   Treated wastewater storage and return.
                              XV-5

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                           SECTION XVI

                    ENVIRONMENTAL ASSESSMENT
An assessment of the environmental effects  of  implementing  the
recommended   standards  and  limitations  is  presented  in  two
separate  documents prepared during July,  1985 by EPA/Monitoring
and Data Support Division:  (1) Environmental Assissement of  the
Direct  and Indirect Discharges of Wastewater from the Pesticides
Manfacturing  Industry;  and (2) Environmental Assessment of  the
Pesticides  Formulating/Packaging  Industry.   These  assessments
project  the  significance  of  post-regulatory   discharges   of
nonconventional  pesticides  and  priority  pollutants  on  human
health, aquatic life, and the operation of POTWs.


Impacts   are   evaluated  on  receiving  streams  and  on   POTW
operations.   Receiving  stream  impacts  are  evaluated  at  low
receiving  stream flow using a simplified dilution water  quality
model   which   predicits  instream   pollutant   concentrations.
Calculations of instream concentrations from indirect dischargers
incorporated  pollutant removal at POTWs as well as  dilution  in
the  collection  systems.   Impacts were determined by  comparing
these  pollutant concentrations with EPA water  quality  criteria
established  for the protection of aquatic life and human health.
Not  all  the  pollutants  have  water  quality  criteria.    For
pollutants without criteria, specific toxicity data (i.e., lowest
reported  LCso  values)  were  used  in  evaluating  impacts.
Potential impacts in receiving stream mixing zones were evaluated
by comparing undiluted effluent concentrations with acute aquatic
life criteria or toxicity values.


Impacts to POTW operations were evaluated in terms of  inhibition
of  POTW  processes  and contamination of POTW  sludges  using  a
simplified  POTW model.   Inhibition of POTW treatment  processes
was  determined  by  comparing calculated  POTW  influent  levels
available   inhibition  values.    Contamination  of  sludge  was
evaluated  by  comparing projected  pollutant  concentrations  in
sludge  with available sludge impact values.  Contractor-provided
data, in the form of recommended effluent standards (expressed as
plant-specific  concentrations),  average daily plant production,
total plant discharge flow, and size of the receiving  POTW  were
also used in the model.
                               XVI-1

-------
The study on pesticide manufacturers evaluated the  environmental
impacts   of  20  priority  pollutants  and  22   nonconventional
pesticide   pollutants  (NCPs)   discharging  to  waters  from  19
pesticide manufacturing plants  (12 direct and 7 indirect).  These
discharges were examined at three technology levels (1)  current,
(2) proposed BAT/PSES levels,  and (3) projected final BAT/PSES.


Under current conditions,  ten of the twelve direct facilities and
two  of the seven indirect facilities would exceed water  quality
criteria/toxicity  values.   Implementating  the BAT/PSES  levels
radices  the number of plants exceeding criteria and reduces  the
severity of the exceedances at  the remaining plants.   The number
of  pollutants exceeding criteria at current treatment levels  is
reduced by as much as 50 percent with the implementation of BAT.


There were no exceedances of inhibition vales for POTW operations
based  on  the  four  of eleven  priority  pollitants  which  had
inhibition values.   Furthermore,  the impact on sludge could not
be  determined since no sludge  impact values were  available  for
the pollutants examined.


The   study  on  pesticide  formulators/packagers  evaluated  the
environmental   impacts   of  17  priority  pollutants   and   11
nonconventional pesticide pollutant (NCP's) discharged to  waters
from     8     indirect    dischargers    in    the     pesticide
formulating/packaging industry.   These dischargers were examined
at two technology levels:   (1)  current treatment and (2) proposed
30-day  average  PSES,   a  considered  option.    Under  current
conditions  five  of  the eight  facilities  would  exceed  water
quality criteria/toxicity values.   Implementation of the PSES 30
day  option  reduced  the  severity of  the  exceedances  at  the
remaining plants.  The number of pollutants exceeding criteria at
current  treatment was reduced  by as much as 83 percent with  the
impklementation of the 30 day PSES option.


The  recommended option of zero discharge (though not part of the
study) would eliminate the limited remaining impacts).


Inhibition of two POTW processes projected at current  conditions
was  reduced  to zero at the PSES 30 day option.   No impacts  on
sludge  were  predicited  for the only pollutant  with  a  sludge
impact values.
                               xvi-2

-------
                          SECTION XVII

                        ACKNOWLEDGEMENTS
The  project was sponsored by the Industrial Technology  Division
(ITD)  of the Office of Water Regulations and Standards under the
management of Mr.  George M.  Jett and I wish to acknowledge  the
personnel  who assisted in the creation of this  document.   This
report  is a continuation of the study that was presented in  the
proposed   development  document,   EPA  440/l-82/079b  and  much
information  from that document has been used in the  manufacture
of  this  report.   The effort of the staff  that  provided  that
document is appreciated.


This  report was constructed on the basis of the proposed  report
with  the assistance of a large but competant staff.  The primary
assistance in gathering information for this report came from the
joint  effort  of  the two firms  of  Environmental  Science  and
Engineering  and  JRB Associates under Contract  No.  68-01-6947.
Ms. Barbara Brown provided the leadership to produce the basis of
an  excellent  study.  The work was then turned over to  the  JRB
staff  of Mr.'s Barry Langer,   Andy Mantis  Bill  Hahn,  Richard
Hergenroeder,  Bill Hughes,  and Dr.  Ed Chen.  L. Marlin  Eby of
Infotech,   Incorporated   provided  the  contractor  statistical
support.   I  wish to thank these people for their assistance  in
construction of this report.


The  draft  report  was  then turned  over  to  ITD  where  final
construction  was  completed by Mr.'s Devereaux Barnes,  Gary  E.
Stigall,  Elwood Forsht, Ronald Kirby and Dr. Thomas Fielding and
Hugh Wise.   The Office of General Counsel's legal assistance was
provided by Ms.  Susan Schmedes,  Ms.  Susan Lepow,  and Mr.  Lee
Schroer.  The  Agency  statistical guidance was provided  by  Dr.
Henry  Kahn and Dr. Cliff Bailey.  The Agency's economic analysis
assistance  was  provided  by Dr.  Ellen  Warhit  and  Mr.  Mitch
Dubenski.   Dr.  Richard  Healy provided  Agency's  environmental
assessment  information and Mr.  Mahesh Podar provided assistance
from  the  Office  of Program  and  Policy  Evaluation.   Special
acknowledgement  must  be  made  to  the  word  processors  whose
patience,   cooperation  and  enormous  assistence  produced  the
majority of this text.   These employees are Ms.'s Glenda  Nesby,
Pearl  Smith,  and Carol Swann.   The most competent  Ms.  Arelia
Wright  provided  the remaining portions.   The entire  text  was
carefully proofed by Ms. Micki Treacy.


The  cooperation and participation of the manufacturing industry,
trade  associations  and public participants in  developing  this
report is also appreciated.
                              XVII-1

-------

-------
                          SECTION XVIII

                          BIBLIOGRAPHY


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American Public Health Association, AWWA, and WPCF.  1975.  Standard
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                              XVIII-1

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Barnes, D.  1978.  Development Document for Proposed Existing Source
     Pretreatment Standards for the Electroplating Point Source
     Category.  U.S. Environmental Protection Agency, Washington,
     D.C.  EPA 440/1-78/085.

BASF Wyandotte Corporation, et al.  1976.  Petition for Rehearing,
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BASF Wyandotte Corp. (Industry Comments) Vol. IA.

Beaudet, B.A.  1979a.  Study of the Effectiveness of Activated Carbon
     Technology for the Removal of Specific Materials from Organic
     Chemicals Processing Wastewater.  Prepared for U.S. EPA Draft
     Report on Pilot Operations at Dow Chemicals USA Plaquemine,
     Louisiana Plant.  Environmental Science and Engineering, Inc.,
     Gainesville, Florida.

Beaudet, B.A.  1979b.  Study of the Effectiveness of Activated Carbon
     Technology for the Removal of Specific Materials from Organic
     Chemicals Processing Wastewater.  Prepared for U.S. EPA Draft
     Report on Pilot Operations at Ethyl Corporation, Baton Rouge,
     Louisiana Plant.  Environmental Science and Engineering, Inc.,
     Gainesville, Florida.
                              XVIII-2

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Beaudet, B.A.  1979c.   Study of the Effectiveness of Activated Carbon
     Technology for the Removal of Specific Materials from Organic
     Chemical Processes.  Prepared for U.S. EPA, Final Report on
     Pilot Operations  at USS Chemicals, Neville Island Plant.
     Environmental Science and Engineering, Inc., Gainesville,
     Florida.

Bell, H.L.  1974.   An  Appraisal of Pesticide Usage and Surface Waste
     Quality Effects in the United States.  U.S. EPA, Office of
     Enforcement,  National Field Investigations Center, Denver,
     Colorado.

Bender, M.L. and Homer, R.B.  1965.  The Mechanism of the Alkaline
     Hydrolysis of the p-Nitrophenyl n-Methylcarbamate.  Journal of
     Organic Chemistry, November, 30:3975.

Berg, G.L., Editor.  1973.  Farm Chemicals Handbook.  Meister
     Publishing Company, Willoughby, Ohio.

Berkowitz, Joan B., John Funkhouser, and James I. Stevens 1978.
     Unit Operations For Treatment of Hazardous Industrial Waste.
     Noyes Data Corporation Park Ridge, New Jersey.

Bernardin, F.E., Jr.  1976.  Selecting and Specifying Activated
     Carbon-Adsorption Systems.  Chemical Engineering, October,
     18:77-82.

Bernardin, F.E., Jr. and Froelich, E.M.  1975.  Practical Removal of
     Toxicity by Adsorption.  Thirtieth Annual Purdue Industrial
     Waste Conference.

Berndt, C.L. and Polkowski, L.B., Dr.  1978.  PAC Upgrades Wastewater
     Treatment.  Water and Wastewater Engineering, May, 48-50.

Birge, W.J., Black, J.A., and Bruser, D.M. 1979.  Toxicity of
     Organic Chemicals to Embryo-Larval Stages of Fish.
     EPA-560/11-79-007.

Birkmeier, J.L., LaRocca, S.A., and Haulsee, R.E.  1978.   Activated
     Carbon Removes Pesticides from Wastewater at Research Facility.
     Industrial Wastes, September/October, 20-24.

Black, J.A., e_t al. 1982, The Aquatic Toxicity of Organic Compounds
     to Embyro-Larval  Stages of Fish and Amphibians, PBB2-224601, NTI
     U.S. Depart,  of Commerce.

Boyle, H.  January 1971.  Analysis of Raw Sewage Sludge and Effluent
     for Chlorinated Insecticides for the Los Angeles County
     Sanitation District.  Waste Identification and Analysis.
     U.S. EPA, AWTRL,  NERC-Cincinnati, Ohio.

Bridger, T.T., Jr., and Hill, D.O.  1978.  Methyl Parathion
     Wastewater Treatment Program Status Report.  Kerr-McGee Chemical
     Corporation,  Hamilton, Mississippi.
                              XVIII-3

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Brown, B.S. March 27, 1984. Hazard-Weighting for Cost Effectiveness
     Analysis.  Prepare for U.S. EPA, Effluent Guidelines Division.
     Environmental Science and Engineering, Inc., Miami, PL.

Brown, B.S. May 25, 1984.  Final Pesticide Process Profiles for
     the Notice - Confidential.  Prepared for U.S. EPA, Effluent
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     Engineering, Inc., Miami, FL.

Brown, N.P.H., Furmidge, C.G.L., and Grayson, B.T.  1972.  Hydrolysis
     of the Triazine Herbicide, Cyanazine.  Pesticide Science,
     3:669-678.

Brungs, W.A.,  Carlson, R.W., Hornung, W.B.,McCormick, J. H.,
     Spehar, R.L., and Yount, J.D. 1978.  Effects of Pollution on
     Freshwater Fish.  Jour. WPCF, June, 1582-1637.

Buccafusco, R.J., B.J. Ells, and G.A. LeBlanc, 1981, 'Acute Toxicity
     of Priority Pollutants to Bluegill (LEPOMIB MACROCHIRUS), in
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Buesche, C.A., ejb al.  1964.  Chemical Oxidation of Selected Organic
     Pesticides.  Journal WPCF, 36(8):1005-1014.

Cabasso, I., Eyer, C.S., Klein, E., and Smith, J.K.  1975.
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     Organic Contaminants in Drinking Water.  Gulf South Research
     Institute. Prepared for U.S. EPA Office of Research and
     Development.

Cairns, M.A.,  and A.V. Nebeker, 1982, 'Toxicity of Acenaphthane and
     Isophirine to Early Life Stages of Fathead Minnows,' in Arch.
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Cadwgan, G.E.  1980. Determination of Pesticide Hydrolysis Half-Life
     Under  Acid and Base Conditions. E.I.  DuPont de Nemours and Co.

Calgon Corporation.  1980.  Adsorption Technology Using Granular
     Activated Carbon.  Pittsburgh, Pennsylvania.

Calgon Corporation.  1974.  Basic Concepts of Adsorption of Activated
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Camisa, A.G.  1975.  Analysis and Characteristics of
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Games, R.A. and Oberacker, D.A.  1976.  Pesticide Incineration.
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Casida, J.  E., Augustinsson, K.B., and Jonsson, G. 1960. Stability,
     Toxicity and Reaction Mechanism With Esterase of Certain
     Carbamate Insecticides.  Journal of Economic Entomology., 53, 20
                              XVIII-4

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CCI Environmental Systems Division.  1974.  Incineration of DDT
     Solutions.  Prepared for the Sierra Army Depot, Report S-1276,
     Herlon, California.

Centec.  1979.  Contractor Report for Development of Effluent
     Limitations Guidelines for Paint Application Processes Used in
     the Mechanical and Electrical Products Industries.  Prepared for
     U.S. EPA, Effluent Guidelines Division, Washington, D.C.

Cheah, M.L., Avault, J.W., Jr., and Graves, J.B. 1980.  Acute
     Toxicity of Selected Rice Pesticides to Crayfish
     (Procambarus clarkii).  Prog. Fish Cult., 42(3): 169-172.

Chemical Week.  May 7, 1980.  Pesticides:  6 Billion by 1990.
     Patrick P. McCuroy, Editor.  McGraw Hill, New York.

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     Handbook.  P.N. Cheremisinoff, Editor.  Ann Arbor Science
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City of Jacksonville, Arkansas.  1971.  Biological Treatment of
     Chlorophenolic Wastes.  Prepared for U.S. EPA, Office of Water
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Coco, J.H., et^ al.  1978.  Development of Treatment and Control
     Technology for Refractory Petrochemical Wastes.  Prepared for
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     Oklahoma.  Gulf South Research Institute, New Orleans, LA.

Coley, G. and Stutz, C.H.  1966.  Treatment of Parathion Wastes and
     Other Organics.  Journal WPCF, 38(8).

Colley, J.D., ejt al.  1978.  Assessment of Technology for Control of
     Toxic Effluents from the Electric Utility Industry.  Prepared
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     D.C., EPA 600/7-78-090.  Radian Corporation, Austin, Texas.

Collins, R.J. and Purkiss, B.E. 1960.  The Applications of
     Dichlorophen in the Textile Industry.  The Textile Manufacturer.

Conservation and Resource Recovery Engineering.  1977.  Compilation
     of Toxic Rejection Data for Membranes.  Prepared for U.S. EPA.

Considine, D.M.  1974.  Chemical and Process Technology Encyclopedia.
     McGraw-Hill, Inc., New York.

Conway, R.A.  1974.  Treatability of Wastewater from Organic
     Chemicals and Plastics Manufacturing—Experience and Concepts.
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Cooper, W.J. and Dennis, W.H., Jr.  1978.  Catalytic Dechlorination
     of Organochlorine Compounds IV.  Mass Spectral Identification of
     DDT and Heptachlor Products.  Chemosphere, No. 4, 299-305.
                              XVIII-5

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Cooper, W.J., Dennis, W.H.,  Jr., DeLeon, I.R., and Laseter, J.L.
     1979. Catalytic Dechlorination of Organochlorine Compounds VI.
     Mass Spectral Identification of Aldrin and Dieldrin Products.
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Cowart, R.P., e_t al.  1971.    Rate of Hydrolysis of Seven Organophos-
     phate Pesticides.   Bulletin of Environmental Contamination and
     Toxicology, 6(3).

Cristol, S.J.  1947.  The Kinetics of the Alkaline
     Dehydrochlorination of  the Benzene Hexachloride Isomers.  The
     Mechanism of Second-Order Elimination Reactions.  Journal of
     American Chemical  Society, 69:338.

Cronan, C.S., Editor-in-Chief.  1971.  A System for Removing Trace
     Amounts of Pesticide from Wastewater.  Chemical Engineering,
     August 9th.

Crook, E.H., e_t al.  1975.  Removal and Recovery of Phenols from
     Industrial Waste Effluent with Amberlite XAD Polimeric
     Adsorbents I and EC. Prod., 14(2):113.

Davis, E.M... Petros, J.K., and Power, E.L.  1977.  Organic
     Biodegradation in  Hypersaline Wastewater.  Manufacturing,
     January/February.

Davis, K.E. and Funk, R.J.  1975.  Deep Well Disposal of Industrial
     Waste, January/February.

Dean, J.A., Editor.  1973.  Lange's Handbook of Chemistry.  llth
     Edition.  McGraw-Hill Book Company, New York.

DeFilippi, R.P., e_t al.  1980.  Supercritical Fluid Regeneration of
     Activated Carbon Adsorption of Pesticides.  Prepared for
     U.S. Environmental Protection Agency, Office of Research and
     Development, Research Triangle Park, NC, March.
     EPA 600/2-80-054.

DeJohn, P.B. and Adams, A.D.  1975.  Activated Carbon Improves
     Wastewater Treatment.  Hydrocarbon Processing, October.

Dennis, W.H., Jr. and Cooper, W.J.  1977.  Catalytic Dechlorination
     of Organochlorine  Compounds III.  Lindane.  Bulletin of
     Environmental Contamination and Toxicology, 18(l):57-59.

Dennis, W.H., Jr. and Cooper, W.J.  1976.  Catalytic Dechlorination
     of Organochlorine  Compounds II.  Heptachlor and Chlordane.
     Bulletin of Environmental Contamination and Toxicology,
     16(4):425-430.

Dennis, W.H., Jr., e_t al.  1979.  Degradation of Diazinon by Sodium
     Hypochlorite.  Chemistry and Aquatic Toxicity.  Environmental
     Science and Technology, 13(5):594-598.
                              XVIII-6

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Derache, R. (Ed.). 1977.  Organophosphorus Pesticides.  Pergamon
     Press, Oxford.

Dillion, A.P.  1981.  Pesticide Disposal and Detoxification Processes
     and Techniques, 13(5):594-598.

Dobbs, R.A., e_t al.  May 1978.  Carbon Adsorption Isotherms for Toxic
     Organics.  U.S. EPA Office of Research and Development,
     Cincinnati, Ohio.

Dryden, F.E.,  e_t al.  1979.   Assessment of Dioxin-Forming Chemical
     Processes.  Prepared for U.S. EPA, IERL, Cincinnati, Ohio.
     Walk, Haydel and Associates, Inc., New Orleans, Louisiana.

Duolite International.  Carbonaceous Adsorbents.  Diamond Shamrock
     Corporation, Redwood City, CA.

Dyke, R.B., Sanderson, D.M., and Noakes, D.N. 1970.  Acute
     Toxicity Data for Pesticides.  World Rev. Pest. Contr.,
     9(3):119-127.

Earhart, J.P., Won, K.W., Wong, H.Y., Praunnitz, J.M., and King, C.J.
     1977.  Recovery of Organic Pollutants via Solvent Extraction.
     Chemical Engineering Progress, May, 67-73.

Ebon Research System.  1977.  Catalytic Hydrodechlorination of
     Polychlorinated Pesticides and Related Substances.  Prepared for
     U.S. EPA Municipal Environmental Research Laboratory,
     Cincinnati, Ohio, EPA 600/8-77-013.

Egekeze, J. 0. and Oehme, F. W. 1979.  Inorganic and Organic
     Fluoride Concentrations in Tissues after the Oral
     Administration of Sodium Monofluoroacetate (Compound 1080) to
     Rates.  Toxicology, 15:43-53.

Egekeze, J.O.  and Oehme, F.W. 1979.  Sodium Monofluoroacetate
     (SMFA, Compound 1080):  A Literature Review.  Vet. Hum.
     Toxicol,  1979:411-416.

Eichelberger,  J.W. and Lichtenberg, J.J.  1971.  Carbon Adsorption
     for Recovery of Organic Pesticides.  Journal WPCF, 63(1).

Eichers, T.R., Andrilenas, P.A., and Anderson, T.W.  1978.  Farmers'
     Use of Pesticides in 1976.  U.S. Economics, Statistics, and
     Cooperative Service.  Agricultural Economic Report No. 418.
     Washington, D.C.

Eisenhauer, H.H.  1964.  Oxidation of Phenolic Wastes, Part I:
     Oxidation with Hydrogen Peroxide and a Ferrous Salt Reagent.
     Journal WPCF, 36(9).

El-Dib, M.A. and Aly, 0.  1975.  Persistence of Some Phenylamine
     Pesticides in the Aquatic Environment-I, Hydrolysis.  Water
     Research, 10:1047-1050.
                              XVIII-7

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Engineering-Science, Inc.  1979.  Evaluation of the Potential for Air
     Stripping of Hydrocarbons During Activated Sludge Wastewater
     Treatment.  Prepared for Petro-Tex Chemical Corp., Denka
     Chemical Corp., and the Industrial Advisory Council for the
     Washburn Tunnel Plant of the Gulf Coast Disposal Authority,
     Austin, Texas.

Entomological Society of America.  1974.  Pesticide Handbook.
     Twenty-Fourth Edition.

Environmental Research Laboratory. 1981.  Acephate, Aldicarb,
     Carbophenothion, DBF, EPN, Ethoprop, Methyl Parathion, and
     Phorate—Their Acute and Chronic Toxicity, Bioconcentration
     Potential and Persistence As Related to Marine Environments.
     EPA-600/4-81-023.

Environmental Science and Engineering, Inc.  (ESE).   1979.  Pesticide
     BAT Review Verification Sampling Protocol.  Prepared for
     U.S. EPA, Research Triangle Park, North Carolina.

Environmental Science and Engineering, Inc.  (ESE).   1978.  Revised
     Technical Review of the Best Available  Technology, Best
     Demonstrated Technology, and Pretreatment Technology for the
     Timber Products Processing Point Source Category.  Prepared for
     U.S. EPA, Washington, D.C.

Environmental Science and Engineering, Inc.   1975.   Feasibility
     Evaluation of Advanced Wastewater Treatment.   Prepared for Gulf
     Oil Chemicals Company, St. James Plant.  Environmental Science
     and Engineering, Inc., Gainesville, Florida.

Environmental Science and Technology.  1977.  Putting Powdered Carbon
     in Wastewater Treatment, 11(9):854-855.

Environmental Science and Technology.  1974.  In Roads to Activated
     Carbon Treatment, 8(1):14-15.

Environmental Studies Board.  1978a.   Chloroform,  Carbon
     Tetrachloride, and Other Halomethanes:   An Environmental
     Assessment.  National Academy of Sciences.

Environmental Studies Board.  1978b.  Kepone/Mirex/
     Hexachlorocyclopentadiene:  An Environmental Assessment.
     National Academy of Sciences.

Epstein, E. and Chaney, R.L.  1978.   Land Disposal of Toxic
     Substances and Water-Related Problems.   Journal WPCF, August,
     2037-2042.

Farmer, J.D.  1978.  Treatability of  a Phenolic Waste in a Saline
     Environment.  Thesis Submitted to Mississippi State University,
     State College, Mississippi.
                              XVIII-8

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Farmer, W.J. and Letey, J.  1974.  Volatization Losses of Pesticides
     from Soils.  U.S. EPA, Environmental Protection Technology
     Series, EPA 660/2-74-054.

Faust, S.D. and Aly, O.M.  1964.  Water Pollution by Organic
     Pesticides.  Journal AWWA, 56(3).

Federal Water Pollution Control Administration.  1968.  Report of the
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Feiler, H.  1980.  Fate of Priority Pollutants in Publicly Owned
     Treatment Works.  Interim Report.  Prepared for U.S. EPA
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     Management, Washington, D.C.  EPA-440/1-80-301.

Feiler, H.D., Storch, P.J., and Shattuck, A.  1979.  Treatment and
     Removal of Priority Industrial Pollutants at Publicly Owned
     Treatment Works.  Prepared for U.S. EPA, Washington, D.C.

Ferguson, T.L.  1975.  Pollution Control Technology for Pesticide
     Formulators and Packagers.  U.S. Environmental Protection
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Flynn, B.P. and Stadnik, J.G.  1979.  Start-up of a Powdered
     Activated Carbon-Activated Sludge Treatment System.  Journal
     WPCF, 51(2):358-369.

Folmar, L.C., Sanders, H. 0., and Julin, A.M. 1979.  Toxicity of
     the Herbicide of Glyphosate and Several of Its Formulations to
     Fish and Aquatic Invertebrates.  Arch. Environm.  Contam.
     Toxicol., 8:269-278.

Ford, D.L. and Eckenfelder, W.W.  1979.  Design and Economics of
     Powdered Activated Carbon in the Activated Sludge Process.
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Fornwalt, H.J. and Hutchins, R.A.  1966.  Purifying Liquids with
     Activated Carbon.  Chemical Engineering, April llth.

Fowler, D., Witham, C., e_t a^L., 1979.  Pesticides Engineering Control
     Technology Assessment Survey.  Prepared for NIOSH, Washington,
     D.C.  Southern Research Institute.  Birmingham, Alabama.

Fox, R.D.  1973.  Pollution Control at the Source.  Chemical
     Engineering, 80(18), August 6th.

Frohlich, G., Ely, R.B., and Vollstedt, T.J.  1976.  Performance of a
     Biophysical Treatment Process on a High Strength Industrial
     Waste. Presented to 31st Annual Purdue Industrial Waste
     Conference. Zimpro, Inc., Rothschild, Wisconsin.
                              XVIII-9

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Gaddis, L., PhD.  1978.  Rejection of Chemical Species by Membrane,
     Clemson University.

Gains, T.B. 1969.  Acute Toxicity of Pesticides.  Toxicol, and
     Applied Pharmacol., 14:515-534.

Gibbons, J.D.  1971.  Nonparametric Statistical Interference.
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Gomaa, H.M. and Faust, S.D.  1971.  Chemical Hydrolysis and Oxidation
     of Parathion and Paraoxon in Aquatic Environments.  Fate of
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     D.C.

Gomaa, H.M., Suffet, I.M., and Faust, S.D.  1969.   Kinetics of
     Hydrolysis of Diazinon and Diazoxon.  Residue Review, 29.

Goodrich, P.R. and Monke, E.J.  1970.  Insecticide Adsorption on
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     Agricultural Engineers, 13(1), January/February.

Gould, J.D. and Weber, W.J.  1976.  Oxidation of Phenols by Ozone.
     Journal WPCF, January, 48(1):47-60.

Gupta, S.K. and Chen, K.Y.  1978.  Arsenic Removal by Adsorption.
     Journal WPCF, March, 493-506.

Hager, D.G.  1976.  Wastewater Treatment via Activated Carbon.
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     Activated Carbon.  Industrial Water Engineering,
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Hagar, and Rizzo.  1974.  Removal of Toxic Organics from Wastewater
     by Adsorption with Granular Carbon.  Presented at EPA, Technical
     Transfer Session, Athens, Georgia, April 19th.

Hall, C.V.  1980.  Holding and Evaporation of Pesticide Wastes.  Iowa
     State University.  Proceedings of the Sixth Annual Research
     Symposium:  Treatment of Hazardous Waste, 86-87.

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     Guidelines Division, Washington, D.C.

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     (7):80-116.
                              XVIII-10

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Hannah, S.A., Jelus, M., and Cohen, J.M.  1976.  Removal of Uncommon
     Trace Metals by Physical and Chemical Treatment Processes.
     U.S. EPA, Wastewater Research Division.

Hawley, G.G. 1981. The Condensed Chemical Dictionary 10th Edition.
     Van Nostrand Reinhold Co.

Heath, Harry W., Jr. 1980.  The Pact Process to Treat 40 MGD of
     Industrial Waste.  Presentation at WWEMA Industrial Pollution
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Hermanertz, R.O. 1978.  Endrin and Malathion Toxicity to Flagfish
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Hill, D.O., Bryant, J.L.  1979.  A Summary of Activated Sludge
     Treatability Studies.  Kerr-McGee Chemical Corporation,
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Holdway, D.A., and J.B. Spraque, 1979, 'Chronic Toxicity of Vanadium
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Holiday, Allan D., Hardin, David P., Activated Carbon Removes
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Huang, J. and Steffens, C.T.  1977.  Competitive Adsorption of
     Organic Materials by Activated Carbon.   Proceedings of the
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     and Percutaneous Toxicity of Pesticides to Mallards:
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     69(11).


                              XVIII-11

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Hutchins, R.A.  1973b.   New Method Simplifies Design of
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Hwang, S.T. and Fahrenthold, P.   1980.   Treatability of the Organic
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I.C.I. America, Inc.   1968.  A  Symposium on Activated Carbon.

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     Cost Factors for Small Wastewater  Treatment Plants Less than
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     5P2-WP-195-0452.

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     Control/Quality Assurance  for the  Determination of Priority
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Jett, G.M.  1980.  Unreferenced Data Provided to Environmental
     Science and Engineering, Inc. Entitled The Environmental and
     Health Effects of Certain  Priority Pollutants and Their Effects
     on the Operation of Publicly-Owned Treatment Works.


                              XVIII-12

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Jett, G.M.  1978.  Development Document for Effluent Limitations
     Guidelines for the Pesticide Chemicals Manufacturing Point
     Source Category.  U.S. Environmental Protection Agency Effluent
     Guidelines Division, Washington, D.C., EPA 440/l-78-060e.

Johnson, W.W.  1980.  Handbook of Acute Toxicity of Chemicals to Fish
     and Aquatic Invertebrates.  Prepared for U.S. Fish and Wildlife
     Services, Washington, D.C.

Johnson, W.W. and Finley, M.T.  1980.  Handbook of Acute Toxicity of
     Chemicals to Fish and Aquatic Invertebrates.  Prepared for
     U.S. Department of the Interior, Washington, D.C.  Publication
     No. 137.

Jones, K.H., Sanderson, D.M., and Noakes, D.N. 1968.  Acute
     Toxicity Data for Pesticides.  World Rev. Pest. Cont.,
     7(3):135-143.

JRB Associates.  1981.  Assessment of the Impacts of Industrial
     Discharges on Publicly Owned Treatment Works.  Prepared for
     U.S. EPA.  Nov.

Kanazawa, J. 1981.  Measurement of the Bioconcentration Factors
     of Pesticides by Freshwater Fish and Their Correlation with
     Physiochemical Properties or Acute Toxicities.  Pestic. Sci.,
     12:417-424.

Karnofsky, B., e_t al.  1981.  Chemical Information Resources
     Handbook.  Prepared for U.S. Environmental Protection Agency,
     Office of Pesticides and Toxic Substances.  Washington, D.C.
     EPA 560/TIIS-81-001.

Kearney, P.C. and Kaufman, D.D., Editors.  1975.  Herbicides,
     Chemistry, Degradation, and Mode of Action.  Second Edition,
     Volumes 1 and 2.  Marcel Dekker, Inc., New York.

Kearney, P.C. and Kaufman, D.D.  1969.  Degradation of Herbicides.
     Marcel Dekker, Inc., New York.

Keinath, T.M.  1976.  Design and Operation of Activated Carbon
     Adsorbers Used for Industrial Wastewater Decontamination.
     Water, 73(166):l-8.

Kenaga, E.E.  1979.  Predicted Bioconcentration Factors of Soil
     Sorption Coefficients of Pesticides and Other Chemicals.
     Ecotoxicology and Environmental Safety.  4:26-38.

Kennedy, D.C.  1973.  Treatment of Effluent from Manufacture of
     Chlorinated Pesticides with a Synthetic, Polymeric, Adsorbent,
     Amberlite XAD-4.  Environmental Science and Technology, 1(2).

Kennedy, M.V., et al.  1969.  Chemical and Thermal Methods for
     Disposal of Pesticides.  Residue Reviews, 29.
                              XVIII-13

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Kernan, J.R. and Fincke, J.K.  1978.  Removal of Pollutants from
     Wastewater by Activated Carbon Adsorption.   U.S. EPA, Industrial
     Environmental Research Laboratory, Research Triangle Park, North
     Carolina.

Kessick, M.A. and Manchen, K.L.  1976.  Salt Water Domestic Waste
     Treatment.  Journal WPCF, 48(9):2131-2135.

Ketly,  A.D.,  The  Stereochemistry of  Macro-molecules,  London,
     Edward Arnold, New York, Mercel Dekker, 1967 i.e., 1968, v.,
     24 cm.

Kim, B.R., Snoeyink, V.L., and Saunders, F.M.  1976.   Adsorption of
     Organic Compounds by Synthetic Resins.  Journal  WPCF,
     48(1):120-133.

Kinglle, M.G. and Stuart, A.  1961.  The Advanced Theory of
     Statistics.  Charles Griffin and Co., LTD., 11:452-457.

Kincannon, D.F., Stover, E.L., and Chung, Y.  1981.   Biological
     Treatment of Organic Compounds Found in Industrial Aqueous
     Effluents.  Presented at the American Chemical  Society National
     Meeting, Atlanta, Georgia.  Oklahoma State  University,
     Stillwater, Oklahoma.

Kirk-Othmer.  Encyclopedia of Chemical Technology.  Second Edition.
     John Wiley and Sons, Inc., Interscience Publishers Division.

Klancko, R.J., Jones, R.B., and Michalak, M.  1976.   Industrial Waste
     Treatment System Reduces Pollution.  Industrial  Wastes,
     January/February, 27-29.

Klieve, J.R. and Rawlings, G.D.  1979.  Source Assessment:  Textile
     Plant Wastewater Toxics Study, Phase II. Prepared for U.S. EPA
     Office of Energy, Minerals, and Industry.  Monsanto Research
     Corporation, Dayton, Ohio.

Kilingman, G. C., and Ashton, F.M. 1975 Weed Science: Principles and
     Practices. John Wiley, New York.

Klinkowski, P.R.  1978.  Ultrafiltration:  An Emerging
     Unit-Operation: Chemical Engineering, May,  8:165-173.

Korn, S. and Earnest, R. 1974.  Acute Toxicity of Twenty
     Insecticides to Striped Bass (Morone saxatilis).
     Calif. Fish and Game, 60(3):128-131.

Kraybill, H.F. and Helmes, C.T.  1977.  Biomedical Aspects of
     Biorefractories in Water.  Presented to the Second International
     Symposium on Aquatic Pollutants, Noordwijkerhout, Amsterdam.

Ruhr, Ronald J. Carbamate insecticides Cleveland, CRC Press.
                              XVIII-14

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Kunin, R.  1980.  Porous Polymers as Adsorbents—A Review of Current
     Practice.  Amber-Hi-Lites, Rohm and Haas Company, No. 163,
     Winter.

Lafornara, J.P.  1978.  Cleanup After Spills of Toxic Substances.
     Journal WPCF, April, 617-627.

Lai, R.J.  1977.  Letter to N.L. Wolfe, U.S. EPA.  Hydrolysis Data on
     Some S-Triazine Studies.  Environmental Science and Engineering,
     Inc., Gainesville, Florida.

Lambden, A.E. and Sharp, D.H.  1960.  Treatment of Effluent from the
     Manufacture of Weedkillers and Pesticides.  Manufacturing
     Chemist, 31:198-201.

Lanquette, K.H. and Paulson, E.G.  1976.  Treatment of Heavy Metals
     in Wastewater.  Pollution Engineering, October.

Larson, E.  1980.  TCE, Solvent Suspected as Cancer Cause, Frequently
     Shows up in Drinking Water.  The Wall Street Journal.  Tuesday,
     August 12.

Lawless, E.W., e_t a_l.  1974.  Production, Distribution, Use and
     Environmental Impact Potential of Selected Pesticides.  Midwest
     Research Institute, Kansas City, Missouri.

LeBlanc, B.A. 1980, 'Acute Toxicity of Priority Pollutants to
     Water Fleas (DAPHNIA MAGNA),' in Bull. Environm. Contam.
     Toxicol., 24, 884-691.

Leigh, G.M.  1969.  Degradation of Selected Chlorinated Hydrocarbon
     Insecticides.  Journal WPCF, 41(11):450-459.

Lemely, A.T., Janauer, G.E. 1984. Investigation of Degradation
     Rates of Carbamate Pesticides. American Chemical Society.

Leshendok, T.V.  1976.  Hazardous Waste Management Facilities in the
     United States.  U.S. EPA, EPA 530-SW-146.2.

Lewis, R.J. and Tatkein, R.L.  1979.  Registry of Toxic Effects of
     Chemical Substances.  Volumes I and II.  Prepared for
     U.S. Department of Health and Human Services, Washington, D.C.

Liptak, B.C., Editor.  1974.  Environmental Engineers' Handbook,
     Volume 1, Water Pollution.  Chilton Book Company, Radnor,
     Pennsylvania.

Little, A.p. 1970.  Water Quality Criteria Data Book. Vol. I.
     Organic Chemical Pollution of Freshwater.  EPA 18010 DPV.

Little, L.W., Zweidinger, R.A., Monnig, E.G., and Firth, W.J.  1980.
     Treatment Technology for Pesticide Manufacturing Effluents:
     Atrazine, Maneb, MSMA, and Oryzalin.  Prepared for U.S.  EPA
     Office of Research and Development, EPA 600/2-80-043.  Research
     Triangle Institute, Research Triangle Park, N.C.


                              XVIII-15

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Little, L.W. and Firth, W.  1977.  Use of Activated Carbon for
     Removal of Pesticides from Water and Wastewaters.  Literature
     Review, October.  Prepared for U.S. EPA Office of Research and
     Development.  Research Triangle Institute, Research Triangle
     Park, N.C.

Lowenback, W. and Schlesinger, J.  1977.  Pollution Source
     Information for Organo-Nitrogen Manufacturing Processes.  Draft
     Contractor Proprietary Report Prepared for U.S. EPA, Office of
     Research and Development, Washington, D.C.  Mitre Corporation,
     Washington, D.C.

Lue King, et. al., Explosion at a Pesticide Manufacturing Plant;
     Industrial Wastes, January/February, 1981.

Ludzack, F.J. and M.B. Ettinger; Chemical Structures Resistant to
     Aerobic  Biochemical Stabilization;  Journal WPC;  November
     1960; pp 1173-1200.

Luthy, Richard G. Review of the EPA Protocal for Technology Transfer
     for the Pesticide Chemicals Industry.  Report to the EPA Science
     Advistory Board Environmental Engineering Commitee 1983.

Mabey, W.R., e_t al.  1981.  Aquatic Fate Process Data for Organic
     Priority Pollutants.  Prepared for U.S. Environmental Protection
     Agency, Washington, D.C.  EPA 440/4-81-014.

Macek, K. J., Buxton, K.S., Sauter, S., Grilka, S., and Dean, J.W.
     1976.  Chronic Toxicity of Atrazine to Selected Aquatic
     Invertebrates and Fishes.  EPA-600/3-76-047.

Mackay,   Donald;   Correlation   of   Bioconcentration   Factor;
     Environmental Science and Technology; 1982, 16,274-278.

Manufacturing Chemists Association, Inc.  1972.  Guidelines for
     Chemical Plants in the Prevention, Control and Reporting of
     Spills. Washington, D.C.

Marck, A.  1978.  Personal Communication.  American Cyanamid Company,
     Bound Brook, NJ.

Marks, D.R.  1980.  Chlorinated Hydrocarbon Pesticide Removal from
     Wastewater.  Prepared for U.S. EPA, Chemical Processes Branch,
     Industrial Processes Division, Industrial Environmental Research
     Laboratory, Research Triangle Park, North Carolina.  Velsicol
     Chemical Corporation, Memphis, Tennessee.

Marquardt Company.  1974.  Report on the Destruction of "Orange"
     Herbicide by Incineration.  Prepared for U.S. Air Force,
     Environmental Health Laboratory, Kelly Air Force Base, Texas.

Martin, H., Worthing, C.R., Editors.  1977.  Pesticide Manual.  Fifth
     Edition.  British Crop Protection Council, Worcestershire,
     England.


                              XVIII-16

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Maruyama, T., Hannah, S.A., and Cohen, J.M.  1975.  Metal Removal by
     Physical and Chemical Treatment Processes.  Journal WPCF,
     47(5):962-975.

Matsumura, Fumio, 1982.  Degradation of Pesticides in the Environment
     by Microorganisms and Sunlight.  Plenum Press, New York.

McCreary, J.J. and Snoeyink, V.L.  1977.  Granular Activated Carbon
     in Water Treatment.  Journal AWWA, 69(8):437-444.

Meta Systems, Inc. June 1984.  Economic Impact Analysis of
     Effluent Limitations Guidelines and Standards for
     the Pesticide Chemicals Industry. Prepared for U.S.
     EPA, Office of Analysis and Evaluation, Office of Water
     Regulation and Standards, Washington, D.C.

McEwen, F.L. and Stephenson, G.R.  1979.  The Use and Significance of
     Pesticides in the Environment.  John Wiley & Sons, New York.

McKim, J.M., Benoit, D.A., Biesinger, K.E., Brungs, W.A., and
     Seifert, R.E. 1975.  Effects of Pollution on Freshwater
     Fish. Jour. WPCF, 47(6):1711-1768.

McKim, J.M., Anderson, R.L., Benoit, D.A., Spehar, R.L., and
     Stokes, G.N. 1967.  Effects of Pollution on Freshwater Fish.
     J. WPCF, 48(6):1544-1620.

Midwest Research Institute.  1976a.  Wastewater Treatment Technology
     Documentation for Aldrin/Dieldrin, Manufacture and Formulation.
     Prepared for U.S. EPA, Hazardous and Toxic Substances Regulation
     Office.

Midwest Research Institute.  1976b.  Wastewater Treatment Technology
     Documentations for DDT, Manufacture and Formulation.  Prepared
     for U.S. EPA, Hazardous and Toxic Substances Regulation Office.

Midwest Research Institute.  1976c.  Wastewater Treatment Technology
     Documentations for Endrin, Manufacture and Formulation.
     Prepared for U.S. EPA, Hazardous and Toxic Substances Regulation
     Office.

Midwest Research Institute.  1976d.  Wastewater Treatment Technology
     Documentations for Toxaphene, Manufacture and Formulation.
     Prepared for U.S. EPA, Hazardous and Toxic Substances Regulation
     Office.

Miller, D.W., Geraghty, J.J., and Collins, R.S.  1963.  Water Atlas
     of U.S. Water Information Center, Inc., Port Washington, L.I.,
     New York.

Mills, R.E.   1959.  Development of Design Criteria for Biological
     Treatment fo 2,4-D Wastewater.  Canadian Journal of Chemical
     Engineering, 37(55).
                              XVIII-17

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Modell, M.  1978.  Process for Regenerating Adsorbents with
     Supercritical Fluids.  U.S. Patent Number 4,124,528,
     November 7.

Modell, M.  1977.  Process Using a Supercritical Fluid for
     Regenerating Synthetic Organic Polymeric Adsorbents and
     Wastewater Treatment Embodying the Same.  U.S. Patent
     Numbe r 4,061,566, Decembe r 6.

Monnig, E.G. and Zweidinger, R.A.  1979.  Treatment Technology for
     Pesticide Manufacturing Effluents:  Dinoseb and Atrazine.
     Prepared for U.S. EPA Office of Research and Development,
     Research Triangle Park, N.C.  Research Triangle Institute,
     Research Triangle Park, N.C.

Monnig, E., Murphy, M., Zweidinger, R., and Little, L.  1979.
     Treatability Studies of Pesticide Manufacturing Wastewaters:
     Carbaryl.  Prepared for U.S. EPA, Industrial Environmental
     Research Laboratory, Research Triangle Park, N.C.  Research
     Triangle Institute, Research Triangle Park, N.C.

Monsanto Company.  (Industry Comments) Vol. III.

Moore, F.L., e_t al.  1973.  Recovery of Toxic Metals from Industrial
     Effluent Solutions by Solvent Extraction, Ecology, and Analysis
     of Trace Contaminants.  Oak Ridge National Laboratory.

Morrison, R.T. and Boyd, R.N.  1975.  Organic Chemistry.  Allyn and
     Bacon, Inc.  Boston, Massachusetts.

Mowat, A.  1976.  Measurement of Metal Toxicity by Biochemical Oxygen
     Demand.  Journal WPCF, 48(5):853-866.

Moyer, J.R. and Parmele, C.S.  Demonstration of Ultraviolet
     Chlorination of Organic Acids in Waste Brines.  U.S. EPA,
     Environmental Research Laboratory, Athens, Georgia.

Mulligan, T.J. and Fox, R.D.  1976.  Treatment of Industrial
     Wastewaters.  Chemical Engineering/Deskbook Issue, October,
     49-66.

Munnecke, D.M.  1978.  Detoxification of Pesticides Using Soluble or
     Immobilized Enzymes.  Journal of Process Biochemistry, 13(2).

Munnecke, D.M.  1976.  Enzymatic Hydrolysis of Organophosphate
     Insecticides, A Possible Pesticide Disposal Method.  Applied and
     Environmental Microbiology, 32(1):7-13.

Nathan, M. F., Choosing A Process for Chloride Removal, Chemical
     Engineering, January 30, 1978.

National Agricultural Chemical Associate (NACA).  1978.  Pesticides
     Industry Profile Study for 1977.  Washington, D.C.

Necly, M. #123. Personal Communication. Versar, Springfield, Va.


                              XVIII-18

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Nemerow, N.L.  1971.  Liquid Waste of Industry—Theories, Practices,
     and Treatment.  Addison-Wesley Publishing Company, Reading, MA.

Neufeld, R.D. and Spinola, A.A.  1978.  Ozonation of Coal
     Gasification Plant Wastewater.  American Chemical Society,
     12(4):470-472.

Nimmo, D.R., Hamaker, T. L., Matthews, E., and Moore, J. C. 1981.
     An Overview of the Acute and Chronic Effects of First and
     Second Generation Pesticides on an Estuarine Mysid.  Vernberg,
     F.J. (Ed.), Biological Monitoring of Marine Pollutants,
     p.p 3019.  Academic Press, New York.

NIOSH.  1978.  Occupational Exposure During the Manufacture and
     Formulation of Pesticides.  Prepared for U.S. Department of
     Health, Education, and Welfare, Cincinnati, OH.  No. 78-174.

Nippon Soda Company, Tokyo, Japan.  1975.  Adsorbents Win Heavy
     Metals from Process Streams and Wastes.  Chemical Engineering,
     September, 29:49-50.

Novak, F.C.  1980.  Ozone for Industrial Wastewater Treatment.
     Howe-Baker Engineers, Inc.  Proceedings of the Eighth Annual
     Industrial Pollution Conference, 415-429.

O'Brien, R.M. and DeFilippi, R.P.  1981.  Supercritical Carbon
     Dioxide Regeneration of Activated Carbon Loaded with
     Contaminants from Rocky Mountain Arsenel Well Water.  Submitted
     to USATHAMA, Aberdeen Proving Ground (Edgewood), MD, December.

Oswald, E.O.  1978.  Summary of Results for Analyses of Samples of
     Fish from Michigan—EPA Region V—for 2,3,7,8-Tetrachlorodi-
     benzoparadioxin (TCDD).  U.S. EPA, Analytical Chemistry Branch,
     Environmental Toxicology Division, Health Effects Research
     Laboratory, Research Triangle Park, North Carolina.

Overcash, M.R., Gilliam, J.W., Humenik, F.J., and Westerman, P.W.
     1978. Lagoon Pretreatment:  Heavy Metal and Cation Removals.
     Journal WPCF, August, 2029-2036.

Owen, W.J. and DeRouen, T.A.  1980.  Estimation of the Mean for
     Lognormal Data Containing Zeroes and Left-Censored Values, with
     Applications to the Measurement of Worker Exposure to Air
     Contaminants.  Biometrics.  36:707-719.

Packer, K., Editor.  1975.  Nanogen Index.  Nanogens International,
     Freedom, CA.

Paris, D.F. and Lewis,  D.L.  1973.  Chemical and Microbial
     Degradation of Ten Selected Pesticides in Aquatic Systems.
     Residue Reviews, 45:95-124.
                              XVIII-19

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Parrish, P.R., Dyar, E.E., Enos, J.M., and Wilson, W.G. 1978.
     Chronic Toxicity of Chlordance, Trifluralin, and
     Pentachlorophenol to Sheepshead Minnows
     (Cyprinodon variegatus).  EPA-600/3-78-010.

Parrish, P.R., Dyar, E.E., Lindberg, M.A., Shanika, C.M., and Enos,
     J.M. 1977.  Chronic Toxicity of Methoxychlor, Malathion, and
     Carbofuran to Sheepshead Minnows (Cyprinodon variegatus.
     EPA-600/3-77-059.

Patterson, J.W.  1975.  State-Of-The-Art for the Inorganic Chemicals
     Industry:  Inorganic Pesticides.  U.S. EPA Office of Research
     and Development, EPA 600/2-74-009a.

Perrich, Jerry R.  1981 Activated Carbon Adsorption for Wastewater
     Treatment.  BOCA Raton Fl: CRC Press

Perry,  J.H., et^ al..  1973.  Chemical Engineer's Handbook.  Fifth
     Edition.  McGraw Hill Book Company, New York.

Pickering, Q.H., Hunt, E.P., Phipps, G.L., Roush, T.H., Smith, W.E.,
     Spehar, R.L., Stephan, C.E., and Tanner, O.K. 1983.
     Effects of Pollution on Freshwater Fish and Amphibians.
     Journ. WPCF,  55(6):840-863.

Piecuch, P.  1981.  Literature Review.  Journal WPCF.  June.

Piecuch, P.  1980.  Literature Review.  Journal WPCF.  June.

Piecuch, P.  1979.  Literature Review.  Journal WPCF.  June.

Piecuch, P.  1978.  Literature Review.  Journal WPCF.  June.

Piecuch, P.  1974.  Literature Review.  Journal WPCF.  June.

Pittsburgh Activated Carbon.  The Laboratory Evaluation of Granular
     Activated Carbons for Liquid Phase Applications.  Division of
     Calgon Corporation, Pittsburgh, Pennsylvania.

Prengle, H.W., Jr., Mauk, C.E., Legan, R.W., and Hewes, C.G., III.
     1975. Ozone/UV Process Effective Wastewater Treatment.
     Hydrocarbon Processing, October, 82-87.

Randall, T.L. and Knopp, P.V.  1978.  Detoxification of Specific
     Organic Substances by Wet Oxidation.  Presented to 51st Annual
     Conference of Water Pollution Control Federation.  Zimpro, Inc.,
     Rothschild, Wi.

Rawlings, G.D.  1978.  Textile Plant Wastewater Toxics Study.
     Phase I.  Prepared for U.S. EPA Office of Energy, Minerals, and
     Industry.  Monsanto Research Corporation, Dayton, Ohio.

Reid, F., e_t al.  1977.  Carbon Advanced Waste Treatment.  Industrial
     Wastes, July/August, 40-41.
                              XVIII-20

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Reynolds, T.D. and Shack, P.A.  1976.  Treatment of Wood Preserving
     Wastewater.  Prepared for U.S. Department of the Interior,
     Office of Water Research and Technology, Washington, D.C.  Texas
     A&M University, College Station, Texas.

Rice R.G.  1980a.  Ozone Gives Boost to Activated Carbon.  Water and
     Sewage Works, April, 40-42, 80-82.

Rice, R.G.  1980b.  Ozone for Industrial Water and Wastewater
     Treatment. Jacobs Engineering Group.  Proceedings of the Eighth
     Annual Industrial Pollution Conference, 391-413.

Riley, B.T., Jr.  1975.  The Relationship Between Temperature and the
     Design and Operation of Biological Waste Treatment Plants.
     Prepared for U.S. EPA, Effluent Guidelines Division, Washington,
     D.C.

Rizzo, J.L.  1974.  Use of Granular Activated Carbon for Industrial
     Wastewater Treatment.  Ohio Water Pollution Control Conference,
     Forty-Eighth Annual Meeting, Toledo, Ohio, June 14th.

Rizzo, J.R. and Shepherd, A.R.  1977.  Treating Industrial Wastewater
     with Activated Carbon.  Chemical Engineering, January 3rd.

Robeck, G.G., et al.  1965,  Effectiveness of Water Treatment Process
     in Pesticide Removal.  Journal AWWA, 57(8).

Robertson, K.B. and Buting, D.L. 1976.  The Acute Toxicity of
     Four Herbicides to 0-4 Hour Nauplii of Cyclope vernalis.
     Fisher (Copepod.) Cyclopoida.

Rohm and Haas Company.  1977.  Ambersorb Carbonaceous Adsorbents.
     Philadelphia, PA, August.

Rosfjoro, R.E., Trattner, R.B., and Cheremisinoff, P.N.  1976.
     Phenols—A Water Pollution Control Assessment.  Water and Sewage
     Works, March.

Roy F. Weston, Inc.  1974.  Draft Development Document for Effluent
     Limitations Guidelines and Standards of Performance—Organic
     Chemicals Industry, Phase II.  Prepared for U.S. EPA, Office of
     Air and Water Programs, Effluent Guidelines Division,
     Washington, D.C.

Saldick, J.  1975.  Biological Treatment of Plant Waste Streams to
     Remove Cyanuric Acid.  U.S. Patent Number 3,927,795.

Saleh, F.Y., Lee, F.G., and Wolf, H.W.  1982.  Selected Organic
     Pesticides, Behavior and Removal from Domestic Wastewater by
     Chemical and Physical Processes.  Water Research, 16(4).
                              XVIII-21

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Schimmel, S.C., Garnas, R.L.,  Patrick,  J.M.,  Jr.,  and Moore, J.C.
     1983. Acute Toxicity, Bioconcentration,  and Persistence of
     AG 222, 705, Benthiocarb, Chlorpyrifos,  Fenvalerate, Methyl
     Parathion, and Permethrin in the Estuarine Environment. J.
     Agric.  FoodChem., 31(1):104-113.

Schneider, B.A. 1979.  Toxicology Handbook—Mammalian and Aquatic
     Data.  EPA-540/9-79-003.

Sawyer, C.N. 1979, Chemistry for Environmental Engineers,
     3rd ED. p. 161.

Schweitzer, P.A.  1979.  Handbook of Separation Techniques for
     Chemical Engineers.  McGraw-Hill,  New York.  1-416 to 1-417.

Shapiro, B.S. and Wilk, M.B.  1965.   An Analysis of Variance Test for
     Normality.  Biometrika, 591-611.

Sharp,   D.H.  and  A.E.  Lambden;  Treatment  of  Effluent  from
     Pesticide Manufacture;  Manufacturing Chemist; May 1985;
     pp. 210-215.

Sherma, J.f Dr.  1981.  Manual of Analytical  Quality Control for
     Pesticides and Related Compounds,  In Human and Environmental
     Samples—Second Revision.  Prepared for  U.S.  Environmental
     Protection Agency, Office of Research and Development, Research
     Triangle Park, NC.  EPA 600/2-81-059.

Simpson, R.M.  1972.  The Separation of Organic Chemicals from Water.
     Presented at the Third Symposium of the  Institute of Advanced
     Sanitation Research, International, April 13.

Sittig, M.  1980.  Pesticide Manufacturing and Toxic Materials
     Control Encyclopedia.  Noyes Data Corporation.  Park Ridge, New
     Jersey.

Sittig, M.  1977.  Pesticides Process Encyclopedia.  Chemical
     Technology Review No. 81.  Noyes Data Corporation.  Park Ridge,
     New Jersey.

Skipper, H.D.,  Volk, V.V., and Freeh, R.  1976.  Hydrolysis of a
     Chloro-S-Triazine Herbicide.  Journal of Agriculture and Food
     Chemistry, 24(1).

Spiller, D.  1961.  A Digest of Available Information on the
     Insecticide Malathion.  Adv. Pest Control Research, 4:249-335.

SRI International.  1979.  Water Related Environmental Fate of
     129 Priority Pollutants.   Prepared for U.S. EPA, Office of Water
     Planning and Standards, Monitoring and Data Support Division,
     Washington, D.C.

Stanford Research Institute International.  February 1977.  Chemical
     Economics Handbook.  Pesticides Proprietary Information.  SRI,
     Menlo Park, CA.


                              XVIII-22

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Stephens, M.A.  1974.  EOF Statistics for Goodness of Fit.  Journal
     of American Statistical Association.  6:730-737.

Stereochemistry and Biological Activity of Drugs, Oxford Boston
     Blackwell Scientific Publications St. Louis, Mo. Blackwell
     Mosby Book Distributors, 1983, 194 p. ill., 24 cm.

Stereochemistry   and   Reactivity  of  System   Containing   (Pi
     Electrons),     Deerfield   Beach,   Fla.,   Verlag   Chemie
     International, c!983, xiv, 439 p. ill., 25 cm.

Stevens, B.W. and Kerner, J.W.  1975.  Recovery Organic Materials
     from Wastewater.  Chemical Engineering, February, 3;84-87.

Strier, M.P.  1979.  Treatability of Organic Priority Pollutants—
     Part E—The Relationship of Estimated Theoretical Treatability
     with Water Solubility, Partition Coefficient, Bioconcentration
     and Aquatic Life Toxicity.  U.S. EPA, Office of Quality Review,
     Effluent Guidelines Division, Washington, D.C.

Strier, M.P.  1978a.  Treatability of Organic Priority Pollutants—
     Part D—The Pesticides—Their Estimated (30-Day Average) Treated
     Effluent Concentration.  U.S. EPA, Office of Quality Review,
     Effluent Guidelines Division, Washington, D.C.

Strier, M.P.  1978b.  Treatability of Pentachlorophenol.  U.S. EPA,
     Office of Quality Review, Effluent Guidelines Division,
     Washington, D.C.

Strier, M.P.  1978c.  Treatability of Organic Priority Pollutants—
     Part C—Their Estimated (30-Day Average) Treated Effluent
     Concentration—A Molecular Engineering Approach.  U.S. EPA,
     Office of Quality Review, Effluent Guidelines Division,
     Washington, D.C.

Strier, M.P.  1977.  Treatability of "65" Chemicals, Part
     B—Adsorption of Organic Compounds on Activated Carbon.
     U.S. EPA, Office of Quality Review, Effluent Guidelines
     Division, Washington, D.C.

Strunck, W.G.  1979.  Hydrogen Peroxide Treats Diverse Wastewaters.
     Industrial Wastes, January/February, 32-35.

Stutz, C.N.  1966.  Treating Parathion Wastes.  Chemical Engineering
     Progress, 62(10).

Sublette, K.L., Snider, E.H., Sylvester, N.D.  1980.  Powdered
     Activated Carbon Enhancement of the Activated Sludge Process:
     A  Study of the Mechanism.  University of Tulsa, Chemical
     Engineering Department. Part of the Proceedings of the Eighth
     Annual Industrial Pollution Conference, 351-369.

Sweeny, K.H.  1979.  Reductive Degradation:  Versatile, Low Cost
     Water and Sewage Works, January, 40-42.


                              XVIII-23

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Szalkowski, M.B. and Stallard, D.E.  1977.  Effect of pH on the
     Hydrolysis of Chlorothalonil.  Journal AFC, 25(1):208-210.

Thompson, J.F. and Watts, R.R.  1978.  Analytical Reference Standards
     and Supplemental Data for Pesticides and Other Organic
     Compounds.  Prepared for U.S. Environmental Protection Agency,
     Office of Research and Development, Research Triangle Park, N.C.
     EPA 600/9-78-012.

Thompson, W.S.  1974.  Wood Preservatives and the Environment:
     Detreating Plant.  American Wood Preservers Association, 107.

Thompson, J.F.  1976.  Analytical Reference Standards and
     Supplemental Data for Pesticides and Other Organic Compounds.
     U.S. EPA, Office of Research and Development,
     EPA 600/9-76-012.

Toxler, W.L., Parmele, C.S., and Barton, D.A.  1980.  Survey of
     Activated Carbon Use in the Organic Chemical Industries.
     Volumes I and II.  Prepared for U.S. EPA Industrial
     Environmental Research Laboratory.  Hydroscience.

Trucco,  R.B., e_t al. 1983, 'Toxicity, Accumulation and Clearance
     of Aromatic Hydrocarbons in DAPHNIA PU in Environ. Pollut.,
     31A, 191.

TRW Systems.  1973.  Recommended Methods of Reduction,
     Neutralization, Recovery or Disposal Hazardous Waste, Volume V,
     National Disposal Site Candidate Waste Stream Constituent
     Profile Reports—Pesticide and Cyanide Compounds.  Prepared for
     U.S. EPA, Office of Research and Development.

Union Carbide Corporation.  Experimental Procedure for Obtaining Data
     Required for Sizing Liquid Absorption Systems Using Granular
     Carbon.  Carbon Products Division, New York.

U.S. Congress.  October 18, 1972.  Public Law 92-500.  Ninety-Second
     Congress, S.2770.

U.S. Court of Appeals for the First Circuit.  1979.  Opinion of the
     Court on Petition for Review by BASF Wyandotte Corporation, et
     al. v. U.S. EPA.

U.S. Department of the Interior.  1970.  Phenolic Waste Reuse by
     Diatomite Filtration.  Water Pollution Control Research Series.
     Federal Quality Administration, Washington, D.C.

U.S. District Court, District of Columbia.  1980.  Opinion of the
     Court on Petition for Writ of Certiorari by Eli Lilly and
     Company, e_t al. v. Douglas Costle, Administrator.  U.S.
     Environmental Protection Agency.

U.S. District Court, District of Columbia.  1976.  Natural Resources
     Defense Council v. Russell E. Train.


                              XVIII-24

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U.S. Environmental Protection Agency; Case Studies 1-23, Remedial
     Response at Hazardous Waste Sites, EPA 540/2-84-002b;
     March 1984

U.S. Environmental  Protection  Agency.    1982.    Development
     Document for Effluent Limitations Guidelines for the Coil
     Coating Point Source Category.  EPA 440/1-82/071.

U.S. Environmental Protection Agency.  1981.  Environmental
     Assessment Tab for the Pesticides Development Document,
     Washington, D.C.  December.

U.S. Environmental Protection Agency.  1981a.  Water Pollution
     Regulations.  Bis(chloromethyl) ether Removal from Priority
     Pollutant List.  Federal Register, 46(23):10723-10724.

U.S. Environmental Protection Agency.  1981b'.  Water Pollution
     Regulations.  Trichlorofluoromethane and Dichlorodifluoromethane
     Removal from Priority Pollutant List.  Federal Register,
     46(5):2266.

U.S. Environmental Protection Agency.  1980.  Treatability Manual—
     Volumes 1-5.  Office of Research and Development, Washington,
     D.C.  EPA 600/8-80-042a-e.

U.S. Enviromental Protection Agency, MERL, ORD, Cincinnati, Ohio
     45268;   Literature Study of the Biodegrad ability of Chemicals
     in Water,  volumes 1 and 2,  EPA 600/2-81-175 and EPA-600/2-81
     176, September 1981.

U.S. Environmental Protection  Agency,  MDSD,  Washington,  D.C.
     20460;    Water   Related  Environmental  Fate  of  129   Priorit
     Pollutants,  Volume  I:  Introduction  and Technical  Background
     Metals   and  Inorganic,   Pesticides  and  PCB's;   Section  III
     Pesticides, Chapter 20-35, EPA 440/4-79-029 a: December 31, 1979

U.S. Environmental Protection  Agency,  MERL,  Cincinnati,  Ohio
     45268;   Presence  of  Priority  Pollutants in  Sewage  and
     Their Removal in Sewage Treatment Plants; Sections 10,
     through 12.

U.S. Environmental Protection Agency.  1980a.  Storage and Disposal
     of Waste Material; Prohibition of Disposal of
     Tetrachlorodibenzo-p-dioxin.  Federal Register,
     45(98):32676-32686.

U.S. Environmental Protection Agency.  1980b.  Hazardous Waste and
     Consolidated Permit Regulations.  Federal Register,
     45(98):33084-33135.
                              XVIII-25

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U.S. Environmental Protection Agency.  1980d.  TSCA Chemical
     Assessment Series, Chemical Screening:  Initial Evaluations of
     Substantial Risk Notices, Section 8(E).  January 1, 1977 to June
     30, 1979.  Office of Pesticides and Toxic Substances,
     Washington, D.C.  EPA 560/11-80-008.

U.S. Environmental Protection Agency.  1980e.  TSCA Chemical
     Assessment Series, Chemical Hazard Information Profiles (CHIPS).
     April 1, 1976 to November 20, 1976.  Office of Pesticides and
     Toxic Substances, Washington, D.C.  EPA 560/11-80-011.

U.S. Environmental Protection Agency.  1980f.  Part V.  Water Quality
     Criteria Documents; Availability.  Federal Register,
     45(231):79318-79370.

U.S. Environmental Protection Agency 1980 g. Onsite Wastewater
     Treatment and Disposal Systems.  Office of Research and
     Development Municipal Environmental Research Laboratory.
     Cincinnati, Ohio.  EPA 615/1-80-012.

U.S. Environmental Protection Agency. 1980. Carbon Adsorption
     Isothered for Toxic Organics. Merk, Cincinnati, OH.
     EPA 600/8-80023.

U.S. Environmental Protection Agency Oct., 1973. Process
     Design Manual for Carbon Adsorption.

U.S. Environmental Protection Agency.  1979a.  Part II.  Best
     Conventional Pollutant Control Technology; Reasonableness of
     Existing Effluent Limitation Guidelines.  Federal Register,
     44(169).

U.S. Environmental Protection Agency.  1979b.  Part III.  Guidelines
     Establishing Test Procedures for the Analysis of Pollutants;
     Proposed Regulations.  Federal Register, 44(233):69464-69575.

U.S. Environmental Protection Agency.  1979c.  Water Quality
     Criteria; Availability.  Federal Register, 44(144).

U.S. Environmental Protection Agency.  1979d.  Water Quality
     Criteria; Availability.  Federal Register, 44(191).

U.S. Environmental Protection Agency.  1979e.  Water Quality Criteria
     Request for Comments.  Federal Register, 44(52).

U.S. Environmental Protection Agency.  1979f.  Draft Development
     Document for Proposed Effluent Limitations Guidelines, New
     Source Performance Standards and Pretreatment Standards for the
     Textile Mills Point Source Category.  Effluent Guidelines
     Division, Office of Water and Waste Management, Washington,
     D.C.

U.S. Environmental Protection Agency.  1979g.  Indicatory Fate Study.
     Industrial Sources Section, Source Management Branch.  Robert S.
     Karr Environmental Research Laboratory.  Ada, Oklahoma.


                              XVIII-26

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U.S. Environmental Protection Agency.  1979h.  Brief for Respondent.
     BASF Wyandotte Corporation, et al. v. U.S. EPA.

U.S. Environmental Protection Agency.  1979i.  Revised July 1.  Toxic
     Pollutant Effluent Standards.  Code of Federal Regulations,
     40(129):244-255.

U.S. Environmental Protection Agency.  1979j.  Toxicology Handbook,
     Mammalian and Aquatic Data.  EPA 540/9-79-003.

U.S. Environmental Protection Agency.  1978a.  Comparative Cost
     Analysis and Environmental Assessment for Disposal of
     Organochlorine Wastes.  Industrial Environmental Research
     Laboratory, Research Triangle Park, North Carolina.  EPA
     600/2-78-190.

U.S. Environmental Protection Agency.  1978b.  Innovative and
     Alternative Technology Assessment Manual.  Municipal
     Environmental Research Laboratory, Office of Research and
     Development, Cincinnati, Ohio.  EPA 430/9-78-009.

U.S. Environmental Protection Agency.  1978c.  Source Assessment:
     Textile Plant Wastewater Toxics Study Phase 1.  Environmental
     Protection Technology Series.  Research Triangle Park, North
     Carolina.  EPA 600/2-78-004h.

U.S. Environmental Protection Agency.  1978d.  Part IV.  Hazardous
     Waste Proposed Guidelines and Regulations and Proposal on
     Identification and Listing.  Federal Register, 43(243).

U.S. Environmental Protection Agency.  1978e.  Analytical Reference
     Standards and Supplemental Data for Pesticides and Other Organic
     Compounds.  Health Effects Research Laboratory, Environmental
     Toxicology Division, Research Triangle Park, North Carolina.
     EPA 600/9-78-012.

U.S. Environmental Protection Agency.  1978f.  Response to
     Interagency Testing Committee Recommendations.  Federal
     Register, 43(208).

U.S. Environmental Protection Agency.  September 1978g.  Organic
     Compounds in Organophosphorus Pesticide Manufacturing
     Wastewaters.  Environmental Research Laboratory, Athens,
     Georgia.  EPA 600/4-78-056.

U.S. Environmental Protection Agency.  October 1978h.  Sludge
     Treatment and Disposal.  Number 2.  EPA Technology Transfer.
     Environmental Research Information Center, Cincinnati, Ohio.
     EPA 625/4-78-012.

U.S. Environmental Protection Agency.  January 31, 1978i.  Listing of
     Toxic Pollutants.  Federal Register, 43(21).
                              XVIII-27

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U.S. Environmental Protection Agency.  1978j.   Economic Analysis of
     Effluent Limitations Guidelines for the Pesticide Chemicals
     Manufacturing Point Source Category.  Office of Water Planning
     and Standards.  EPA 230/2-78-065f.

U.S. Environmental Protection Agency. 1978 K.  Assessment of
     Technology for Control of Toxic Effluents From the Electric
     Utility Industry.  Industrial Environmental Research
     Laboratory, Office of Research and Development, Research
     Triangle Park, North Carolina. EPA 600/7-78-090.

U.S. Environmental Protection Agency.  1977a.   Controlling Pollution
     from the Manufacturing and Coating of Metal Products, Water
     Pollution Control.  EPA Technology Transfer Seminar Publication.
     Washington, D.C., EPA 625/3-77-009.

U.S. Environmental Protection Agency.  1977b.   Industrial Process
     Profiles for Environmental Use:  Chapter  8.  Pesticides
     Industry.  Environmental Protection Technology Series.
     Industrial Environmental Research Laboratory, Office of Research
     and Development, Research Triangle Park,  North Carolina.  EPA
     600/2-77-023h.

U.S. Environmental Protection Agency.  May 1977c.  Controlling
     Pollution from the Manufacturing and Coating of Metal Products.
     Water Pollution Control.  3.  EPA Technology Transfer Seminar
     Series.  Environmental Research Information Center, Washington,
     D.C., EPA 625/3-77-009.

U.S. Environmental Protection Agency.  February 24, 1977d.  Pesticide
     Products Containing Nitrosamines.  Federal Register, 42(37).

U.S. Environmental Protection Agency.  1977e.   Council on
     Environmental Quality, TSCA Interagency Committee.  Federal
     Register, 42(197).

U.S. Environmental Protection Agency.  1977f.   PCB's Removal in
     Publicly-Owned Treatment Works.  Criteria and Standard Division.
     EPA 440/5-77-017.

U.S. Environmental Protection Agency.  1977g.   Sampling and Analysis
     Procedures for Survey of Industrial Effluents for Priority
     Pollutants.  Environmental Mo-.itoring and Support Laboratory,
     Cincinnati, Ohio.

U.S. Environmental Protection Agency.  January 12, 1977h.  Listing of
     Toxic Pollutants.  Federal Register, 42.

U.S. Environmental Protection Agency.  February 2, 1977i.  Listing of
     Toxic Pollutants.  Federal Register, 42.

U.S. Environmental Protection Agency.  1976a.   Development Document
     for Interim Final Effluent Limitations Guidelines for the
     Pesticide Chemicals Manufacturing Point Source Category.  EPA
     440/l-75-060d.


                              XVIII-28

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U.S. Environmental Protection Agency.  1976b.  Process Design Manual
     for Carbon Adsorption, U.S. EPA Technology Transfer.
     Washington, D.C.

U.S. Environmental Protection Agency.  1976c.  Development Document
     for Interim Final Effluent Limitations, Guidelines, and Proposed
     New Source Performance Standards for the Pesticide Industry.
     Office of Water and Hazardous Materials, Washington, D.C.

U.S. Environmental Protection Agency.  1976d.  Initial Scientific and
     Mini Economic Review of Carbofuran, Substitute Chemicals
     Program.  Office of Pesticide Programs, EPA 540/1-76-009.

U.S. Environmental Protection Agency.  1976e.  Pesticides and
     Pesticides Containers, Port IV.  Federal Register/ 39(85).
     Washington, D.C.

U.S. Environmental Protection Agency.  1976f.  Initial Scientific
     Review of PCNB, Substitute Chemical Program.  Office of
     Pesticide Programs, EPA 540/1-75-016.

U.S. Environmental Protection Agency.  1976g.  Quality Criteria for
     Water.  Office of Water and Hazardous Materials.  Washington,
     D.C.

U.S. Environmental Protection Agency.  1976h.  Technical and
     Microeconomic Analysis of Arsenic and Its Compounds.  Office of
     Toxic Substances, Washington, D.C., EPA 560/6-76-016.

U.S. Environmental Protection Agency.  1976i.  Economic Analysis of
     Final Interim Final Effluent Guidelines for the Pesticides and
     Agricultural Chemicals Industry—Group II.  Office of Water
     Planning and Standards.  EPA 230/l-76-065f.

U.S. Environmental Protection Agency.  1975.  Review of Toxicology of
     Organo Halogenated Pesticides.  Residue Reviews, 56:75-107.

U.S. Environmental Protection Agency.  1975a.  Initial Scientific
     Review of Cacodylic Acid, Substitute Chemical Program.  Office
     of Pesticide Programs, EPA 540/1-75-021.

U.S. Environmental Protection Agency.  1975b.  Initial Scientific
     Review of MSMA/DSMA, Substitute Chemical Program.  Office of
     Pesticide Programs, EPA 540/1-75-020.

U.S. Environmental Protection Agency.  1975c.  The Federal
     Insecticide, Fungicide, and Rodenticide Act.  As amended Public
     Law 94-140.

U.S. Environmental Protection Agency.  1975d.  Initial Scientific and
     Mini Economic Review of Monuron, Substitute Chemicals Program.
     Office of Pesticide Programs, EPA 540/1-75-028.
                              XVIII-29

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U.S. Environmental Protection Agency.   1975e.   Information About
     Hazardous Waste Management Facilities,  EPA 530/SW-145.

U.S. Environmental Protection Agency.   1975f.   Guidelines for the
     Disposal of Small Quantities of Unused  Pesticides,  Environmental
     Protection Technology Series.  Office of  Research and
     Development, EPA 670/2-75-057.

U.S. Environmental Protection Agency.   1975g.   Radiation Treatment of
     High Strength Chlorinated Hydrocarbon Wastes,  Environmental
     Protection Technology Series.  Office of  Research and
     Development, EPA 660/2-75-017.

U.S. Environmental Protection Agency.   1975h.   Initial Scientific and
     Mini Economic Review of Aldicarb,  Substitute Chemicals Program.
     Office of Pesticide Programs, EPA 540/1-75-013.

U.S. Environmental Protection Agency.   1975i.   Effluent  Limitations
     Guidelines and Standards of Performance,  Metal Finishing
     Industry, Draft Development Document.  Office of Air and Water
     Programs, Effluent Guidelines Division, Washington, D.C., EPA
     440/1-75-040 and EPA 440/l-75-040a.

U.S. Environmental Protection Agency.   1975j.   Initial Scientific and
     Mini Economic Review of Captan, Substitute Chemicals Program.
     Office of Pesticide Programs, EPA 540/1-75-012.

U.S. Environmental Protection Agency.   1975k.   Initial Scientific and
     Mini Economic Review of Bromacil,  Substitute Chemicals Program.
     Office of Pesticide Programs, EPA 540/1-75-006.

U.S. Environmental Protection Agency.   19751.   Initial Scientific and
     Mini Economic Review of Malathion,  Substitute Chemicals Program.
     Office of Pesticide Programs.

U.S. Environmental Protection Agency.   1975m.   Draft  Development
     Document for Interim Final Effluent  Limitations, Guideines and
     Standards of Performance of the Miscellaneous Chemicals Manu-
     facturing Point Source Category.   Supplement A and  B.
     Washington, D.C.

U.S. Environmental Protection Agency.   1975n.   Initial Scientific and
     Mini Economic Review of Methyl Parathion, Substitute Chemicals
     Program.  Office of Pesticide Programs.

U.S. Environmental Protection Agency.   1975o.   Summation of
     Conditions and Investigations for the Complete Combustion of
     Organic Pesticides.  Office of Research and Development, EPA
     5-03-3516A.

U.S. Environmental Protection Agnecy.   1975p.   Initial Scientific and
     Mini Economic Review of Parathion,  Substitute Chemicals Program.
     Office of Pesticide Programs, EPA 540/1-75-001.
                              XVIII-30

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U.S. Environmental Protection Agency.  1975q.  Pollution Control
     Technology for Pesticide Formulators and Packagers,
     Environmental Protection Technology Series.  Office of Research
     and Development, EPA 660/2-74-094.

U.S. Environmental Protection Agency.  1975r.  Process Design Manual
     for Suspended Solids Removal, U.S. EPA Technology Transfer,
     Washington, D.C., EPA 625/l-75-003a.

U.S. Environmental Protection Agency.  1975s.  Production,
     Distribution, Use and Environmental Impact Potential of Selected
     Pesticides.  Office of Pesticide Programs, Office of Water and
     Hazardous Materials, Washington, D.C., EPA 540/1-74-001.

U.S. Environmental Protection Agency.  1975t.  Substitute Chemical
     Program, Initial Scientific and Minieconomic Review of
     Malathion.  Office of Pesticide Programs, Washington, D.C.  EPA
     540/1-75-005.

U.S. Environmental Protection Agency.  1974a.  Promising Technologies
     for Treatment of Hazardous Wastes, Environmental Protection
     Technology Series.  Office of Research and Development, EPA
     670/2-74-088.

U.S. Environmental Protection Agency.  1974b.  Process Design Manual
     for Sludge Treatment and Disposal, U.S. EPA Technology Transfer,
     Washington, D.C., EPA 625/1-74-006.

U.S. Environmental Protection Agency.  October 15, 1974c.
     Pesticides—EPA Proposal on Disposal and Storage, Part I.
     Federal Register, 39(200).

U.S. Environmental Protection Agency.  1974d.  Process Design Manual
     for Upgrading Existing Wastewater Treatment Plants, U.S.  EPA
     Technology Transfer, Washington, D.C.

U.S. Environmental Protection Agency.  1974e.  Wastewater Filtration
     Design Consideration, U.S. EPA Technology Transfer, Washington,
     D.C.

U.S. Environmental Protection Agency.  1974f.  Wastewater Sampling
     Methodologies and Flow Measurement Techniques.  Region VII,
     Surveillance and Analysis, Technical Support Branch, EPA
     907/9-74-005.

U.S. Environmental Protection Agency.  1974g.  Flow Equalization,
     U.S. EPA Technology Transfer, Washington, D.C.

U.S. Environmental Protection Agency.  1974h.  Development Document
     for Effluent Limitations Guidelines and Standards of
     Performance—Organic Chemicals Industry.  Office of Air and
     Water Programs, Effluent Guidelines Division, EPA
     440/l-74-009a.
                              XVIII-31

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U.S. Environmental Protection Agency.  February 4, 1974i.  Effluent
     Guidelines and Standards.  General Provisions.  Federal
     Register, Part II, 39(24):4531-4533.

U.S. Environmental Protection Agency.  1974j.  Compilation of
     Municipal and Industrial Injection Wells in the United States.
     Volumes I and II.  Washington, D.C., EPA 520/9-74-020.

U.S. Environmental Protection Agency.  1974k.  Methods for Chemical
     Analysis of Water and Wastes, U.S. EPA Technology Transfer,
     Washington, D.C., EPA 625/6-74-003.

U.S. Environmental Protection Agency.  19741.  Herbicide Report.
     Office of Pesticide Programs.  EPA 540/1-74-001.

U.S. Environmental Protection Agency. 1974M.  Effluent Guidelines
     and Standards.  General Provisision.  Federal Register,
     Part II, 39(24):4531-4533.

U.S. Environmental Protection Agency.  July 1973a.  Waste Treatment.
     Upgrading Metal-Finishing Facilities to Reduce Pollution.
     Number 2.  EPA Technology Transfer Seminar Publication.
     Washington, D.C.  EPA 625/3-73-002.

U.S. Environmental Protection Agency.  December 27, 1973b.  Part II.
     Proposed Toxic Pollutant Effluent Standards.  Federal Register,
     38(247).

U.S. Environmental Protection Agency.  1973c.  Development Document
     for Proposed Effluent Limitations Guidelines and New Source
     Performance Standards for the Basic Fertilizer Chemicals Segment
     of the Fertilizer Mnaufacturing Point Source Category.  Office
     of Air and Water Programs,  EPA 440/1-73-011.

U.S. Environmental Protection Agency.  1973d.  Pretreatment of
     Pollutants Introduced into Publicly Owned Treatment Works.
     Office of Water Program Operations, Washington, D.C.

U.S. Environmental Protection Agency.  1973e.  Handbook for
     Monitoring Industrial Wastewater.  EPA Technology Transfer,
     Washington, D.C.
U.S. Environmental Protection Agency.  1973f.  Oxygen Activated
     Sludge Wastewater Treatment Systems, Design Criteria and
     Operating Experience, U.S.  EPA Technology Transfer, Washington,
     D.C.

U.S. Environmental Protection Agency.  1973g.  Physical-Chemical
     Wastewater Treatment Plant Design, U.S. EPA Technology Transfer,
     Washington, D.C.

U.S. Environmental Protection Agency.  1973h.  Development of
     Treatment Process for Chlorinated Hydrocarbon Pesticide
     Manufacturing and Processing Wastes, Water Pollution Control
     Research Series, Office of Research and Development.
                              XVIII-32

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U.S. Environmental Protection Agency Oct., 1973. Process Manual
     for Carbon Adsorption.

U.S. Environmental Protection Agency.  1972a.  The Pollution
     Potential in Pesticide Manufacturing.  Pesticide Study Series-5,
     Technical Studies Report Number T.S.-00-72-04.

U.S. Environmental Protection Agency.  1972b.  Handbook for
     Analytical Quality Control in Water and Wastewater Laboratories.
     U.S. EPA Technology Transfer, Washington, D.C.

U.S. Environmental Protection Agency.  1972c.  Initial Scientific and
     Mini Economic Review of Crotoxyphos, Substitute Chemical
     Program.  Office of Pesticide Programs, EPA 540/1-75-015.

U.S. Environmental Protection Agency.  1972d.  Acceptable Common
     Names and Chemical Names for the Ingredient Statement on
     Pesticides Labels.  Second Edition.  Pesticide Regulation
     Division.

U.S. Environmental Protection Agency.  1972e.  Methods for Organic
     Pesticides in Water and Wastewater.  Mental Research Center,
     Cincinnati, Ohio, EPL 8:P43/2.

U.S. Environmental Protection Agency.  1972f.  Tertiary Treatment of
     Combined Domestic and Industrial Wastes.  Washington, D.C., EPA
     R2-73-236.

U.S. Environmental Protection Agency.  A Catalog of Research in
     Aquatic Pest Control and Pesticide Residues in Aquatic
     Environments.  Pesticide Study Series-1.

U.S. Fish and Wildlife Service. 1980.  Handbook of Acute Toxicity
     of Chemicals to Fish and Aquatic Invertebrates.  Resource
     Publication 137.  Washington, D.C.

Verlag Chemie International. 1983. Stereochemistry and
     Reactivity of System Containing (Pi Electrons). Deerfield
     Beach, Fl.

Vanschueren, K. 1977. Handbook of Environmental Data on Organic
     Chemicals.  Van Nostrand Reinhold Co.

Versar Inc.  A Study of Pesticide Disposal in a Sewage Sludge
     Incinerator.  Prepared for U.S. EPA, Office of Research and
     Development.

Verschueren, K.  1977.  Handbook of Environmental Data on Organic
     Chemicals.  Van Nostrand Reinhold Company, New York.

Vettorazzi, G.  1979.  International Regulatory Aspects for Pesticide
     Chemicals.  Toxicity Profiles.  CRC Press.  Florida.
                              XVIII-33

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Vliet, B.M. and Webber, W.J., Jr.  1981.  Comparative Performance of
     Synthetic Adsorbents and Activated Carbon for Specific Compound
     Removal from Wastewaters.  Journal WPCF 53(11).

Wagner, N.J., Lutchko, J.R., and Deithorn, R.T.  1979.  Control of
     Toxic Emissions from the Thermal Reaction of Activated Carbon.
     Purdue Industrial Waste Conference.

Walk, Haydel and Associates.  1978.  Preliminary Priority Pollutant
     Treatability Matrices.  Prepared for U.S. EPA, Cincinnati,
     Ohio.

Walsh, John E.  1962.  Handbook of Non-Parametric Statistics.
     B. Van Nostrand, Princeton, N.J.

Ware, G.M.  1978.  The Pesticide Book.  W.H. Freeman and Company, San
     Francisco, California.

Warren, W. and Cote, D.R.  1979.  Removal of Phenolic Compounds from
     Wastewater.  Prepared for U.S. EPA, Industrial Environmental
     Research Laboratory, Cincinnati, OH.  Edward C. Jordan Company,
     Inc.

Water and Wastewater Equipment Manufacturers Association.  1980.
     Proceedings of the Eighth Annual Industrial Pollution
     Conference, Houston, Texas.  June 4-6.

Weast, R., Editor.  1974.  CRC Handbook of Chemistry and Physics.
     54th Edition.  CRC Press, Cleveland, Ohio.

White, G.C.  1972.  Handbook of Chlorination for Potable Water, Waste
     Water, Cooling Water, Industrial Processes, and Swimming Pools.
     Van Norstrand Reinhold Company, New York.

Whitehouse, J.D.  1967.  A Study of the Removal of Pesticides from
     Water.  Research Report No. 8.  Kentucky University, Lexington,
     Kentucky.

Wilhelmi, A.R.  1979.  Personal Communication to J.B. Cowart.  Effect
     of Wet Air Oxidation on Several Priority Pollutants.
     Environmental Science and Engineering, Inc., Miami, Florida.

Wilhelmi, A.R. and Ely, R.B.  1976.  A Two-Step Process for Toxic
     Wastewaters.  Chemical Engineering, February 16.

Wilhelmi, A.R. and Ely, R.B.  1975.  The Treatment of Toxic
     Industrial Wastewaters by a Two-Step Process.  Presented to 30th
     Annual Purdue Industrial Waste Conference.  Zimpro, Inc.,
     Rothschild, Wi.

Wilhelmi, A.R. and Knopp, P.V.  1978.  Wet Oxidation as an
     Alternative to Incineration.  Presented to 71st Annual Meeting
     of the American Institute of Chemical Engineers.  Zimpro, Inc.,
     Rothschild, Wi.
                              XVIII-34

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Windholz, M., Budavari, S., Stroumisos, L.Y., and Fertig, M.N.  1976.
     The Merck Index.  M. Windholz, Editor.  Merck and Company, Inc.,
     Rahway, New Jersey.

Wolfe, N.L.  1976.  Hydrolysis of Atrazine.  Interoffice Memo to
     L. Miller.  U.S. EPA, August 13.

Wolfe, N.L., e_t al.  1976.  Captan Hydrolysis.  Journal of
     Agriculture and Food Chemistry, 24(5).

Wolfe, N.L., Zepp, R.G., Baughman, G.L., Fencher, R.C., and Gordon,
     J.A. 1976.  Chemical and Photochemical Transformation of
     Selected Pesticides in Aquatic Systems.  U.S. EPA, Environmental
     Research Laboratory, Georgia.

Wolfe, N.L., Zepp, R.G., and Paris, D.F.  1977.  Carbaryl, Propham,
     and Chlorpropham:  A Comparison of the Rate of Biolysis.
     U.S. EPA, Environmental Research Laboratory, Georgia.

Woodward, D.F., e_t al. 1983, 'Accumulation, Bublethal Effects
     and Safe Concentration of a Refined Oil as Evaluated
     with the Cutthroat Trout,1 in Arch. Environm. Contam.
     Toxicol., 12, 455.

Woodward, D.F. and Mauck, W.L. 1980.  Toxicity of Five Forest
     Insecticides to Cutthroat Trout and Two Species of Aquatic
     Invertebrates.  Bull. Environ. Contam. Toxicol., 25:846-853.

Wroniewicz, V.S.  1978.  Controlling Chlorinated Benzene Compounds in
     Plant Wastewaters.  Pollution Engineering.  November, 43-44

Zepp, R.G., Wolfe, N.L., Gordon, J.A., and Baughman, G.L.  1975.
     Dynamics of 2,4-D Esters in Surface Water.  Hydrolysis,
     Photolysis, and Vaporization.  U.S. EPA, Environmental Research
     Laboratory, Georgia.

Zhang, R. and Zhang, 1982, 'Toxicity of Fluorides to Fishes,1 in C.A.
     Selects - Environm. Pollut. 24,97:176354K

Zimpro, Inc.  1980.  Report on Wet Air Oxidation for Pesticide
     Chemical Manufacturing Wastes.  Prepared for George M. Jett,
     U.S. EPA.  June.  Rothchild, Wisconsin.

Zogorski, J.S. and Faust, S.D.  1977.  Removing Phenols via Activated
     Carbon.  Chemical Engineering Progress, May, 65-66.

Zweig, G., Editor.  1964.  Analytical Methods for Pesticides, Plant
     Growth Regulations, and Food Additives, Volume I; Insecticides,
     Volume II; Fungicides, Nematocides and Soil Fumigants,
     Rodenticides and Food and Feed Additives, Volume III; and
     Herbicides, Volume IV.  Academic Press, New York.
                              XVIII-35

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                           SECTION XIX

                            GLOSSARY
Abscission—Process by which a leaf or other  part  is  separated
from the plant.

Acaricide (miticide)—An agent that destroys mites and ticks.

Act—The  Federal Water Pollution Control Act Amendments of 1972,
Public Law 92-500, as amended by the Clean  Water  Act  of  1977,
Public Law 95-217.

Activated  Carbon—Carbon  which  is  treated by high-temperature
heating with steam or carbon dioxide producing an internal porous
particle structure.

Activated  Sludge—Sludge  floe  produced  in  raw   or   settled
wastewater by the growth of zoogleal bacteria and other organisms
in the presence of dissolved oxygen and accumulated in sufficient
concentration by returning floe previously formed.

Activated   Sludge  Process—A  biological  wastewater  treatment
process in which a mixture of wastewater and activated sludge  is
agitated  and  aerated.   The  activated  sludge  is subsequently
separated  from  the  treated  wastewater   (mixed   liquor)   by
sedimentation and wasted or returned to the process as needed.

Active   Ingredient—The  ingredient  of  a  pesticide  which  is
intended to prevent, destroy, repel, or mitigate any  pest.   The
active  ingredients  may  make  up only a small percentage of the
final product which also consists of binders, fillers,  diluents,
etc.

Activity  Coefficient—An  auxiliary  thermodynamic  function  to
express the volatile properties of binary  systems  that  exhibit
nonideal  vapor equilibrium behavior.  It may also be regarded as
a correction factor that may be applied to  ideal  conditions  to
obtain  "real"  system  properties  under  proper temperature and
pressure conditions.

Aerated Lagoon—A natural or artificial wastewater treatment pond
in  which  mechanical  or  diffused-air  aeration  is   used   to
supplement the oxygen supply.

Aerobic—Condition in which free molecular oxygen is present.

Aldrin-Toxaphene     Pesticide    Structural    Group—Chlordane,
Dienochlor, Endosulfan,  Endrin,  Heptachlor,  Mirex,  Toxaphene.
Algicide—Chemical used to control algae and aquatic weeds.

Amide  Pesticide  Structural  Group—Alachlor,  Butachlor,  Deet,


                               XIX-1

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Diphenamid, Fluoroacetamide,  Napropamide,  Naptalam,  Pronamide,
Propachlor.

Amide   Type   Pesticide  Structural  Group—Aldicarb,  Methomyl,
Oxamyl, Thiofanox.

Anaerobic—Condition in which free molecular oxygen is absent.

Avicide—Lethal agent used to destroy birds but  also  refers  to
materials used for repelling birds.

Attractant,  insect—A  substance  that  lures insects to trap or
poison-bait stations.  Usually classed as food, oviposition,  and
sex attractants.

Bactericide—Any bacteria-killing chemical.

BAT  Effluent  Limitations—Limitations  for point sources, other
than publicly owned treatment  works,  which  are  based  on  the
application   of   the  Best  Available  Technology  Economically
Achievable.  These limitations must be achieved by July 1, 1984.

BCT—Best Conventional Pollutant Control Technology.

Benzidines      (Priority      Pollutant)—Benzidine,       3,3:-
Dichlorobenzidine.

Best    Performance   Treatment   Technologies—Those   treatment
technologies  selected by the Agency and currently inuse  in  the
pesticide industry.   They are:  biological oxidation,  activated
carbon,  hydrolysis, metals separation, chemical oxidation, resin
adsorption, and steam stripping.

Bioconcentration  Factor (B.C.F.)—The ratio of the concentration
of a chemical in aquatic organisms (ug  chemical/g  organism)  to
the amount in water at equilibrium (ug chemical/g water).

Biological Oxidation—Breaking down (oxidizing) organic carbon by
bacteria   that   utilize  free  dissolved  oxygen  (aerobic)  or
"chemically bound" oxygen (anaerobic).

Biological Wastewater Treatment—Forms of wastewater treatment in
which  bacterial  or  biochemical  action   is   intensified   to
stabilize,  oxidize,  and  nitrify  the  unstable  organic matter
present.  Intermittent  sand  filters,  contact  beds,  trickling
filters, and activated sludge processes are examples.

Slowdown—The  removal  of  a  portion  of  any  process  flow to
maintain the constituents of the flow at desired levels.

BOD—Biochemical  oxygen  demand  is  a  measure  of   biological
decomposition  of  organic  matter  in  a  water  sample.   It is
determined by measuring the oxygen required by microorganisms  to
oxidize the organic contaminants of a water sample under standard
laboratory   conditions.    The   standard   conditions   include


                               XIX-2

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incubation for five  days  at  20° C.   BODS—Biochemical  oxygen
demand, measured after five-day.

Botanical   Pesticide—A   pesticide   produced   from  naturally
occurring chemicals found in some plants.  Examples are nicotine,
pyrethrum, strychnine, and rotenone.

Botanical  Pesticide  Structural  Group—Allethrin,   Permethrin,
Pyrethrin, Resmethrin, Rotenone.

BPT  Effluent  Limitations—Limitations  for point sources, other
than publicly owned treatment  works,  which  are  based  on  the
application  of the Best Practicable Control Technology Currently
Available.  These limitations must be achieved by July 1, 1977.

Btu—British thermal unit.

Bypass—An act of intentional noncompliance  during  which  waste
treatment facilities are circumvented in emergency situations.

C—Degrees Centigrade.

Carbamate    Pesticide   Structural   Group—Aminocarb,   Barban,
Bendiocarb,   Benomyl,   Carbaryl,    Carbendazim,    Carbofuran,
Chlorpropham,   Methiocarb,  Mexacarbate,  Polyphase  antimildew,
Propham, Propoxur, Sulfallate, SWEP.

cc—Cubic centimeter.

Cal—Calorie.

Carbamates—A group of insecticides  which  act  on  the  nervous
system by inhibiting the acetylcholinesterase enzyme at the nerve
synapse.

Carbon  Regeneration—The  process  of reactivating  exhausted  or
"spent" carbon by thermal means.

Carcinogen—A substance that causes cancer in animal tissue.

Chemical  Name—Scientific name of the active ingredient(s) found
in the formulated product.  The name is derived from the chemical
structure of the active ingredient.

Chemical Oxidation—Oxidizing organic carbon by chemical means.

Chemosterilant—Chemical compounds that  cause  sterilization  or
prevent effective reproduction.

Chlorinated   Ethanes   and   Ethylenes   (Priority  Pollutant)—
Chloroethane;  1,1-Dichloroethane;   1,2-Dichloroethane;   1,1,1-
Trichloroethane;          1,1,2-Trichloroethane;         1,1,2,2-
Tetrachloroethane;   Hexachloroethane;   Vinyl   chloride;   1,1-
Dichloroethylene;  1,2-Trans-dichloroethylene; Trichloroethylene;
Tetrachloroethylene.   Chlorinated  Aryloxyalkanoic   Acids   and


                               XIX-3

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Esters  Pesticide  Structural Group—2,4-D; 2,4-D isobutyl ester;
2,4-D isooctyl ester; 2,4-D salt; 2,4-DB; 2,4-DB isobutyl  ester;
2,4-DB  isooctyl  ester;  Dichlorprop; MCPA; MCPA isooctyl ester;
MCPP, Silvex; Silvex isooctyl ester; Silvex salt; 2,4,5-T.

Cholinesterase—The  enzyme  responsible  for   nervous   impulse
transmission.

Clarifier—A  treatment  unit  of which the primary purpose is to
reduce the amount of suspended matter in a liquid.

Clean Water Act—Enacted in  1977  to  amend  the  Federal  Water
Pollution Control Act of 1972 and broadens regulations to improve
water quality and the control of potentially toxic pollutants.

cm—Centimeter.

COD—Chemical   oxygen  demand.   Its  determination  provides  a
measure of the oxygen demand equivalent to that portion of matter
in a sample  which  is  susceptible  to  oxidation  by  a  strong
chemical oxidant.

Combined  Wastewater—Wastewater  from  a  number  of  pesticide,
pesticide intermediate, and non-pesticide processes.

Common  Pesticide  Name—A  common  chemical  name  given  to   a
pesticide  by  a  recognized committee on pesticide nomenclature.
Many pesticides are known by a number of trade or brand names but
have only one recognized common name.  For  example,  the  common
name for Sevin insecticide is carbaryl.

Contract  Hauling—Disposal  of waste products through an outside
party for a fee.

Conventional Pollutants—For the Pesticide Industry  conventional
pollutants are defined as BOD, TSS, and pH.

cu ft—Cubic feet.

Cyanate  Pesticide  Structural  Group—Methylene  bisthiocyanate;
Nabonate; TCMTB.

Cyanides (Priority Pollutant)—Cyanide.

Cyclodienes—A  group  of  insecticides  which  are  structurally
characterized as chlorinated cyclic hydrocarbons.

DDT  Type  Pesticide Structural Group—Chlorobenzilate; ODD; DDE;
DDT; Dicofol;  Methoxychlor;  Perthane.   Deep  Well  Injection—
Disposal  of  wastewater  into  a  deep-well  such that a porous,
permeable formation of a large area and thickness is available at
sufficient depth to ensure continued, permanent storage.

Defoliant—A chemical that initiates abscission.
                               XIX-4

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Desiccant—A chemical that induces rapid dehydration of a leaf or
plant part.

Design  Effluent   Level—Long-term   average   effluent   levels
demonstrated  or  judged  achievable  for  recommended  treatment
technologies presented in Section VI, from maximum raw waste load
levels presented in Section V.

Dichloropropane  and  Dichloropropene  (Priority  Pollutant)-1,2-
Dichloropropane; 1,2-Dichloropropylene.

Dienes         (Priority         Pollutant)—Hexachlorobutadiene;
Hexachlorocyclopentadiene.

Dioxin Type Pesticide Structural Group—Dimethoxane.

Direct Discharge—Discharge of wastewater into navigable waters.

Disinfectant—A substance used for the art of killing the  larger
portion   of  microorganisms  in  or  on  a  substance  with  the
probability that all pathogenic bacteria are killed by the  agent
used.

Dual Media Filtration—The process of separation suspended solids
from wastewater; dual media filtration contains sand, anthracite/
or garmet for the removal of suspended solids.

Dual  Significance—Classification  of  priority pollutants which
are: (1) manufactured pesticide products  (primary  significance)
and  are  controlled  by  monitoring  other pollutants of primary
significance  (secondary  significance),  or   (2)   manufactured
pesticide   products  with  zero  wastewater  discharge  (primary
significance) and lack  adequate  monitoring  data  to  recommend
regulation in other pesticide processes (secondary significance).

e—The  base  for the natural or Naperian logarithms which equals
2.71828...

EMSL—Environmental Monitoring and Support Laboratory.

Evaporation  Pond—An  open  holding   facility   which   depends
primarily   on   climatic   conditions   such   as   evaporation,
precipitation, temperature, humidity, and wind velocity to effect
dissipation (evaporation) of wastewater.  External means such  as
spray  recirculation  or heating can be used to increase the rate
of evaporation.

Excursion—An  excursion,   sometimes   called   an   upset,   is
unintentional  noncompliance  occurring  for  reasons  beyond the
reasonable control of the permittee.  F—Degrees Fahrenheit.

Equalization—A treatment unit consisting of a wastewater holding
vessel  that  functions  to equalize wastewaters  and  provide  a
constant discharge rate and wastewater quality.
                               XIX-5

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FIFRA—The Federal Insecticide, Fungicide and Rodenticide Act  of
1947.

Flocculation—The  agglomeration  of colloidal and finely divided
suspended matter.

Flotation—The raising of suspended matter to the surface of  the
liquid  in  a  tank  as  scum—by aeration, the evolution of gas,
chemicals, electrolysis, heat,  or  bacterial  decomposition—and
the subsequent removal of the scum by skimming.

F:M  ratio—The  ratio of organic material (food) to mixed liquid
(microorganisms) in an aerated sludge aeration basin.

Formulation/packaging  of  Pesticides—The  physical  mixing   of
technical  grade  pesticide  ingredients  into liquids, dusts and
powders,  or  granules,  and  their  subsequent  packaging  in  a
marketable container.

fpm—Feet per minute.

fps—Feet per second.

ft—Feet.

Fumigant—A  volatile  material  that  forms  vapors that destroy
insects, pathogens, and other pests.

Fungicide—A chemical that kills fungi.

Gal—Gallons.

Gal/1,000 Ibs—Gallons of wastewater flow  per  1,000  pounds  of
pesticide production.

GC—Gas chromatograph.

GC/MS—Gas chromatography/mass spectrometry.

Genome—A  haploid  set  of chromosomes, or of chromosomal genes,
inherited as a unit from one parent.

Girdling—Removal of bark and cambium layer around a  plant  stem
in the form of a ring.

Goitrogenic—Tending  to  produce  goiters (an enlargement of the
thyroid gland visible as a swelling of the front of the neck).

gpd—Gallons per day.

gpm—Gallons per  minute.   Growth  Regulator—Organic  substance
effective  in  minute amounts for controlling or modifying (plant
or insect) growth processes.

Haloethers (Priority  Pollutant)—Bis(chloromethyl)ether;  Bis(2-


                               XIX-6

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chloroethyl)ether;     2-chloroethyl    vinyl    ether;    Bis(2-
chloroisopropyl)ether; Bis(2-chloroethoxy)methane; 4-chlorophenyl
phenyl ether; 4-Bromophenyl phenyl ether.

Halogenated   Aliphatic    Pesticide    Structural    Group—BHC;
Chloropicrin;    Dalapon;   DBCP;   D-D;   Dichloroethyl   ether;
Dichloropropene; Ethylene dibromide; Lindane; Methyl bromide.

Halogenated   Aromatic   Pesticide   Structural   Group—Bifenox;
Bromoxynil;    Bromoxynil    octanoate;   Captafol;   Chloramben;
Chlorobenzene; Chlorophacinone; Chlorothalonil; Coumachlor; DCPA;
Dicamba;   Dichlorobenzene,   ortho;    Dichlorobenzene/    para;
Dichlorophen; Dichlorophen salt; Hexachlorophene; Nitrofen; PCNB;
PCP; PCP salt; Piperalin; Propanil; Trichlorobenzene.

Halomethanes   (Priority   Pollutant)—Methyl   chloride;  Methyl
bromide;    Methylene    chloride;     Chloroform;     Bromoform;
Dichlorobromomethane; Chlorodibromomethane; Carbon tetrachloride;
Trichlorofluoromethane; Dichlorodifluoromethane.

Hepatocellular   Carcinomas—Malignant   tumors   of   the  cells
comprising the outer layer of the liver.

Hepatoma—'Malignant tumor of the liver proper.

Herbicide—Chemical substance used to destroy  undesirable  plant
life such as weeds.

Heterocyclic  With  Nitrogen  in  the  Ring  Pesticide Structural
Group-BBTAC;  Bentazon;  Captan;   Cycloheximide;   Dowicil   75;
Ethoxyquin  66%;  Ethoxyquin  86%;  Fenarimol;  Folpet;  Glyodin;
Maleic  Hydrazide;  MGK  264;  MGK  326;  Molinate;  Norflurazon;
Paraquat;  Picloram; 8 Quinolinol citrate; 8 Quinolinol sulphate;
Quinomethionate.

hp—Horsepower.

hr—Hour.

Hydrolysis—The degradation of pesticide active ingredients, most
commonly through the  application  of  heat  at  either  acid  or
alkaline conditions.

in—Inch.

Incineration—The  combustion  (by  burning) of organic matter in
vapor and/or aqueous  streams.   Inorganic  Pesticide—Pesticides
that do not contain carbon.

Insect-Growth  Regulator  (IGR)—Chemical substance that disrupts
the action of insect hormones controlling molting, maturity  from
pupal stage to adult, and others.

Insecticide—Chemical substance used to control insects.
                               XIX-7

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Intraperitoneal — Within  the  smooth  transparent serous membrane
that lines the cavity of the abdomen of mammals.

kg — Kilogram.

kkg — 1,000 kilograms.

kPa — Kilopascal-SI unit of pressure equal to 0.01  bars  or  0.75
millimeters of mercury.

kw — Kilowatt.

L(l)— Liter.

Lagoon — A  pond containing raw or partially treated wastewater in
which aerobic or anaerobic stabilization occurs.

Land Disposal — Disposal of wastewater onto land.

Ib — Pound.

lbs/1,000 Ibs — The mass of a particular pollutant (in pounds) per
1,000 pounds of pesticide production.

LC50 — Lethal concentration  50;  the  concentration  of  a  toxic
material  at  which  50  percent  of  the test organisms die when
exposed to the toxic material by a route other than  respiration,
i.e.,  orally  or  dermally,  expressed in mg (toxic material)/kg
(body weight) .

LD50 — Lethal dose 50; the dose of a toxic material  at  which  50
percent  of  the  test  organisms  die  when exposed to the toxic
material by a route  other  than  respiration,  i.e.,  orally  or
dermally, expressed in mg (toxic material)/kg (body weight).

Long-Term  Average — The  average (mg/1 or lbs/1,000 Ibs) effluent
for a pollutant at a particular point in the wastewater treatment
system, based on available data.  Treatment  variability  factors
may  be  multiplied  by  the  long-term  average to derive 30-day
maximum  and  daily  maximum  effluent  limitations.
Level    of  Interest — The  detection
goal  for this project,  as follows:
mg/1; Pesticides
                                       limit  as  an   analytical
                                       Organic pollutants =  0.01
= 0.001 mg/1; Metals (mg/1)
Zn
Sb
As
Be
Cd
Cr
Cu
=
1
0
0
0
0
0
0
.0
.1
.025
.05
.005
.025
.02
Pb
Hg
Ni
Se
Ag
Tl
=
0.
0.
0.
0.
0.
0.
025
001
5
01
005
05
m — Meter.
                               XIX-8

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Manufacturer of Pesticide Active Ingredients—The chemical and/or
physical  conversion  of  raw  materials   to   technical   grade
ingredients  intended to prevent, destroy, repel, or mitigate any
pest.  For purposes of this study only the final  synthesis  step
is included.

Manufacturer   of  Pesticide  Intermediates—The  manufacture  of
materials resulting from each reaction step in  the  creation  of
pesticide  active  ingredients,  except  for  the final synthesis
step.  According to this definition an excess of  materials  need
not be produced.

Manufacturer  of  Products Other Than Pesticides—The manufacture
of products not specifically defined in  the  scope  of  coverage
(e.g.,    organic    chemicals,    plastics    and    synthetics,
Pharmaceuticals, etc.).

Membrane Processes—Such as reverse osmosis,  and ultrafiltration
are  used primarily in the metal industry to remove solutes  from
wastewater.

Mercaptan—Various compounds with the general formula  R-SH  that
are  analogous to the alcohols and phenols but contain sulphur in
place of oxygen and often have disagreeable odors.

Metallo-Organic  Pesticides—A  class   of   organic   pesticides
containing one or more metal or metalloid atoms in the structure.

Metallo-Organic  Pesticide  Structural  Group—Cyhexatin;  Fentin
hydroxide;  Ferbam;   Mancozeb;   Maneb;   Niacide;   Tributyltin
benzoate;  Tributyltin  fluoride; Tributyltin oxide; Vancide 512;
Vancide 512 dispersion; ZAC; Zineb; Ziram.

Metals  (Priority   Pollutant)—Antimony,   Arsenic,   Beryllium,
Cadmium,  Chromium,  Copper,  Lead,  Mercury,  Nickel,  Selenium,
Silver, Thallium, Zinc.

Metals  Separation—Metallic  ion  removal  from  wastewater   by
conversion  to  an insoluble form using such agents as lime, soda
ash,  or  caustic  followed  by  a  separation  process,  usually
clarification or filtration.

mg—Milligram.

MG—Million gallons.

MGD—Million  gallons per day.  mg/1—Milligrams per liter (equal
parts per million, ppm, when the specific gravity is one).

Microbial—Of or pertaining to a pathogenic bacterium.

min—Minute.

Miscellaneous   Priority   Pollutants—Acrolein,   Acrylonitrile,


                               XIX-9

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Asbestos, Isophorone, lf2-Diphenylhydrazine.

Miticide—Chemical substance used to destroy mites, acaricides.

ml/1—Milliliters per liter.

MLSS—Mixed-liquor suspended solids.

MLVSS—Mixed-liquor volatile suspended solids.

mm—Millimeter.

Moiety—A chemical functional group.

Molluscicide—A  chemical  used  to  kill  or  control snails and
slugs.

Mutagen—Substance causing genes in  an  organism  to  mutate  or
change.

NACA—National Agricultural Chemicals Association.

Navigable  Waters—Includes  all  navigable  waters of the United
States;  tributaries  of  navigable  waters;  interstate  waters;
intrastate  lakes;  rivers  and  streams  which  are  utilized by
interstate  travelers  for  recreational   or   other   purposes;
intrastate lakes, rivers and streams from which fish or shellfish
are  taken and sold in interstate commerce; and intrastate lakes,
rivers and streams which are  used  for  industrial  purposes  by
industries in interstate commerce.

Nematicide—A chemical used to kill nematodes.

Neutralization—The  process  of  neutralizing  wastewater  using
alkaline or acidic agents.

Nitro   Pesticide   Structural   Group—Benfluralin,  CDN,  DCNA,
Dinocap,   Dinoseb,   Ethalfluralin,   Fluchloralin,    Giv-Gard,
Isopropalin, Metasol J-26, Oryzalin, Profluralin, Trifluralin.

Nitrosamines   (Priority  Pollutant)—N-nitrosodimethylamine,  N-
nitrosodi-n-propylamine, N-nitrosodiphenylamine.

Nitrosubstituted  Aromatics  (Priority  Pollutant)—Nitrobenzene;
2,4-Dinitrotoluene; 2,6-Dinitrotoluene.

Noncategorized   Pesticides  Structural  Group—Benzyl  benzoate,
Benzyl bromoacetate, Busan 90, Cycloprate, Fluoridone, HAE, HAMP,
Kinoprene,  Methoprene,  NMI,  Oxyfluorfen,  Piperonyl  butoxide,
Sodium   monofluoroacetate,  Warfarin.

Noncontact   Wastewater—Wastewater which is not contaminated  by
the  process  or  related materials.    Examples  include  boiler
blowdown,   cooling water, sanitary  sewage.   Storm  water  from
outside    the   immediate manufacturing  area  may  be  included


                               XIX-10

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in this definition if it is not contaminated from product spills,
etc.

Nonconventional   Pollutants—For    the    Pesticide    Industry
nonconventional  pollutants  are defined as nonpriority pollutant
pesticides, COD, ammonia, and manganese (see Table X-l).

Nonhalogenated Aliphatic  Pesticide  Structural  Group—Propionic
acid.

Nonhalogenated  Aromatic  Pesticide  Structural  Group—Biphenyl,
Coumafuryl,     Coumatetralyl,     Diphacinone,     Phenylphenol,
Phenylphenol sodium salt, Pindone.

Nonhalogenated  Cyclic  Aliphatic  Pesticide  Structural  Group—
Endothall.

Non-Pass   Through   Pollutants—Those   pollutants   that    are
biodegradable,   and  do  not  pass  through  biogical  oxidation
treatment systems.

NPDES—National  Pollution  Discharge  Elimination   System.    A
federal program requiring industry to obtain permits to discharge
plant effluents to the nation's water courses.

NSPS—New Source Performance Standards.

Nutrients—The  nutrients  in  contaminated  water  are routinely
analyzed to characterize the food available for microorganisms to
promote  organic  decomposition.   They  are:   Ammonia  Nitrogen
(NH3),  mg/1  as  N;  Kjeldahl Nitrogen (TKN), mg/1 as N; Nitrate
Nitrogen (NO3), mg/1 as N; Total Phosphate (TP), mg/1 as P; Ortho
Phosphate (OP), mg/1 as P.

Ocean Discharge—Discharge of wastewater into an ocean.

Oncogenic—The  property  to  produce  tumors  (not   necessarily
cancerous) in tissues (see Carcinogen).

Opacity—The ratio of transmitted to incident light.

Organo-Nitrogen  Others  Pesticide  Structural  Group—Alkylamine
hydrochloride,  Benzethonium  chloride,  Dazomet,  Diphenylamine,
Dodine,  Etridiazole,  Hyamine  2389,  Hyamine  3500, Kathon 886,
Lethane  384,  Metasol   DGH,   Methyl   benzethonium   chloride,
Octhilinone, PBED, Thiabendazole, Triadimefon, Tricyclazole.


Organo—Phosphorus Pesticide Structural Group—Dyfonate, phorate,
naled, diazinon, malathion.

Organo-Sulfur Pesticide Structural Group—EXD, HPTMS, Propargite,
Sulfoxide, Vancide PA.

Ovicide—A chemical that destroys an organism's eggs.


                               XIX-11

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Pass-Through  Pollutants—Those  pollutants that are not  readily
biodegradable  and  pass through biological  oxidation  treatment
systems.

Patent—An official document issued by the U.S. Office of Patents
conferring  an  exclusive  right or privilege to produce, use, or
sell a pesticide for a specified period of  time.   Pathogen—Any
disease-producing organism or virus.

PCS—Polychlorinated biphenyl.

Pesticide—Any  technical  grade ingredient used for controlling,
preventing, destroying, repelling, or mitigating any  pest.   See
Section III for classes of pesticides covered; see Section XVIII-
Appendix 3 for individual pesticides covered.

Pesticide   (Priority  Pollutant)—Aldrin;  Dieldrin;  Chlordane;
4,4'-DDT; 4,4'-DDE; 4,4'-ODD;  a-endosulfan-Alpha;  b-endosulfan-
Beta;  endosulfan  sulfate;  endrin; endrin aldehyde; heptachlor;
heptachlor epoxide; a-BHC-Alpha; b-BHC-Beta; r-BHC-Gamma;  g-BHC-
Delta; Toxaphene.

pH—pH  is  a  measure  of  the  acidity or alkalinity of a water
sample.  It is equal to the negative  log  of  the  hydrogen  ion
concentration.

Phenols   (Priority   Pollutant)—Phenol;   2-Chlorophenol;  2,4-
Dichlorophenol;  2,4,6-Trichlorophenol;   Pentachlorophenol;   2-
Nitrophenol;   4-Nitrophenol;  2,4-Dinitrophenol;  Parachlorometa
cresol; 4,6-Dinitro-o-cresol; 2,4-Dimethylphenol.

Pheromones—Highly potent insect sex attractants produced by  the
insects.   For  some  species,  laboratory-synthesized pheromones
have been developed for trapping purposes.

Phosphate and Phosphonate Pesticide Structural Group—Dichlorvos,
Mevinphos, Monocrotophos, Naled, Stirofos.

Phosphorothioate  and  Phosphorodithioate  Pesticide   Structural
Group-Aspon,    Azinphos    methyl,   Bolstar,   Carbophenothion,
Chlorpyrifos, Chlorpyrifos methyl, Coumaphos, Cythioate, Demeton,
Demeton-o,  Demeton-s,  Diazinon,   Dichlofenthion,   Dioxathion,
Disulfoton,   EPN,   Ethion,   Ethoprop,  Famphur,  Fenitrothion,
Fensulfothion, Fenthion, Fonofos, Malathion, Merphos, Oxydemeton,
Parathion ethyl,  Parathion  methyl,  Phorate,  Phosmet,  Ronnel,
Temephos, Terbufos, Thionazin, Trichloronate, Tokuthion.

Phosphorus-Nitrogen    Pesticide    Structural   Group—Acephate,
Bensulide, Glyphosate, Mephosfolon, Methamidophos, Phosfolan.

Phthalate       Esters        (Priority        Pollutant)—Bis(2-
ethylhexyl)phthalate;    Butyl   benzyl   phthalate;   Di-n-butyl
phthalate;  Di-n-octyl  phthalate;  Diethyl  phthalate;  Dimethyl
phthalate.


                               XIX-12

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Phytotoxic—Poisonous to plants.

Piscicide—Chemical used to kill fish.

Polychlorinated  Biphenyl's  (Priority Pollutant)—PCB-1242; PCB-
1254;   PCB-1221;   PCB-1232;   PCB-1248;   PCB-1260;   PCB-1016.
Polynuclear    Aromatic   Hydrocarbons   (Priority   Pollutant)—
Benzo(a)anthracene;    Benzo(a)pyrene;     3,4-Benzofluoranthene;
Benzo(k)fluoranthene;   Chrysene;   Acenaphthylene;   Anthracene;
Benzo(ghi)perylene;            Fluorene;             Phenathrene;
Dibenzo(a,h)anthracene;  Indeno(lf2,3-cd)  pyrene;  Fluoranthene;
Naphthalene; 2-Chloronaphthalene; Acenaphthene.

Polyploidy—Exhibiting entire  extra  sets  of  chromosomes  with
three or more genomes.

Postemergence—After emergence of the specified weed or crop.

POTW—Publicly owned treatment works.

ppb—Parts  per  billion  (equal micrograms per liter, ug/1, when
the specific gravity is one).

ppm—Parts per million (equal milligrams per  liter/  mg/1,  when
the specific gravity is one).

ppt—• Parts  per  trillion  (equal nanograms per liter/ ng/1/ when
specific gravity is one).

Pre-emergence—-Refers to the time before sprouting from the  soil
of a specific weed or crop.

Primary  Significance—Pollutants  are of primary significance if
they are recommended for  regulation  due  to  their  deleterious
effects on humans and the environment.

Primary  Treatment—The  first  major  treatment  in a wastewater
treatment works.  In the classical sense/ it normally consists of
clarification. As used in this document, it generally  refers  to
treatment steps preceding biological treatment.

Priority  Pollutant—Those compounds specified as an outgrowth of
the 1976 Consent Decree as listed in Section XVIII—Appendix 1.

Process Wastewater—Any aqueous discharge which results  from  or
has  had contact with the manufacturing process.  For purposes of
this study only wastewater from the final synthesis step  in  the
manufacture  of  pesticide  active  ingredients  is  included, in
addition to  the  following:   (1)  Wastewater  from  vessel-floor
washing  in  the  immediate  manufacturing  area;  (2) Stormwater
runoff from the immediate manufacturing area; (3) Wastewater from
air pollution scrubbers utilized in the manufacturing process  or
in the immediate manufacturing area.
                               XIX-13

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PSES-Pretreatment Standards for Existing Sources.

psi—Pound per square inch.

PSNS-Pretreatment Standards for New Sources.

QA/QC—Quality  Assurance/Quality  Control.   Quaternary Ammonium
Salt—Chemical compound having a chlorine or bromine ion attached
to a nitrogen atom with four carbon-nitrogen bonds.  May be  used
as algicides, bactericides, piscicides, etc.

Raw  Waste  Load—The quantity of flow or pollutant in wastewater
prior to a treatment process.

Repellent (insects)—Substance used  to  repel  ticks,  chiggers,
gnats, flies, mosquitoes, and fleas.

Resin  Adsorption—A  method  of  treating  wastewater in which a
resin material removes organic matter by adherence on the surface
of solid bodies.

Risk Level—The population size on which it is estimated that one
additional case of cancer will  be  reported  due  to  the  daily
consumption of water and edible aquatic organisms.

Rodenticide—Pesticide  applied  as  a bait, dust, or fumigant to
destroy or repel rodents and other animals,  such  as  moles  and
rabbits.

rpm—Revolution per minute.

Sanitary   Wastewater—Wastewater   discharging   from   sanitary
conveniences such as toilets, showers, and sinks.

Sec—Second.

Secondary Significance—Pollutants are of secondary  significance
if  they are not recommended for regulation, but are specified to
be considered on a case-by-case basis for  potential  deleterious
effects on humans and the environment.

Secondary  Treatment—The  second major step in a waste treatment
system. As used in this document, the term refers  to  biological
treatment.

Segregated  Wastewater Stream—A wastewater stream generated from
part or all of one pesticide process.

Slimicide—Chemical used to prevent slimy  growth,  as  in  wood-
pulping processes for manufacture of paper and paperboard.

Sludge—The  accumulated  solids  separated from liquids, such as
water or wastewater, during processing.

Spray Evaporation—A method of wastewater disposal in  which  the


                               XIX-14

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water  in a holding lagoon equipped with spray nozzles is sprayed
into the air to expedite evaporation.

Sq. ft.—Square foot.  Steam  Stripping—An  operation  in  which
relatively  volatile  components  are  transferred  from a liquid
mixture to the gas phase by passage of steam through the liquid.

Air/Steam Stripping—A treatment unit process used for separating
volatile organics from water and wastewater.

Synergism—Increased activity resulting from the  effect  of  one
chemical to another.

Systemic—Compound  that  is absorbed and translocated throughout
the plant or animal.

TCDD   (Priority    Pollutant—TCDD(2,3,7,8-tetrachlorodibenzo-p-
dioxin).

TDS—Total dissolved solids.

Teratogenic—Substance  that causes physical birth defects in the
offspring following exposure of the pregnant female.

Tertiary  Treatment—The  third  major step   in   a   wastewater
treatment process.   As used in this document, the term refers to
treatment processes following biological treatment.

Thiocarbamate Pesticide Structural Group—Amobam, AOP,  Aquatreat
DNM  30,  Busan 40, Busan 85, Butylate, Carbarn S, Cycloate, EPTC,
KN Methyl, Metham, Nabam, Pebulate, Vernolate.

TKN—Total Kjeldahl nitrogen.

TLM—Median tolerance limit; the concentration in the environment
of a toxic substance  at  which  only  50  percent  of  the  test
organisms survive.

TOC—Total   organic   carbon   is   a  measure  of  the  organic
contamination  of  a  water  sample.    It   has   an   empirical
relationship with the biochemical and chemical oxygen demands.

TOD—Total oxygen demand.

Toxic—Poisonous to living organisms.

Treatment  Technology—Any  pretreatment or end-of-line treatment
unit which is utilized in conjunction  with  process  wastewater.
The unit may be employed at any point from the process wastewater
source to final discharge from plant property.

Triazine   Pesticide   Structural   Group—Ametryne,   Anilazine,
Atrazine, Cyanazine, Hexazinone, Metribuzin, Prometon, Prometryn,
Propazine,  Simazine,   Simetryne,   Terbuthylazine,   Terbutryn,
Vancide TH.
                               XIX-15

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TSS—Total suspended solids.

ug—Microgram.

Upset—An  upset, sometimes called an excursion, is unintentional
noncompliance  occurring  for  reasons   beyond   the  reasonable
control of the permittee.

Oracil Pesticide Structural Group—Bromacil, Terbacil.

Urea  Pesticide  Structural  Group—Diuron, Fenuron, Fenuron-TCA,
Fluometuron, Linuron,  Monuron,  Monuron-TCA,  Neburon,  RH  787,
Siduron, Tebuthiuron,

Volatile  Aromatics {Priority Pollutant)—Benzene? Toluene? Ethyl
benzene? Chlorobenzene; 1,2-Dichlorobenzene; 1,3-Dichlorobenzene;
1,4-Dichlorobenzene, 1,2,4-Trichlorobenzene; Hexachlorobenzene.

VSS—Volatile suspended solids.

Wastewater—See process wastewaters.

Wet  Air  Oxidation-Is  a liquid  phase  oxidation  process  that
destroys pollutants by oxidizing them totally.

Wet Scrubber—An air pollution control device which involves  the
wetting  of particles in an air stream and the impingement of wet
or dry particles on collecting surfaces, followed by flushing.

Zero Discharge—The prevention of process wastewater  from  point
sources  entering  navigable waters either directly or indirectly
through publicly owned treatment works.
                               XIX-16

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                         SECTION XX—APPENDIX 1
                       PRIORITY POLLUTANTS BY GROUP
Benzidines

  1.  Benzidine
  2.  SfS'-Dichlcrobenzidine

Chlorinated Ethanes and Ethylenes

  3.  Chlcc oethane
  4.  1,1-Di chlcc oethane
  5.  1,2-Di chlcc oe thane
  6 .  1 , 1-Di chlcc ce thylene
  7 .  Ifexachlccoetnane
  8.  1,1,2,2-Tetrachlccoethane
  9.  Tetrachlccoe thylene
 10.  1,2-Trans-dichloroethylene
 11.  1,1,1-Trichlccoe thane
 12.  1,1,2-Trichlor oethane
 13.  Tri chlcc oe thylene
 14.  Vinyl chloride
      ( Chi cr ce thylene )

Cyanides

 15.  Cyanide

Dichlccopropane and Dichloropcopene
 16.
 17.

Dienes
      1,2-Di chloropropane
      1,3-Dichlorocropene
 1 8 .  tfexachlccobutad iene
 19.  ffexachlccocyclopentadiene

Haloethers

 20.  Bis(2-chlcroethoxy) methane
 21.  Bis(2-chloroethyl) ether
 22.  Bis(2-chloroisopropyl) ether
 23.  Bis (chlcc erne thyl) ether*
 24.  4-Bronophenyl phenyl ether
 25.  2-Chlcroethyl vinyl ether
 26.  4-Chlcrophenyl phenyl ether
Halcne thanes

  27.  Bromofcrm
       (Tr ibr onone thane)
  28.  Carbon tetrachlcr ide
       (Te tr achlcc one thane)
  29.  Chi cccd ibr emote thane
  30.  Chlcc of crm
       (Tr ichlor one thane)
  31.  Di chlcc cbrcmcme thane
  32.  Dichlccodiflur onethane*
  33.  tethyl bromide
       (Br atone thane)
  34.  tethyl chlcc ide
       (chlcc one thane)
  35.  fethylene chloride
       (Di chlcc one thane)
  36.  Trichlcc of luor ore thane*

  Metals

  37.  Aitinony
  38.  Arsenic
  39.  Berylliun
  40.  Cadmiun
  41.  Chromiun
  42.  Copper
  43.  lead
  44.  ffercury
  45.  Nickel
  46.  Selenium
  47.  Silver
  48.  Thalliun
  49.  Zinc

  Miscellaneous Priority Pollutants

  50.  Acrolein
  51.  Acrylonitrile
  52.  Asbestos
  53.  1,2-Diphenylhydrazine
  54.  Isophorone

  Nitrosamines

  55.  N-nitrosodJmethylamine
  56.  N-nitrosodiphenylamine
  57.  N-nitroscdi-n-propylamine
                                       XX-1

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                          SECTION XX—APPENDIX 1
                       PRIORITY POLLUTANTS BY GROUP
                         (Continued,  Page 2 of 3)
Nitrosubstituted Aronatics

58.  2,4-Dinitrotoluene
59.  2,6-Dinitrotoluene
60.  Nitrobenzene

Pesticides

61.  Aldrin
62.  a-BHC-Alpha
63.  b-BHC-Beta
64.  r-BHC-Garana (Lindane)
65.  d-BHC-DBlta
66.  Chlordane
67.  Dieldrin
68.  4,4'-ODD (p-p'-TDE)
69.  4,4'-DDE (p-p'-DDX)
70.  4,4'-DDT
71.  a-Bidosulfan-Alpha
7 2.  b-Ehdosulfan-Be ta
73.  Bidosulfan sulfate
74.  Endrin
75.  Ehdrin aldehyde
76.  ffeptachlor
77.  Ffeptachlor epoxide
78.  Toxaphene

Phenols

79.  2-Chlorophenol
80.  2,4-Dichlorophenol
81.  2,4-Dimethylphenol
82.  4,6-Dinitro-o-cresol
83.  2,4-Dinitrophenol
84.  2-Nitrophenol
85.  4-Nitrophenol
86.  Parachlorophenol
8 7.  Pen tachlor ophenol
88.  Phenol
89.  2,4,6-Trichlorophenol
Polychlor inated Biphenyls
96.
97.
98.
100.
101.
102.
PCB-1242
PCB-1254
PCB-1221
PCB-1232
PCB-1260
PCB-1016
(Arochlor 1242)
(Arochlor 1254)
(Arochlor 1221)
(Arochlor 1232)
(Arochlor 1260)
(Arochlor 1016)
Polynuclear Aromatic Hydrocarbons

 103.  Acnaphthylene
 104.  Acenaphthene
 105.  Anthracene
 106.  Benzo(A)anthracene
       (1,2-Benzanthracene)
 107.  Bsnzo(a)pyrene
       (3,4-Ben zopyr ene)
 108.  3,4-B9nzofluoranthene
 109.  Benzo(k)fluoranthene
       (1,12-Bsn zoper ylene)
 110.  Benzo(k)fluoranthene
       (11,12-Bsn zoper ylene)
 111.  2-Chlorcnaphthalene
 112.  Chrysene
 113.  Dibenzo(a,h)anthracene
       (1,2,5,6-Diben zan thr acene)
 114.  Fluoranthene
 115.  Fluorene
 116.  3hdeno(l,2,3-cd)pyrene
       (2,3-o-Phenylenepyr ene)
 117.  Napthalene
 118.  Phenanthrene
 119.  Pyrene

TCDD

 120.  TCDD (2,3,7,8-Tetrachloro-
       d iben zo-p-d ioxin)
                                   XX-2

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                          SECTION XX—APPENDIX 1
                       PRIORITY POLLUTANTS BY GROUP
                         (Continued, Page 3 of 3)
Phthalate Esters

  90.  Bis(2-ethylhexyl) phthalate
  91.  Butyl benzyl phthalate
  92.  Diethyl phthalate
  93.  Dimethyl phthalate
  94.  Di-n-butyl phthalate
  95.  Di-n-octyl phthalate
Volatile Aromatics

 121.  Benzene
 122.  Chlorobenzene
 123.  1,2-Dichlorobenzene
 124.  1,3-Dichlorobenzene
 125.  1,4-Dichlorobenzene
 126.  Ethylbenzene
 127.  Ffexachlorobenzene
 128.  1,2,4-Trichlorobenzene
 129.  Toluene
   Classification as a priority pollutant discontinued by EPA.
                                     XX-3

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                  SECTION XX--APPENDIX 2
          LIST OF PESTICIDE ACTIVE INGREDIENTS
        Common Name
     Chemical Name
 1.   Acephate (Orthene)
 2.   Alachlor  (Lasso)
 3.   Aldicarb (Temik)
 4.   Alkylamine
     hydrochloride

 5.   Allethrin
 6.   Ametryne (Evik)



 7.   Aminocarb


 8.   Amobam


 9.   Anilazine (Dyrene)


10.   [AOP]  (Ambam oxidation
     product)
OfS-Dimethyl acetylphosphor-
amidothioate

2-Chloro-2',6'-diethyl-N-
(methoxymethyl) acetanilide

2-Methyl-2-(methylthio)-
propionaldehyde-o-
(methylcarbomoyl) oxime

Alkylamine hydrochloride
2-methyl-4-oxo-3-(2-propenyl)-
2-cyclopenten-l-yl 2,2-dimethyl-
3-(2-methyl-l-propenyl)
cyclopropane carboxylate

2-Ethylamino-4-isopropyl-
amino-6-methylthio-l,3,5-
triazine

4-Dimethylamino-3-methyl-phenyl
methyl-carbamate

Diammonium ethylenebisdi-
thiocarbamate

2,4-Dichloro-6-(2-chloroanil-
ino)-lf3,5-triazine

Ethylene bis (dithiocarbamic
acid) bimolecular and trimole-
cular cyclic anhydrosulfides
and disulfides
                        XX-4

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                  SECTION XX—APPENDIX 2
          LIST OF PESTICIDE ACTIVE INGREDIENTS
        Common Name
     Chemical Name
11.  (Aquatreat DNM 30)
12.  (Aspon)
13.  Atrazine (Aatrex)
14.  Azinphos methyl
     (Guthion)
15.  Barban (Carbyne)
16.  l,l'-(2-butenylene)bis
     (3,5,7-triaza-l-azo
     (niaadiamantane chloride)
     [BBTAC]

17.  Bendiocarb (Ficam)
18.  Benfluralin (Benefin)
19.  Benomyl (Benlate)
20.  Bensulide (Prefar)
21.   Bentazon (Basagran)
15% Sodium dimethyl dithio-
carbamate 15.0% Disodium
ethylene bisdithiocarbamate

tetra-n-Propyl dithio-
pyrophosphate

2-Chloro-4-ethylamino-6-iso-
propylamino-1,3,5-triazine

0,0-Diethyl S-[4-oxo-l,2,3-ben-
zotriazin-3(4H)-ylmethylj
phosphorodithioate

4-Chlorobut-2-butynyl-m-
chlorocarbanilate

1,1'-(2-Butenylene)bis(3,5,7-
triaza-1-azo niaadamantane
chloride)
2,3-Isopropylidenedioxyphenyl
methylcarbamate

N-Butyl-N-ethyl-2,6-dinitro-
4-trifluoro-methylaniline

Methyl l-(butylcarbamoyl)-
2-benzimidazolecarbamate

S-(0/0-Diisopropyl phosphoro-
dithioate) ester of N-(2-mer
captoethyl)benzene sulfonamide

3-Isopropyl-lH-2,1,3-benzo-
thiadiazion-(4) 3H-one 2,
2-dioxide
                             XX-5

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                  SECTION XX—APPENDIX  2
          LIST OF PESTICIDE ACTIVE INGREDIENTS
        Common Name
     Chemical Name
22.   Benzethonium chloride
     (Hyamine 1622)
23.   Benzyl benzoate

24.   Benzyl bromoacetate
     (Merbac 35)

25.   BHC (Alpha,  Beta,
     and Delta Isomers)*

26.   Bifenox (Modown)
27.  Biphenyl (Diphenyl)

28.  (Bolstar)  Sulprofos


29.  Bromacil (Hyvar)


30.  Bromoxynil (Brominal)


31.  Bromoxynil octanotate


32.  (Busan 40)


33.  (Busan 85)


34.  (Busan 90)
Benzyldimethyl[2-<2-(p-1,
1,3,3-tetramethylbutylphen-
oxy)ethoxy>ethy1]ammonium
chloride

Benzylbenzenecarboxylate

Benzyl bromoacetate
1,2,3,4,5,6-Hexachlorocyclohexane
mixed ixomers

Methyl 5-(2,4-dichlorophenyl)
2-nitrobenzoate

Diphenyl

O-Ethyl O-[4(methylthio)phenyl]
-s-propyl phosphorodithioate

5-Bromo-3-sec-butyl-6-methyl-
uracil

3,5-Dibromo-4-hyroxyben-
zonitrile

2,6-Dibromo-4-cyanophenyl
octanoate

Potassium N-hydroxymethyl-
-N-Methyldithio carbamate

Potassium dimethyldithio
carbamate

2-Bromo-4-L-hydroxyaceto-
phenone
                           XX-6

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                  SECTION XX—APPENDIX 2
          LIST OF PESTICIDE ACTIVE INGREDIENTS
        Common Name
     Chemical Name
35.  Butachlor (Machete)


36.  Butylate (Sutan)


37.  Captafol (Difolatan)


38.  Captan (Orthocide 406)


39.  (Carbam-S)  (Sodam)

40.  Carbaryl (Sevin)

41.  Carbendazim


42.  Carbofuran  (Furadan)
43.  Carbophenothion
     (Trithion)

44.  Chloramben
     (Amiben)

45.  Chlordane*
     (Octachlor)
46.  Chlorobenzene*

47.  Chlorobenzilate
     (acaraben)

48.  Chlorophacinone
N-(Butoxymethyl)-2-chloro-2',6'-
-diethylacetanilide

S-Ethyl Nf N-diisobutylthio-
carbamate

N-(1,1,2,2-Tetrachloroethylthio)
tetrahydrophthalimide

N-[(Trichloromethyl)thio]-4-
-cyclohexene-1,2-dicarboximide

Sodium dimethyldithiocarbamate

1-Naphthyl N-methylcarbamate

2-(Methoxycarbonylamino)benzi-
midazol

2, 3-Dihydro-2,2-dimethyl-7-
benzofuranyl methylcarbamate

S-[(p-Chlorophenylthio)-methyl]
0,0-diethyl phosphorodithioate

3-Amino-2, 5-dichloro-
benzoic acid

1,2,4,5,6,7,8,8-Octachloro-
-2,3,3a,4,7,7a-hexhydro-
-4,7-methanoindene

Monochlorobenzene

Ethyl 4,4'-dichlorobenzilate
2-[(p-chlorophenyl)phenyl-
-acetyl]-1,3-indandione
                         XX-7

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                  SECTION XX—APPENDIX 2
          LIST OF PESTICIDE ACTIVE INGREDIENTS
        Common Name
     Chemical Name
49.   Chloropicrin
     (Larvacide, Nemax)

50.   Chlorothalonil
     (Daconil 2787)

51.   Chlorpropham
52.   Chlorpyrifos
     (Dursban)
53.   Chlorpyrifos methyl
54.   Coumachlor
Trichloronitromethane
2,4,5,6-Tetrachloroisophtha-
lonitrile

Isopropyl-3-chlorophenyl
carhamate

0,0-Diethyl 0-(3,5,6-tri-
chloro-2-pyridyl)phospho-
rothioate

0,0-Dimethyl 0-(3,5,6-tri-
chloro-2-pyridyl) phospho-
rothioate

3-(-acetonyl-4-chlorobenzyl)
-4-hydroxycoumarin
55.   Coumafuryl
56.  Coumaphos (Co-Ral)
57.  Coumatetralyl
58.  Cyanazine (Bladex)
59.  Cycloate (Ro-Neet)
60.  Cycloheximide
     (Actidione)
4-hydroxy-3-[3-oxo-l-(2-
furyl)butyl]coumarin

0-(3-Chloro-4-methyl-2-oxo-
-2H-l-benzopyran-7-yl)
0,0-diethyl phoaphorothi-
oate

4-hyroxy-3-(l,2,3,4-tetra-
hydro-l-naphthyl)coumarin

2-[(4-Chloro-6-(ethylamino)-
-S-triazine-2-yl)amino]-2-
-methylpropionitrite

S-Ethyl ethylcyclohexylthio-
carbamate

3[2-(3,5-Dimethyl-2-oxo-
cyclohexyl)-2-hydroxy-
ethyl] glutarimide
                          XX-8

-------
                  SECTION XX—APPENDIX 2
          LIST OF PESTICIDE ACTIVE INGREDIENTS
        Common Name
     Chemical Name
61.  Cycloprate


62.  Cyhexatin

63.  Cythioate (Probam)



64.  2,4-D


65.  2,4-D isobutyl ester




66.  2,4-D isooctyl ester
67.  2,4-D salt


68.  Dalapon (Dowpon)

69.  Dazomet  (Thiadiazin)


70.  2,4-DB


71.  2,4-DB isobutyl ester
Hexadecylcyclopropane
carboxylate

Tricyclohexytin hydroxide

0,0-Dimethyl 0-p-sulfa-
moylphenyl phosphoro-
thioate

2,4-Dichlorophenoxyacetic
acid

2,4-Dichlorophenoxyaxetic
acid, technical mixture:
Isobutyl ester, 60%
N-butyl ester, 40%

2,4-Dichlorophenoxyacetic
acid isooctyl ester
3,4-Dimethylhexanol, 20%
3,5-Dimethylhexanol, 30%
4,5-Dimethylhexanol, 30%
3-Methylheptanol, 15%
5-Methylheptanol, 5%

2,4-Dichlorophenoxyacetic
acid dimethylamine salt

2,2-Dichloropropionic acid

Tetrahydro-3,5-dimethyl-
l,3,5-thiadiazine-2-thione

4-(2,4-Dichlorophenoxy)-
butyric-acid

4-(2,4-Dichlorophenoxy)-butyric-
-acid isobutyl ester
                           XX-9

-------
                  SECTION XX—APPENDIX 2
          LIST OF PESTICIDE ACTIVE INGREDIENTS
        Common Name
     Chemical Name
72.  2,4-DB isooctyl ester


73.  DBCP
     (Dibromochloropropane,
     Nemagon)

74.  DCNA (Dichloran,  Botran)

75.  DCPA (Daethai)


76.  ODD (TDE)*


77.  DDE (DDX)*


78.  DDT*

79.  Deet

80.  Demeton (Systox)



81.  Demeton-o


82.  Demeton-s


83.  Diazinon (Spectracide)



84.  Dicamba (Banvel D)
85.  Dichlofenthion
     (Nemacide)
4-(2,4-Dichlorophenoxy)-butyric-
-acid isooctyl ester

1,2,Dibromo-3-chloropropane
and related halogenated C3
hydrocarbons

(2,6 Dichloro-4-,nitroaniline)

Dimethyl 2,3,5,6-tetrachloro
terephthalate

2,2-Bis(p-chlorophenyl)-!,!-
dichloroethane

1,l-Dichloro-2,2-Bis(p-chloro-
phenyl) ethylene

Dichlorodiphenyl trichloroethane

NN-Diethyl-m-toluamide

Mixture of 0,0-diethyl-S(and
0)-[2-(ethylthio)ethyl]
phosphorothioates

0,0-Diethyl 0-[2-(ethylthio)
ethyl] phosphorothioate

0,0-Diethyl S-[2-(ethylthio)
ethyl] phosphorothioate

0,0-Diethyl 0-(2-isopropyl-
b-methyl-4-pyrimidinyl)
phosphorothioate

2-Methoxy-3,b-dichlorozben-
zoic acid

0-2,4-Dichlorophenyl 0,0-diethyl
phosphorothioate
                          XX-10

-------
                   SECTION XX—APPENDIX 2_

           LIST OF PESTICIDE ACTIVE INGREDIENTS
         Common Name
     Chemical Name
 86.  Dichlorobenzene, ortho*

 87.  Dichlorobenzene, para*

 88.  Dichloroethyl ether*
      (Chlorex)

 89.  Dichlorophen


 90.  Dichlorophen salt
 91.  D-D (Dichloropropane-
      dichloropropene mixture)
 92.  Dichloropropene (Telone)*

 93.  Dichlorprop (2,4-DP)


 94.  Dichlorvos (DDVP)


 95.  Dicofol


 96.  Dienochlor (Pentac)


 97.  Dimethoxane (Dioxin)


 98.  Dinocap (Karathane)


 99.  Dinoseb (DNBP)

100.  Dioxathion (Delnav)



101.  Diphacinone (Diphacin)
1,2-Dichlorobenzene

1,4-Dichlorobenzene

Bis(2-chloroethyl) ether
2,2'-Methylene bis(4-chlo-
rophenol)

Sodium salt of 2,2'-methyl-
ene bis(4-chlorophenol)

(60-66%) 1,3-Dichloropropene &
(30-35%) 1,2-Dichloropropane &
other constitutents

1,3-Dichloropropene

2-(2,4-Dichlorophenoxy)-
-propionic acid

2,2-Dichlorovinyl dimethyl
phosphate

1,1-Bis(p-chlorophenyl)-2,2,2-
trichloroethanol

Perchlorobi (cyclopenta-2,
4-dien-l-yl)

6-Acetyl-2,4-dimethyl-m-
-dioxane

2-(1-Methylheptyl)-4,6-
-dinitrophenyl crotonate

2-(sec-Butyl)-4,6-dinitrophenol

s,s'-p-Dioxane-2,3-diyl O,
0-diethyl phosphorodithioate
(cis and trans isomers)

2-Diphenylacetyl-l,3-inda-
ndione
                             XX-11

-------
                   SECTION XX—APPENDIX 2
           LIST OF PESTICIDE ACTIVE INGREDIENTS
         Common Name
     Chemical Name
102.  Diphenamid (Enide)


103.  Diphenylamine (DFA)

104.  Diaulfoton (Di-Syston)


105.  Diuron (DCMU)


106.  Dodine (Carpene)

107.  (Dowicil   75)


108.  Endosulfan*
109.  Endothall (Endothal)
110.  Endrin*
111.  EPN


112.  EPTC (Eptam)

113.  Ethalfluralin (Sonalan)



114.  Ethion


115.  Ethoprop  (Mocap)
N,N-Dimethyl-2,2-diphenyl-
acetamide

Diphenylamine

0,0-Diethyl S-[2-(ethylthio)-
ethly] phosphorodithioate

3-(3,4-Dichlorophenyl)-1-di-
methylurea

n-Dodecylguanidine acetate

1-(3-Chlorallyl)-3,5,7-
triaza-1-azonia-ad mentane

6,7,8,9,10,10-Hexachloro-1,5,5a,
6,9,9a-Hexahydro-6,9-methano-
2,4,3-Benzo[e]-dioxathiepin-
3-oxide

7-oxabicyclo(2,2,1)heptane-2,
3-dicarboxylic acid monohydrate

1,2,3,4,10,-Hexachloro-b,
7-epoxy-l,4,4a,5,6,7,8,8a-
-octahydro-exo-1,4-exo-5,
8-dimethanonaphthalene

O-Ethyl O-p-nitrophenyl
phenyl phosphonothioate

S-Ethyldipropylthiocarhamate

N-Ethyl-N-(2-methyl-2-propenyl)
-2,6-dinitro-4-(trifluoromethyl)
aniline

0,0,0',0-Tetraethyl S,S'-methy-
lene bisphosphorodithioate

O-Ethyl S,S,'dipropyl
phosphorodithioate
                          XX-12

-------
                   SECTION XX—APPENDIX 2
           LIST OF PESTICIDE ACTIVE INGREDIENTS
         Common Name
     Chemical Name
116.   Ethoxyquin 66%



117.   Ethoxyquin 86%



118.   Ethylene dibromide (EDB)

119.   Etridiazole (Terrazole)
120.   EXD (Bisethylxanthogen)
      (Herbisan)

121.   Famphur (Warbex)
122.   Fenarimol
123.   Fenitrothion (Sumithion)
124.   Fensulfothion
      (Dasanit)

125.   Fenthion (Baytex)
126.   Fentin hydroxide
      (Du-Ter)

127.   Fenuron

128.   Fenuron-TCA


129.   Ferbam (Fermate)

130.   Fluchloralin (Basalin)
1, 2-Dihydro-6-ethoxy-2,2,4
trimethyl quinoline
60-66%

1,2-Dihydro-6-ethoxy-2,2,4
trimethyl quinoline
80-86%

1,2-Dibromoethane

5-Ethoxy-3-trichloromethyl-
1,2,4-thiadiazole

Diethyl dithiobis(thionoformate)
O-[p(Dimethylsulfamoyl)phenyl]
O,O-dimethyl phosphorothioate

a-(2-Chlorophenyl)-a-(4-chloro-
phenyl)-5-pyrimidine-methanol

0,0-Dimethyl O-(4-nitro-m-tolyl)
phosphorothioate

O,O-Diethyl O-[p(methylsulfinyl)
phenyl]phosphorothioate

O,O-Dimethyl O-[4-(methyl-thio)-
-m-tolyl] phosphorothioate

Triphenyltin hydroxide
1,l-Dimethyl-3-phenylurea

3-Phenyl-l,1-dimethylurea
trichloroacetate

Ferric dimethyldithiocarbamate

N-Propy1-N-(2-chloroethyl)-a,
a,a-trifluoro-2,6-dinitro-p-
-toluidine
                      XX-13

-------
                   SECTION XX--APPENDIX 2
           LIST OF PESTICIDE ACTIVE INGREDIENTS
         Common Name
     Chemical Name
131.  Fluoridone (EL-171)


132.  Fluometuron (Cotoran)


133.  Fluoroacetamide

134.  Folpet (Phaltan)


135.  Fonofos (Dyfonate)


136.  (Giv-gard)

137.  Glyodin


138.  Glyphosate (Roundup)

139.  2-[(Hydroxymethyl)
      amine]ethanol [HAE]

140.  2-[(Hydroxymethyl)
      amine]-2-methyl propanol
      [HAMP]

141.  Heptachlor*



142.  Hexachlorophene (Nabac)

143.  Hexazinone



144.  HPTMS


145.  (Hyamine 2389)
l-Methyl-3-phenyl-5[3-(trifluor-
omethyl)phenyl]-4-(lH)-pyridinone

1,l-Dimethyl-3-(3-trifluoromethyl
phenyl)urea

Fluoroacetamide

N-Trichloromethylthio)-phthal-
imide

0-Ethyl S-phenyl ethyl-phosphono-
dithioate

Beta-bromo-beta nitrostyrene

2-Heptadecyl-2-imidazoline
acetate

N-(Phosphonomethyl)glycine

2-[(Hydroxymethyl)amine]
ethanol

2-[(Hydroxymethyl)amine]
-2-methyl propanol
1,4,5,6,7,8,8-Heptachloro-3a,4,
7,7a-tetrahydro-4,7-methano-
indene

2-2'-Methylene bis (3,4,6-

3-Cyclohexyl-6-(dimethylamino)
-1-methyl-l,3,5-triazine-2,
4(lH,3H)-dione

S-(2-Hydroxy propyl)
thiomethane Sulfonate

Methyl dodecyl benzyl trimethyl
ammonium chloride, 80% and
Methyl dodecyl xylylene bis(tri-
methyl ammonium chloride)20%
                         XX-14

-------
                   SECTION XX—APPENDIX 2
           LIST OF PESTICIDE ACTIVE INGREDIENTS
         Common Name
     Chemical Name
146.  (Hyamine 3500)


147.  Isopropalin (Paarlan)

148.  (Kathon 886)



149.  Kinoprene


150.  (KN methyl)


151.  (Lethane 384)


152.  (Lindane) BHC-Gamma*
153.  Linuron
      (Afolan,  Lorox)

154.  Malathion
      (Mercaptothion,
      Cythion)

155.  Maleic hydrazide
156.  Mancozeb
      (Dithane M-45)
157.   Maneb (Manzate)
158.   MCPA
159.  MCPA isooctyl ester
n-Alkyl (50% C14,40% C12, 10% C16
dimethyl benzyl ammonia chloride

2,6-Dinitro-N,N-dipropylcumidine

5-Chloro-2-methyl 4-isothiazolin-
-3-one   and   2  methyl   4-
isothiazolin-3-one

Prop-2-ynyl(+)-(£,E)-3,7,11-
-trimethyldodeca-2,4-dienoate

Potassium N-methyl
dithiocarbamate

b-Butoxy-B'thiocyanodiethyl
ether

1,2,3,4,5,6-Hexachlorocyclohexane
gamma isomer

3-(3,4-Dichlorophenyl)-1-methoxy-
-1-methylurea

Diethyl mercaptosuccinate
S-ester with 0,0-dimethyl
phosphorodithioate

1,2-Dihydropyridazine-3,6-di-
one

Coordination product of maneb
containing 16 to 20% Mn and
2.0 to 2.5%  Zn (zinc)
(maneb-manganous ethylene-1,
2-bis-dithiocarbamate)

Manganous ethylene-1,2-bis-
-dithiocarbamate

4-Chloro-2-methylphenoxy
acetic acid

4-Chloro-2-methylphenoxy
isooctly ester
                          XX-15

-------
                   SECTION XX—APPENDIX 2
           LIST OF PESTICIDE ACTIVE INGREDIENTS
         Common Name
     Chemical Name
160.  MCPP
161.   Mephosfolan
      (Cytrolane)
162.   (Merphos) (Folex)

163.   (Metasol DGH)

164.   {Metasol J-26)


165.   Metham (Vapam, SMDC)
166.   Methamidophos
      (Monitor) (Tamaron)

167.   Methiocarb
168.  Methomly (Lannate)
169.  Methoprene (Altosid)
170.  Methoxychlor (Marlate)


171.  Methylbenzethonium
      chloride
      (Hyamine 10X)

172.  Methyl Bromide*
      (Metabrom)

173.  Methylene bisthiocyanate
      (Cytox)

174.  Metribuzin (Sencor)
2-Methyl-4-chlorophenoxy
propionic acid

P,P-Diethyl cyclic propylene
ester of phosphonodithiomido-
-carbonic acid

Tributyl phosphorotrithioite

Dodecylguanidine HC1

N(l Nitroethyl benzyl)
ethylene diamine 25%

Sodium  N-methyldithio
carbamate

O-S-Dimethyl phosophoroamido-
thioate

4-Methylthio-3,5-xylyl methyl-
carbamate

S-Methyl N-[(methylcarbomoyl)-
-oxyjthioacetimidate

Isopropyl (2E,4E)-ll-methoxy-3,
7,ll-trimethyl-l,4-dodecadi-
enoate

2,2-Bis(p-methoxyphenyl)-1,1,1-
-trichloroethane

Benzyldimethyl [2-<2-(p-l,lf3,
3-tetramethyl-butylcresoxy)
-ethoxy>ethyl] ammonium chloride

Bromomethane
Methylene bisthiocyanate
4-Amino-6-tert-butyl-3-(methyl-
thio)-l,2,4ftriazine-5-one
                          XX-16

-------
                   SECTION XX—APPENDIX 2_

           LIST OF PESTICIDE ACTIVE INGREDIENTS
         Common Name
     Chemical Name
175.   Mexacarbate


176.   Mevinphos (Phosdrin)


177.   (MGK 264)


178.   (MGK 326)

179.   Mirex



180.   Molinate (Ordram)


181.   Monocrotophos (Azodrin)


182.   Monuron


183.   Monuron-TCA


184.   Nabam (Dithane D-14)


185.   (Nabonate)


186.   Naled (Dibrom)
4-(Dimethylamino)-3,5-xylyl
methyl carbamate

Methyl 3-hydroxy-alpha-croton-
ate, dimethyl phosphate

N-(2-EthyIhexyl)bicyclo(2,2,1)-
-5-heptene-2,3-dicarboximide

Di-n-propyl isocinchomeronate

Dodecachloro-octahydro-1,3,4-
metheno-2h-cyclobuta[c,d]
pentalene

S-Ethyl hexahydro-lH-azepine-
-1-carbothioate

Dimethyl phosphate of 3-hydroxy-
N-methyl-cis-crotonamide

3-(p-chlorophenyl)-1,1-dimethy-
lurea

3-(p-chlorophenyl)-1,1-dimethy-
lurea trichloroacetate

Disodium ethylene bis(dithio-
carbamate)

Disodium cyanodithio-
imidocarbonate

1,2-Dibromo-2,2-dichloro-
ethyl dimethyl phosphate
187.   1,8-Naphthalic anhydride     1,8-Naphthalic anhydride
188.  Napropamide (Devrionl)
189.   Naptalam
2-(a-Naphthoxy)-N,N-diethy1-
propionamide

N-1-Naphthylphtalamic acid
                          XX-17

-------
                   SECTION XX—APPENDIX  2_

           LIST OF PESTICIDE ACTIVE INGREDIENTS
         Common Name
     Chemical Name
190.   Neburon
191.   (Niacide)
192.   Nitrofen (TOK)
193.  (NMI)
194.  Norfluazon (Evital)
195.  Octhilinone (RH-893)
196.  Oryzalin (Surflan)
197.  Quinomethionate
198.  Oxamyl (Vydate)
199.  Oxydemeton
      (Metasystox-R)

200.  Oxyfluorfen (Goal)
201.  Paraquat
202.  Parathion ethyl
203.  Parathion methyl
l-n-Butyl-3-(3,4-dichloro-
phenyl)-1-methylurea

Manganeous dimethyldithio-
carbamate

2,4-Dichlorophenyl-p-
nitrophenyl ether

2,6,Bis dimthylamine methyl
cyclohexanone

4-Chloro-5-(methylamino)-2-(a,
a,a-trifluoro-m-tolyl)-2H-
-pyridazinone

2-n-Octyl-4-isothiazolin-
-3-one

3,5-Dinitro-N4,N4,dipropyl-
sulfanilamide

6-methyl-2-oxo-l,3-dithiolo-
[4,5b]quinoxaline

Methyl n',n'-diomethyl-N-[(methyl
carbomoyl)oxy]-l thio oxami-
midate

S-[2-(Ethylsufinyl)ethyl-0,0-
-dimethyl phosphorothioate

2-Chloro-l-(3-ethoxy-4-nitro-
phenoxy)-4-(trifluoromethyl)
benzene

l,l'-Dimethyl-4,4'-bipyridalium
ion

0,0-Diethyl-O-p-nitrophenyl
phosphorothioate

0,0-Dimethyl 0-p-nitro-phenyl
phosphorothioate
                      XX-18

-------
                   SECTION XX—APPENDIX 2_

           LIST OF PESTICIDE ACTIVE INGREDIENTS
         Common Name
     Chemical Name
204.  PBED (Busan 77)



205.  (Perthane)  Ethylan


206.  PCNB (Quintozene)

207.  PCP*

208.  PCP salt


209.  Pebulate (Tillman)

210.  Permethrin  (Ambush)
211.   Phenylphenol
      (Dowicide 1)

212.   Phenylphenol sodium salt
      (Dowicide A)

213.   Phorate
      (Thimet)

214.   Phosfolan (Cyolane)
215.   Phosmet (Imidan)
216,  Picloram (Trodon)
217.   Pindone (Pival)
218.   Piperalin (Pipron)
Poly[oxyethylene(dimethylimino)
ethylene(dimethylimino)ethylene
dichloride]

l,l-Dichloro-2,2-bis(p-ethyl-
phenyl) ethane

Pentachloronitrobenzene

2,3,4,5,6-Pentachlorophenol

2,3,4,5,6-Potassium-
pentachlorophenate

S-Propyl butylethylthiocarbamate

m-phenoxybenzyl (j-)-cis,
trans-3-(2,2-dichlorovinyl)-
-2,2-dimethylcyclopropane-
carboxylate

o-Phenylphenol
Sodium o-phenylphenate
0,0-Diethyl S-[(ethylthio)-
-methyl]phosphorodithioate

P,P-Diethyl cyclic ethylene
ester of phosphonodithiomido-
-carbonic acid

0,0-Dimethyl-S-phthalimido-
-methyl phosphorodithioate

4-Amino-3,5,6-trichlor-
-picolinic acid

2-Trimethylacetyl-l,3-
-indandione

3-(2-Methylpiperidino)propyl-
-3,4-dichlorobenzoate
                           XX-19

-------
                   SECTION XX--APPENDIX 2
           LIST OF PESTICIDE ACTIVE INGREDIENTS
         Common Name
     Chemical Name
219.  Piperonyl butoxide
      (Butacide)
220.  (Polyphase antimildew)


221.  Profluralin (Tolban)



222.  Prometon (Pramitol)


223.  Prometryn (Caparol)


224.  Pronamide (Kerb)


225.  Propachlor (Ramrod)

226.  Propanil (Stam)

227.  Propargite (Omite)


228.  Propazine (Milogard)


229.  Propham (IPC)

230.  Propionic acid

231.  Propoxur


232.  Pyrethrins



233.  8 Quinolinol citrate

234.  8 Quinolinol sulfate
a-[2-(Butoxyethoxy-ethoxy]
-4,5-methylenedioxy-2-propyl-
toluene

3-Ido-2 propynyl butyl
carbamate

N-Cyclopropylmethyl-2,6-dinitro
-N-propyl-4-trifluoromethyl-
aniline

2,4-Bis(isopropylamino)-6-
-methoxy-s-triazine

2,4-Bis(isopropylamino)-6-
(methyl-thio)-S-teiazine

3,5-Dichloro-N-(l,l-dimethyl-2-
-propynyl)benzamide

2-Chloro-N-isopropylacetanilide

3,4-Dichloropropionanilide

2-(p-tert-Butylphenoxy)cyclo-
hexyl 2-propynyl sulfite

2-Chloro-4,6-bis(isopropylamino)
-s-triazine

Isopropyl carbanilate

Propanoic acid

o-Isoporpoxyphenyl methyl
carbamate

Standardizes mixture of pyrethrin
I and II  (mixed esters of pyre-
throlone

8-Quinolinol citrate

8-Quinolinol sulfate
                          XX-20

-------
                   SECTION XX—APPENDIX 2^

           LIST OF PESTICIDE ACTIVE INGREDIENTS
         Common Name
     Chemical Name
235.   Resmethrin
236.  RH 787 (Vacor)
237.  Ronnel (Fenchlorphos)
238.  Rotenone
239.    Siduron  (Tupersan)
240.   Silvex (Fenoprop)
241.   Silvex isooctyl ester
242.  Silvex salt
243.  Simazine (Princep)
244.  Simetryne (Gybon)
245.  Sodium monofluoroacetate

246.  Stirofos
      (Tetrachlorvinphos)

247.  Sulfallate (CDEC)
248.  Sulfoxide
(5-Benzyl-3-furyl)methyl-2,2
-dimethyl-3-(2-methyl propenyl)
cyclopropane carboxylate
(approximately 70% trans,
30% Cis isomers)

N-3-Pyridylmethyl N'-nitro-
phenyl urea

0,0-Dimethyl 0-(2,4,5-trichloro-
pnenyl)phosphorothioate

l,2,12,12a, Tetrahydro-2-isopro-
penyl-8,9-dimethoxy-[1]benzo-
pyrano [3,4-b] furo [2f3-b] [1]
benzopyran

1-(2-Methylcyclohexyl)-3-
phenylurea

2-(2,4,5-Trichlorophenoxy)
propionic acid

Isooctyl ester of 2-(2,4
5-trichlorophenoxy)propionic acid

Dimethyl amine salt of
2-(2,4,5-trichlorophenoxy)
propinoic acid

2-Chloro-4,5,6-bis(ethyl-amino)
-s-triazine

2-Methylthio-4,6-bis-ethylamino
-s-triazine

Sodium monofluoroacetate

2-Chloro-l-(2,4,5-t richlorophenyl
vinyl dimethyl phosphate

2-Chloroallydiethyldithio-
carbamate

1,methyl-2-(3,4-methylene-
dioxyphenyl)ethyl octyl sulfoxide
                            XX-21

-------
                   SECTION XX—APPENDIX 2
           LIST OF PESTICIDE ACTIVE INGREDIENTS
         Common Name
     Chemical Name
249.   Swep


250.   2,4,5-T

251.   TCMTB


252.   Tebuthiuron


253.   Temephos (Abate)



254.   Terbacil (Sinbar)


255.   Terbufos (Counter)
256.   Terbuthylazine
      (GS 13529)

257.   Terbutryn (Igran)
258.  Thiabendazole (Mertect)

259.  Thiofanox
      (DS-15647)
260.  Thionazine (Nemafos)
261.  (Tokuthion)  (NTN 8629)
      Prothiofos

262.  Toxaphene (Camphechlor)*
Methyl N-(3,4-dichlorophenyl)
carbamate

2,4,5-Trichlorophenoxyacetic acid

2-[Thiocyanomethythio]
benzothiazole

l-(5-tert-Butyl-l,2,4-thia-diazol
-2-yl)-l,3-dimethylurea

0,0-Dimethyl phosphorothioate
0,0-diester with 4,4'-thio-
diphenol

3(tert-Butyl)-5-chlor-6-methyl
uracil

5-tert-Butylthiomethyl 0,0-
dimethyl
phosphorodithioate

2-tert-Butylamino-4-chloro
-6-ethylamino-l,3,5-triazine

2-(tert-Butylamino)-4-
-(ethyl-amino)-6-(methylthio)
-s-triazine

2-(4'-Thiazolyl) benzimidazole

3,3-Dimethy1-1-(methylthio)
-2-butamone 0-[(methylamino)
-carbonyl] oxine

0,0-Diethyl 2-pyrazinyl
phosphorothioate

0,-2,4-Dichlorophenol-O-ethyl-
s-propyl phosphorodithioate

A mixture of chlorinated
camphene compounds of uncertain
identity (combined chlorine
67-69%)
                      XX-22

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                   SECTION XX—APPENDIX 2
           LIST OF PESTICIDE ACTIVE INGREDIENTS
         Common Name
     Chemical Name
263.  Triadimefon (Bayleton)



264.  Tributyltin benzoate

265.  Tributyltin fluoride

266.  Tributyltin oxide

267.  Trichlorobenzene (TCB)*

268.  Trichloronate


269.  Tricyclazole


270.  Trifluralin (Treflan)


271.  (Vancide TH)


272.  (Vancide 51Z)



273.  (Vancide 51Z dispersion)



274.  (Vancide PA)


275.  Vernolate (Vernam)


276.  Warfarin
277.   [ZAC]  (zinc ammonium
      carbonate)
l-(4-Chlorophenoxy)-3,3-
-dimethyl-l-(l,2,4-triazol-l-yl)
buton-2-one

Tributyltin benzoate

Tributytin fluoride

Bis(tri-n-butyltin) oxide

1, 2,4-Trichlorobenzene

0-ethyl 0-(2,4,5-trichloro-
phenyl)ethylphosphorothioate

5-Methyl-l,2,4-triazolo
[3A-b] Benzothiazole

a,a,a-Trifluoro-2,6-dinintro-
-N, N-Dipropyl-p-toluidine

Hexahydro-1,3,5-triethyl-s-
-triazine

Zinc dimethyldithiocarbamate
and Zinc 2-mercaptobenzo-
thiazole

50% Zinc dimethylydithiocarbamate
and Zinc 2-mercaptobenzothiazole
50% water

0-ethyl 0-(2,4,5-trichloro-
phenyl)ethylphosphorothioate

S-Propyl N,N-dipropylthio-
carbamate

4-hydroxy-3-(3-oxo-l-phenyl-
butyl)coumarin

Ammoniates of  [ethylenebis
(dithiocarbamate)]-zinc
                         XX-23

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                    SECTION XX—APPENDIX 2
            LIST OF PESTICIDE ACTIVE INGREDIENTS
          Common Name                    Chemical Name

 278.  Zineb                        Zinc ethylenebisdithiocarbamate
 279.  Ziram (Vancide MZ-96)        Zinc dimethyldithiocarbamate

Under the column titles common name (  )  = trade name
Under the column titled common name [  ]  = contractor abbreviation for
pesticides that have no common name and  an extensive chemical name.
*Pesticide active ingredients which are  also priority pollutants.
                            XX-24

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                          SECTION XX—APPENDIX 3
                   BPT EFFLUENT LIMITATIONS GUIDELINES
The following pesticides were excluded from BPT regulations according to
the April 25, 1978 Federal Register;

     Allethrin                            Naphthalene acetic acid
     Benzyl benzoate                      1,8-Napthalic anhydride
     Biphenyl                             Phenylphenol
     Bisethylxanthogen*                   Pipercnyl butoxide
     Chlorophacinone                      Propargite
     Ooumafuryl                           Cu inane thicnate
     Dimethyl phthalate                   Hesmethrin
     Diphacincne                          Rotencne
     Ehdothall acid                       Sodium pnenylphenate
     EXD (fferbisan)*                      Sulfoxide
     Gibberellic acid                     Triazine conpounds (both
     Glyphosate                             symmetrical and asymmetrical)
     Jfethoprene                           Warfarin and similar anticoagulants

     *  Although originally listed as two compounds, it has been determined
        that the two are the same.  EXD is the common name used throughout
        this regulation; bisethylxanthogen is a trade name.
The following pesticides were regulated for the direct discharge to
navigable waters of BOD, COD, TSS, Pesticides, and pH according to the
September 29, 1978 Peder al Register as listed below:

Aldrin                     Dicamba               Msxacarbate
Minocarb                  Dichloran             Mirex
Azinphos methyl            Dicofol               Monurcn
Barban                     Dieldrin              Monurcn-TCA
BHC                        Disulfoton            Neburon
Captan                     Diurcn                Parathicn ethyl
Carbaryl                   Ehdosulfan            Parathicn methyl
Chlordane                  Ehdr in                PCNB
Chlorpropham               Fenuron               Par thane
2,4-D                      Fenurcn-TCA           Rropham
DDD                        tfeptachlor            Propoxur
DDE                        Lindane               Sidurcn
DDT                        Linuron               Silvex
Demeton-O                  Melathicn             SWEP
Dameton-S                  Wethiocarb            2,4,5-T
Diazincn                   Methoxychlor          irifluralin
                                                 Toxaphene
                                    XX-25

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                          SECTION  XX—APPENDIX  3

                   BPT EFFLUENT  LIMITATIONS  GUIDELINES

                         (Continued,  Page  2  of  2)
All other manufactured pesticides  were  regulated  for the direct discharge
to navigable waters of BOD,  COD, TSS, and  pH  according to the September
29, 1978 Federal  Register as listed  below:

                                               Effluent Limitations
                       Effluent            Average  of Daily ValuesDaily
Subcategory*        Characteristic         for  30 Consecutive Days    Maximum

     1                  BOD5                        1.6              7.4
                        COD                         9.0             13.0
                        TSS                         1.8              6.1
                        Pesticide Chemicals          0.0018           0.010
                        pHt

     2                  NO DISCHARGE  OF  PROCESS WASTEWATER POLLUTANTS

     3                  NO DISCHARGE  OF  PROCESS WASTEWATER POLLUTANTS

Note:  All units are kg/kkg

* Subcategory 1:  Organic Pesticide Chemicals  Manufacturing
  Subcategory 2:  Metallo-Orgam'c Pesticide  Chemicals Manufacturing
  Subcategory 3:  Pesticide Chemicals Formulating  and Packaging

t The pH shall be between the values  of  6.0  to 9.0
                                XX-26

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                        SECTION XX - APPENDIX 4
CONVERSION TABLE
Multiply (English Units) By To Obtain (Metric Units)
English Unit Abbreviation Conversion Abbreviation Metric Unit
acre
acre-feet
British Thermal
Unit
British Thermal
Unit/pound
cubic feet
per minute
cubic feet
per second
cubic feet
cubic feet
cubic inches
degree Fahrenheit
feet
gallon
gallon per
minute
ac
ac ft
BTU
BTU/lb
cfm
cfs
cu ft
cu ft
cu in
op
ft
gal
gpni
0.405
1233.5
0.252
0.555
0.028
1.7
0.028
28.32
16.39
0.555(°F-32)*
0.3048
3.785
0.0631
ha hectares
cu m cubic meters
kg cal kilogram-
calories
kg cal/kg kilogram
calories
per kilo-
gram.
cu m/min cubic meters
per minute
cu m/min cubic meters
per minute
cu m cubic meters
1 liters
cu cm cubic centi-
meter
°C degree
Centigrade
m meters
1 liter
I/sec liters per
second
gallon per ton
gal/ton
4.173
liters per
  metric ton
*  Actual conversion, not a multiplier
                                XX-27

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             SECTION XX - APPENDIX 4 (Continued,  Page 2 of 2)
CONVERSION TABLE
Multiply (English
Enqlish Unit
horsepower
inches
pounds per
square inch
million gallons
per day
pounds per square
inch (gauge)
pounds
pounds
ton
mile
square feet
Units)
Abbreviation
hp
in
psi
M3D
psi
Ib
Ib
ton
mi
ft2
By To Obtain (Metric Units)
Conversion
0.7457
2.54
0.06803
3.7 x 10-3
(0.06805 psi
+ 1 TM)
0.454
454,000
0.907
1.609
0.0929
Abbreviation
kw
cm
atra
cu m/day
atm
kg
mg
kkg
km
m2
Metric Unit
kilowatts
centimeters
atmosphere
(absolute)
cubic meters
per day
atmospheres
kilograms
milligrams
metric ton
kilometer
square meters
*  Actual conversion, not a multiplier.
                                  XX-28

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        Section XX-APPENDIX 5
                          FORM APPROVED
                          OMB No.2040-0041
                          EXPIRES June 30, 1984
            QUESTIONNAIRE

  FORMULATING/PACKAGING SEGMENT OF
  THE PESTICIDE CHEMICALS INDUSTRY
U.S. ENVIRONMENTAL PROTECTION AGENCY
                 XX-29

-------
                                 INTRODUCTION

     The Environmental Protection Agency 1s conducting this survey 1n support
of rulemaking to control pollutants 1n wastewaters discharged by pesticide
chemicals formulator/packagers (PFP), one segment of the pesticide chemicals
Industry.  The objective of the questionnaire 1s to obtain Information on
current PFP plant operations and on wastewater control and treatment practices.

     Facilities covered by this survey are those classified as agricultural
and/or household pest control chemicals formulator/blendor/repackagers
under the Federal Insecticide, Fungicide, and Rodentldde Act (FIFRA) that
currently discharge wastewater to Publicly Owned Treatment Works (POTWs).
These plants formulate and/or package pesticide active Ingredients and may,
1n the process, generate wastewater contaminated by priority, conventional,
and/or nonconventlonal pollutants.  More specifically, these plants physically
mix technical grade pesticide Ingredients Into liquids, dusts and powders, or
granules and then package these products Into marketable containers.

     All pesticide manufacturers are required under FIFRA to register their
products with the EPA Office of Pesticides and Toxic Substances.  The Effluent
Guidelines Division used this registration information to Identify your plant
as a formulator/packager, and it used a telephone survey to Identify your
plant as an indirect discharger.  The information obtained from the PFP survey
will be analyzed in addition to the FIFRA production data in order to promulgate
effluent guidelines for pesticide formulator/packagers that are Indirect
dischargers.

     This questionnaire is organized Into six parts:  (1) General Informa-
tion; (2) Plant Characteristics; (3) Plant Personnel; (4) Plant Operations:
Formulating/Packaging Production; (5) Wastewater Generation/Characteristics;
(6) Wastewater Treatment/Control Technology.  Definitions of terms used 1n
the questionnaire are given at the back of the document.  To aid the respondent,
Instructions have been incorporated Into the questionnaire.  Space has been
provided so that responses may be given directly on the questionnaire.
Additional  sheets should be attached if more space is needed.

     In parts II through VI of the questionnaire, pesticide formulation/
packaging (PFP) operations refer exclusively to operations for the formulation
and/or packaging of agricultural  and/or household pesticide control chemicals
such as insecticides, fungicides and herbicides from technical grade chemicals
or concentrates.

-------
                                                        QUESTIONNAIRE
                                                        PESTICIDE
                                                        FORMULATING/PACKAGING

                            QUESTIONNAIRE CONTENTS

                                                                         Page

PART I.       GENERAL INFORMATION                                          1

PART II.      PLANT CHARACTERISTICS                                        2

PART III.     PLANT PERSONNEL                                              3

PART IV.      PLANT OPERATIONS:  FORMULATING/PACKAGING PRODUCTION          3

PART V.       WASTEWATER GENERATION/CHARACTERISTICS                        5

PART VI.      WASTEWATER TREATMENT/CONTROL TECHNOLOGY                      7

DEFINITIONS OF TERMS USED IN QUESTIONNAIRE                                11

APPENDIX A

PART I.  GENERAL INFORMATION

     The Information requested 1n this section is necessary to Identify the
plant and to determine whether the plant 1s conducting activities relevant to
this survey.

1.  Name and Address of Plant  	

    Street 	

    City	  State	Zip Code	

2.  Plant Contact:   Name
                    Title
                    Telephone
3.  Respondent (1f different from above):

                    Name	

                    Title 	

                    Telephone 	
                               XX-33

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                                            Company Name

PART I.  Continued                          Plant Name
4.  In 1982, did you formulate and/or package nonagrlcultural  pest control
    chemicals such as disinfectants and sanltlzers. Inorganics and surface
    active agents?  (Do not Include these products as PFP products 1n the
    remaining parts of this questionnaire.  See note at top of page 3).
    (See below for definitions of formulating and packaging)

    Yes                      No
5.  In 1982,  was this plant engaged In pesticide formulating and/or packaging
    (PFP) of agricultural or household pest control  chemicals such as
    Insecticides, fungicides and herbicides from technical  grade chemicals
    or concentrates?  (See below for definitions of  formulating.and packaging)

    Yes                  No
    If NO, please stop here and return the questionnaire.

    If YES, proceed with the following questions.


6.  In 1982, did this plant discharge water or any other liquid to a waste
    treatment facility not owned by the plant?       Yes           No

    If NO, please stop here and return the questionnaire.

    If YES, proceed with the following questions.


Pest1c1de Packaglng;  The transfer and packaging of formulated products Into
a marketabiecontainer.

Pesticide Formulating;  The physical  processing of pesticide active Ingredients
Into wettable powders, granules, and emulslflable  concentrates.
                                    xx-3 2

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PLEASE NOTE;

    In Parts II through VI , pesticide formulating/packaging (PFP)  operations
    refer exclusively to operations for the formulation and/or packaging  of
    agricultural and/or household pest control  chemicals such as  Insecticides,
    fungicides and herbicides from technical  grade chemicals or concentrates.

PART II.  PLANT CHARACTERISTICS

     This section requests data that will  be  used 1n determining  the costs
and economic ach1evabH1ty of effluent regulations.

1.  Area (square feet) of the buildings on the site:

    a.  Total plant area: 	
    b.  Total plant area used anytime 1n 1982 for pesticide
        formulat1ng/packag1ng:	
    c.  Percent of area 1n l.b. used exclusively for pesticide
        formulat1ng/packag1ng:	
 2.* Investment costs for pesticide formulating/packaging
     operations only:

    See Definitions for "bookvalue" and "Investment cost."

                                                    Building        Equipment

    a.  Total  1982 book value net of                 	        	
        depreciation:

    b.  Total  Investment for 1978-1982:             	        	

3.* 1982 operating and maintenance costs (labor,
    raw material, and energy) for the PFP
    operations at the plant:  	
4.* 1982 Interest and depreciation costs and other general
    administrative and overhead costs for PFP operations at
    the plant:  	
5.* a.  Capital  cost of plant facilities used for treatment of
        process  wastewater associated with PFP operations:
    b.  Year Investment made:
  If the cost or an estimate of the cost  1s  not available,  provide an estimated
  cost 1n proportion to the pounds of formulated PFP products and Indicate
  that your answer 1s an estimate by an "E"  after the value.
                                   XX-3 3

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                                            Company Name

                                            Plant  Name
PART III.  PLANT PERSONNEL (1982)

     Employment data will  be used to determine  the  degree  to which the  plant
1s dedicated to PFP operations and the Impact of effluent  regulations on
plant personnel.

1.  Indicate the number of weeks 1n 1982 during which  the  plant  formulated/
    packaged pesticide products: 	
2.  Provide the number of employees for the  pay period  which  Includes  the  12th
    day of the designated months 1n 1982 and the total  hours  worked  for 1982.

Activity
a. Production: Formulating/
packaging pesticide products
Production: Other production
b. Nonproductlon
Number of Employ
Mar.



May



Aug.



rees*
Nov.



Estimated Total
Hours Worked 1982



*An employee who worked 1n production of PFP products  and 1n other production
 during the pay period which Includes March 12 would be  counted  1n both
 categories.

 Nonproductlon employees Include supervisory,-clerical and other support
 personnel.
                            XX-34

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                                           Company Name

PART IV. PLANT OPERATIONS:                 Plant Name
         FORMULATING/PACKING
         >RODUCTION (1982)

     This part requests Information on total  plant production  and  on  each
different pesticide product.  EPA will use the Information obtained from this
part together with the production data provided by your plant  under FIFRA
1n conducting the necessary economic and engineering analyses  of this segment
of the Industry.

1.  Percentage of total plant production (weight 1n pounds) attributable
    to PFP operations 1n 1982: 	
2.  Percentage of active Ingredient used 1n PFP operations  that  was  produced
    at the plant 1n 1982: 	
3.  Total  market value (dollars)  of pesticide products  formulated  or  packaged
    at this plant 1n 1982: 	
4.  Total  market value (dollars)  of all  plant*production:
5.  Provide the following Information on Table IV.5 for each different  pesticide
    product formulated/packaged (PFP) during 1982.   To group products,  see
    Appendix A.

    a.  FIFRA product number or Group Code for PFP  products.

    b.  Number of production days.   If a Group Code is used then the number
        of production days is the number of days in 1982 on which at least
        one of the products was produced.  For example, if three products
        from Group Code A were produced on July 14, 1982, this counts as
        one production day.

    c.  Type of formulation Base (D « dry formulation, S « solvent formulation,
        U * water formulation)

    d.  Total  market  value of processed (PFP)  product  (dollars)

    e.  Common names  of each pesticide active  ingredient contained in formu-
        lation

    f.  Name of solvents used (if none, write  none)

    g.  Quantity (gals) of solvents used (if none,  write none).

    If additional  space is needed,  make additional  copies of the table  before
    entering data.
                               XX-35

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     PART IV. Continued
     5.  Formulating/Packaging Production (1982)
Company Name



Plant Name
x
x
i
FIFRA
Pesticide
Product
Number*or
Group Code









Number of
Production
Days









Type of
Formulation
Base









Total
Value of
Processed
Product
(dollars)









Names of
Active Ingredients









Solvents Used
Name









Quantity
(gals.)









     *  Number assigned under Federal Insecticide, Fungicide, and Rodentlclde Act (FIFRA).

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                                            Company Name

                                            Plant Name
 PART V.  WASTEWATER GENERATION/
         CHARACTERISTICS  (19B?T

     The data requested 1n this section will be used to determine the source
 and amount of wastewater  generated by PFP operations.  This Information 1s
 Important 1n analyzing the existing treatment/control technology.  If the
 Information 1s not available or estimated for PFP operations, provide an
 estimate based on your answer to questions IV.1 and the plant totals.  Indicate
 these estimates by an "E" following the estimate.
1.  Pesticide Process Wastewater:
  Flow per typical
operating day (gals.)
Total annual
flow (gals.)
a.  Chemical Processing  (solvent
    water, wash water)

b.  Vessel or floor washdown of
    formulating/packaging area

c.  Vent scrubbers for the
    formulating/packaging area

d.  Runoff from the formulating/
    packaging area

e.  Laboratory wastewater

f.  Other (specify) 	
2.Non-contact Wastewater:
  Flow per typical
operating day (gals.)
Total annual
flow (gals.)
a.  Cooling water

b.  Boiler blowdown

c.  Stormwater runoff (not contami
    nated by pesticide contact)

d.  Toilet sewage

e.  Other (specify) 	
3.  Potentially Contaminated
    Wastewater
  Flow per typical
operating day (gals.)
Total annual
flow (gals.)
a.  Laundry

b.  Shower/lavatory

c.  Other (specify)
                                    X-3 7

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                                            Company Name

                                            Plant Name
PART VI.  WASTEWATER TREATMENT/
          CONTROL TECHNOLOGY (T982)

     The Information requested 1n this  section will  be used to conduct
technical and economic analyses pertinent to recommended treatment.

1.  What is the total  plant process  (contact) wastewater generated,
    including wastewater generated in PFP operations, during 1982?

                                        	gals
    Provide the following Information regarding the disposal  of process
    (contact) wastewater generated during 1982 as a consequence of the
    formulating/packaging of the products listed in Table IV-.5.  Use the
    attached Table VI.2:

    a.  Pesticide product:  Use the same combinations of products used
        to answer Part IV.5.

    b.  Wastewater flow on a typical  operating day (gals.).  If not
        available or estimated for PFP operations, provide an estimate
        based on your answer to questions IV.I and the plant  totals.
        Indicate these estimates by an "E" following the estimate.

    c.  Total annual wastewater flow (gals.)

    d.  A list of all treatment or control units employed in  the disposal of
        wastewater (in order of use)

        Use the following abbreviations, as necessary:

        AC - Activated Carbon Adsorption
        AL - Aerated Lagoon
        BO - Biological Oxidation
        CH - Contract Hauling
        CO - Chemical Oxidation
        DW - Deep Well Injection
        EQ - Equalization
        EV - Evaporation
        SS - Gravity Separation
        HD - Hydrolysis
        IN - Incineration
        LA - Land Application
        MF - Multimedia Filtration
        MS - Metals Separation
        NE - Neutralization
        RA - Resin Adsorption
        RR - Recycle/Reuse
        SS - Steam Stripping
        TF - Trickling Filter System

    e.  If no treatment/control units are used, write NONE.


                                XX-38

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      PART VI.  Continued
      2.   Wastewater generation, treatment, and control (1982)
Company Name

Plant Name
 i
U)
VO
FIFRA Pesticide
Product Number or Group Code










Mastewater Discharge Flow (gals.)
Typical Day










Annually








i

Mastewater Treatment /Control
Treatment /Control Units (In order)











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      PART VI.   Continued
Company Name

Plant Mane
                                                                                    Year  for which
                                                                                    data  are provided
      3.   Complete the following table for samples collected  for  any  chemical  analyses  of treated or  pretreated
          effluent during 1982.   If data  are unavailable  for  1982,  provide the most  recent  Information available,
          Use  additional  copies  of this sheet as necessary.
x
x
i-
IDENTIFY EFFLUENT
STREAM*




NUMBER OF
SAMPLES




TYPE OF
SAMPLE**




CONSTITUENTS




















AVERAGE
CONCENTRATION
(mg/1 )




















DISSOLVED
OR TOTAL
(CIRCLE ONE)
D T
D T
D T
D T
D T
D T
D T
D T
D T
D T
D T
D T
D T
D T
D T
D T
D T
D T
D T
D T
ANALYTICAL
METHOD***




















          * By treatment/control  unit, by FIFRA Product  Number  or  by  Product  Group  Code
         ** Grab or composite.
        *** Standard methods, EPA, ASTM,  or  other  (specify).

-------
                                            Company Name

PART VI.  Continued                         Plant Name
4.  a.  Specify the 1982 cost of operating and maintaining plant
        facilities used for treatment of process wastewater associated
        with PFP processes: 	
    b.  Specify the 1982 cost of off-site disposal  of PFP process
        wastewater:
5.  a.  Specify the amount (Ibs. or tons) of hazardous waste generated
        during 1982 for PFP operations (answer even 1f plant Is
        exempt from regulation as a small generator):	•_	
    b.  Specify 1n Table VI.5 the location and method of hazardous waste disposal
        and Indirect treatment or disposal method(s) practiced (answer even 1f
        small  generator):

6.  If the pretreatment standard of zero discharge were Imposed please list all
    the options available to your plant to comply (e.g. contract haul, Incineration
    evaporation, etc.)
                                xx-41

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          PART VI.   Continued
                                                                             Company Hi


                                                                             Plant Naae
          5.     Hazardous Waste Disposal
                                                 Pounds Disposed In 1982

Method
Direct discharge to navigable
waterway.
Municipal waste treatment
facility of POTW.
No-discharge Incineration.
No-discharge evaporation.
Land Disposal
Other (specify)
If methods unknown, please
provide name and address
of contract hauler.
/
Location / Operator
On Site







Off Site







Self







Contract







X
X
 I

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                  DEFINITIONS OF TERMS USED IN QUESTIONNAIRE
Bookvalue Net of Depreciation - Total Investment cost minus depreciation.

Conventional Pollutants — For the Pesticide Industry conventional pollutants
are defined as BOD, TSS, and pH.

Investment Cost - For a property 1s the amount paid either directly or 1n-k1nd
at the time of the transaction.

Noncontact Wastewater - Wastewater which 1s not contaminated by pesticide
active Ingredients or solvents.  Stormwater from outside the formulating and
packaging areas 1s Included 1n this definition 1f 1t 1s not contaminated from
product spills, etc.

Nonconventlonal Pollutants — For the Pesticide Industry nonconventlonal
pollutants are defined as nonprlorlty pollutant pesticides, COD, ammonia,
and manganese.

Pesticide Formulating - The physical processing of pesticide active Ingredients
Into wettable powders, granules, and emulsifiable concentrates.

Pesticide Packaging - The transfer and/or packaging of formulated products Into
a marketable container.

POTW - Publicly Owned Treatment Works

Priority Pollutant — Those 126 compounds specified as an outgrowth of the
1976 Consent Decree.

Process Wastewater - Any aqueous discharge which results from contact with
pesticide active Ingredients or solvents, including:

     1.  Reaction wastewater or dilution water used directly 1n the process.

     2.  Wastewater from vessel or floor washdown in the Immediate formu-
         lating/packaging area.

     3.  Runoff from the formulating/packaging areas, and other areas
         where pesticide contamination occurs.

     4.  Wastewater from pollution control  devices, such as vent scrubbers in
         the immediate formulating/packaging area.

Zero Discharge - No discharge of PFP process (contact) wastewater (no flow).
                                  XX-43

-------
                                  APPENDIX A
                               Product Grouping
Products may be combined Into groups  1f all  of the  following  criteria are
met:
     1.  All products contain the same active 1ngred1ents(s).
    11.  If solvents are used, products contain  the same  sol vent(s).
   111.  All products have the same type of formulation base  (dry,  solvent
         or water).
    1v.  All products are formulated  and/or packaged on the same  equipment
         or s1mH1ar equipment that would result 1n the same  volume and
         concentration of waste load  generated per  unit of production.
Label each product group by a group code A,B,C,  etc.  In  each column below,
11st the FIFRA products grouped under each product  code.
                                 GROUP CODES
                                 XX-44

-------
                    SECTION XX- APPENDIX £

       Priority Pollutants Regulated in Organic Pesticide
         Chemicals Manufacturing Wastewaters Subcategory
Column A


Pesticide Active Ingredient

Acephate


Alachlor
    Column B

Priority Pollutant
    Regulated

    Methylene chloride
    Toluene

    1,2-Dichloroethane
    Chlorobenzene
Aldicarb

Alkylamine hydrochloride

Allethrin

Ametryne


Aminocarb

Amobam

Anilazine


AOP
    Cyanide
    Toluene
    1,2-Dichloroethane
    Cyanide
Aquatreat DNM 30

Aspon

Atrazine
    Toluene

    Cyanide
    Carbon tetrachloride
    Toluene
Azinphos methyl

Barban


BBTAC
    1,2-Dichloroethane

    Toluene
    1,2-Dichloroethane
                           XX-45

-------
               SECTION XX- APPENDIX 6
   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subcategory
Bendiocarb
Benfluralin
Benomyl
Bensulide

Bentazon

Benzethonium chloride
Benzyl benzoate
Benzyl bromoacetate

BHC
Bifenox

Biphenyl
Bolstar


Bromacil
Bromoxynil

Bromoxynil octanoate

Busan 40
Benzene
Toluene
Carbon tetrachloride
Chlorobenzene
Toluene
Benzene
Toluene
a-BHC-Alpha
b-BHC-Beta
d~BHC-Delta
g-BHC-Gamma
Benzene
Chlorobenzene
Methyl chloride
2,4-Dichlorophenol
Phenol
Benzene
Toluene
2,4-Dichlorophenol
Phenol
Methylene chloride
Benzene
Toluene
Benzene
Toluene
                         XX-46

-------
               SECTION XX- APPENDIX 6

   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subcategory
Busan 85

Busan 90



Butachlor

Butylate

Captafol

Captan
1,2-Dichloroethane
Methylene chloride
Phenol

1,2-Dichloroethane

Methylene chloride

Toluene
Carbam-S

Carbaryl

Carbendazim
Toluene
Carbofuran

Carbophenothion


Chloramben

Chlordane


Chlorobenzene


Chlorobenzilate

Chlorophacinone

Chloropicrin

Chlorothalonil



Chlorpropham
Methylene chloride

Benzene
Chlorobenzene
Hexachlorocyclopentadiene
Heptachlor

Benzene
Chlorobenzene

Cyanide
Tetrachloroethylene
Cyanide
Carbon tetrachloride

1,2-Dichloroethane
Tetrachloroethylene
                              XX-47

-------
               SECTION XX- APPENDIX <>
   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subcategory
Chlorpyrifos
Chlorpyrifos methyl
Coumachlor
Coumafuryl
Coumaphos
Coumatetralyl
Cyanazine

Cycloate
Cycloheximide
Cycloprate
Cyhexatin

Cythioate
2,4-D


2,4-D isobutyl ester
2f4-D isooctyl ester
2,4-D salt
Dalapon
Dazomet
2f4-DB
Methylene chloride
Methylene chloride
Cyanide
Methylene chloride
Methylene chloride
Toluene
Benzene
Toluene
Benzene
Toluene
2,4-Dichlorophenol
Phenol
Toluene (plants 4 and 5 only)
2,4-Dichlorophenol
2,4-Dichlorophenol (plant 6 on
Methylene chloride
2,4-Dichlorophenol
Phenol
                           XX-48

-------
               SECTION XX- APPENDIX 6^

   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subcategory
2f4-DB isobutyl ester

2f4-DB isooctyl ester

DBCP

DCNA
DCPA



D-D

ODD

DDE


DDT

Deet


Demeton

Demeton-o


Demeton-s


Diazinon

Dicamba




Dichlofenthion
Carbon tetrachloride
Benzene
Toluene
Chlorobenzene

Chlorobenzene
Chlorobenzene

Benzene

Benzene
Toluene

Toluene

Toluene
Copper

Copper
Toluene

Toluene

Methyl chloride
2,4-Dichlorophenol
Benzene
Toluene

2,4-Dichlorophenol
Phenol
                          XX-49

-------
               SECTION XX- APPENDIX £

   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subcategory


Dichlorobenzene, ortho                 Chlorobenzene
                                       1,2-Dichlorobenzene

Dichlorobenzene, para                  Chlorobenzene
                                       1,4-Dichlorobenzene

Dichloroethyl ether                    Bis(2-chloroethyl)ether+

+ = Regulated as a priority pollutant only in those processes
in which it is the manufactured product.

Dichlorophen                           Phenol
                                       Toluene

Dichlorophen salt

Dichloropropene                        1,3-Dichloropropene+

+ = Regulated as a priority pollutant only in those processes
in which it is a manufactured product

Dichlorprop                            Phenol
                                       1,4-Dichlorophenol

Dichlorvos                             Methyl chloride

Dicofol                                1,2-Dichloroethane
                                       Chlorobenzene
                                       Toluene
                                       Cyanide

Dienochlor                             Hexachlorocyclopentadiene
                                       Copper
                                       Toluene

Dimethoxane

Dinocap                                2,4-Dinitrophenol
                                       4-Nitrophenol
                                       Phenol

Dinoseb                                Phenol
                                       2,4-Dinitrophenol

Dioxathion                             Benzene

Diphacinone
                        XX-50

-------
               SECTION XX- APPENDIX 6

   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subcategory
Diphenamid

Diphenylamine
Benzene
Disulfoton

Diuron


Dodine

Dowicil 75

Endosulfan
Endothall

Endrin


EPN



EPTC

Ethalfluralin

Ethion




Ethoprop

Ethoxyquin 66%

Ethoxyquin 86%

Ethylene dibromide
Toluene

Chlorobenzene
Carbon tetrachloride

Cyanide
Hexachlorocyclopentadiene
a-Endosulfan-Alpha
b-Endosulfan-beta
Benzene
Toluene
Hexachlorocyclopentadiene
Endrin

4-Nitrophenol
Phenol
Toluene

Methylene chloride
Methylene chloride
Methyl bromide

Toluene
                       XX-51

-------
               SECTION XX- APPENDIX £
   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subcategory
Etridazole
EXD
Famphur

Fenarimol

Fenitrothion

Fensulfothion

Fenthion
Fentin hydroxide

Fenuron
Fenuron-TCA

Ferbam
Fluchloralin
Chloroform
Benzene
Toluene
Chlorobenzene
Toluene
Copper (plant 8 only)
Toluene
Copper
Toluene
Toluene
Chlorobenzene
Phenol
Benzene
Toluene
Fluoridone
Fluometuron
Chloroform
Toluene
Cyanide
Fluoroacetamide
Folpet
Fonofos

Giv-gard
Toluene
Phenol
Toluene
                          XX-52

-------
               SECTION XX- APPENDIX 6
   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subcategory
Glyodin
Glyphosate
HAE
HAMP
Heptachlor

Hexachlorophene

Hexazinone
RPTM8
Hyamine 2389
Hyamine 3500
Isopropalin
Kathon 886
Kinoprene
KN methyl
Lethane 384
Lindane
Linuron

Malathion
Hexachlorocyclopentadiene
Carbon tetrachloride
Heptachlor
1,2-Dichloroethane
Phenol
2,4-Dichlorophenol
Toluene
Toluene
Toluene
Cyanide
a-BHC-Alpha
b-BHC-Beta
d-BHC-Delta
g-BHC-Gamma
Benzene
Chlorobenzene
Chlorobenzene
Carbon tetrachloride
Toluene
                              XX-53

-------
               SECTION XX- APPENDIX £

   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subcategory
Maleic hydrazide

Mancozeb

Maneb

MCPA


MCPA isooctyl ester

MCPP (Mecoprop)


Mephosfolan

Merphos

Metasol DGH

Metasol J-26

Metham

Methamidophos

Methiocarb

Methomy1

Methoprene

Methoxychlor

Methylbenzethonium
  chloride

Methyl bromide

Methylene bisthiocyanate



Metribuzin

Mevinphos

Mexacarbate
Zinc

Zinc (plant 9 only)

Phenol
Toluene
Phenol
Toluene

Toluene
Cyanide
1,2-Dichloroethane



Methylene chloride



Phenol

Toluene


Methyl bromide

Cyanide
Methyl bromide
Methylene chloride

Methyl bromide

Methyl chloride
                          XX-54

-------
               SECTION XX- APPENDIX 6

   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subcategory
MGK 264

MGK 326

Mirex


Molinate

Monocrotophos


Mon

Monuron-TCA


Nabam
Toluene

Benzene

Hexachlorocyclopenta-
Diene

Methylene chloride

Chloroform
Copper
Benzene
Toluene
Nabonate

Naled

1,8-Napthalic anhydride

Napropamide


Naptalam


Neburon


Niacide

Nitrofen
NMI

Norflurazon
Cyanide

Carbon tetrachloride
Toluene
Chlorobenzene

Benzene
Toluene

Carbon tetrachloride
Chlorobenzene
2,4-Dichlorophenol
4-Nitrophenol
Benzene
Toluene

Toluene
                        XX-55

-------
               SECTION XX- APPENDIX 6
   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subcategory
Octhilinone
Oryzalin
Oxamyl
Oxydemeton
Oxyfluorfen
Paraquat
Parathion ethyl

Parathion methyl
PBED
PCNB

PCP

PCP salt

Pebulate

Pendimethalin

Perfluidone
Permethrin
Perthane
Toluene
Toluene
Copper
Tetrachloroethylene
Methyl chloride
4-Nitrophenol
Benzene
Toluene
4-Nitrophenol
Benzene
Toluene

1,2-Dichloroethane
Pentachlorophenol
1,2,4-tr ichlorobenzene
Pentachlorophenol
Phenol
Phenol
Pentachlorophenol
Methylene chloride
Zinc
Benzene
Toluene
                         XX-5fi

-------
               SECTION XX- APPENDIX 6
   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subcategory
Phenylphenol

Phenylphenol sodium salt

Phorate
Phosfolan
Phosmet
Picloram

Pindone
Piperalin

Piperonyl butoxide
Polyphase antimildew
Profluralin

Prometon
Prometryn
Pronamide
Propachlor
Propanil
Propargite
Propazine

Propham
Phenol
Benzene
Chlorobenzene
Phenol
Benzene
Chlorobenzene
Toluene
Benzene
Cyanide
Carbon tetrachloride
Benzene (plant 12 only)
Chlorobenzene
Toluene
Benzene
Toluene
Cyanide
Toluene
Cyanide
Toluene
Toluene
1,2-Dichloroethane
Toluene (plants 14 and 15 only
Cyanide
Carbon tetrachloride  (plant 16
                             XX-57

-------
               SECTION XX- APPENDIX 6
   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subcategory
Propionic acid
Propoxur
Pyrethrins
8 Quinolinol citrate
8 Quinolinol sulfate
Quinomethionate
Resmethrin
RH-787
Ronnel
Rotenone
Siduron
Silvex

Silvex isooctyl ester
Silvex salt
Simazine

Simetryne

Sodium monofluoroacetate
Stirofos
Sulfallate
Sulfoxide
SWEP
Toluene
2,4-Dichlorophenol
Phenol
Toluene
2,4-Dichlorophenol
Phenol
Toluene (plant 17 only)
Cyanide
Carbon tetrachloride (plant 18
Toluene (plant 18 only)
Cyanide
Toluene
Methyl chloride
2,4-Dichlorophenol

Benzene
                                 XX-58

-------
               SECTION XX- APPENDIX 6

   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subeategory
2,4,5-T



TCMTB


Tebuthluron

Temephoa
Phenol
2,4-Dichlorophenol
Toluene (plant 19 only)

Cyanide
Methylene chloride

Toluene

1,2-Dichloroethane (plant 20 o
Toluene (plant 21 only)
Terbacil


Terbufos

ferbuthylazine

Terbutryn


Thiabendazole

Thiofanox
Methylene chloride
Toluene
Cyanide

Cyanide
Toluene

Cyanide
Thionazin

Tokuthion



Toxaphene




Triadimefon

Tributyltin benzoate

Tributyltin fluoride

Tributyltin oxide
1,2-Dichloroethane

Phenol
2,4-Dichlorophenol
Toluene

Carbon tetrachloride
Toxaphene
Benzene (plant 22 only)
Toluene (plant 22 only)

Phenol
                              xx-5 9

-------
               SECTION XX- APPENDIX £

   Priority Pollutants Regulated in Organic Pesticide
     Chemicals Manufacturing Wastewaters Subcategory
Trichlorobenzene



Trichloronate



Tricyclazole


Trifluralin

Vancide TH

Vancide 51Z

Vancide 51Z dispersion

Vancide PA

Vernolate

Warfarin

ZAC

Zineb


Ziram
Benzene
Chlorobenzene
1,2,4-Trichlorobenzene

2,4-Dichlorophenol
Phenol
Toluene

Benzene
Toluene

N-Nitrosodi-n-propylamine
Methylene chloride



Zinc

Zinc


Zinc (plants 23 and 24 only)
                          XX-60

-------
                     SECTION XX- APPENDIX 6

       Priority Pollutants Regulated in Organic Pesticide
           Chemicals Manufacturing Wasters Subcategory


2   Regulated  only  in  those  processes  in  which  it  is  the
manufactured product.

3   Limits apply only for PSESf  NSPS,  and PSNS.  BPT limits are
established by 455.20(b).
                         XX-61

-------
                      Section XX-APPENDIX 7
          Design Criteria for  Recommended Technologies
         Recommended
        Technology

(1)   Pump Station
(2)   Equalization
(3)   Steam Stripping
(4)   Chemical Oxidation
(5)   Metals Separation
(6)   Hydrolysis
                 Design
          Criteria

8 Hours of Service Time
Three Pumps at 50%  of Total Flow Each
Pumping Head=20 ft.
Pump Efficiency=85%
Wet Well Capacity=0.5% of Daily flow

Use at Least Two Basins
Aeration and Mixing=75 HP/MG
Detention Time Alternatives=12 Hours
                  Before pretreatment)
                  24 Hours (Before
                  Biological Treatment)

Reflux ratio-0
Steam-to-feed ratio-0.10
Operating pressure=1.0 at
Henry's Law Contant

Use Two Batch Vessels with 24 HR.
Detention Time
Reaction Time=4 HR.
Caustic Usage=3 Parts/Part CN
Chlorine Usage=3 Parts/Part CN
Operating Range=pH 8.5 to 11.0

Mixing Tank Detection Time=24 HR
Mixing Horshepower=72 HP/MGD
Filter Press Runtime=8 HR
Holding Tank Detention Time=24 HR
Operating pH=9.0
Influent Zinc=245 MG/1:
Caustic Addition=6000 MG/1
Influent Copper=4500 MG/1:
Caustic Addition=110,000 MG/1

Use Two Flow-Through Basins
Basin Length/Width=20/l
Influent T=22°C=72°F
Basin Length/Depth=20/l
Basin T = 40°C=104
Basin pH-11
Detention Time Alternatives
                               XX-62

-------
                             0.28;  2.8;  6.9;  16.7 Days
(7)   Neutralization
(8)   Dual  Media Filtration
(9)   Carbon Adsorption
(10)  Carbon  Regeneration
(11)  Resin Adsorption
(12)  Resin Regeneration
(13)  Nutrient  Addition

(14)  Aeration  Basin


(15)  Clarification




(16)  Incineration
(17)  Sludge  Thickening
6 Min. Detention Time for Mixing Tank
Caustic Addition=100 PPM
Caustic Storage=30 Days

Pumpung Head=20 Ft.
Filter Rate=4 Gal/Min/Ft2
Backwash 2 Filters At One Time
Backwash Rate=20 Gal/Min/Ft2
Backwash Head=30 FT.
Run Length=12 Hours
Backwash Duration=15 Min.

Surface Loading=0.5 GPM/FT2
  (Primary Use)
Surface Loading=4 GPM/FT2
  (Tertiary Use)
Backwash Rate=20 GPM/FT2
Two Columns in Series

Carbon Usage Rate=20 lbs/1,000
gallons

Empty Bed Contact Time=15 Min
Surface Loading=4 GPM/FT2
Use Two Columns in Parallel,
One Column Spare

Regeneration Frequency (Primary)=
Twice Daily
Solvent Loading=0.3 GPM/Ft2
Pump Head=20 FT
Methanol Loss=l% Yearly
Batch Distillation
Reflux Ratio=3/l

Maintain BOD/N/P=100/5/l

Aeration=100 HP/MG
Use Two Basins in Parallel

Overflow Rate=400 GPD/FT2
Depth=12 Ft.
Sludge Return Capacity=200%
Minimum of Two Basins in Parallel

Chlorinated Organics pH Adjustment
For Small Flows with Caustic
Chlorinated Organics pH Adjustment
for Large Flows with Lime
Steam Recovery Included

Surface Loading=0.4 GPM/FT2
Solid Loading=10 LB/FT2/Day
                                XX-63

-------
(18)  Aerobic Digestion
(19)  Vacuum Filtration
Influent=0.5% Solids
Effluent-2.0% Solids

Detention Time*20 Days
Influent=2% Solids
Effluent=3.5% Solids

Ferric Chloride Addition=7% of
Dry Solids Weight
Effluent=15% Solids
                                  XX-64

-------
                        SECTION XX — APPENDIX 8

NONOONVENTIONAL EESTICICE POLLUTANTS ANALYTICAL METHOD AVAILABILITY/STATUS
                                EPA Promulgated                    Under
                                                                  Current
     Pesticide        40 CFR Part 136      40 CFR Part 455       EPA Review
Acephate                     -                                       X
Alachlor                     -                    X                  -
Aldicarb                     -                                       X
Alkylamine hydrochlride      -                                       X
Ametryn                      X                    -
Amobam                       -                                       X
Anilazine                    -                    -
AOP                                               X
Aquatreate E*M 30            -                    -                  X
Aspon                        -                                       X
Atraton                      X                    -
Atrazine                     X                    -
Azinphos methyl              X                    -
Barban                       X                    -                  -
BBTAC                        -                                       X
Bendiocarb                   -                    -                  X
Benfluralin                  -                    X                  -
Bencmyl                      -                    X                  -
Bensulide                    -                                       X
Bentazon                     -                    X                  -
Benzethonium Chloride        -                                       X
Benzyl bronoacetate          -                                       X
Bibenox                      -                                       X
Biphenyl                     -                    -                  X
Bolstar                      -                    X                  -
Bronacil                     -                    X                  -
Bromoxynil                   -                    -                  X
Bronoxynil octanoate         -                                       X
Busan 40                                          X
Busan 85                                          X
Busan 90                                                             X
Butachlor                    -                    X                  -
Butylate                     -                    -                  -


Note:  1.  40 CFR 136 as corrected on January 4, 1985 (50 CFR 691,  695)
       2.  40 CFR 455 promulgated on August 31, 1985.
                                           XX-65

-------
                        SECTION XX — APPENDIX 8

                        (Continued, Page 2 of 9)

NONCONVENTIONAL PESTICIDE POLLUTANTS ANALYTICAL METHOD AVAILABILITY/STATUS
                                EPA Promulgated                    Under
                                                                  Current
     Pesticide        40 CFR Part 136      40 CFR Part 455       EPA Review
Captafol                     -                                       X
Captan                       X                    -                  -
Carbam-S                     -                    X                  -
Carbaryl                     X                    -
Carbendazim                  -                    X                  -
Carbofuran                   -                    X                  -
Carbophenothion              X                    -                  -
CDN                                                                  X
Chloramben                   -                                       X
Chlorobenzilate              -                    X                  -
Chloropicrin                 -                                       X
Chlorothalonil               -                                       X
Chlorpyrifos                 -                    X                  -
Chlorpyrifos methyl          -                    X                  -
Coumaphos                    -                    X                  -
Cyanazine                    -                    X                  -
Cycloate                     -                                       X
Cyclohexixnide                -                                       X
Cycloprate                   -                                       X
Cyhexatin                    -                                       X
Cythioate                    -                                       X
2f4-D                        X                    -
2,4-D isobutyl ester         X                    -                  -
2,4-D isooctyl ester         X                    -
2,4-D salt                   X                    -
Dalapon                      -                    -                  X
Dazcmet                      -                                       X
2,4-DB                       -                    X                  -
2f4-DB isobutyl ester        -                    X                  -
2f4-DB isooctyl ester        -                    X                  -
DBCP                         -                    X                  -
DCPA                         -                                       X
D-D                                                                  X
Deet                         -                    X                  -
Demeton  (as Demeton-0 and    X                    -
  Demeton-S)
Diazinon                    X                    -
Dicarnba                      X                    -                  -
Dichlorfenthion              X                    -
                                              XX-66

-------
                        SECTION XX — APPENDIX 8

                        (Continued, Page  3 of 9)

NONCONVENTIONAL PESTICIDE POLLUTANTS ANALYTICAL METHOD AVAILABILITY/STATUS
     Pesticide
          EPA Promulgated

40 CFR Part 136      40 CFR Part 455
  Lhder
 Current
EPA Iteview
Dichloran
Dichlorophen salt
Dichlorprop
Dichlorvos
Dienochlor
Dimethoxane
Dlnocap
Dinoseb
Dioxathion
Diphacinone
Diphenamid
Disulfoton
Diuron
Dodine
Dowicil 75
Ehdothall
EPN
EPTC
Ethalfluralin
Ethicn
Ethoprop
Ethoxyguin 66%
Ethoxyquin 86%
Ethylene dibromide
Etridiazole
EXD
Fanphur
Fenar drool
Fenitrothion
Fensulfothicn
Fenthion
Fentin hydroxide
Fterbam
Fluchlor aline
Fluor idone
Fluoneturon
Fluroacetamide
Folpet
Fonofos
Giv-gard
       X
       X
                            X
                            X
                                               X
                                               X

                                               X
                                               X
                                               X
                                               X
                                               X
                                               X
                                               X
                                               X
                                               X
                                               X
                                               X
                                               X

                                               X
                                               X
                                               X
                                               X
                                               X
                                               X

                                               X
                                               X
                                               X
                                               X
                                      XX-67

-------
                        SECTION XX — APPENDIX 8

                        (Continued, Bage 4 of 9)

                PESTICIDE POLLUTANTS ANALYTICAL METHOD AVAILABILITY/STATOS
                                EPA Promulgated                    Lhder
                                                                  Current
     Basticide        40 CPR Part 136      40 CFR Part 455       EPA Hsview
Glyodin                      -                                       X
Glyphosate                   -                    X                  -
HAS                          -                                       X
HAMP                         -                                       X
ffexachlorophene              -                                       X
Ffexazincne                   -                    X                  -
HPTMS                        -                                       X
ftyanine 2389                 -                                       X
Hyanine 3500                 -                                       X
isodrin                      X                    -
Isopropalin                  -                    X                  -
Kathcn 886                   -                                       X
Kinoprene                    -                                       X
KN Msthyl                    -                    X                  -
lethane 384                                                          X
Linurcn                      X                    -
Malathicn                    X                    -
Maleic hjdrazide             -                                       X
Mancozeb                     -                    X                  -
Maneb                        -                    X                  -
MCPA                         -                                       X
MCPA isooctyl ester          -                                       X
MCPP                         -                                       X
Msphosfolan                  -                    X                  -
Jferphos                      -                                       X
tetasol DGH                  -                                       X
Wfetasol J-26                 -                                       X
tetham                       -                    X                  -
tethamidc^hos                -                                       X
Btethonyl                     -                    X                  -
ffethoprene                   -                                       X
Jfethoxychlce                 X                    -                  -
^fethylbenzethcniun chloride  -                                       X
Msthylene bisthiocyanate     -                                       X
ftetribuzin                   -                    X                  -
Jtevinphos                    -                    X                  -
MGK 264                                                              X
MGK 326                                                              X
MDlinate                     -                                       X
Mcjnocrotcsphos                -                                       X
                                           XX-68

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                        SECTION XX — APPENDIX 8

                        (Continued, Page 5 of 9)

NCNCONVENTIONAL PESTICIDE POLLUTANTS ANALYTICAL METHOD AVAILABILITY/STATUS
                                EPA Pronulqated                    Uider
                                                                  Current
     Pesticide        40 CFR Part 136      40 CFR Part 455       EPA Review
Nabam                        -                    X                  -
Nabonate                     -                                       X
Naled                        -                    X                  -
Napropamide                  -                    -                  X
Naptalam                     -                                       x
Niacide                      -                    X                  -
Nitrofen                     -                                       x
»1I                                                                  X
Norflurazon                  -                                       x
Octhilinone                  -                                       X
Oryzalin                     -                    -                  X
Oxanyl                       -                    x                  -
Oxyderoton                   -                                       x
OxyfLuocfen                  -                    -                  X
Paraquat                     -                                       x
Parathioi ethyl              X                    -
Parathioi mathyl             X                    -
PBED                         -                                       x
PCNB                         X                    -
PCP salt                     X                    -
Pabulate                     -                                       x
Pwnnethcin                   -                                       x
Phenylphsnol                 -                                       x
Phenylphenol sodium salt     -                                       x
Phorate                      -                    X                  -
Fhosfolan                    -                                       x
Phoanet                      -                    -                  X
Plcloran                     -                                       x
Pindone                      -                    -                  X
Piper al in                    -                    -                  X
Piperonyl butoxide           -                                       x
Polyphase antimildew         -                                       x
ftrofluralin                  -                    X                  -
Prone.tcn                     X                    -
Pronetryn                    X                    -
Prcnamide                    -                                       x
Propachlor                   -                    x                  -
Propanil                     -                    -X
Propargite                   -                                       x
                                     XX-69

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                        SECTION XX — APPENDIX 8

                        (Continued, Page 6 of 9)

NONCONVENTIONAL PESTICIDE POLLUTANTS ANALYTICAL METHOD AVAILABILITY/STATUS
                                EPA Promulgated                    Under
                                                                  Current
     Pesticide        40 CFR Part 136      40 CFR Part 455       EPA Iteview
Propazine                    X                    -
Propionic acid               -                                       X
Pyrethrins                   -                                       X
8 Quinolinol citrate         -                                       X
8 Quinolinol sulfate         -                                       X
Reamethrin                   -                                       X
RH 787                       -                    -                  X
Ronnel                       -                    X                  -
Rotenone                     -                                       X
Secbumetcn                   X                    -                  -
Siduron                      X                    -                  -
Silvex (2,4,5-TP: silvex)    X                    -
Silvex iscoctyl ester        X                    -
Silvex salt                  X                    -
Simazine                     X                    -
Simetryne                    -                    X                  -
Sodium mcnofluroacetate      -                    -                  X
Striofos                     -                    X                  -
Strcbane                     X                    -
Sulfallate                   -                                       X
2,4,5-T                      X                    -
TCMTB                        -                                       X
Tebuthiuron                  -                                       X
Tanephos                     -                                       X
Terbacil                     -                    X                  -
Terbufos                     -                    X                  -
Terbuthylazine               X                    -                  -
Terbutryn                    -                    X                  -
Thiabendazole                -                                       X
Thiofanox                    -                                       X
Thionazin                    -                    -                  X
Tbkuthicn                    -                                       X
Triadiroefcn                  -                    X                  -
Tributyltin benzoate*        -                                       X
Tributyltin fluoride*        -                                       X
Tributyltin oxide*           -                                       X
Trichlcronate                -                    X                  -
Tricyclazole                 -                    X                  -
Trifluralin                  X                    -
                                          XX-70

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                         SECTION XX—APPENDIX 8

                        (Continued, Page 7 of 9)

NONOONVENTIONAL PESTICIDE POLLUTANTS ANALYTICAL METHOD AVAILABILITY/STATUS
                                EPA Promulgated                    Uhder
                                                                  Current
     Pesticide        40 CFR Part 136      40 CFR Part 455       EPA Review
Vancide PA                                                           X
Vancide TH                                                           X
Vancide 51Z**                -                                       X
Vancide 51Z dispersion**     -                                       X
Vernolate                    -                                       X
ZAC                                               X
Zineb                        -                    X                  -
Ziram                        -                    X                  -
                                                 XX-71

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                         SECTION XX—APPENDIX 8

                        (Continued, Page 8 of 9)

NONOONVENTTCNAL PESTICIDE POLLUTANTS ANALYTICAL METHOD AVAILABILITY/STATUS
                                EPA Promulgated                    tnder
                                                                  Current
     Pesticide        40 CFR Part 136      40 CFR Part 455       EPA Review
Pesticides Previously Regulated But Currently Not Manufactured

Aminocarb                    X
Chlorjropham                 X
Danetcn-o                    X
Dsneton-s                    X
Dicofol                      X
Ebnuron                      X
Ftenurcn-TCA                  X
Mathiocarb                   X
MBxacarbate                  X
Mirex                        X
Monuron                      X
Monuron-TCA                  X
Neburcn                      X
Perthane                     X
Propham                      X
Propoxur                     X
Swep                         X
                                    XX-72

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                         SECTION XX — APPENDIX 8

                         (Continued, Page 9 of 9)

 NCNCENVENTIONAL PESTICIDE POLLUTANTS ANALYTICAL METHOD AVAILABILITY/STATUS
                                 EPA Promulgated                    tader
                                                                   Current
      Pesticide        40 CFR Part 136      40 CPR Part 455       EPA teview
 Pesticides Excluded frcrn BPT and Currently Not Manufactured

 Alletrin                     -                                       X
 Benzyl benzoate              -                                       X
 Chlorophacinone              -                    -                  X
 Counachlcr                   -                                       X
 Coumafuryl                   -                                       X
 Counatetralyul               -                                       X
 1,8-Naphthalic anhydride     -                                       X
 Quincmethicnate              -                                       X
 Sulfoxide                    -                                       X
 Warfarin                     -                                       X

 Total Number of Pesticides   59                   61                148
 *  Pesticides may be monitored by analysis for Tin using analytical
    methods promulgated at 40 CFR Part 136.

**  Pesticides may be monitored by analysis for Zinc using analytical
    methods promulgated at 40 CFR Part 136.
                                        XX-73

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                     Section XX - APPENDIX 9

       List of Approved Test Procedures for Nonconventional
        Pesticide Pollutants Promulgated at 40 CFR Part 455
Parameter
CAS No.
  EPA Method
Number (2)
Other
 1.  Alachlor
 2.  AOP
 3.  Benfluralin
 4.  Benomyl
 5.  Bentazon
 6.  Bolstar
 7.  Bromacil
 8.  Busan 40
 9.  Busan 85
10.  Butachlor
11.  Carbam-S
12.  Carbendazim
13.  Carbofuran
14.  Chlorobenzilate
15.  Chloropyrifos
16.  Chloropyrifos Methyl
17.  Coumaphos
18.  Cyanazine
19.  2,4-DB
20.  2,4-DB isobutyl ester
21.  2,4-DB isooctyl ester
22.  DBCP
23.  DEET
24.  Dichlorvos
25.  Dinoseb
26.  Ethalflurlin
27.  Etridiazole
28.  Fensulfothion
29.  Fenthion
30.  Ferbam
31.  Fluometuron
32.  Glyphosate
33.  Hexazinone
34.  Isopropalin
35.  KN Methyl
36.  Mancozeb
37.  Maneb
38.  Mephosfolan
39.  Metham
40.  Methomyl
41.  Metribuzin
42.  Mevinphos
43.  Nabam
 15972-60-8
    (NA)
  1861-40-1
 17804-35-2
 25057-89-0
 35400-43-2
   314-40-9
 51026-28-9
   128-03-0
 23184-66-9
   128-04-1
 10605-21-7
  1563-66-2
   510-15-6
  2921-88-2
  5598-13-0
    56-72-4
 21725-46-2
    94-82-6
   533-74-4
  1320-15-6
    96-12-8
   134-62-3
    62-73-7
    88-85-7
 55283-68-6
  2593-15-9
   115-90-2
    55-38-9
 14484-64-1
  2164-17-2
  1071-83-6
 51235-04-2
 33820-53-0
    (NA)
  8018-01-7
 12427-38-2
   950-10-7
   137-42-8
 16752-77-5
 21087-64-9
  7786-34-7
   142-59-6
       630
       627
       631

       622
       633
       630
       630

       630
       631
       632
       608.1
       622
       622
       622
       629
       615
       615
       615
       608.1
       633
       622
       615
       627
       608.1
       622
       622
       630
       632

       633
       627
       630
       630
       630

       630
       632
       633
       622
       630
                      102
107A
102
140A
130

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44.  Naled                     300-76-5        622
45.  Niacide                 15339-36-3        630
46.  Oxamyl                  23135-22-0        632
47.  Phorate                   298-02-2        622
48.  Profluralin             26399-36-0        627
49.  Propachlor               1918-16-7        608.1          102
50.  Ronnel                    299-84-3        622
51.  Simetryne                1014-70-6        619
52.  Stirofos                  961-11-5        622
53.  Terbacil                 5902-51-2        633
54.  Terbufos                13073-79-9                       130
55.  Terbutryn                 886-50-0        619
56.  Triadimefon             43121-43-3        633
57.  Trichloronate             327-98-0        622
58.  Tricyclazole            41814-78-2        633
59.  ZAC                        (NA)           630
60.  Zineb                   12122-67-7        630
61.  Ziram                     137-30-4        630
(NA) = Not Available

(1) All parameters are expressed in micrograms per liter (52/L)

(2) The full text of methods 102, 107A, 130,  140A,  608.1,  615,
619,  622,  627, 629 630, 631, 632, and 633 are given at Appendix
E, "Text Procedures for  Analysis  of  Nonconventional  Pesticide
Pollutants" of this Part 455.  The standardized test procedure to
be  used  to determine the method detection limit (MDL) for these
test procedures is given at Appendix B, "Definition and Procedure
for the Determination of the Method Detection Limit"  of  40  CFR
Part 136.
                          XX-75

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                    Section XX - APPENDIX 10

       Priority Pollutants and Subcategories Excluded


1.   Priority Pollutants Excluded
I.      Subcategory   1   - Organic   Pesticide    Chemicals
Manufacturing

     Under   Paragraphs   8(a)(iii)  and  8(b)(i)   of   the
Settlement   Agreement,   EPA  is  excluding  certain  toxic
pollutants   from  regulation  in  the   Organic   Pesticide
Chemicals  Manufacturing Subcategory,  for one or all of the
following reasons:

     (a)   The  pollutant is not detectable in the  effluent
with  the  use of analytical methods  approved  pursuant  to
304(h)  of the Act or other state of the art methods.

     (b)  The pollutant is present only in trace amounts and
is neither causing nor likely to cause toxic effects.

     (c)   The pollutant is present in amounts too small  to
be   effectively  reduced  by  technologies  known  to   the
Administrator.

     (d)   The pollutant will be effectively  controlled  by
the   technologies  upon  which  are  based  other  effluent
limitations  and guidelines,  standards of  performance,  or
pretreatment standards

     (e)   The pollutant is detectable in the effluent  from
only  a  small number of sources within the subcategory  and
the pollutant is uniquely related to only those sources.

     (f)   Ninety-five percent or more of all point  sources
in  the  subcategory  introduce into POTWs  only  pollutants
which use susceptible to treatment by the POTW and which  do
not interfere with, do not pass through or are not otherwise
incompatible with such treatment works.

A.   Excluded from the BAT, NSPS, PSES, and PSNS regulations
with  the reasons(s) for each of the exclusions keyed to the
above list:
Volatile Aromatics
     1,3-Dichlorobenzene (d)
     Ethylbenzene (d)
     Hexachlorobenzene (d)

Haloethers
     Bis(2-chloroethoxy)methane (b)

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     Bis(2-chloroisopropyl)ether (b)
     4-lromophenyl   phenyl  ether  (b)
     2-Chloroethyl  vinyl  ether (b)
     4-Chlorophenyl  phenyl  ether  (b)

Haloraethanes
     Chlorodibromomethane (a)
     Dichlorobromomethane (a)
     Tribromomethane (d)

Phenols
     2-Chlorophenol (d)
     2,4-Dimethylphenol (d)
     4,6-Dinitro-o-cresol («}
     2-Nitrophenol  (d)
     Parachlorometacresol (d)
     2,4,6-Trichlorophenol (d)

Nitrosubstituted Aromatics
     2,4-Dinitrotoluene (a)
     2,6-Dinitrotoluene (a)
     Nitrobenzene (a)

Polynuclear Aromatic Hydrocarbons
     Acenaphtylene (b)
     Acenaphthene (b)
     Anthracene (b)
     Benzo{a)anthracene (a)
     Benzo(a)pyrene (a)
     3,4-Benzofluoranthene (a)
     Benzo(ghi)perylene (a)
     Benzo(k)fluoranthene (a)
     2-Chloronaphthalene (e)
     Chrysene (a)
     Dibenzo(a,h)anthracene (a)
     Pluoranthene (b)
     Pluorene (b)
     Indeno(l,2,3-cd}pyrene (a)
     Napthalene (e)
     Phenathrene (b)
     Pyrene (a)

Metals
     Arsenic (c)
     Antimony  (c)
     Beryllium (c)
     Cadmium (c)
     Chromium (c)
     Lead (c)
     Mercury  (c)
     Nickel  (c)
     Selenium  (c)
     Silver  (c)
     Thallium  (c)
                               XX-77

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Chlorinated Ethanes and Ethylenes
     Chloroethane  (d)
     lf1-Dichloroethane  (d)
     1,1-Dichloroethylene   (d)
     Hexachloroethane (d)
     1,1,2,2-Tetrachloroethane (d)
     1,2-trans-Dichloroethylene  (d)
     1,1,1-Trichlorbethane  (d)
     1,1,2-Trichloroethane  (d)
     Trichloroethylene   (d)
     Vinyl chloride  (d)

Nitrosamines
     N-nitrosodimethylamine  (d)
     N-nitrosodiphenylamine (a)

Phthalate Esters
     Bis(2-ethylhexyl)phthalate  (a)
     Butyl benzyl phthalate (b)
     Diethy phthalate (b)
     Dimethyl phthalate (e)
     Di-n-butyl phthalate (b)
     Di-n-octyl phthalate (a)

Pesticides
     Aldrin (a)
     Chlordane (e)
     Dieldrin (a)
     4,4'-DDD (a)
     4,4'-DDE (a)
     4,4'-DDT (a)
     Endosulfan sulfate (a)
     Endrin aldehyde (d)
     Heptachlor    epoxide  (d)

Dichloropropane and Dichloropropene
     1,2-Dichloropropane (b)

TCDD
     TCDD (a)

Dienes
     Hexachlorobutadiene  (d)

Miscellaneous
     Acrolein (a)
     Acrylonitrile (e)
     Asbestos (a)
     1,2-Diphenylhydrazine  (a)
     Isophorone (a)

Polychlorinated Biphenyls
     PCB - 1242 (a)
     PCB - 1254 (a)
     PCB - 1221 (a)
                              XX-78

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     PCB - 1232 (a)
     PCB - 1248 (a)
     PCB - 1260 (a)
     PCB - 1016 (a)

Benzidines
     Benzidine (a)
     3,3'-Dichlorobenzidine (a)

B.   Excluded from the BAT regulation for reason (d) above:

     a-BHC-Alpha
     b-BHC-Beta
     d-BHC-Delta
     g-BHC-Gamma (Lindane)
     a-Endosulfan-Alpha
     b-Endosulfan-Beta
     Endrin
     Heptachlor
     Toxaphene

C.   Excluded  from PSES regulation for reason (f)  above:

     1,2-dichloroethane
     chlorobenzene
     tetrachloroethylene
     toluene
     benzene
     phenol


II.   Subcategory  2 - Metallo-Organic  Pesticide  Chemicals
Manufacturing


     In the metallo-organic pesticide chemicals subcategory,
in  the  mercury-organic pesticide segment,  the  Agency  is
excluding  zinc  from the PSES  regulation  under  paragraph
8(a)(iii)  because the pollutant is present in the  effluent
from  only one source and  is uniquely related to only  that
source.  (reason (e) in I. above).

2.   Subcategories Excluded

     The  Agency is excluding the metallo-organic  pesticide
chemicals   manufacturing   and  the   pesticide   chemicals
formulating  and packaging subcategories from  national  BAT
regulation   development  under  Paragraph  8(a)(i)  of  the
Settlement  Agreement  because  the  existing  BPT  effluent
limitations  guidelines  provide  equal  or  more  stringent
protection.  BPT requires no discharge of process wastewater
pollutants for those two subcategories.
                              XX-79

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      The  Agency is excluding the metallo-organic  pesticide
 chemicals  manufacturing subcategory from   further   national
 N6P3   and  PSNS  regulation  development   under    Paragraph
 8(a)(iv)  and 8(b)(i) because of the small  potential  number
 of  sources.


*UJ. OOVMNMtNT PWNTINO OWCI:  1 • 8 5 -1 » 1 -I » I - * • I 0 7
                                 XX-80

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