PROCEEDINGS
OF THE
REGION VIII
PESTICIDES DISPOSAL CONFERENCE
U.S. ENVIRONMENTAL PROTECTION AGENCY
DENVER, COLORADO
APRIL 4, 5, and 6, 1973
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11555
CONTENTS
PAGE
CONTENTS i
REFACE -m
WORK GROUP RECOMMENDATIONS 1
Collection and Transportation 2
Disposal Facilities 5
Disposal Process 7
Disposal Alternatives 9
Suggested State Legislation, Regulations,
and Guidelines 12
CONFERENCE AGENDA
Program 1ft
Work Group Designations 16
Work Group Assignments 18
Attendance List 20
Speakers 26
MATERIALS PRESENTED
Interim Region VIII Pesticides Land Storage and
Disposal Guidance, January 1974 28
Merline W. Van Dyke; Consulting Engineer;
Denver, Colorado
i
Technical Brief, The Atomics International Molten Salt
Combustion Process for the Disposal of Pesticides 41
Dr. Donald F.. McKenzie; Manager, Chemistry Technology,
Atomics International Division, Rockwell International;
Canoga Park, California
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PAGE
M1crob1al Degradation 51
Dr. Eldon P. Savage; Chief, Chemical Epidemiology
Section, Institute of Rural Environmental Health;
Colorado State University, Ft. Collins, Colorado.
California Collection, Transportation, and
Disposal Systems 65
Dr. Robert M. Pratt; Chairman of the
Interdepartmental Task Force on Pesticide
Container Disposal; State Department of Food
and Agriculture, Los Angeles, California
Disposal Facilities 86
Harry Trask; Program Manager, Pesticide
Disposal Activities, Hazardous Waste Management
Division; U.S. Environmental Protection Agency,
Washington, D.C.
Air Force Research on Ecoloaical Effects of Herbicide
Application 95
Captain Alvin Young; Ph.D., Associate Professor
of Life Sciences, Herbicide Specialist;
USAF Academy, Colorado
COMMENTS ON WORK GROUP RECOMMENDATIONS 114
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PREFACE
The accumulation of unwanted pesticides and used pesticide
containers is becomino an increasingly pressing nationwide problem.
Due to the difficulties of collecting materials distributed over wide
areas, the states in Region VIII do not yet have coordinated programs
to deal specifically with these wastes -- most of which are not suited
to disposal in municipal sanitary landfills.
Under Section 19 of the Federal Insecticide, Fungicide, and
Rodenticide Act, procedures and regulations for the storage and
disposal of unwanted pesticides are in process. The Region VIII
Pesticide Disposal Conference and Uorkshop was conducted so that we
can begin laying the groundwork to handle these problems before
they present additional hazards to the public and the environment
through inadequate or uncontrolled disposal techniques.
These proceedings, including the workshop recommendations, are
a first attempt at setting up guidelines for the different phases of
the disposal process from which we can build workable solutions to
these collection and disposal problems.
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WORK GROUP RECOMMENDATIONS
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John A. Lnvii
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COLORADO DEPARTMENT OF AGRICULTURE
U'/4|>ilri t . Sv.'(lrn;m
U "fiul v Cwnmi s .*; * nna
406 STATE SERVICES BUILDING
1525 SHERMAN STREET
DENVER, COLORADO 80203
June 20, 1973
AGRICUl.TURAl COMMISSION
(.'/f.'fff/n/in
KtMini'th f'i. W ,: ', .
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Aniil!> S.'lin Arulci ",i:n , An'l
M. C. McOmnK-.h. Hnlly
Mil.--; l);ivi*>-;. D
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EPA Disposal Conference (continued)
c. Health Department
d. Applicator Advisory Committee
e. State Transportation Agency
f. Extension Service
g. Dept. of Interior
h. Dept. of Defense (National Guard - Military)
i. Colo. Agri. Chem. Assn.
j. EPA
III. Collection Scope
a. Primary collection (Colorado as example)
1. Primary site (possibility of two) '
The two sites felt most capable of handling and
storage indefinitely are the Pueblo Army Depot and Lowry Bombing Range.
2. Secondary collection site
(1) Initial collection site
Approximately four secondary/initial sites on
the Western Slope and three sites on the Eastern Slope.
Western Slope sites could be located on BIM property
while the three sites-oh the Eastern Slope could be located at several points
on State property.
Secondary sites would be open four to six weeks
during the year with each collection period lasting two weeks. During the
year, collections will be made at the Secondary site and moved to the
Primary site.
Certain circumstances will call for initial deposit
to be made at the Primary site.
These Secondary sites are for deposit by the princi-
pal problem groups - such as pesticide applicators, manufacturers, government
agencies and chemical distributors. Until materials are deposited at collec-
tion site, they remain the responsibility of the individual or organization.
Transportation to the site is the responsibility of the individual. Transpor-
tation from Secondary to Primary site will be under the control of the respon-
sible designated agency.
Possible transportation arranged through Highway
Department, Dept. of Interior or National Guard.
Personnel to aid in collection and transportation
will consist of representatives from the Extension Service, Industry, Depart-
ment of Health, Dept. of Interior and the Agriculture Department. Personnel
from these agencies will aid in all phases of work, from manning collection
;ji.tes and transportation to supervision.
b. Home owner collection
1. Five-week collection period.
2. Collection :;ite established by County Agent (guidelines
established through Advisory Committee.
3. Possible collection sites.
(1) Fire Stations (knowledge - but lack of space) ,
(2) Highway Dept. (space - but lack of knowledge) ;
(3) National Guard (space - some knowledge)
(4) Weed & Insect Abatement District)
4. Products removed to Secondary or Primary storage area..
Because of the types of products most generally
abandoned by home owners, it is felt that 55-gallon drums should be placed at
~ continued
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EPA Disposal Conference (continued
each county collection site for the purpose of collecting home owne::
products. It should be noted that several home owner sites may exist
within a given county or metropolitan area. Transportation to the
Secondary or Primary site will be accomplished in the manner previously
mentioned.
A log will be kept on what has been collected and stored with entries
beginning at the county lavel. The site will be monitored continuously
and will meet specifications as outlined by the study group. Evaluation
of the project will be made after the first year to see what, if any,
projects should be carried out in the future, or to make improvements in
the present system.
Empty container disposal is considered a large enough problem to warrant
special consideration. Amounts are such that a rinse/crush should be
considered in each county as is needed, in cooperation with State and
Federal agencies. This special consideration is needed because of
problems in storage, transportation and economics. If reconditioning
plants are available and meet various safety standards, then this dis-
posal method would be satisfactory. It is recommended that EPA spear-
head the development of a suitable mobile rinse/crusher for empty
drums, with the equipment being made available nationwide upon demand.
DMB: j.bf
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PESTICIDE CONTALNEK DISPOSAL CONFERENCE
April 4-f., 1973
Denver, Colorado
Prepared by: Dean K. McBrido
Extension Entomologist
NDSU - Fargo, North Dakota
DISPOSAL FACILITIES
A. Location
1.) Soil characteristics
a.) check with SCS people for information on soil type in
an intended disposal area.
b.) soil should be of a relatively non-porous nature.
c.) check with University soils department for information
on soil types in an intended disposal area.
2.) Proximity to surface water and operating supply wells.
a.) check on 100 year flood schedule
b.) topography and drainage of the area.
3.) Nature of water table and its fluctuation over a period of
years.
4.) Landfill site where a specific pesticide disposal area is
designated.
5.) Proximity to human habitation, livestock etc.
6.) Zoned strictly as a pesticide disposal and/or storage area
(consider future wells etc.).
B. On-Site Storage
1.) Pesticide container stack bays as according to procedure
used by Oregon.
2.) Fencing, posting, monitoring.
a.) adequate fencing angled outward at the top 6 feet high.
.b.) posting signs should be all-weather.
c.) signs should be in bright red and easily visible from
all four directions.
d.) signs should be in English, Spanish and other languages
where applicable.
e.) storage areas should he: monitored al least twice a year.
3.) In situations where (li<> distance to a landfill site having
a pesticide container disposal facility is 35-40 miles radius
or greater it is suggested that a pesticide container storage
facility be built to accomodate farmers and commercial appli-
cators within this 35-40 mile distance.
4.) Pesticides containers should be sorted to type of pesticide.
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C. Site Design and Equipment *
1.) Dates and times specified for manned landfill disposal sites
as well as storage sites possibly on a twice monthly basis
(contact with county agent or other responsible person.)
2.) Adequate equipment available at landfill sites where pesticides
and pesticide container disposal will be done.
3.) Pesticide disposal area should be well separated from disposal
areas used by public.
4.) Diversion of surface drainage away from disposal area.
5.) Adequate posting of direction signs to pesticide burial site,
6.) Safety and safety equipment - protective clothing, goggles,
respirators, gloves, soap, water.
a.) A qualified site foreman should be on hand at all times
when pesticides are being disposed of.
7.) Depth of soil - at least two feet of compacted soil.
8.) Records of types and amounts of pesticides and where they are
buried.
* Reference is made to feasibility study - Interim Guidelines for Land Dis-
posal of Excess Pesticides and Pesticide Containers. (by M.W. Van Dyke)
D. Recommendations
1.) Adequate publicity to inform the public of pesticide container
disposal sites and/or pesticide container storage sites
should indicate when sites will be open to receive pesticides
and pesticide containers.
2.) Future Needs - Research into the pesticide disposal problems
peculiar to each state within Region VIII and attempt to
arrive at workable solutions through research and demonstra-
tions coordinated by EPA.
Examples-
a.) pesticide degradation programs for pesticide disposal.
I).) portable incinerator.
c.) guidelines should be flexible enough to be compatible
with existing state laws and regulations.
d.) soil degradation studies on pesticides.
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PESTICIDE CONTAINER DISPOSAL CONFERENCE
April 4-6, 1973
U.S. ENVIRONMENTAL PROTECTION AGENCY
DENVER, COLORADO
Prepared by: Ronald Disrud
Solid Waste Management Prograrc
State Department of Health
Pierre, South Dakota 57501
DISPOSAL PROCESS
L. Problem Definition - Lack of adequate information on proper disposal
techniques.
Background information - Disposal of in open dumps either private or
municipal - (Past & Present)
Types of Waste and How Disposed:
Cans - Dumps
Barrels - Dumps & Returned to Mfg.
Bottles - Dumps
Bags - Burned & Dumps
Unwanted Pesticides - Dumps, sewage systems, spreading on
land, collection and storage.
Other Hazardous Wastes - Same as above
Legal Constraints - Transportation across state lines, unrealistic
laws, lack of responsibility for authority.
2. Alternative Solutions -
Feasible Alternatives
(a) Storage
(1) Temporary
(2) Security
(3) Space
' (4) Monitoring
(b) Use
(1) Rid of Material
(2) New Law Restricts Some Use
(3) Residue
(c) Landfill Disposal
(1) OK for Rinsed Containers
(2) OK for Small Quantities
(3) Large Quantities or Concentrations Pose Problems
(d) Return Containers to Mfg. or Distributor or Recycled
7
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(1) Contamination
(2) Transportation
(3) Leakage
(A) Label problems
(5) Collection Points
(e) Incinerating
(1) Cost
(2) Emissions
(3) Disposal
(4) Transportation
(f) Bio-degradation
(1) Lack of Technical Knowledge
(2) Land
3. Prefered Alternatives & Implementation
System Description - A multiple disposal system involving incineration and
Bio-degradation should possibly be developed, preferably at the same location.
System Management & Coordination - Coordination of all Federal & State Agencies
involved in the pesticide problem.
Funding Requirements - Considerable
Legal - Transportation
Ultimate Authority
8
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DISPOSAL ALTERNATIVES
A KEY TO DISPOSAL OF WASTE
PESTICIDES
NOTE: Return excess and surplus pesticides to original company if they accept
surplus and excess pesticides
1. a.) Industrial
b.) A Pesticide go to 2
2. a.) Approved and current Registration go to 3
b.) No approved and current Registration go to 4
3. ,a.) Pesticide contaminated, adulterated, or with no label go to 4
b.) Not contaminated, adulterated, or with a label use it for ap-
proved and a
real control
program
4. a.) Inorganic classification < go to 5
s
b.) Orgnic classification --T go to 9
5. a.) Commercial reprocessor available sell or contrib-
ute
b.) No commercial reprocessor available go to 6
6. a.) Incinerator available - ---- Incinerate, re-
cover ash for
valuable elements
or burial in ap-
propriate sanitary
landfill (Except
for Mercury resi-
due)--- go to 8.a.)
b.) No incineration--- go to 7
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7. a.) Possibility for incineration in near future storage
b.) No possibility for incineration in near future go to 8
8. a.) No. 1, approved landfill available chemically de-
* activate and/or
encapsulate in-
t organics & dis-
pose. (Excep-
tion to encapsu-
lation may be Ca
or NaOH.)
b.) No. 1, approved landfill available- storage until an
approved landfill
becomes available.
Or incinerator
becomes available
9. a.) A water solu. chemical go to 10
b.) Not a water solu. chemical go to 14
(DDT)
10. a.) Effective decontaminates available decontaminate
and dispose in
an approved pes-
ticide landfill.
b.) No effective decontaminate available go to 11
11. a.) Condusive to photodecomposition (if highly toxic may-- photodecompose
not be a disirable
method because of human
or environment risk.) i
i
b.) Cannot be photodecomposed go to 12
12. a.) Condusive to microbial degradation Soil incorpora-
tion within top
6" with a highly
organic media'and
not exceeding
1000#/A
10
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b.) Not condusive to microbial degradation go to 13
13. a.) A suitable pesticide incinerator available Incinerate,
collect ash or
4 place in #1 land-
fill.
b.) No suitable pesticide available, or dilute
formulation : go to 14
14. a.) Insecticide formulation storage
b.) Herbicide (insol. in H20) go to 15
15. a.) Condusive to photodecomposition - ^ photodecompose
b.) Not condusive to photodecomposition go to 16
16. a.) Condusive to microbial degradation soil incorpora-
tion (see 12. a.)
b.) Not condusive to microbial degradation land disposal
or storage.
Specifications
- landfill site
- soil incorporation
- photodecomposition
11
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Work Group Recommendations on State Legislation, Regulations
and Guidelines Needed for Pesticide Waste and
Container Disposal
Legislative Proposal
That the State Department of Agriculture, in cooperation with the
Department of Health, be given authority to regulate the safe disposal,
storage, or destruction of pesticides, and used pesticide containers in
such a manner that potential pesticide danger to human life, vegetation,
crops, livestock, or any other portion of the environment is minimized and
the regulating agency be granted authority to draft regulation and cooperate
with other State or Federal agencies.
Problem definitions and regulations need to be addressed to the
following areas:
A. The prevention of further accumulations of emptied pesticide
containers.
1. Rinsed or decontaminated containers.
a. Possibility of increasing exposure to pesticide poisoning
when rinsing large containers (30 and 55 gal.).
b. For reuse (non-food or domestic) or return to manufacturer.
c. Disposal at approved designated sites.
2. Collection and disposal of empty or partially filled
containers already in the hands of pesticide users.
a. Disposal at designated or approved landfill site.
1. Regulations for specific .types of containers (metal,
glass, plastic, and paper).
12
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2. Regulations for landfill operation (Type I, II,
or III similar to California designations).
b. Disposal by incineration or other approved methods of
disposal.
B. Safe transportation to collection or disposal sites.
1. Responsibility of owner.
a. Take or send container or pesticide to proper site.
b. Comply with rules or regulations.
2. Responsibility of the carrier.
a. Transport according to state or local regulations.
C. Designate adequate disposal site and/or approved method for the
disposal of unwanted pesticides.
It was the concensus of the group that regulations be established to fit
the problem areas to fit an individual State's needs. California's laws and
regulations can be used as a guide.
This report is respectively submitted to other members of pesticide waste
and container disposal workshops by the following persons participating in the
State Legislation, Regulation, and Guideline Workgroup.
Gale, Alvin F., Chairman Wyo. Ext.
Patch, Walter Wyo. DA
Harman, Frank R. Wyo. SHD
Downs, Ray J. Utah DA
Essey, Dr. Mitchell USDA APHIS
Stoddard, Orville Colo. SHD
Schroeder, Henry C. Reg. VIII EPA
13
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CONFERENCE AGENDA
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AGENDA
REGION VIII PESTICIDES DISPOSAL CONFERENCE
HOSTED BY:
U.S. ENVIRONMENTAL PROTECTION AGENCY, DENVER, COLORADO
APRIL 4, 5, and 6, 1973
C.i.
* '
APRIL 4
BACKGROUND INFORMATION
Time Item
8:30 Introduction
8:45 Present Legislation and Guidelines
(Including Sec. 19 FIFRA)
9:15 COFFEE
9:30 Sanitary Landfill Design for
Hazardous Wastes
10:00 Presentation by States - 15 minutes
^i;
a) Problems
b) Legislation
11:30 LUNCH
1:00 Rockwell International Project on
Hazardous Waste Disposal
2:00 Microbial and Chemical Degradation
3:00 COFFEE
3:15 California Collection, Transportation,
and Disposal Systems
4:15 EPA Hazardous Waste Classification
Speaker
David A. Wagoner
Larry P. Gazda
Ivan W. Dodson
Merline W. Van Dyke
Dr. Donald E. McKenzie
Dr. El don P. Savage
Dr. Robert M. Pratt
Dan W. Bench
14
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Time
8:30
9:00
9:30
9:45
10:15
11:30
1:00
1:20
4:00
8:30
11:30
1:00
APRIL 5
WORK GROUP SESSIONS
Item
Transport Regulations, Inter,
Intra/state
Hazardous waste sources related
to Pesticides
COFFEE
Disposal Facilities
Air Force Pesticide Biodegradation
Research
LUNCH
Balcom and Pueblo Chemical Drum
Cleaning and Crushing
Work Group Discussion
ADJOURN
APRIL 6
Work Group Recommendations and Discussion
LUNCH
OPEN
Speaker
Orris Gram
Robert W. Harding
Harry W. Trask
Capt. Alvin Young
Dennis M. Burchett
15
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1. Collection and Transportation
a) Used Pesticide Containers
I)) Excess and cancelled pesticides
c) Regulations
d) Recommendations
2. Disposal Facilities
a) Location
b) On-site storage
c) Site design
d) Recommendations
3. Disposal Process
a) Reuse of containers returnable to manufacturer or bulk
shipments v/ith reuse-able containers
b) Disposal of non-recyclable containers
c) Dispose;! of current backlog of unv/anted pesticides
d) Recommendations
4. Disposal Alternatives
a) Photo decomposition
^
b) Incineration
c) Microbial degradation
d) Chemical degradation
c) Storage (until satisfactory dispnv.ijl methods become available)
f) Land disposal
q) Recommendations
16
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5. Suggested State Legislation, Regulations, and Guidelines
a) Recommendations
17
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1. CplloctKMi and Trarj':,jK)rt_
Burchott, Dennis M., Chainii.jn Colo. DA
Roberts, Reed S. Utah Cxi.
USFS (R 2)
Linnell, Lyle BLM
Baghott, John Colo. SHD
EPA
2. Pi s posa1 Faci1ities
McBride, Dean, Chairman N.D. Ext.
Rountree, Leonard Colo. DA
Berndt, Or. Wayne S.D. Ext.
Rolshoven, Raymond N.D. SHD
Rivas, Alfred M. USFS (R 4)
EPA
3. Disposal
Disrud, Ronald, Chairman S.D. SHD
Pearson, Rodger H. b.D, DA
Bohmont, Dr. Bert L. Colo. Ext.
Hi lien, Boh USBS.FW
Tardif, Kenneth W. N.D. SIID
Hubert, Robert Colo. DA
EPA
18
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Disposal AlternatiVR_S_
Gingery, Gary, Ctuiirinan
Walther, Kit
Jackson, Manford J.
Pond, Floyd W.
Afjej]cy_
Mont. DA
Mont. Sill)
Mont. Ext.
USFS (R 1)
Utah SHD
EPA
5. SuggestedInstate Legislation, Regulations, and Guidolines
Gale, Alvin F., Chairman Wyo. Ext.
Patch, Halter Wyo. DA
Harman, Frank R. Wyo. SHD
Downs, Ray J. Utah DA
Essey, Dr. Mitchell USDA APHIS
Stoddard, Orville . Colo. SHD
EPA
19
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ATTENDANCE LIST
COLORADO
1. Dr. Bert L. Bohmont
Agricultural Chemicals Specialist
Colorado State University
Cooperative Extension Service
South Hall
Ft. Collins, .Colorado 80521
303-491-5353
2. Dennis M. Burchett
Chief, Pesticide Section
Division of Plant Industry
Colorado Department of Agriculture
1525 Sherman
Denver, Colorado 80203
303-892-2838
3. Orville Stoddard
Public Health Engineer
Project Director, Solid Waste Planning Grant
Division of Engineering and Sanitation
Colorado Department of Health
4210 E. llth Avenue
Denver, Colorado 80220
303-388-6111, Ext. 323
4. John Baghott
Assistant Chief, Milk, Food and Drug Section
Colorado Department of Health
4210 E. llth Avenue
Denver, Colorado 80220
303-388-6111, Ext. 265
5. Leonard Rountree
Livestock Disease Control Inspector
Colorado Department of Agriculture
1525 Sherman
Denver, Colorado 80203
303-892-2828
6. Robert Hilbert
Livestock Disease Control Inspector
Colorado Department of Agriculture
1525 Sherman
Denver, Colorado 80203
303-892-2828
20
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ATTENDANCE LIST (Continued)
COLORADO Cont.
7. Ted Davis
Vector Control Specialist
Milk, Food, and Drug Section
Colorado Department of Health
4210 E. llth Avenue
Denver, Colorado 80220
303-388-6111, Ext. 265
MONTANA
1. Kit Walther
State Pesticide Project Coordinator
Montana State Department of Health
Helena, Montana 59601
406-442-2408
2. Gary Gingery, Administrator
Montana State Department of Agriculture
Pesticides Division
Helena, Montana 59601
406-449-3730
3-. Manford J. Jackson
Extension Agronomist
Montana Extension Service
Montana State University
Bozeman, Montana 59715
406-587-4511
NORTH DAKOTA
1. Dean McBride
Extension Entomologist
North Dakota State University
Fargo, North Dakota 58102
701-237-7581
21
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ATTENDANCE LIST (Continued)
NORTH DAKOTA Cont.
2. Raymond Rolshoven
Project Director
Solid Waste Planning Grant
North Dakota State Department of Health
State Capitol Building
Bismarck, N.D. 58501
701-224-2381
3. Kenneth W. Tardif, Director
Division of Environmental Sanitation
and Food Protection
North Dakota State Department of Health
Bismarck, N.D. 58501
701-224-2382
SOUTH DAKOTA
1. Ron Disrud, Chief
Solid Waste Management
State Department of Health
Office Building #2
Pierre, South Dakota 57501
605-224-3351
2. Rodger H. Pearson, Director
Division of Plant Industry
South Dakota Department of Agriculture
Office Building #1
Pierre, South Dakota 57501
605-224-3375
3. Dr. Wayne Berndt
Extension Pesticide Specialist
South Dakota State University
Brookings, South Dakota 57007
605-688-6176
22
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ATTENDANCE LIST (continued)
UTAH
~ \
1. Ray Downs, Director
Division of Plant Industries
Utah State Department of Agriculture
Room 412, Capitol Building
Salt Lake City, Utah 84114
801-328-5421
2. Reed S. Roberts
Extension Entomologist
Utah State University
Logan, Utah 84321
801-752-4100, Ext. 7871
3. Mervin R. Reid, Chief
General Sanitation Section
Bureau of Environmental Health
44 Medical Drive
Salt Lake City, Utah 84113
801-328-6163
WYOMING
1. Walter Patch, Director
Plant Industries
Wyoming State Department of Agriculture
2218 Cary
Cheyenne, Wyoming 82001
307-777-7321
2. Alvin F. Gale
Extension Pesticide Specialist
University of Wyoming
College of Agriculture
Laramie, Wyoming 82070
307-766-3369
3. Frank R. Harman
Public Health Engineer
Sanitary Engineering Services
Division of Health and Medical Services
Wyoming Department of Health and Social Services
State Office Building
Cheyenne, Wyoming 82001
307-777-7513
23
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ATTENDANCE LIST (Continued)
U.S. FOREST SERVICE - NORTHERN REGION
Floyd W, Pond, Regional Ecologist
(Pesticide Coordinator)
Division of Biological Sciences
jU.S. Forest Service
Federal Building
Missoula, Montana 59801
406-543-6511, Ext. 3309
U.S. FOREST SERVICE - ROCKY MOUNTAIN REGION
George L. Downing, Chief
Forest Pesticide Control Branch
U.S.F..S.
Building 85
Denver Federal Center
Denver, Colorado 80225
|303-234-4365
U.S. FOREST SERVICE - INTERMOUNTAIN REGION
Alfred M. Rivas, Branch Chief
Division of Timber Management
U.S. Forest Service
324 25th Street
Ogden, Utah 84401
801-399-6141
BUREAU OF LAND MANAGEMENT
Lyle Linnell
Acting Staff Director
Watershed Staff
Bureau of Land Management
Denver Service Center
Denver Federal Center
Denver, Colorado 80225
303-234-2368
Johnnie L. Lightsey
Property Utility Specialist
Bureau of Land Management
Denver Federal Center
Denver, Colorado 80225
303-234-4964
24
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ATTENDANCE LIST (Continued)
i
U.S.' BUREAU OF SPORT FISHERIES AND -WILDLIFE
Bob Hi 11 en
'Pesticide Staff Specialist
U.S. Bureau of Sport Fisheries and Wildlife
10597 W. 6th Avenue
Denver, Colorado 80215
303-234-4616
U.S.D.A., ANIMAL AND PLANT HEALTH INSPECTION SERVICE
Dr. Mitchell A. Essey
Animal and Plant Health Inspection
U.S. Department of Agriculture
2490 W. 26th Avenue
Denver, Colorado 80211 i
303-837-3481
25
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SPEAKERS
Bench, Dan W.
Pesticides Disposal Coordinator
U.S. Environmental Protection Agency
Region VIM
Denver, Colorado
I j
Burchett, Dennis M
Chief, Pesticide Section
Colorado Department of Agriculture
Denver, Colorado
Dodson, Ivan W.
Pesticides General 1st
U.S. Environmental Protection Agency
Region VIII
Denver, Colorado
Gazdal, Larry P.
Regional Solid Waste Representative
U.S. Environmental Protection Agency
Region VIII
Denver, Colorado
Gram, Orris
Safety Investigator
Bureau of Motor Carrier Safety
U.S. Department of Transportation
Denver, Colorado
Harding, Robert W.
Sanitary Engineer
U.S. Environmental Protection Agency
Region VIII
Denver, Colorado
McKenzie, Dr. Don E,
Manager, Chemistry Technology
Atomics International Division
Rockwell International
Canoga Park, California
Pratt, Dr. Robert M.
Chairman of the Interdepartmental Task Force
on Pesticide Container Disposal
State Department of Food and Agriculture
Los Angeles, California
26
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Savage, Dr. El don P.
Associate Professor of Microbiology
Colorado State University
Fort Collins, Colorado
Van Dyke, Merline W.
Consulting Engineer
Denver, Colorado
Wagoner, David A.
Director, Categorical Programs Division
U.S. Environmental Protection Agency
Region VIII
Denver, Colorado
Trask, Harry W.
Industrial and Agricultural Wastes Section
U.S. Environmental Protection Agency
Washington, D.C.
Young, Capt. Alvin, Ph.D.
Associate Professor of Life Sciences
Herbicide Specialist
USAF Academy, Colorado
27
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MATERIALS PRESENTED
-------
Preliminary --
For Administrative Use Only
INTERIM REGION VIII
PESTICIDES LAND STORAGE AND DISPOSAL GUIDANCE
JANUARY 1974
28
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This report has been reviewed by the U.S. Environmental Protection Agency
and approved for distribution. Approval does not signify that the
contents necessarily reflect the views and policies of the U.S. Environmental
Protection Agency.
-------
This report has been reviewed by the U.S. Environmental Protection Agency
and approved for distribution. Approval does not signify that the
contents necessarily reflect the views and policies of the U.S. Environmental
Protection Agency.
-------
FOREWARD
Interim Guidelines for land storaqe and disposal of excess pesticides and
pesticide containers were developed by the Division of Hazardous Materials
Control, EPA, Reoion VIII and are intended to serve the needs in Region
VIII until other or more refined disposal methods become functional.
Adequate site investigation of soils, geology, bedrock, water tables,
etc., must precede disposal site selection. This ouidance may,
where soils and hydrolooy are different, not be widely applicable in
other parts of the country, so should not be construed as national
EPA guidance.
Draft guidelines were reviewed at the pesticide disposal conference
held April 4-6, 1973 in the EPA, Regional Office. Reviewal was also
solicited from the Regional Air and Water Programs and the Office
of Pesticide Programs and Solid Waste. Management. All comments
received were taken into consideration when preparing this document.
29
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FOREWARD
Interim Guidelines for land storage and disposal of excess pesticides and
pesticide containers were developed by the Division of Hazardous Materials
Control, EPA, Renion VIII and are intended to serve the needs in Region
VIII until other or more refined disposal methods become functional.
Adequate site investigation of soils, geology, bedrock, water tables,
etc., must precede disposal site selection. This nuidance may,
where soils and hydrolony are different, not be widely applicable in
other parts of the country, so should not be construed as national
EPA guidance.
Draft guidelines were reviewed at the pesticide disposal conference
held April 4-6, 1973 in the EPA, Regional Office. Reviewal was also
solicited from the Regional Air and Water Programs and the Office
of Pesticide Programs and Solid Waste Management. All comments
received were taken into consideration when preparing this document.
29
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Table of Contents
I. Landfillino - General
I!. Landfillino - Specifications
A. Site Location Requirements
B. Site Desiqn
C. Structural Parameters
D. Moisture Content
E. Rollers
III. Landfillinq - Construction
A. General
B. Preparation of the Foundation
C. Haste Placement and Coverinq
30
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Table of Contents
I. Landfillino - General
I!. Landfillino - Specifications
A. Site Location Requirements
B. Site Design
C. Structural Parameters
D. Moisture Content
F. Rollers
III. Landfill ing - Construction
A. General
B. Preparation of the Foundation
C. Uaste Placement and Covering
30
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INTERIM REGION VIII
PESTICIDES LAND STORAGE AND DISPOSAL
GUIDANCE
JANUARY 1974
I. Landfill ing - General
Most excess pesticides and pesticide containers can be placed
in individually desioned sanitary landfills. However, not all
sites used in Reniori VIII today can be used for pesticides
unless these sites are specially designed and constructed for
that purpose.
Mhile it is possible to construct a sanitary landfill on nearly all
topographies, some land formations are more difficult than others
to use, therefore, soil reinforcement may be necessary for pesticide
wastes. This makes each sanitary landfill distinctive. It
v/ould be impossible to standardize all techniques required at
every potential disposal site. This discussion is intended to cover
those features and procedures that are intrinsic to a nood sanitary
landfill operation for pesticide land storage and disposal.
31
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These interim guidelines will not supersede the proposed guide-
lines for "Land Disposal of Solid Wastes" or the proposed guidelines for
"Disposal and Storage of Pesticide Related Hastes" being developed
under Section 209 of the Resource Recovery Act and Section 19 of
the Federal Insecticide, Fungicide and P.odenticide Act of 1972.
The following criteria are essential for landfilling pesticide
wastes:
A. All cells should he desicmed and constructed for a particular
stockpile of ingredients.
B. All cells should be constructed, filled and covered as rapidly
as possible to maintain the integrity of the structure.
C. Wastes should be temporarily stored until there is a sufficient
guantity to warrant the desinn and construction of a cell.
D. A detailed site description and a: plat of the completed land-
fill should be permanently recorded in the appropriate office
of legal jurisdiction.
II. Landfilling - Specifications
A. Site Location Requirements
It is important that the structure:
1. Be readily accessible for construction, operation, and
maintenance; . <
2. Conform to zoninn and land use requirements and plans
of the area;
3. Not be located in a known flood plain;
4. Not be in an area where the around water table is hi oh; and
i
32
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5. Contain sufficient and suitable cover material.
B. Site Design
Site development plans should include a topographic man
showing land use and zoning within one mile of the disposal
site. The map should show all homes, buildings, wells,
watercourses, dry runs, rock outcroppings, roads, and other
pertinent data, i.e., USRS 7 1/2 minute quadrangle map.
Additional site detail should show the location of all soil
borings to a depth sufficient to allow evaluation of water
quality protection, location of proposed buildinos, area
roads and fences, and detailed contours or cross sections of
proposed structures.
A report accompanyino the plans and specifications should
document the following:
1. The volume and comprehensive description of the waste
materials which may be accepted for disnosal;
2. The tynes of hazardous waste materials which can be stored
tonether;
3. : The aeology, hydrolony, and soil testinas;
4... .The interpretation and classification of all materials
encountered in the site area using the Unified Soil
Classification System:
5. The method of soil placement and/or structural additives;
6. The schedule of periodic inspections;
7. The responsible agency for construction and maintenance; and
^
33
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8. The method of control of off/on site, surface and subsurface
drainage.
C. Structural Parameters
1. Soil characteristics of the disposal site should have:
a. Classifications of CL, CH or OH by the USCS or some
combination thereof.
b. A fine qrained texture (more than 50% passinci the
number 200 sieve size - U.S. standard) as determined
by testinq procedures of AASHO T88.
c. A Plasticity Index (PI) areater than 20 by AST'1 Test
D424 or AASHO T90.
ri. A permeability less than 10-8 cm/sec or 0.2 feet per
year, whichever is less.
2. For structural integrity, soil should be placed in six inch
layers and compacted with a sheens foot roller of more then
4,000 pounds per lineal foot, to a density of 95% of
modified proctor at optimum moisture content (ASTf! Test
D1557 or AASHO T180). Cell bottoms and sides should be
t*
constructed in a continuous operation.
3. Depth requirements of compacted backfill surrounding the
material will vary with wastes placed in the structure.
Using the EPA, Office of Pesticide Programs' classification,
the following should serve as a guide until more complete
data is accumulated:
34
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8. The method of control of off/on site, surface and subsurface
drainage.
C. Structural Parameters
1. Soil characteristics" of the disposal site should have:
a. Classifications of CL, CH or OH by the USCS or some
combination thereof.
b. A fine qraincd texture (more than 50% passino the
number 200 sieve size - U.S. standard) as determined
by testinq procedures of AASHO T88.
c. A Plasticity Index (PI) oreater than 20 by A.STM Test
D424 or AASHO T90.
d. A permeability less than 10-8 cm/sec or 0.2 feet per
year, whichever is less.
'2. For structural integrity, soil should be placed in six inch
layers and compacted with a sheens foot roller of more th?n
'4,000 pounds per lineal foot, to a density of 95% of
modified proctor at optimum moisture content (ASTM Test
D1557 or AASHO T180). Cell bottoms and sides should be
constructed in a continuous operation.
3.. Depth requirements of compacted backfill surrounding the
material will vary with wastes placed in the structure.
Using the EPA, Office of Pesticide Programs' classification,
the following should serve as a guide until more complete
data is accumulated:
34
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Hazardous Waste Class I II III IV V
(depth of fill necessary in feet) 55 42 2
;
i
4. Soil types mentioned above may not be available in all
areas of the United States. Therefore, reinforcements may
be used to upgrade the soil characteristics, i.e.., soil, '
cement, asphaltic materials, concrete bentonitic clays,
impervious membranes, etc. When reinforcements are used, the
; recommended compacted soil depths may be reduced significantly.
5. The Cell shall be capped with a minimum of 2 feet of com-
pacted soil.
D. Moisture Content
The water content of the earthfill materials prior to and during
compaction should be distributed uniformly throughout each
layer of the material. The soil water content should allow
maintenance of the modified proctor laboratory condition.
(This optimum water content is defined as that water content
which results in a maximum dry unit weight of soil when subject
to the modified proctor compaction test). The proctor compaction
tests should be conducted by a qualified person using the appro-
priate ASTK designation 01557 or standard AASHO T180 method.
The material should contain the proper moisture content in the
borrow pit before excavation. Supplementary water, if required,
should be added to the material by sprinklino on the earthfill
and should be mixed uniformly throughout the layers.
35
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E. Rollers
Tamping rollers should he used for compacting the earthfill.
They should he furnished by the contractor and should meet
ii
the following requirements:
1. Roller drums - Each drum should have an outside diameter
of not less than five feet and should not be less than
four feet nor more than six feet in length. The space
between adjacent drums, when on a level surface, should
not be less than twelve inches nor more than fifteen inches.
Each drum should be free to pivot about an axis parallel
i
to the direction of travel and should be eguipped with a
suitable pressure-relief valve.
i
2. Tamping Feet - At least one tamping foot should be provided
for each 100 sguare inches of drum surface. The space
measured on the surface of the drum, between the centers of
..' ' ' '!
any two adjacent tampinn feet, should not be less than nine
inches. The distance between the tampinn foot and the outside
surface of the drum should not be less than nine inches.
The cross-sectional area of each tamping foot should not be
more than ten square inches at a plane normal to the axis of
the shank six inches from the drum surface, and should not
tt.
be less than seven sguare inches nor more than ten square
inches at a plane normal to the axis of the shank eight
inches from the drum surface.
3. Roller Height - The weinht of the roller when fully loaded
should not be less than 4,000 pounds per foot of drum
36
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length. If more than one roller is used on any one layer
of fill, all should be the same type and with the same
dimensions. During rolling, the contractor should keep the:
i
spaces between the tamping feet clear of materials which
would impair tamping.
III. Landfi11 ing - Construction
A. General
1. Access to the site should be controlled to keep unauthorized
persons out.
2. Open burnino of waste should be prohibited.
3. Design provisions should ensure that no pollution of
surface or ground water results from the operation. Routine
monitoring should be performed by gualified personnel.
*
4. Provisions should be made for on-site control of potential
gas movement from the landfill.
B. Preparation of the Foundation
No material should be placed in any section of the earthfill
portion of the storage site until the foundation for that
section has been prepared and approved by a gualified person.
Test pits and all other existing cavities found within the
area covered by the earthfill and which extend below the
established lines of excavation for the structural embankment ,
should be filled with material and compacted as specified
for the earthfill. The foundation should be prepared by
level inn and rolling so that subsurface material of the
foundation will be as compacted and well bonded with the ;
37
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first layer of earthfill as for each subsequent layer of earth.
All rock, shale, and other undesirable materials should be
excavated from the foundation as indicated in the plans or
directed by a qualified person. Surfaces should be protected
from air slacking and freezing. Surfaces upon or against which
the earthfill portions of the structural embankment are to
be placed, should be cleaned of all loose and objectionable
materials in an approved manner by hand or other effective means
immediately prior to placinq the first layer of earthfill.
C. Waste Placement and Covering
1. Placing
The distribution and gradation of materials throughout the
earthfill should assure that the fill is free from lenses,
pockets, streaks, or layers of materials differing substantially
in texture or qradation from the surroundino materials.
l"l t
Placing of materials should be subject to the apnroval of a
'! '
gualified person who may designate the placing of individual
loads. Impervious materials should be placed'in the central
1 portion of the earthfill so that the permeability will
gradually increase toward the outside. Cobbles and rock
fragments with a diameter greater than three inches should
: be removed from the structural material.
28
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Structural material should be placed in horizontal layers
not more than six inches thick and then compacted. If
the surface of the foundation or the rolled surface of any
layer of earthfill is too dry or smooth to bond properly
with the next layer of material, it should be moistened
and/or worked with harrow, scarifier, or other suitable equip-
ment to a sufficient depth to provide a satisfactory bonding
surface before the next layer of earthfill material is
placed. If the rolled surface of any layer of earthfill is
too, wet for proper compaction with the next layer to be
placed, It should be removed or dried until the water content
is satisfactory for compaction before the next layer of
earthfill is placed.
Landfillinq
a. All slopes at the working face should enable machinery
to function properly and be 3:1.
b. Groups of hazardous materials should be in separate
partitioned areas. ''
c. Liquid materials, in barrels or drums, should have an
appropriate absorbent placerd around the containers to
.retain the liquid if leakage occurs.
d. After all materials, pesticides, etc., have been placed,
covering operations should., proceed inrnediately.
e. After compacting the cover material, all exposed earth
should be covered with topsoil and appropriate grass or
. shallow rooted shrubs planted. .,
39
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f. Surface slopes on areas with intermediate or final cover
should be at least two percent to facilitate surface
runoff.
g. At least semiannually, each site should be inspected by
a qualified person and a report presented to the
appropriate regulatory agency. Deficiencies, alonn
with recommended corrective action, should be reported.
40
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Atomics International
North American Rockwell
P O Bo. 309
Canoga Park. California 9'3tM
TECHNICAL BRIEF
THE ATOMICS INTERNATIONAL
MOLTEN SALT COMBUSTION PROCESS
FOR THE DISPOSAL OF PESTICIDES
April 1973
41
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INTRODUCTION
The disposal of pesticides in a non-polluting manner is an increasingly
important problem. Conventional incineration leads often to toxic gases,
e.g. phosgene, and the ash residue is often toxic.
Atomics International Division of Rockwell International Corp. has ,
developed a Molten Salt Combustion process which can be used to dispose of
pesticides in a non-polluting manner. The process takes advantage of two .
facts demonstrated at Atomics International:
(1) Molten salts, containing non-volatile alkali metal carbonates,
are excellent absorbents for acidic gaseous pollutants.
(2) Carbonaceous materials are rapidly consumed in carbonate
melts containing a dissolved catalyst;
CONCEPT
The Molt'en Salt Combustion process uses,a sodium carbonate melt con-
taining a dissolved catalyst. One of Hie important functions of the sodium
carbonate is tq.instantly neutralize any acidic gases such as HC1. The
catalyst accelerates the combustion process in the salt*.
In the present concept, the pesticide and air are blown into the melt,
at 1800 F, using a continuous feeder. Several reactions take place upon the
addition of the p-^.»ticide. Combustion occurs with the formation of carbon
dioxide, steam, and acidic gases. The acidic gases are instantly neutralized
by the alkaline sodium carbonate. In the case of chlorinated pesticides, any
HC1 that is formed is immediately converted to sodium chloride. Any char
*To illustrate the accelerated combustion rate,in this process, the com-
bustion of charred bituminous coal in the molten salt has beenjfound to be
50 to 100 times.more rapid than in conventional boilers. ,
42
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remaining in the salt melt is completely consumed by reaction with air and
the dissolved catalyst. Since the salt will combust all carbonaceous material
and destroy glass and metal, pesticide containers can also be disposed of in
the salt.
The process may be operated on a continuous or a batch basis. Thus,
f
either a side stream may be treated to remove ash and recycle salt or the
complete salt charge may be treated for disposal. Disposal of the spent salt
is effected by treating the dissolved salt with lime to yield insoluble calcium
compounds, e.g., CaSO , Ca (PO ) , etc. Thus, the only soluble compound
^ J T C* \
in the spent salt is sodium chloride. Since it contains no pesticide, it can
be disposed of by burial or by dumping into the ocean.
TESTS WITH PESTICIDES
Laboratory bench scale tests have been carried out on four different
classes of commercial pesticides. These were: chlordane, a chlorinated
hydrocarbon; Weed B Gon, an herbicide containing esters of 2, 4-D and
2,4, 5-T chlorinated phenoxyacctic acids; Malathion, a typical organo-
phosphorus pesticide; and Sevin, a typical carbamate pesticide. The com-
bustor was a ceramic vessel 6-1/2 in. ID x 20 in. long placed within a
laryu clamshell furnace; it contained 15 Ib of salt. The pesticide was added
in such a manner that any ;v"is formed during pyrolysis or reaction with the
melt v/a s forced to pass through the melt.
' ' f~ ' '
Several l,0--gm polyethylene packets of each pesticide were, treated.
Nitric oxide, unburned hydrocarbons and carbon monoxide were measured
during (;-.<. tests. After the tests, benzene extractions of particulates collected
in .1 f.;las.s wool trap and extractions of material collected in water scrubbers
were analyzed to determine whether any benzene-soluble material containing
the trace characteristic element of the pesticide (e.g., phosphorus for an
organophosphorus compound) was emitted. All the pesticides were destroyed,
43
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the analytical results indicating that much less than 0. 1% of 'ihe original pesti-
cide could have been present in the outlet traps. Analysis of the off-gases
from the secondary burner showed loss than 50 ppm NO , less than 10 pprn
J\
unburned hydrocarbons and less than 0.05% carbon monoxide.
ADVANTAGES OF THE MOLTEN SALT COMBUSTION
PROCESS FOR DISPOSAL OF PESTICIDES
1) Destruction of the pesticide is complete
2) Pollutant emissions such as HC1, NO are minimal
x
3) No toxic products are formed
4) Combustion is more rapid than in conventional incinerators
5) Particulates are trapped by the salt .
6) No water pollution since products are insoluble calcium salts
and sodium chloride
.ATOMICS INTERNATIONAL'S BACKGROUND IN
". MOLTEN SALT TECHNOLOGY
i r
Atomics International has a thorough background in all aspects of
molten salt technology, having had over 18 years experience in this field.
This experience started with a basic program carried out over a 12-year
period to study the fundamental properties of molten salts. This yielded a
good understanding of the basic nature of molten salts, an insight into the
chemical reactions of molten salts and served as a base on which .an in-depth
molten salt'technology could be utilized in national problems.
In recent years, Atomics International has been applying molten salt
technology to attack such problems as air pollution from stationary and
'i
mobile sources, solid waste disposal and, in addition, the overall problem
44
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of providing sufficient energy capacity to meet the nation's growing require-
ments. These activities have resulted in a diversity of molten salt experi-
ence ranging from basic laboratory studies through engineering bench-scale
tests and pilot plant programs. This background and experience can be char-
acterized in terms of total expenditures. To date Atomics International has
been funded on molten salt technology by various agencies for a total of
$9.7 million. In addition, $2.4 million of corporate funding has been spent
on these or related molten salt programs resulting in a total of about
$ 12 million.
The large,st molten salt program currently underway is the Molten
Carbonate Process for Removal of SO from Stack Gases. In this process
a molten eutectic mixture of lithium, sodium, and potassium carbonates is
used to scrub the power plant gas stream. The sulfur oxides in the gas
stream react .with the carbonates to form sulfites and sulfates, which remain
dissolved in excess unreacted carbonate melt.1' The resulting molten carbonate-
sulfite-sulfate mixture is then regenerated chemically by converting the
sulfite and sulfate back to carbonate and recovering the sulfur values as
elemental sulfur. The regenerated carbonate is then rccirculated to the
scrubber to repeat the process cycle.
The Molten Carbonate Process for the removal of sulfur oxides from
, i
power plant stack gases was selected by Consolidated Edison from among
39 processes, investigated for installation at the Arthur Kill Station on Staten
Island. A $4 million pilot plant, funded by Consolidated Edison, Northeast
Utilities and Rockwell International, will process a sidestream equivalent to
10 electrical megawatts of plant output and will be in operation early in 1973.
: >\
Other molten salt programs currently underway for pollution abatement
are:
1) "Removal of NO from Diesel Exhaust with Molten Carbonates"
x
for'the Rapid Transit District of Los Angeles which received a
gra'nt from the Department of Transportation.
-------
2) "Molten Salt Combustion of Coal," a jointly funded program by
Northeast Utilities and Rockwell International.
3) "Removal of Lead from Automobile Exhaust with Molten Car-
i
bonates," funded by a tetraethyl lead producer.
4) "Disposal of Explosives and Propellants with Molten Salts,"
funded by the Naval Ordnance System Command.
5) "Recovery of Metallic Silver from Photographic and X-ray Film
with Molten Salts" funded by the Naval Ordnance System Command.
6) "Copper Metal Recovery from Scrap Wire with Molten Salts,"
company-supported.
7) "Municipal Waste Disposal with Molten Salts," company-supported.
ATOMICS INTERNATIONAL'S BACKGROUND
IN MOLTEN SALT COMBUSTION
In addition to existing bench-scale units, t-two large scale combustors
are beginning operation. These combustors are being used to obtain data
from which prototype or commercial plants can be designed.
The first molten salt cornbu.stor has beeja: erected at the Atomics Inter-
n-uional Santa1 Susana Facilities. The combust.or vessel is 8 ft high and 3 :ft ID
and contains melt to a depth of about 3 ft. The system can operate at up to
100 psig. The combu.stor contains about 1 ton of salt and is capable of corn-
busting about 250 Ib/hr of coal. It is anticipated that the following processes
vill be tested in this combustor: coal combustion for power production,
municipal wa'ste disposal, disposal of low level radioactive waste, recovery
of silver metal from photographic and x-ray film, and disposal of pesticides
and other hazardous materials. '
The second combustor is being used to carry out the reduction of sulfate
to sulfide with carbon in the Molten Carbonate Process for removal of SO..
46
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from stack gases. To supply heat for this endothermic reaction, carbon is
combusted in the melt while reduction is taking place. This reducer-combustor
has been constructed for the Molten Carbonate Process pilot plant at the Con-
solidated Edison Company, Arthur Kill Station. Debvigging is virtually com-
plete and operation will be underway in May 1973. The reducer-combustor
is 7 ft ID and 16 ft high, will contain 5 to 6 tons of salt and will burn
240 Ib coke/hr to supply heat for the reduction step.
In addition to these units process engineering studies have been com-
pleted on a mobile unit directed specifically to pesticide (and container) dis-
posal. The first chart indicates how this unit would be used. The second
chart givps a plan and elevation of the unit and the concluding table gives
costs for a first unit. Following a demonstration run on the Santa Susana
^
Combustor, Atomics International is prepared to offer these units for sale.
;>
For further information call
W. V. Botts (213) 341-1000, Ext. 1978
Program Manager
Advanced Programs
Atomics International Division
Rockwell International Corporation
8900 DeSoto Avenue
Canoga Park, California 91304
47
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TYPICAL OPERATING MODE (MOBILE)
CO
TRANSPORT TO.SITE
CHARGE AND START-UP
OPERATE AT 500 Ib/hr
DISPOSE OF ASH AND INSOLUBLE PRODUCTS AT
LOCAL SANITARY LAND FILL
SHUT DOWN AND PREPARE FOR MOVE
MOVE TO NEXT SITE
LOGISTICS SUMMARY
1 WEEK
1 WEEK
1 TO Z MONTHS
CONTINGENCY
1 WEEK
1 WEEK
PREPARATION TIME
OPERATION TIME
~4 WEEKS/SITE
1 TO 2 MONTHS/SITE
-------
*>!<«. 6O-\ tcttlt !Tta\ ,
TtlK UMK&D \ «*» »'«»>
*» .. NrTMnr 1
I \i iTi i i
ELEVATION
SIDt ELEWTIQM
PORTAftLt WA.STL
Dl &POSAU UNI T
{QUlPMtUT PLAN < tLtV*Tl«S
-------
en
O
PRELIMINARY COSTS FOR MOBILE PESTICIDE (AND CONTAINER)
DISPOSAL UNIT - FIRST PLANT
CAPACITY « 500 Ib/hr
($)
EQUIPMENT AND INSTALLATION 190, 000
PROGRAM MANAGEMENT 21, 000
ENGINEERING 145, 000
TOTAL 356, 000
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WICROBIAL DEGRADATION
Eldon P. Savage
Hio Cuwmi tto'.' reports i Vic Tor l:.hi:; ri;:,>i .-::;> on C!;:':;;ii'':;i 1 I!,.;;.'. .
Disposal should be congratulated for developing an interesting program.
The continuing technological progress and improvement in methods of
manufacturing, packaging and marketing of pesticides has resulted in an
ever-mounting increase and diversity in the characteristics of solid
wastes. Estimates of present solid waste production per capita range
from 5 to 9 pounds daily. Municipal government cost analyses reveal that
only 21 percent of the monies allocated for solid waste management are
expended for solid waste disposal.
Although solid wastes disposal can be accomplished through composting,
incineration, hydropulping, pyrolysis, recycling, or burial, the primary
method in use in the Rocky Mountain area is land disposal.
. I* f
Due to the predominance of poorly operated landfills in the Rocky
Mountain area and the accompanying lack of preplanning and expenditure
on the proper operation and maintenance of the disposal sites, chemical
A
pollution emanating from these sites is an area of prime concern to the
maintenance of environmental quality.
: . i . '
Pollutants from improperly disposed pesticides may contaminate the
ecosystem through both air and water. The pollution of water, in the
form of leachate, or drainage, appears to be a major problem. Through
i .' .
this vehicle, pollutants may be transported in solution or in suspension
from the pesticide disposal site. Below the disposal site, dissolved
. .,':
material from the entire drainage area may be concentrated into the
drainage system. Users of these waters for drinking water sources for
animals or for irrigation purposes may be unaware of the chemical hazards.
51
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Another major problem associated with contamination from waste
disposal sites may be the buildup of concentrations of pollutDn
rood chain. Biological concentration in thij iijjp^r ur/.-j]-; of tii.^ " '.
cause some of the more persistant types of pesticides to reach dangerous
levels in the individual organisms.
You probably remember that during the period of 1953 to 1960 a total
of 121 people living near Minamata, Japan were poisoned from fish fvwing
high concentrations of methylmercury obtained from waste products contain-
ing mercury dumped into Minamata Bay. The mercury entered the food c'nairi
and the human poisoning cases resulted.1
More recently in Alamagordo, Mew Mexico, mercury treated seed dis-
carded outside an elevator was collected by a farmer and later fed to his
hogs. When the hogs reached slaughter size, he slaughtered one and after
his family ate the pork, some members became acutely ill from mercury
poisoning. The mother was pregnant at the time and the baby she later
gave birth to, was born with serious after effects. These two incidents
exemplify some of the responsibilities we are talking about when we discuss
disposal of pesticides.2
Pesticide sales and the volume of pesticides used have increased
i
dramatically since World War II. During this 30 year period, pesticide
i * ' ' ;
wastes have frequently been disposed of in a careless manner and it is
a miracle that we have not experienced more serious problems from care-
less waste disposal than we have during this period of time. Prior to
the advent of modern pesticides, some microbiologists had thbught that
soil bacteria would degrade most environmental chemicals but some pest-
icides, including many of the chlorinated hydrocarbons, have proven to be
. ii ; '
very resistant to degradation. In microbial degradation, the pesticide
52
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is used as a mir.robial energy source.
Normal soil microbial populations generally range from protozoa
i'trough fir! i;-!C f.-:ri.j. ( r;;!)h-i One). Any l.iii!..: w can irif:r;:-'V: i.ii- I-".. '
l.hat accelerate growth of microorganisms in Liu: soil, we may be n\>\<: '.<>
speed up the microbial degradation. Researchers at Oregon State Univer-
sity working on the dispos'al of selected pesticides found i F you increase;-:
th^ r.oisti r.'.". content of the soil, and adjusted the pil, you could acceler-
ate the microbial activity in the soil.
Most of the v/ork dona to date on microbial degrading has been done
in laboratories and only limited research has been done where there is
microbial interaction with more than one species of bacteria involved.
This is one aspect of degrading that needs further clarification. Other
factors that affect microorganisms in the soil are shown in Table Two.
These include temperature, moisture, ionic composition, and related
microbial growth factors.
Kevif.w of the degrading rate of p,p'-DDT to p,p'-DDD by bacteria under
aerobic and anaerobic conditions as shown in Table Three. Under aerobic
conditions for 14 days there is very little or no degrading or decomposi-
tion, but for several species of bacteria there are rather high levels of
, :2robic activity in a fourteen day period. Some give as high as 48.8%
breakdown. In evaluating the 27 bacterial species for their ability to
degrade p,p'-DDT, the conversion of DDT to DDD occurred most actively
during the second 7-day period of incubation under anaerobic conditions.'1
It is worthwhile for us to review the fundamental types (of oxidation
processes; Ipss of hydrogen, oxidation by the additon of oxygen, using
sodium chloride and oxidation by the loss of electrons. All three of
these processes of oxidation are important in decomposition of pesticide/..
53
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Aldrin, endrin, and dieldrin can be dchydrochlbrinated by merely ii
the pH to below 3. Potassium permanganate, as an oxidiziny agent, can also
spot?'.! DP i:ha m'crc.ihiijr-i-.ii.-y; or '.'^.w*. p:^tic:dos.
i
The decomposition and period of persistence of herbicides ii al.:o
interesting. The reason that I am including a few slides on herbicides
is not because we know a great deal about them but because the states that
you people represent use a large volume of herbicides. Table Four shows
the decomposition and period of persistence of several herbicides. Monuron
takes four to twelve-months to decompose and the active organism is
Pseudomonas.5 The range of persistence of herbicides in soil varies from
two weeks to twelve months.
!
The structural formula of the herbicides 2,4,5-Trichlorophenoxyacetic
acid and 2,4-Dichlorophenoxyacetic acid are shown in figure 1. Although
the only structural difference you will note is an additional chlorine in
2,4,5-T, decomposition of 2,4-D and 2,4,5-T presents a completely different
i'
story. Microb.ial decomposition of 2,4-D and 2,4,5-T is shown in figure 2.
Note the relative herbicide concentration of 2,4-D drops rapidly in a 10
day period while the concentration of 2,4,5-T remains quite high during
the 20 day period. Even under optimum conditions 2,4,5-T remains in non-
sterile soil .for periods of six months to a year or longer.6
.
Most land disposal plans are designed for a cell depth of usually 6 to
8 feet. A second parameter is a width generally at least twice the width
of the tractor for maneuverability. A third operating parameter is you
must compact refuse continuously. -.? ;
These plans also call for 6 inches of da'ily cover with a final cover
of 2 feet. This type of landfill design probably doesn't lend itself to
54
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the best degrading of chemicals. If you look at the soil depth in
centimeters of a normal soil profile, and at the anaerobic bacteria
i
iiJi aro Important for clocoirriosi ti'in yon'V! ;^i:icu t!:''t as ihs J?;>'.'
increases to a level of 40 cm you obtain only limited degrading, nose.
microbial degrading is accomplished in the extreme upper soil levels,
but what we have been doing for the last 40 years is burying waste
products as deep as we can without contaminating ground water. At
Colorado State University, a graduate student has been studying the
blodegradation of p.p'DDT and arochlor 1254 in soil obtained from the
Fort Collins Solid Waste Disposal Site.7
The rate of microbial degradation of p,p'-DDT and Aroclor 1254 in-
oculated into alfalfa-amended and nonamended soil from the site was
recorded over a twenty-two week period. The inoculated soil samples
were waterlogged and incubated at 30 C for the duration of the experiment.
For purposes of comparison, all soil samples were analyzed by
electron capture gas-liquid chromatography and quantitated by comparing
the peak height of the sample to the standard's peak height. A method
of qualatative-quantitative analysis of Aroclor 1254 is also presented.
i
i
The p,p'-DDT was moderately degraded in both the alfalfa-amended
and nonamended soils, however, there was no-significant difference in
the rate of degradation between the amended and nonamended soil prepara-
tions. No significant degradation of the Aroclor 1254 occurred over the
twenty-two week period and likewise there was no difference in the degra-
dation rate betv/een the Aroclor 1254 amended and nonamended soil. (Table
Six).
All four soil preparations had microbial cell counts characteristic.
of a fertile soil at the end of the twenty-two week period. The Ardor
55
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1254 soil preparations had significantly greater populations than the
p,p'-DDT soil preparations. There were no significant population differ-
ences between the amended and nonamended soils for each of the chlorinated
hydrocarbons. Therefore, the alfalfa amendment did not induce cell
growth and proliferation in the soil. Seven different genera of micro-
organisms were isolated from the soil and identified.
Table Seven depicts the factors affecting microorganisms in soil. All
of these are very important in obtaining breakdown of environmental chemicals,
For the past thirty years many farmers in the United States have disposed
of used pesticide containers by using them to fill in small ravines in
an effort to stop land erosion. Unknowingly, they may have been following
some aspects of successful chemical waste disposal. They have placed
the pesticides at a shallow depth in areas of high organic load, in areas
where microbial breakdown should be quite high. I would hope in the future
that we can conduct enough applied and basic research to develop some
\:\ ' : ' .:<.
answers to this tremendous problem of pesticide waste disposal by
I"-'1 . i' '
microbial degradation.
56
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TABLE ONE
SOIL MICROBIAL POPULATION
1. Bacteria
2. Actinomycetes
3. Fungi
4. Algae
5. Protozoa
57
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TAIJLE TWO
FACTORS AFFECTING MICROORGANISMS IN THE SOIL
Substrates
Mineral Nutrients
Grov/th Factors
Ionic Composition
Temperature
Pressure
Radiation
Moisture
58
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TABLE THREE
Degradation of p,p' DDT (100 yg DDT per 10 ml culture fluid) to p,p' ODD by bacterin.
.1
Bacterial species
Control, media
Aekrw&iatee sp.
AeirjlxK: t--ir aerogenes
Agrobac'-.epium tumefaciens
Azttobzcter sp.*
Bacillus cereus
Bacillus cereus mycoides
Bacillus subtilis
Clostridium pasteurianum
Olostridium sporogenes
« Corynebaaterium michiganense
Erwinia amylovora
Erwinia ananas ;
Erwinia carotovora
Erwinia chrysanthemi '
Erwinia sp.
Kurthia zopfii
Pseudomonas fluorescens
Pseudomonas glycinea
i
'Tseudomonas marginalis
Pseudomonas mors-prunprum
fseudomonas syringaa
Pseudomonas tabaci
Sarcina lutea
Xanthomonas pruni
Xanthomonas steuartii
X^inthomonas uredovorus
Xinthomonas vcsicatoria
* Grown only aerobically. t 1 to 2 yg.
>
Concentration of DUJ
Aerobic
(14 days)
N
N
N
N
N
Tt
T
T
S.A.
S.A."
N
N
N
T
N
N
N
N
N
N
N
N
N
.N
N
N
N
N
N=None. T=Trace. S.A.=Strict
59
Ug)
Anaerobic
(14 days)
N
44.7
11.4
30.9
14.3
20.4
34.6
27.4
N
T
28.1
42.9
45.3
32.4
50.1
27.0
31.9
48.8
7.8
32.6
40.8
23.2
N
5.7
54.4
48.6
8.1
anaerobe.
-------
TAW.I: TOUR
Decomposition and period of persistence of several herbicides
Herbicide
Monuron
Dalapon
DNBP
TCA
4-CPA
2,4-D (Acid)
MCPA
4-CPA
2,4-D (Acid)
2,4-D (Acid)
DNBP
DNOC
MCPA
Dalapon
Persistence
in soil
4-12 months
2-4 weeks
2-6 months
2-9 weeks
4-12 months
2-8 weeks
3-12 weeks
4-12 months
2-8 weeks
2-8 weeks
2-6 months
2-6 months
3-12 weeks
2-4 weeks
Active
organisms
Pseudomona.s
Pseudomony.,'i
Pseudomono.?
Pseudomonaz
Achromobactcr
Achromobac t vr
Ackpomobactsr
Flavobacteriwn
Flaoobaotor-Lum
Corynebacterivjn
Corynebao'terivjn
Covynebacterivjn
Mycoplana
Agrobac terivjn
60
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TABLE FIVE
SOIL PROFILE AND DISTRIBUTION OF MICROORGANISMS
Depth (cm)
3-8
20-25
35-40
65-75
135-145
Aerobic
Bacteria
7800
1800
472
10
1
Ar aerobic
Bacteria
1950
379
98
1
0.4
Actinomycetes
2080
245
49
5
Fungi Algae
119 25
50 5
14 0.5
6 0.1
3
61
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TABLE SIX
Breakdown of DDT and Aroclor 1254
(Percent recovered of initial 100yg/g soil)
i
Incubation Period (in weeks)
DDT 3 6 22
Amended Soil 82.21 70.71 63.53
DDT
Non-Amended Soil 76.97 73.40 75.74
1254
Amended Soil 93.57 83.96 79.27
1254
Non-Amended Soil 96.89 86.81 75.14
62
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2,4-D
name ; 2 ,4-dichlorophenoxyacetic acid
structural, formula:
OCH2COOH
2,4,5-T
chemicaI name; 2 , A, 5-trichloro|>li«noxyacetlc acid
structural formula:
Cl
/ \OCH2COOH
>=-.--=/
Cl
63
-------
FIGURE: 2
100
2,4,5-T
X
\
\
50
25
\
\
\
2,4-D\
\
\
\
0
10
DAYS
15
20
Microbial decomposition of 2,4-D and 2,4,5-T in soil suspensions,
64
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California Collection, Transportation, and Disposal Systems
Dr. Robert M. Pratt
If you're countinn on me to tell you how we've solved all
problems in California, we're in trouble. The thrust of my message
is . . . this is what we've gone through and ! hope you won't have
to go through all the same things. We have been going along for
some time and haven't solved all our problems, but maybe we're
pointed in some directions. I've enjoyed being with you so far
and participating in this down to earth conference with the emphasis
on problem solving.
I'm aware that people in other states get tired of hearing
how great everything is in California. In fact, when I was a
graduate student at Cornell, my fame was based mostly on the fact
that I never mentioned California except by invitation. Nevertheless,
I think 1'm'goijig to have to give you a little background to give you
an idea of the scale on which we operate.
California agriculture produces 25% of all the table foods and
'. *( '
over 40% of all fresh fruits and vegetables consumed in the United
States. We have over 200 crops. We are the first or sole producer
of 50 or more crops such as almonds, apricots, avocados, and olives.
We are very big in cotton, sugar beets, and feed grain. Nearly all
of the fruits and vegetables and all of the cotton and much of the
grain is irrigated. This all adds up to a high-cost, high-yield,
agricultural industry requiring heavy pesticide use. So it is not
65
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because we're pesticide happy that we use 20% of the national total.
Our problem is further complicated by the fact that our crops are
intermixed to a considerable degree. We became experts early on DDT
problems and put DDT under regulation as early as 1963 because of
contamination of alfalfa by DDT used on cotton. The best estimate
I can make is that we used 116,000 pounds of pesticides, active
ingredients, in 1971-72.
I think I should also give you some idea of the California ,
enforcement structure. The California Department of Food and
Agriculture, as it has been officially known since March 7, has
about 1,400 full-time employees, with a peak of 2,200 in the summer
time. We're into marketing, animal health, all of the usual plant
industry things, fruit and vegetable standardization, and many other
areas, as well as pesticide control. We've been active in pesticide
1.1
enforcement/or a great many years. During the past four years, each
-year, the legislature has passed one or more measures to give us additional
powers. In the field of pesticide regulation, we have 45 people in our
agricultural chemicals unit, which is the field enforcement unit. We
have about 100 man-years equivalent in the offices of the County Agricultural
Commissioners. This, I should stress, is one of the unique ways we operate
' t '
in California. .Each county except five nonagricultural counties has a
County Agricultural Commissioner and staff.. These people operate under
j.:
' ' ' '
state law, under the general guidance and direction of the State Department
66
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of Food and Agriculture, but they are paid by (and therefore ultimately
responsible to) the County Board of Supervisors. This organization
gives us local sensitivity and awareness of problems that we cannot
possibly have at the state level. Me also have about 25 man-years of
v
work in our chemistry laboratory on pesticides. This totals 170 man-year
equivalents in pesticide enforcement.
We have developed quite a body of laws and regulations, and at
this point I come to the packet I have handed out. After the leaflet
on the rinse and drain procedures, the first one is the summary of
California law. I call your attention specifically to the last page,
Section 12991, paragraph e: "It is unlawful for any person to store,
transport, handle, or dispose of any economic poison or of any container
which holds or has held such economic poison,, except in compliance with
rules and regulations of the director." So this ultimately is our authority
to manage pesticides and their containers. We did not have specific
authority over containers until a bill was passed in 1969.
The next document is entitled, "Agricultural Chemicals and Feed
Regulations Concerning Agricultural Pest Control," and I direct your
'-,!..*'
attention to page 36, Article 10, "Storage, Transportation, and Disposal."
!' f
This, and the rest of the pages to the end of the document, are the
regulations which we have implemented as of March 1 to carry. out the
law that I called your attention to previously. I'm not going to dwell
on these things, they are something you can read at your leisure and
i i
perhaps make some use of in your discussion.. groups. Incidentally, I
'
67
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brought the whole summary of our pesticide law and all the regulations,
11
including those not strictly related to disposal and containers, so that
you would have the picture of the whole situation in which we operate.
The next document contains the regulations of the Air Resources
Board, specifically on agricultural burning. The first paragraph on the
front under the heading, "Agricultural Burning Guidelines," says,
"Agricultural burning means open outdoor fires used in agricultural
operations in the growing of crops, or raising of fowls, animals, forest
management, and range improvement." On the next page, paragraph b says,
"This includes the burning of material not produced wholly from such
operations but which are intimately related to the growing or harvesting
of crops and which are used in the field, including pesticide sacks and
containers." More on that later.
. i
On page 10, it provides that the district air pollution boards can
regulate ,o,r permit the burning of materials in agricultural operations:
' <; !
"In developing the rules and regulations, each district shall have additional
provisions," etc. That's paragraph c, and then in number five under c,
it says they may permit, on no-burn days, the burning of combustible
pesticide containers or other toxic substances provided that it is within
"'
the definition of open burning in the field.
The next document is from the State Water Resources Control Board.
s
This defines the disposal sites and the kinds of wastes. In Article 2
H
near the bottom, "Class I disposal sites.are those at which complete
,i
protection is provided for all time, for the quality of ground and
68
-------
surface waters from all wastes deposited therein, and against hazard
to public health and wildlife resources." And it noes on to define
the geological conditions which are pretty restrictive, because a
Class I site is one in which you can put anything. It includes things
like acid waste and chromate waste and all sorts of disaqreeable things
that are really a bigger problem t'han pesticides.
Near the bottom of the second page, you find the heading, "Class II
Disposal Sites." There are Class II Sub 1 sites which overlie usable
ground water, but the geology prevents a lateral-vertical hydraulic
continuity. Class II Sub 2 sites are those having vertical and lateral
continuity but which are somewhat protected. And, finally, there is
the Class III site in which you can put only old concrete, asphalt, tires,
v
and other nonsoluble waste.
On page four, you'll find under group-one wastes, paragraph c,
"Chemicals such as pesticides or chemical fertilizers and discarded
containers of chemicals, unless adequately cleansed." The unwanted
chemicals themselves are restricted to a Class I site; the discarded
containers, not adequately cleansed, can go into a Class II Sub 1 site,
in other words, a selected site. Adequately cleansed pesticide containers
can go into a Class II Sub 2 site which is. actually a general landfill
disposal site. As I said, the only thing.less restrictive is the site
for old concrete. So if we get the containers rinsed, we've got quite
a bit of freedom.
69
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Next comes a one-paae document I'm not going to dwell on, except
to point out that this is something that is just now in process. Vie
are moving strongly into a rinsing program as I shall come back to, and
this is a set of guidelines our task force is about to adopt on adequate
holding sites pending final disposition.
There are three other agencies I should mention as being immediately
involved. The first is the Department of Public Health, Solid Haste, and
Vector Control, which has a great deal to say about the characteristics
of solid waste disposal sites, mostly from the human health standpoint.
The Water Resources Control Board has the say as far as their effect on
the ground water and surface runoff. And finally, the California Highway
.Patrol regulates'hi'ghway'tra'nsportation. They, have adopted the Department
of Transportation 'regulations as applicable in California.
NoW" with "that'legal'background, I'will go on to tell you-that two
years ago last 'December '.we began what is now the Interdepartmental Task .
' Force on Pesticide Container disposal of which-I'happen to be chairman.
! 'i '
At the-beginning, we met^with the Water Resources Control Board and the
Air Resources Board representatives and we've now expanded our membership
to include the Department o.f> Water Resources, the. Department of Public
Health, Solid Waste, and Vector Control, and the Department of Consumer <
Affairs, Structural Pest Control Board. .We brought in the Department
of Industrial Safety, the California Highway Patrol, and the University
of California Agricultural Engineering and Pesticide Program. We have
70
-------
a representative of the California Agricultural Commissioners Association.
We've invited the Department of Fish and Game, but their response
essentially was, "You keep the cans out of the creek and we won't have
any problems."
The main thing this group accomplished, in my mind, is that gradually
we have got all of the named agencies to accept this problem of pesticide
containers and surplus pesticides, which we're handling on the side, as
their problem. Initially, each little jurisdiction was sitting behind its
own barbed wire entanglement saying, "Our job is to keep our part of the
environment clean and pesticides are your problem." So, my advice to all
of you is get everybody on board at the outset and you'll have a lot less
trouble later on. We've done a few finite things to get everybody pulling
together. We started off "gung ho" with a clean-up program. Industry
volunteered through the Aircraft Operators and Western Agricultural
Chemicals Association to furnish transportation and the manpower to find
all of the old containers and get them rinsed and into suitable disposal
sites. We urged the people controlling the dump sites to get the cans in.
This was the genesis of our getting to the point where a rinsed container
could go into a Class II Sub 2 site. The idea was to clean up in late ;
winter when the industry people weren't so busy hauling pesticides, and
trucks were available. We worked with manufacturers, formulators, dealers,
applicators, County Aciricultural Commissioners, the University, including
r
t i '
the Extension Service, and all the aforementioned state agencies. Industry
71
-------
provided transportation, manpower, and some washing sites. Supervision
was provided by the Agricultural Commissioners and some of the local
Health Departments. We put out quite a lot of publicity and a packet
of advice, and information went to all of the concerned local agencies
and industries. I have a copy of the packet if anybody wants to see it.
This was not a complete success. Review of the results indicated
that 18 counties participated, out of about 56 with Aqricultural Commissioners,
They collected 22,000 containers, a fairly small fraction of what we
expected. Twenty-two counties reported they had other disposal programs
going, in other words, they were already putting containers into acceptable
rS-
disposal sites. Eight counties could not participate due to lack of
disposal sites or washing facilities, and 12 counties had no problems.
These were either nonagricultural counties or counties with handy Class I
sites which they were already using. The biqgest problems were a lack of
cleaning facilities and convenient disposal sites. There were some com-
f
munication problems among the agencies involved.
, t
Let me note at this point that we do not recommend gathering and
rinsing old containers; it doesn't work, as we found out th'e hard way.
It's too laborious; it's too expensive; it's not particularly safe, and
in addition, most of this stuff has dried in the can for a period of
i
months. You're not going to qet it out without a strenuous rinse program
with alkalizers. You've then developed a whole new problem of what do
you do with the rinsate. We don't recommend going that route for disposinn
72
-------
of old containers. In 1972, as a result of this experience, we
did not organize a statewide cleanup, but we did put out a similar
packet of information and suggest that problems be dealt with at
the county level.
Coming to our present situation, I've called your attention
to the regulations on containers without going into detail. The
most important thing they say, aside from pointing out that containers,
either full or empty, should be kept behind a locked gate, is that
containers shall be rinsed at the time of use and the rinse water
shall be put in the spray tank. This is our big thrust now. When
you do this you're accomplishing several things. In the first place,
you're saving the operator some money because he doesn't waste several
ounces of very expensive material that stays in the can. In the second
place, if you rinse the can when it is emptied, you can get it clean.
Industry has run several tests on different materials. With the triple
rinse which has been promoted by the National and Western Agricultural
Chemicals Association, you can reduce the residue to the point where
!
you're essentially dealing with scrap steel. I'm not sure who is
entitled to the credit for this -- I might, note in passing that we
have adopted a lot of programs formulated by the industry and then
said, "OK boys,.get crackin'." This is one of them. We wrote into
regulation the detailed procedure for triple rinsinq. We don't
73
-------
seriously expect that very many people are going to do that. It's
too time consuming and perhaps not terribly safe, but it is something
we could define and which we had researched.
The next paragraph says, "... or other equivalent method approved
by the director," and that means as a practical matter the director
will approve rinsing the container with some sort of jet system.
We're now in the process of defining an acceptable jet rinse procedure.
We will not certify individual devices because we figure every
applicator is going to build one out of his own plumbing supplies,
and most or all of them are going to work, and they will all be different.
But we will specify that the device must wet the entire inside of the
can and use at least half of the original volume of water. So this is
the way we're going now, with triple rinsing at the time of use. The
container then can go to any Class I or Class II site or, better yet,
to scrap steel. I'm talking about metal containers, obviously. Glass
containers should also be rinsed. Preferably, glass containers should
be broken so that they can't be reused. This can be achieved fairly
easily. With a 50 gallon drum handy, you just drop the thing in with
some vigor, and the next one on top of it, and most of them are going
to get broken. So you've got some recyclable glass that has been rinsed
for safe handling.
74
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We believe rather strongly that, although rinsed containers can
go in an approved disposal site, as many as possible should be recycled.
This is pretty good high quality scrap steel, and if the containers have
been rinsed in the prescribed manner, there is no big safety problem in
handling them. In this area, of course, I suspect your facilities for
scrap handling may be a little bit limited and your transportation problems,
I'm sure, are larger than ours may be. We (or Western Agricultural Chemical
Association to be exact) are negotiating with a steel company in Oakland
which nakes structural shapes out of scrap steel. They will be quite happy
to receive these rinsed containers. They compress them into a cube and
drop this cube into molten steel at 2800 degrees F which will eliminate
volatile products. With that temperature, you're not going to get much
except carbon dioxide and water. So, we think that is an acceptable way
J
if you've got a steel company within reach.
The ,other thing we're trying to do now is to get rid of the unrinsed
containers and again industry volunteered to do this. The deadline has
" I '
been set back a couple of times, partly because of the weather, but mostly
because of the difficulty of finding suitable sites -- something you have
been talking about all morning. It is a problem, as you know. The ideal
dump site is one that is very handy to me as long as it's'up somebody
else's road and not mine. We ran into things like exorbitantly high costs.
Some of these commercial dumps can make a lot more money receiving liquid
wastes than empty cans. We run into situations where the; man at the gate
75
-------
reads the label and if it says, "flammable," he won't take it. We
finally broke through that, but it took awhile.
Last but not least, in the San Joaquin Valley, which is our biggest
collection of all, Fresno County has been developing a Class I site
near Colinga on the east side of the coastal ranges. There's been delay
after delay after delay, and everybody's been sitting around waiting
for the Fresno Class I site. We hope it's going to be available in
another month. Of course, by that time, the crops are going to be
growing and the people are going to be selling pesticides and they're
not going to have time to haul containers. I don't know how we get out
of that one. However, we did think we had a scheme going in that we
have discovered a scrap dealer who bales up scrap and ships it to Japan.
The Japanese are willing to accept this scrap steel. The difference
between this operation and the Oakland steel mill that I referred to
earlier 1s that the exporter feels there is no personnel hazard in their
materials handling process. The Oakland mill would take unrinsed containers,
* ,
. )
and they feel there would be a little more personnel hazard. The catch is
that right now scrap steel is in very great demand. Most of the scrap
i ' .'
qoing through the Stockton outfit that ships to Japan is shredded; we all
'";<
agree that unrinsed containers should not ;.be shredded in their nonenclosed
[ *. '
setup because of possible air and water contamination as well as personnel
i :
hazards. They're just too busy shredding automobiles to run containers
through their press. So, like most things in life, you get crossed up by
something which has nothing to do with what you're trying'to accomplish
at the moment.
76
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We've not uncovered a big problem on surplus pesticides; they can
go into a Class I site. Some of the chemical companies haul material
to an approved site in Nevada, thereby exporting our problem. We think
we have a handle now on the future accumulation of containers by putting
them through the rinse and drain procedure at the time of use. So right
now when we get, hopefully, all of the present dirty containers cleaned
up, we're going to be in the business of handling these rinsed containers,
which are essentially just so much scrap steel. We have a pilot project
in Kern County where, with industry cooperation, four collection sites are
located on county land. These will be fenced, and are Class II disposal
sites where there is some supervision. They are making a deal with the
scrap dealers down there to keep these things emptied out so they have a
product which somebody will carry off for them or may even pay for. Piaht
now, they are happy enough if they just take them away for free. So this
is about where we are, and, as I pointed out earlier, there is a set of
specifications that we will presumably adopt for these collection sites.
< fi
Now, I'd like to emphasize a little more that we have leaned heavily
on industry. I mean that in two senses; we've depended on .them; we've
also leaned on them a little bit in the other current sense. They are
really responsible for the triple rinse program and they are publicizing
it and putting out these posidrain tools. I have one with me in case
you haven't seen one. It's sort of a king-sized beer can opener. A lot
of the chemical supplies are giving these away to their customers. The
77
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posidrain has two advantages: it makes the container unusable for
other purposes, and it makes a little flap and presses it tightly
against the side of the can so it can be drained more completely.
We're not very strong on crushing. There are a number of crushers,
homemade and otherwise, being used around the state and it may or
may not be advantageous. Again, if the containers are crushed, they
are unusable and you get more of them on a truck until you get up to
your weight limits.
At this point, I want to stress our indebtedness to industry for
recognizing the problem. The policy of the Western Agricultural Chemicals
Association is to solve the problem without increasing costs to the
chemical industry per se, or to agriculture and therefore to all of us.
Most of these things, like recycling the drums and eliminating some of
the less desirable containers, can be done at no cost.
Now I would like to direct your attention to a summary of what we
have done and what we are thinking about. This really stems from the
f. .
Sherman Oaks Conference of August 1 that several of you have referred to.
We agreed at that conference with the Environmental Protection Agency
that we were going to prepare a set of proposals. This is it and we have
distributed it pretty widely. Some of you may have seen it already
because the Western Agricultural Chemicals Association sent it out.
You'll note we start off by summarizing the magnitude of our problem
' .' * <
and the materials. We tried to break thevproblem into three components:
(1) to prevent the further accumulation of empty pesticide containers
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(I have described this to you in part in our rinsing program);
(2) collection and disposal of already existing empty containers
(I have told you about our successes and failures in that); and
(3) the long range solutions including recycling, incineration
techniques, and we should have had biodegradation in there too,
because it is something we have talked about quite a bit.
So then we go on to break up the responsibility among the
California agencies, starting with further regulations needed,, and
this we have already done. Going to page three, I mention structural
pest control operators.
We have not really done much about home use containers, which are
pretty important to us because of our large urban population. What
we hope for there is more education. We don't permit anything very
toxic anymore, to be put in home use packages. We're leaning on the
University a little bit to put statements in their bulletins on care
of the home garden and on the best way to get rid of these home use
packages. Incidentally, there is not much you can do with an aerosol
can except drop it in the trash; maybe it's nice to put it in a plastic
'!'..
bag first. Bottles should be rinsed the same as commercial containers.
Also, we'are working with industry on better labeling and this is, of
course, a place where the Environmental Protection Agency gets into the
act because they've got the last word on labeling. Ditto for disposal
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Instructions on the label, which again, I think EPA wants to think
about. I've told you what we're doing about the central collection
sites for rinsed containers and this we're handling with the Department,
Agricultural Commissioners, and industry. Concerning color coding,
we're pretty well back to EPA again because this obviously should be
done on a national or international basis. Industry tells us they
don't want the container a different color for each pesticide or each
class of hazard. The reason for this is they don't really know at the
beginning of the year how many containers they are going to need for
pesticide "X" and how many for pesticide "Y" and how many for pesticide
^ f
"Z." However, they would be responsive to a scheme for having all
pesticide containers the same color, say, a nice bright chrome yellow.
Well, maybe the "ABC Food Company" is packaging salad oil in chrome
yellow drums, but it seems to me fairly obvious that if we point out
to the "ABC, Food Company" that all pesticide containers after a certain
date, are going to come in chrome yellow drums, they would decide rather
quickly to.put their salad oil in purple drums or something (else. I
think that can be dealt with. Industry is also willing to have the
labels colored by class of hazard, because you can manipulate the labels
I
more easily than the supply of drums. ., ' ' ;
We're trying, through the Department and industry, to keep a
: f
running inventory of the number of containers in storage and use. I
might mention we have an elaborate computerized system for reporting
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all the pesticides that are used in the state. We can now tell you
with some accuracy what is being used on what crops and whether it's
correct or not.
Concerning the prevention of further accumulation, I've told you
about the rinsing regulations, the triple rinse, and the promotion of
the jet rinse. Industry is moving towards standardized packages. This
is another one of these enlightened self-interest moves. We would like
very much to get rid of paper packages. We recommend at this time that
the best way to get rid of paper containers is to burn them in small
numbers at point of use. Now, of course, we're quite aware of all of
the limitations on burning paper packages, including the smoke and the
pesticide fumes and the possible ash problems. But, we are also aware
that there isn't any good way to pick these packages up and move them
to a disposal, site or an incinerator or anything else. If you try to
gather them up, you're going to get a face full of dust. If you stuff
them in plastic bags so they can be moved over to the highway without
leaving a trail of dust, you're again going to get a face full. We
do not encourage accumulation and burning of large piles and certainly
not burning in any urban environments. The Air Resources Board does
not fully share our enthusiasm for this method of disposal ,'il should
add, and so this is an area where we're not terribly happy about current
disposal practices.
i
Skipping to long range solutions, industry is talking to the steel
companies:about standardized drawn 1, 2, 3, 5, and 15 gallon steel
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containers, not the usual kind with the top, bottom, and sides seamed.
There is an unpleasant statistic that I just acquired a couple of days
ago: ten percent of the standard steel pesticide containers leak. Ten
percent! This is an appalling figure when you consider how many of them
are going over the road. Of course, we're fairly nasty in California
about moving pesticides and food on the same truck, because there have
been a few unfortunate episodes, so it is now illegal. If they have a
drawn container, it will not only clean better, but will also reduce the
f
leakage problem. Industry feels they can do this at no real increased
cost. We are recommending the 30 and 55 gallon sizes be limited to
returnable use only. In other words, many of the herbicides and spray
oils can be sent out in drums and the drums reused. The smaller packages
are not practical to reuse because of cross contamination, leakage
problems, and all the rest. Incidentally, our rinse and drain rules only
apply to containers of 28 gallons or less. We are allowing ,for the
return of larger containers.
We and industry recommend eliminating the use of glass and plastic
jugs and paper containers as rapidly and as completely as possible. There
are some materials that have to be in glass and that's why I referred
earlier to recycling glass. They are adopting an amber colored gallon
jug and recommending, as I said, breaking them so all us photographers
can't take these nice brown jugs home to put our solutions in. We're
also urging the development of soluble packages or liners and most of
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the companies are working on these for wettable powders. These are
packets with a soluble plastic inner liner that you drop in the tank
and an outer carton or wrapper of paper presenting no special hazard.
There are some things like granules which we don't have an answer for ,
at this time.
We are also interested in evaluating advanced systems of pesticide
waste and used container disposal. This, of course, is where we get to
things like the Rockwell gadget that we just heard about from Dr. McKenzie.
He was rather tactful in attempting to describe our interest in it. Shall
I say, we are cheering them on but we haven't any money. We are trying to
outstall them and see if they will pick up the tab or maybe get the Air
?.
Force to pick it up or somebody who has money!
You've heard about the Rockwell gadget. Aerojet has one on paper
which is essentially the insides of a jet engine in which they feed the
materials. . There are also others that are being tried that I don't know
as much about. Incidentally, somebody mentioned the Chem Agro presentation
earlier. The impression I got is, they don't operate at a high enough
1 ?
temperature;to degrade everything into carbon dioxide and water. That is
pretty limited and I don't think they are promoting it as a solution. We
are very much interested in this, but we havn't any money so we're about
to write to EPA again and see if we can get ;a grant out of them. There is,
as some of you know, a meeting of military people right now in Washington
to talk about this same thing and we have a representative back there.
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We have listed some research needs that we've identified, some of which i
we are still thinking about, like reducing pesticide hazards in the home
environment. Incidentally, the biggest hazard in the home environment is
the guy who takes something home in a Coke bottle. I have known people,
like park department supervisors and pesticide operators, to tell their
personnel that if they must steal something, steal the whole can. Don't
put some of it in a Coke bottle and take it home for your kids to drink.
The poison information people will tell you that most pesticide deaths
result from exactly that: the stuff is put in an inappropriate container.
There are other ways, I hope, and we need to do better. We need more
evaluation of what we're talking about. We lost interest in a research
" S
project on the design, testing, and evaluation of jet rinsing because I
think all of our handy farmer mechanics are going to solve that one for us.
Industry, of course, is working on all these alternatives.
A subject in which we have a continued interest, but again lack funds
i
;_ .
for, is to assemble and evaluate the existing information worldwide on the
fate and Teachability of pesticides in soils. There is a vast amount of
information on this in the literature, most of it buried somewhere incidental
'*
to work on the control, say, of a given soil insect. There is a strong
tendency on the part of water control people and others toiassume that any-
thing you put on or under the ground is going-to go right into the water
i -,
table. Well friends, it ain't so! I'm aware of things like lenses that
the morning speaker mentioned and cracks and fissures and so forth, but
many of my friends have devoted their lives to figuring out how to get a
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pesticide to move more than three inches in the soil. Certainly, there
are hazards that exist. They must be dealt with, and can't be ignored,
but let's keep them in context and deal with the facts. He haven't found
anybody yet who is willing to stand up and say there is no hazard. We
need a better basis of fact -- possibly some additional research -- but
first of all, let's consolidate the information we already have. And
finally, we should classify pesticides in terms of relative hazard, and
some of that has been done. There is a tendency to assume that all
pesticides are equally horrible and any container that has had any
pesticide in it must be treated as if it were made of solid cyanide or
some such hyperbole.
In summary, mobilize all concerned agencies at the start. Get every-
body into the act and get all their input; you'll need all the help you
can get and you'll have less trouble with that old problem "NMH" if you get
them in at the start. "NMH," in case you don't remember, means "not made
"v
here." I suggest that you promote a rinse program, and again I think I
made it quite clear to rinse it right into the sprayer. You've then got a
''..- '
relatively clean drum, which we still don't recommend for use as stock
troughs or barbeques, but at least it's safe to move into scrap steel
channels or disposal sites. Recycle as much, of the materials as you can.
Get the existing containers into approved sites or into approved channels
and finally, taylor your program to fit your own needs and your own
realities,, because what may be real in California is not necessarily real
.»
in Colorado or Wyoming or North Dakota. Thank you.
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DISPOSAL FACILITIES
Harry W. Trask
The Office of Solid Waste Management Programs was given .the
responsibility for developing "regulations" for the implementation
of Sec. 49(a) of FEPCA last fall. Some preliminary work had been
done by EPA's Task Force on Excess Chemicals, but essentially we
were faced with pulling together ideas from several sources. When
we started developing the recommendations within the Task Force,
we based our first one on incineration because we were told that
is the only real ultimate disposal method that offers assurance
of environmental safety. But then, as we began to look into that,
we found that only some pesticides can be incinerated in a prac-
tical sense, and, as Captain Young told you yesterday, incinera-
tion of D1ox1n requires temperatures over 2200° F., and there
are others requiring even higher temperatures'. So we were faced
immediately with developing a means of separating pesticides which
: ' <'.'
can be readily incinerated from those which can't. Our initial
classification was into pure organlcs, the metallo-organics, and
?
' ' f-
the inorganics, special landfill ing for the metallo-organics (unless
you can remove the metal atoms and then incinerate) and encapsulation
for the inorganics which are really mobile in the soil. Encapsula-
tion was also recommended for the organic mercuries, arsenics,
cadmiums, leads, and all the inorganics, generally. That was
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our simplified method of starting out with this complex problem.
So far it has held up and it's probably what's going to be printed
in the Federal Register sometime.
We have been getting a good deal of static as to why we
did not recommend chemical degradation. I think yesterday we
heard some of the reasons right here. First, there is no one single
chemical degradation method we can recommend across the board.
We have a vast array of pesticides to deal with; many chemical
families, and they all react differently. If we recommend
treatment with caustic soda, that would get some of them, but
again, it doesn't get all of them. Activated charcoal will adsorb
ions out of some pesticides and deactivate them. Again, however,
it won't do for all, and a high concentration of the chemical tends
to load up the charcoal so fast that it is not economical.
' f,
Similarly, clays will adsorb these materials and hold them so
that they are not very soluble, but are much more useful with dilute
'. 1'
solutions and not very good for concentrates. So the chemical degradation
method sort of fell by the wayside and we are saying now that it
t-
should be used only under the guidance of somebody that knows the
specific situation, the specific area, and, ,just as important, what to
do with the products that are found. Biological degradation falls
generally in the same class; as Dr. Savage said yesterday, the
degredation of DDT produces ODD (among other compounds) and
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that is just as bad. So we have that problem facing us.
Now, let's talk about what there are in the way of facil-
ities now in operation. It's a fairly short list; there are
only three major commercial incinerating companies in the
United States. The largest is Rollins Environmental Services,
Inc., which has three plants, one in Logan, New Jersey (near
Wilmington, Delaware), one in Houston, Texas, and one in Baton
Rouge, Louisiana. The plants are all generally the same, with
some differences in efficiencies of their scrubbing systems:
there is a new venturi-type scubber at Logan which has not yet
been installed in the Texas and Louisiana plants,
Rollins now receives technical services from Dow Chemical
which modified all three Rollins plants quite significantly
recently. However, the question of safety of incineration in
these (and other) plants has been raisedwhether EPA really
: -^
should recommend that those plants can be used to dispose of
excess pesticides. We are convinced generally that they can.
Rollins says it can guarantee 99% destruction. Well, EPA being
"i'
EPA, feels it has to be pure, like Caesar's wife, so we can't
except the 99%. Therefore, we are going forward with a test of
the Logan plant and identify what products actually do come
out of the stack. Now, we don't anticipate any organic pesticide
degradation products, but we want to prove once and for all that
there are no pesticides emitted.
-------
The other two commercial operating companies that will
accept pesticides for incineration, are Pollution Control Inc.,
at Shakopee, Minnesota, and Chemtrol Pollution Inc., at Model
City, New York (in the Buffalo area).
Chemtrol has incinerated pesticides in liquid form only,
and have not incinerated any solid pesticides. The problem is
with their feeding arrangement, and they aren't particularly
interested in gearing up for solids. They have about as much
waste chemical disposal business as they want now, I guess
if there were a large quantity of liquid pesticides in that
area, they would be interested.
Pollution Control Inc., up in Minnesota, is like a June
bride; they are getting really anxious, but they haven't done
it yet. There have been problems in getting a permit from the
State Pollution Control Agency, which apparently isn't convinced
that pesticides can be incinerated safely.
There are some commercial landfill groups and some also '
offer chemical treatment. One of these is Chemwaste Inc., in
North Carolina; another one is the Nelson Chemical Company in
Detroit, Michigan; and another one in Michigan is Environmental
Waste Control Inc. Significantly, there aren't any out here in
this area. A reference was made earlier in the conference to
Monsanto Company. Monsanto does have a very large incinerator
near East Sti Louis, Illinois, but they have resisted success-
fully doing any commercial incineration work here. Dow Chemical
earlier did some incineration at their Midland plant, probably
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one of the best such installations in the country. You pro-
bably have heard that the State of Michigan ran a collection
program and Dow did burn up all of the DDT collected, did a
good job of it, and didn't charge the State anything. But
Dow isn't going to do that any more because the people of
Midland got all bent out oj: shape over the incineration of
everyone else's pesticides in their town; obviously, their
environmental quality would suffer !!!
There are a few other special landfills in the country
which accept hazardous waste materials and five are in California,
most in Southern California. As Dr. Pratt told you yesterday
the Fresno County Unit is going to be the first that is really
in an agricultural area in California, and will be of some
practical use in pesticide disposal.
)'.
Nuclear Engineering Inc. has a special landfill in Illinois.
It is getting nearly filled up now, but will still accept some
pesticides. However, the State of Illinois is considering
whether it should allow hazardous waste disposal in that part-
icular area because apparently some question has been raised
t
about the hydrogeoloqy. Which brings up a case in point, one
which the state of Illinois is facing right now. That is, if
-.v
you don't have a-suitable disposal facility, you're going to
have disposal where you don't want it. You may remember that
back East last summer there was Hurricane Agnes. Among other
n
things, it flooded an area in Pennsylvania where some dithiocarbamate
90
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fungicides were stored. The company which owned the pesticides
wanted to landfill them, and did get some buried in a trench
in a nearby field. The insurance company, however, wanted to
explore salvage possibilities, stopped the operation, loaded
everything in a box car and shipped it to a distributor in Illinois.
A federal pesticide inspector took a sample of this shipment and
found it to be out of grade mainly because it was contaminated
with water. Disposal was order by the Court and the Assistant
U.S. Marshall hired the H&L Disposal Company, which got rid of
the materials in an open dump near the Vermillion River. The
State of Illinois finally learned about the operation, located
the material, and found that there was a potential for the generation
\i
of substantial quantities of ethylenethiourea (ETU). Now ETU is
a soluble compound and moves readily in water, including ground
water, and it was moving. But the State Geology Department finally
determined it would take something like 140 years to get to the
Vermillion River, and about 40 years to get to the nearest well.
On the basis of that, we recommended to Region V that the dump
section containing the dithiocarbamate should be sealed off to
prevent water movement into and out of that area, which would be
more environmentally safe than moving the material. But the
.1.
State of Illinois is now asking where to locate such a landfill.
It believes there are going to be other such problems, and they want
to be prepared.
Now another thing we in the Office of Solid Haste Manage-
91
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ment have been looking at is whether we can safely dispose of pes-
ticides in sewage sludge incinerators. Now this is an idea that
was prompted by an announcement that polychlorinated biphenyls
(PCB) could be safely disposed of in sewage sludge incinerators.
One of the largest manufacturers of these incinerators, Envirotech
Corporation, submitted some partial data which indicated that may-
be it could be done. It isn't very conclusive. If it is possible
to do this without interfering with the normal operation of the
incinerator, then it opens a good deal more capacity. In fact,
there is one near your area (Kansas City). Denver also had a
-»
sewage sludge incinerator, but the air pollution agency shut it
down. With the newer, modern design units, the scrubbing devices
are quite efficient, and with the multiple hearth incinerator types,
it appears that more complete combustion is possible. These units
will qenerate temperatures of above 2,000°F., above what is needed
for most pesticides. The real question is whether the addition of
a pesticide is going to upset the normal operation of the incinerator.
Most of these incinerators are loaded to capacity almost as
soon as they are operating. So if we put a quantity of pesticide
in there and the heat of combustion of that pesticide raised the
temperature too high so that the machine doesn't work well--clearly
we are going to get lack of cooperation. So that is another series
of test burns we are going to carry out this summer. We haven't
picked the incinerator yet.
Some of our worst wastes are the mercuries and arsenicals and
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other inorganics and we nave pulled together a list of companies
who will take mercury compounds for reprocessing. Out of the six on
this list, only one takes organic mercuries. Several will take
mercury sulfide for reprocessing. If anybody is interested in this
list, I can supply you with a copy of it. It's going to be updated
as we proceed into this area of hazardous wastes. You see, mercury
is one of the top hazardous waste materials that has been identified
within OSWMP and we are going to be doing a lot more work with it,
including compounds other than pesticides, such as mercury batteries.
Essentially all of the arsenic is produced by the American Smelting
and Refining Company in Washington, recovered from the smelting of
copper ores that contain the arsenic. By cooling the air, arsenic
drops out as a particulate in bag filters. Being a by-product of
copper operation/ there is plenty of it around and not many people
are all that interested in reprocessing it.
Is anybody here familiar with the episode in Minnesota regard-
ing arsenic? Thirty years ago in Perham, Minnesota, a grasshopper
control program was carried out. There was some poison bran bait
(lead arsenite) left over and it was buried on a farm in accordance
with pesticide disposal methods of that time. It was buried deep
enough and in the right place, so they thought. But this last spring
the farmer was taken to the hospital with arsenic poisoning, and
tests showed there was 12,000 ppm arsenic in his well. The material
had moved something on the order of of 1,000 yards in 30 years. How
f
the question is what to do with the contaminated soil? The State
<
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of Minnesota is wrestling with some pretty tough problems. The
soil is contaminated with arsenic and probably with lead too.
It raises some questions about landfill ing we don't have good
answers to, and it also raises some questions about burying
containers in the field. In writing our "regulatory" package we
felt generally that farmers ought not to bury their containers
indiscriminately in the field, and we got all kinds of static
from farm groups. Well, when lead arsenite moves that way in
the soil, if the container is buried without any real regard to
where the underground water systems are, there is no guarantee
that it won't come back to haunt you later and that is what has
**t
happended in Minnesota.
(Tardiff) "I have a letter here from Penwalt Corporation dated
1971, in response to a letter I wrote them. They will buy arsenic
trioxide in their Briant, Texas plant for 4<£/lb. Some of you
gentlemen may have arsenic trioxide which was the arsenic used in
North Dakota for grasshopper poisoning in the 1930's.
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THE ECOLOGICAL CONSEQUENCES OF MASSIVE QUANTITIES
OF 2,4-D and 2,4,5-T HERBICIDES
SUMMARY OF A FIVE YEAR FIELD STUDY*
Young, A.L., C.E. Thalken, W.E. Ward and W.J. Cairney
Department of Life and Behavioral Sciences
United States Air Force Academy, Colorado
In support of programs testing aerial dissemination systems, a one
square mile test grid on Test Area C-52A, Eglin AFB Reservation, Florida
received massive quantities of military herbicides. The purpose of these
test programs was to evaluate the capabilities of the equipment systems,
not the biolopical effectiveness of the various herbicides. Hence, it
was only after repetitive applications that test personnel began to
express concern over the potential ecological and environmental hazards
that might be associated with continuance of the Test Program. This
concern led to the establishment of a research program in the fall of
1967 to measure the ecological effects produced by the various herbicides
on the plant and animal communities of Test Area C-52A. This report
documents six years of research (1967 - 1973) on Test Area C-52A and the
immediately adjacent streams and forested areas.
This report attempts to answer the major questions concerned with
the ecological consequences of applying massive quantities of herbicides
(345,117 pounds), via repetitive applications, over a period of eight
years, 1962 - 1970, to an area of approximately one square mile. More-
over, the report documents the persistence, degradation, and/or dis-
appearance of the herbicides from the Test Area's soils and drainage
waters and their subsequent effects (direct or indirect) upon the vege-
tative, faunal, and microbial communities.
The active ingredients of the four military herbicides (Orange,
Purple, White, and Blue) sprayed on Test Area C-52A were 2,4-dichioro-
phenoxyacetic acid (2,4-D), 2, ,4,5-trichlorophenoxyacetic acid (2,4,5-T),
4-amino-3,5,6-trichloropicolinic acid (picloram), and dimethylarsinic
acid (cacodylic acid). It Is probable that the 2,4,5-T herbicide con-
tained the highly teratogenic (fetus deforming) contaminant 2,3,7,8-te-
trachlorodibenzo-p-dioxin (TCDD). Ninety-two acres of the test grid
received 1,894 pounds 2,4-D, 2,4,5-T per acre in 1962 to 1964, while
another 92 acres received 1,168 pounds per acre in 1964 to 1966. In
the period from 1966 to 1970, a third distinct area of over 240 acre^
received 343 pounds per acre of 2,4-D and 2,4,5-T, 6 pounds per acre
picloram, and in 1969 to 1970, 53 pounds per acre cacodylic acid
(28 pounds per acre of arsenic as the organic pentavalent form; calculated
on weight of Blue applied per acre).
From the rates of herbicides that were applied during the years of
testing spray equipment, it was obvious that Test Area C-52A offered
a unique opportunity to study herbicide persistence and soil leaching.
Yet the problem of how best to assess the level of herbicide residue was
''Presentation to the Weed Sciences Society of America, 14 February 1974,
Las Vegas, Nevada. Abstract No. 164.
95
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a difficult one. The herbicides could be chemically present but be-
cause of soil binding might not be biologically active. Thus, both
bioassay techniques and analytical analyses were employed. The first
major bioassay experiment was conducted in April 1970. By considering
the flightpaths, the water sources, and the terracing effects, it was
possible to divide the one-square mile test grid into 16 vegetation
areas. These areas formed the basis for the random selection of 48
3-foot soil cores. Soybean bioassays indicated that 27 of the 48 cores
were significantly different from control cores (95% probability level).
The results indicated that soil leaching or penetration was much more
prevalent along the dissemination flight paths than in other areas of
the test grid. Efforts to quantitate (chemically) the bioassay were
confined to only the top 6-inch increment because of within-core
variations. By considering that all phytotoxic effects were from
Orange (2,4-D and 2,4,5-T) the average value for the top 6 inches of
soil core for the eight cores showing greatest herbicide concentration
was 2.82 ppm (parts per million) herbicide. Chemical analyses of soil
cores collected from the eight sites showing greatest phytotoxic con-
centrations were performed in December 1970. Results indicated that
the maximum concentration of either 2,4-D or 2,4,5-T was 8.7 ppb (parts
per billion). A 1970 analysis of soil cores for arsenic, from areas
receiving greatest quantities of Blue, indicated maximum levels of
4.70, 1.30, and 0.90 ppm arsenic for the first three 6-inch increments
of the soil profile, respectively. These same increments were again
collected and analyzed in 1973: levels of arsenic were 0.85, 0.47,
and 0.59 ppm for the three consecutive 6-inch increments. Leaching
of the arsenical from the soils may have occurred. Picloram analysis
in November 1969 of soil cores from areas receiving greatest quantities
of White indicated that maximum levels of 2.8 ppm picloram were present
in the 6 to 12-inch depth increment. Analy'sis of the same sites per-
formed in 1971 indicated the picloram had leached further into the
soil profile but concentrations were significantly less (ppb). Analysis
of soil cores in 1971 showed no residue of TCDD at a minimum detection
limit of less than 1 ppb, even in soil previously treated with 947
pounds 2,4,5-T per acre. However, data from soil analysis (via mass
spectrometry) of four total samples collected in June and October 1973
indicated TCDD levels of <10, 11, 30, and 710 parts per trillion (ppt),
respectively. These levels were found in the top six inches of soil
core. The greatest concentration (710 ppt) was found in a sample from
the area that received 947 pounds 2,4,5-T in the 1962 - 1964 test period.
A comparison of vegetative coverage and occurrence of plant species
on the one-square mile grid between June 1971 and June 1973 has indicated
that areas with 0 to 60% vegetative cover in 1971 had a coverage of 15
to 85% in June 1973. Those areas having 0 to 5%"coverage in 1971 (areas
adjacent to or under flightpaths used during herbicide-equipment testing)
had 15 to 54% coverage. The rate of change in coverage seemed to be
dependent upon soil type, soil moisture, and wind. There was no evidence to
indicate that the existing vegetative coverage was in any way related to
herbicide residue in the soil: dicotyledonous or broadleaf plants that are
'j
96
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normally susceptible to damage from herbicide residues occurred through-
out the entire one square mile grid. The square-foot transect method of
determining vegetative cover indicated that the most dominant plants on
the test area were the grasses, switchgrass (Panicum virqatum), woolly
panicum (Parncum lanuqinosum). and the broadleaf plants rough buttonweed
teres) '_ '
polypremum (polypremum procumbens). In 1971, 74 dicotyledonous species
(Diodia teres). poverty weed (Hypericum qentianoides), and common
were collected on the one square mile grid; in 1973, 107 dicotyledonous
species were found. All of the plant species collected were pressed,
mounted, and placed in the Eglin AFB Herbarium.
An evaluation of the effects of the spray-equipment testing program
on faunal communities was conducted from May 1970 to August 1973. The
extent of any faunal ecological alterations was measured by assessing
data on species variation, distribution patterns, habitat preference
and its relationships to vegetative coverage, occurrence and incidence
of developmental defects, as well as gross and histologic lesions in
post mortem pathological examinations.
A total of 73 species of vertebrate animals (mammals, birds, reptiles,
and amphibians) were observed on Test Area C-52A and in the surrounding
area. Of these 73 species, 22 species were observed only off the grid,
11 species were observed only on the grid, and 40 species were observed
to be common to both areas. During the early studies no attempts were
made to quantitate animal populations in the areas surrounding the grid;
however, in 1970, preliminary population studies by trap-retrap methods
were performed on the beach mouse (Peromyscus polionotus) population
for a 60 day period to confirm the hypothesis that it was the most pre-
valent species on the grid. The hypothesis was supported by the capture
of 36 beach mice from widely distributed areas on the grid, except in
areas with less than 5% vegetation. Eight pairs of eastern harvest mice
were taken to the laboratory and allowed to breed. Six of the eight pairs
had litters totalling 24 mice. These progeny were free from any gross
external birth defects. During February - May 1971 population densities
of the beach mouse were studied at eight different locations on the grid
along with two different areas off the grid which served as controls.
Populations were estimated on the basis of trap-retrap data. There was
no difference in mouse population densitites in herbicide treated «nd
control areas affording comparable habitats. All indications were that any
population differences in other animal species between the test area and
the surrounding area were due to differences caused by the elimination of
certain plants and, therefore, certain ecological niches, rather than
being due to any direct detrimental effect of the herbicides on the animal
population present on TA C-52A.
During the last day of the 1971 study, 9 mice were captured and taken
to the laboratory for post mortem pathological examination. There were
no instances of cleft palate or other deformities. Histologically, liver,
kidney and gonadal tissues from these animals appeared normal, In the
1973 study several different species of animals were caught, both on and
97
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off the test arid. These included beach mice, (Peromyscus polionotus).
cotton mice, (Peromyscus gossypinus), eastern harvest mice, (Reitnrodontomys
humulis), hispid cotton rats, (Signodon hispidus), six-lined race-runners,
(Cnemldophorus sexlineatus), a toad, (Bufo americanus), and a cottonmouth
water moccasin, (Ancistrodon piscivorus) A total of 89 animals were sub-
mitted to The Armed Forces Institute of Pathology, Washington, D.C. for
complete pathological examination including gross and microscopic studies.
Liver and fat tissue from 70 rodents were forwarded to the Interpretive
Analytical Services, Dow Chemical U.S.A., for TCDD analyses. The sex
distribution of the trapped animals was relatively equal. The ages of
the animals varied, but adults predominated in the sample. No gross or
histological developmental defects were seen in any of the animals. Sev-
eral of the rats and mice from both groups were pregnant at the time of
autopsy. The stage of gestation varied considerably from early pregnancy
to near term. The embryos and fetuses were examined grossly and micro-
scopically, but no developmental defects or other lesions were observed.
Gross necropsy lesions were relatively infrequent and consisted primarily
of lung congestion in those animals that had died from heat exhaustion
prior to being brought to the laboratory. The organ weights did not vary
significantly between the test and control animals when an animal with
lungs and kidneys showing inflammatory pathological lesions was removed
from the sample. Histologically, the tissues of 13 of the 26 control
animals and 40 of the 63 animals from the test grid, were considered
normal. Microscopic lesions were noted in some animals from both-groups.
For the most part, these were minor changes of a type one expects to
find in any animal population. One of the most common findings
was parasites. A total of 11 controls and 9 grid animals were affected
with one or more classes of parasites. Parasites may be observed in any
wild species and those in this population were for the most part incidental
findings that were apparently not harmful to the animals. There were ex-
ceptions however. Protozoan organisms had produced focal myositis in one
rat, and were also responsible for hypertrophy of the bile duct epithelium
In a six-lined racerunner.
Moderate to severe pulmonary congestion and edema were seen in several
rats and mice. All of these animals were found dead in the traps before
reaching the laboratory, and the lung lesions were probably the results of
heat exhaustion. The remainder of the lesions in both groups consisted
principally of inflammatory cell infiltrates of various organs and tissues.
They were usually mild in extent and although the etiology was not readily
apparent, the cause was not interpreted as toxic. The analyses of TCOD .
from the rodents collected in June and October 1973 indicated that TCDD
or a compound chemically similar to TCDD accumulated in the liver and fat
of rodents collected from an area receiving massive quantities of 2,4,5-T.
However, based on the pathological studies there was no evidence that the
herbicides and/or contaminants produced any developmental defects or other
specific lesions in the animals sampled or in the progeny of those that
were pregnant. The lesions found were interpreted to be of a naturally
occurring type and were not considered related to any specific chemical
toxlclty.
98
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In 1970 beach mice were not found on the more barren sections of the
grid (0-5% vegetative cover). There were, however, some areas of the
grid which had population densities exceeding those of the species pre-
ferred habitat as reported in the literature. In an attempt to correlate
distribution of the beach mouse with vegetative cover (i.e., habitat pre-
ferance) a t.-apping-retrapping program of 8 days duration was conducted in
1973. The majority of animals (63) were found in areas with 5% to 60%
vegetative cover: Within this range, the greatest number of animals trapped
(28) was from an area with 40% to 60% cover. A similar habitat preference has
been observed along the beaches of the Gulf Coast. In this study, it
appeared that the beach mouse used the seeds of switchgrass (Panicum
virgatum) and wooly panicum (Panicum lanuginosum) as a food source.
Trapping data from 1971 was compared to trapping data collected in
1973 to determine whether an increase in the population of beach mice
had occurred. The statistical evidence derived from that study showed
that the 1.64 beach mice per acre population (based on the Lincoln
Index for 1973) was slightly higher than the 0.8 and 1.4 mice per acre
reported for a similar habitat. The population of beach mice was also
higher in 1973 than in 1971 in the area of the test grid. The apparent
increase in beach mouse population on the grid in 1973 over 1971 was
probably due to the natural recovery phenomenon of a previously disturbed
area (i.e., ecological succession). Some areas of the test grid have
currently exceeded that preferred percentage of vegetative coverage of
the beach mouse habitat, and other areas were either ideal or.fast
developing into an ideal habitat. If the test gritf remains undisturbed
and continues toward the climax species, a reduction in the number of
beach mice will probably occur simply due to decline of preferred habitat.
A 1973 sweep net survey of the Arthropods of Test Area C-52A resulted
in the collection of over 1,700 specimens belonging to 66 insect families
and Arachnid orders. These totals represented only one of five paired
sweeps taken over a one-mile section of the test grid. A similar study
performed in 1971 produced 1,803 specimens and 74 families from five
paired sweeps of the same area using the same basic sampling techniques.
A much greater number of small to minute insects were taken in the 1973
survey. Vegetative coverage of the test area had increased since 1971.
The two studies showed similarities in pattern of^distribution of Arthropods
in relation to the vegetation., number of Arthropod species, and Arthropod
diversity. Generally, the 1973 study showed a reduction of the extremes
found in the above parameters in the 1971 study. This trend was expected
to continue as the test area stabilizes and develops further plant cover,
thus allowing a succession of insect populations to invade the recover-
ing habitat.
There are two classes of aquatic areas associated with the Test Area;
ponds actually on the square mile area and streams which drain the area.
Most of the ponds are primarily of the "wet weather" type, drying up once
in the last five years, although one of the ponds is spring fed. Three
major streams and two minor streams drain the test area. The combined
99
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annual flow of the five streams exceeds 24 billion gallons of water.
Seventeen different species of fishes have been collected from the major
streams while three species have been collected from the spring-fed pond
on the grid. Statistical comparisons of 1969 and 1973 data of fish popula-
tions in the three major streams confirm a chronologically higher diversity
in fish populations. However, the two control streams confirm a similar
trend in diversity. Nevertheless, from examining all of the aquatic data,
certain observations support the idea that a "recovery" phenomenon is oc-
curring 1n the streams draining TA C-52A. These observations are difficult
to document because of insufficient data. For example, in 1969, the
Southern Brook Lamprey (Ichthyomyzon gagei) was never collected in one of
the streams immediately adjacent to the area of the grid receiving the
heaviest applications of herbicides; however, in 1973 it was taken in
relatively large numbers. These observations may or may not reflect
a change in habitat due to recovery from herbicide exposure. Residue
analyses (1969 to 1971) of 558 water samples, 68 silt samples and 73
oyster samples from aquatic communitites associated with drainage of
water from Test Area C-52A showed negligible arsenic levels. However,
a maximum concentration of 11 ppb picloram was detected in one of the
streams in June 1971 but dropped to less than 1 ppb when sampled in
December 1971. TCDD analysis of biological organisms from streams
draining Test Area C-52A or in the ponds on the test area were free
from contamination at a detection limit of less than 10 parts per
trillion.
In analyses performed 3 years after the last application of 2,4-D
and 2,4,5-T herbicide the test grid exhibited population levels of soil
microorganisms identical to that in adjacent control areas of similar
soil and vegetative characteristics not exposed to herbicides. There
were increases in Actinomycete and bacterial populations in some test
site areas over levels recorded in 1970. This wav possibly due to a
general increase in vegetative cover for those sampling sites and for
the entire test grid. No significant permanent effects could be at-
tributed to exposure to herbicides.
Data on aquatic algal populations from ponds, on the one square mile
grid (previously exposed to repetitive applications of herbicides) in-
dicated that the genera present were those expected in warm, acid (pH 5.5),
seepage, or standing waters.
100
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FIELD STUDIES ON THE SOIL PERSISTENCE AND MOVEMENT OF 2,4-D, 2,4,5-T, and TCDD*
A.L. Young, E.L. Arnold and A.M. Wachinski
Department of Life and Behavioral Sciences
USAF ACADEMY, COLORADO 80840
INTRODUCTION
Concern over the level of contamination of 2,4,5-trichlorophenoxy-
acetic acid (2,4,5-T) herbicide by the teratogen 2,3,7,8-tetrachlorodi-
benzo-p-dioxin (TCDD) may result in the disposal of selected inventories
of this herbicide. A potential disposal method is that of soil incorpora-
tion. The soil incorporation method is based on the premise that high con-
centrations of phenoxy herbicide and TCDD will be degraded to innocuous
products by the combined action of soil microorganisms and soil chemical
hydrolysis.
It has been known for several years that the rate at which herbicides
disappear from the soil is largely dependent upon their susceptibility
to metabolism by soil microorganisms. Much of the information available
on the biological breakdown of the phenoxy herbicides comes from lab-
oratory studies and is very useful for predicting what might happen
when relatively high concentrations of phenoxy herbicides are applied
to a soil incorporation site. Conversely, a certain amount of caution
must always be used when extrapolating laboratory data to a field
situation. Data on the field persistence of TCDD is extremely limited
primarily due to the low levels of contamination in commercial formulations,
the rate of application of such formulation, and the lack of a sensitive
analytical method for the detection of TCDD. This report documents current
field research on the soil degradation of a TCDD-contaminated phenoxy for-
mulation when incorporated in the soil at massive rates of application.
t' . :
METHODS AND MATERIALS
In August 1972, a site for the soil incorporation of phenoxy herbicides
was selected on the Air Force Logistics Command Test. Range Complex,
Hill Air Force Base, Utah. The potential site was characterized as being
relatively flat and having a uniform surface without rock outcrops
or areas of marked deflation or dunes. Sediments in this area are
lacustrine in origin and were deposited when ancient Lake Bonneville
covered this region of the Great Basin. Sediments consist of clays
interlaced irregularly with sand lenses and remnant stream sands; the
clays predominanting. The undifferentiated clays contain various
amounts of dissolved salts. Table 1 shows an analysis of the top two
*Presentation to the Weed Science Society of America, 13 February 1974,
Las Vegas, Nevada. Abstract No. 226. t<
101
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TABLE 1. Soil analysis of the top two six-inch soil increments from the soil incorporated plots,
Air Force Logistics Command Test Range Complex, Hill Air Force Base, Utah3
Inches
0-6
6-12
PH
7.8
7.9
Organic
Carbon
W
0.82
0.95
Electrical
Conductivity
(EC x in3)b
28.0
31.0
Ca/Mq
K
meq/lOOg soi
- 23.7
23.8
3.9
3.9
Na
D
13.4
13.2
Sand
(*)
27
26
Silt
(%)
53
52
Clay
(%)
20
22
Moisture
at
Saturation
(*)
31.1
34.2
o
ro
Determined by Soils Laboratory, Utah State University, Logan, Utah, and the Soils Laboratory,
Kansas Agricultural Experiment Station, Garden City, Kansas.
Electrical conductivity in millimhos per cm at 25 C.
-------
six-Inch Increments (0-6, 6-12 inches) of the soil profile. The annual rain-
fall of the area is less than ten inches taking into consideration the water
equivalent of snowfall. Ground water of the area varies from 16 to 20 feet
below the surface. It is supplied primarily by the precipitation falling
on the nearby mountains. The small amount of water which percolates through
the existing clays moves laterally westward towards the salt flats, picking
.up chemical matter from these clays. As a result, the ground water contains
up to 1,000 parts per million (ppm) sodium chloride. The annual mean daily
minimum temperature is 38.5 F and the annual mean daily maximum temperature
^is 64.7 F. The experimental area has a vegetative cover of 15 percent and is
dominated by tourwing saltbush, Atrip!ex canescens (Pursh) Nutt,; halogeton,
Halogeton glomeratus (M. Bieb.) C.A. Mey; and graymolly, Kochia vestita.
Six field plots, each 10 x 15 feet, were established on the Air Force
Logistics Command Test Range Complex on 6 October 1972. To simulate
subsurface injection (incorporation), three equally-spaced trenches,
6 inches wide and 10 feet in length were dug to a depth of 4-6 inches in
each plot. The rates of herbicide selected for incorporation were 1,000,
2,000, and 4,000 pounds active ingredient per acre (Ib ai/A) 2,4-D plus 2,4,5-T,
Two replications (plots) per rate were included in the experiment. The
quantity of herbicide required for each rate was divided into three equal s
parts and sprayed, as the concentrate, into each of the three trenches
per plot, respectively. A hand sprayer with the nozzle removed was used
to spray as uniformly as possible an approximate two-to-three-inch band of
herbicide in the center of the 6-inch by 10-foot trench. The trenches in
each plot were then covered by use of a handshovel, tamped, and levelled
using a handrake.
The herbicide formulation used for these simulated incorporation experi-
ments was an approximate 50:50 mixture of the n-butyl esters of 2,4-D and
2,4,5-T. One gallon of this formulation contains 4.21 pounds of the active
ingredient of 2,4-D and ^.41 pounds of the active ingredient of 2,4,5-T.
The formulation was originally specified to contain:
n-butyl ester of 2,4-D 49.40%
free acid of 2,4-D 0.13%
n-butyl ester of 2,4,5-T 48.75%
free acid of 2,4,5-T 1.00%
inert ingredients (e.g., 0.62%
butyl alcohol and ester
moieties)
Some of the physical, chemical, and toxicological properties of the herbicide
formulation are:
Specific Density (25 C) 1.282
Viscosity, centipoise (23 C) 43
Molecular mass 6T8
Weight of Formulation (Ibs/gal) 8.63
Soluble in water no
Specific toxicity for female 566
white rats (mg formulation/
kg body weight)
103
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A 200 ml sample of the formulation was removed from the container of
herbicide used on these plots, placed 1n a hexane-acetone-rinsed glass
jar and shipped to the Interpretive Analytical Services Laboratory,
Dow Chemical U.S.A., Midland, Michigan, for analysis of 2,3,7,8-tetra-
chlorodibenzo-p-d1ox1n (TCDO). The results of the analysis indicated
a concentration of 3.7 parts per million (ppm) TCDD.
The first initial soil samples were to be taken the following day
after incorporation of the herbicide. However, because of adverse weather
initial samples were not obtained. Beginning in January 1973 soil samples
were collected routinely every 2-3 months. Sampling was done by using
a 3-inch by 6-inch hand auger. Each row (trench) in each plot was sampled
once by removing 6-inch increments to a depth of 36 inches. Each depth was
uniformly mixed per plot (i.e., the three rows per plot were mixed for each
depth), placed in sample containers, and shipped under dry ice to the lab-
oratory for herbicide analysis. In all cases, the soil cores were obtained
as accurately as possible from the center of the 6-inch wide row (trench).
In the laboratory, each sample was analyzed for 2,4-D acid, 2,4,5-T acid,
2,4-D n-butyl ester, and 2,4,5-T n-butyl ester by the gas chromatographic
procedure of Arnold and Young (in press, Analytical Chemistry, 1974).
RESULTS AND DISCUSSION
The results of the analysis of soil samples taken from the test plots
are displayed in Tables 2-4. Table 2 Illustrates the loss of total active
herbicide from the upper 12 inches of soil increment over a period of 440
days (6 Oct 1972 - 14 Dec 1973). Assuming normal climatoloqical conditions
this period represents 7 months of relatively cold temperatures and 7 months
of relative warmth. The percent loss of herbicide: over just the 330 day
sampling period (from 110 to 440 days) was 78.2%, 75.2% and 60.8%
for the 1,000, 2,000, and 4,000 Ib ai/A plots, respectively. If the theore-
tical values for herbicide concentration at day 0 are used, percent loss of
herbicide during the entire experiment was 87.8%, 85.3% and 82.6%, respectively.
These data tend to indicate a decreased degradation of herbicide with in-
creased application rate. However, the unusually low rate calculated for
4,000 Ib ai/A application over the 330-day period is likely a result of
low value of herbicide measured in the first sample (110 days) rather
than a difference ;in degradation rate. If a strict exponential decay
curve is assumed, the half life for the total herbicide ranaes from 146
to 155 days depending on application rate.
Tables 3 and 4 illustrate the individual loss of each of the herbicides
(2,4-D and 2,4,5-T) contained in the original formulation. Except at the
lowest rate of applicaton, no significant difference was seen in the rate
of degradation of the individual components in this formulation.
At the application rate of 1000 Ibs/A, there was-a 7.5% difference
(rate, 2,4-D = 81.2%; 2,4,5-T = 73.7%) in dearadation rates. It was
originally thought that this was due to laboratory error, however, further
sampling has tended to confirm this difference. It should be noted at this
104
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TABLE 2. Soil concentration, part per million, of 2,4-D and 2,4,5-T herbicide
at selected sampling periods, days, following soil incorporation.
Application Rate
of Formulation
(Ib ai/A)b
1 ,000
2,000
4,000
Sampling
oc
10,000
20,000
40,000
Time After Incorporation (Days)3
110 220 282
5,580 1,876
11,877 4,670
17,729 8,489
440
1,216
2,944
6,944
Data represent an average of two replications with the duplicate samples of
each replication: the total value for depths 0-6 and 6-12 inches of soil
increment.
Pounds active ingredient per acre.
c Theoretical concentration at time of application based on a two-inch spray
swath at a depth of 4-6 inches within the soil profile.
105
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TABLE 3. Soi* concentration, parts per million, of 2,4-D herbicide at
selected sampling periods, days, following soil incorporation.
Approximate* Sampling Time After Incorporation (Days)
rate of 2,4-D
(Ib ai/A) Oc 110 220 282 440
500
1,000
2,000
5,000
10,000
20,000
3,280
7,261
10,545
976
4,829
-. 616
2,370 1,844
4,112
Rate of herbicide per acre was based on the original specification of the
formulation (i.e., a 50:50 n-butyl formulation containing 8.63 pounds
active ingredient per gallon).
Data represent an average of two replications with two duplicate samples
of each replication: the total for depths 0-6 and 6-12 inches of soil
increment.
0 Theoretical concentration at time of application based on two-inch spray
swath at a depth of 4-6 inches within the soil profile.
106
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TABLE 3. Soi' concentration, parts per million, of 2,4-D herbicide at
selected sampling periods, days, following soil incorporation.
Approximate8 Sampling Time After Incorporation (Days)
rate of 2,4-D
(Ib al/A) Oc 110 220 282 440
500
1,000
2,000
5,000
10,000
20,000
3,280
7,261
10,545
976
4,829
616
2,370 1,844
4,112
Rate of herbicide per acre was based on the oriqinal specification of the
formulation (i.e., a 50:50 n-butyl formulation containing 8.63 pounds
active ingredient per gallon).
Data represent an average of two replications with two duplicate samples
of each replication: the total for depths 0-6 and 6-12 inches of soil
increment.
Theoretical concentration at. time of application based on two-inch spray
swath at a depth of 4^6 inches within the soil profile.
106
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TABLE 3. Soi* concentration, parts per million, of 2,4-D herbicide at
selected sampling periods, days, following soil incorporation.
Approximate8 Sampling Time After Incorporation (Days)
rate of 2,4-D
(Ib ai/A) Oc 110 220 282 440
500
1,000
2,000
5 ,000
10,000
20,000
3,280
7,261
10,545
976
4,829
616
2,370 1,844
- 4,112
Rate of herbicide per acre was based on the original specification of the
formulation (i.e., a 50:50 n-butyl formulation containing 8.63 pounds
active ingredient per gallon).
Data represent an average of two replications with two duplicate samples
of each replication: the total for depths 0-6 and 6-12 inches of soil
increment.
0 Theoretical concentration at. time of application based on two-inch spray
swath at a depth of 4-6 inches within the soil profile.
106
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TABLE 4. Soil concentration, parts per million, of 2,4,5-T herbicide at
selected sampling periods, days, following soil incorporation.
Approximate3
Rate of 2,4,5-T
(lb ai/A)
500
1,000
2 ,000
Sampling Time After Incorporation (Days)
Oc 110 220 282
5,000 2,300 900
10,000 4,616 2,300
20,000 7,184 3,734
440
604
1,100
2,832
a Rate of herbicide per acre was based on the original specification of the
formulation (i.e., a 50:50 n-butyl formulation containing 8.63 pounds
active ingredient per gallon).
Data represent an average of two replications with two duplicate samples of
each replication: the total for depths 0-6 and 6-12 inches of soil
increment.
leoretical <
swath at a depth of 4-6 inches within the soil profile.
c Theoretical concentration at time of application based on two-inch spray
107
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point that while 1t was originally assumed that the formulation which was
applied contained equal amounts of each herbicide, data obtained from soil
analysis tended to contradict this assumption. On the first sampling date
the soils contained an average of 66.9% 2,4-D and only 33.1% 2,4,5-T. This
ratio was approximately maintained throughout the study. A sample of the
herbicide formu'iation was analyzed by gas chromatographic-mass spectrometry
techniques and found to contain approximately 60% 2,4-D and 40% 2,4,5-T
^n addition to the butyl esters, the formulation also contained relatively
large amounts of octyl and 1so-octyl esters of both components.
A great deal of difficulty was encountered in our attempt to accurately
measure the rate of herbicide loss in these field samples. Without averaging,
loss rates calculated varied over a rather large range from sample to sample.
Even with averaging a few samples which were analyzed were not included in
the data due to extreme variations in herbicide concentration, i.e. much
higher or lower than previous samples. We attribute these variations to a
number of uncontrollable variables, the most significant of which was a
variation in application rates within the test rows. When the test plots
were established, the herbicide was sprayed into the rows with a hand
sprayer and it appears likely that there were originally concentration
differences at various points due to this method of application. A second
source of error is attributable to the moisture content of the soil samples.
On some of the sampling dates, the samples received were extremely wet due to
snow drifts over the plots while others were relatively dry. This variation
in moisture tended to change the consistency of the soil and in many cases
made the obtaining of a uniform sample impossible. A third source of varia-
tion occurred due to the composition of the herbicide sample which was origin-
ally applied. As was previously mentioned in addition to the expected n-butyl
esters of 2,4-D and 2,4,5-T, a portion of the formulation of the sample was
made up of n-octyl and iso-octyl esters of the two herbicides. No attempt
was made to analyze for these esters in the soil samples; consequently, the
effect of these compounds on the overall degradation pattern would only be
noted after they had 'been hydrolyzed to the free acid. Since the rates of
hydrolysis of these compounds may be different than that of n-butyl esters,
this is another possible source of variation in the data obtained on early
sampling dates.
In order to minimize variations in the data, on February 1, 1973,
small amounts of soil (200 g) from the field plots were analyzed and placed
in glass stoppered bottles. These bottles were then placed in a constant
temperature incubator at 83 F to be analyzed periodically at later dates.
The analytical data from these samples are presented in Table 5. Average
percent loss/day values calculated from these samples were 0.42%/day for
2,4-D and 0.48%/day for 2,4,5-T. Half lives for 2,4-D and 2,4,5-T
calculated from these data are 119 days and 104 days, respectively. In
these samples it appears that the rate of degradation decreases with time
since, in most samples, the loss of herbicide was greater from day 0 to 82
:than between days 82-156. Apparently initial concentration had little effect
on the degradation rate. The average rates of loss for the 6 samples with
the highest initial concentrations were .43 and .48 while those for the 6
108
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TABLE 5. Loss of herbicide (ppm) from field samples incubated in the laboratory
at 83 F.
Sample
Number
V
1
2
3
4
5
6
7
8
9
V
10
.*-
n
12
AVG.
TOTAL
0 Days
2,4-Da
2740
2440
3220
2360
5704
5484
3260
2980
9680
11000
2820
3320
4584
55,008
2,4,5-T
1980
1500
2380
1500
4220
3388
2100
2200
7080
7720
1820
2440
3194
38,328 -
82 Days
b 2,4-D
2300
1412
1340
1260
3148
2408
1540
1162
4584
4644
1500
1448
2229
26,746
2,4,5-T
1178
695
820
750
1640
1350
760
547
2408
2388
700
895
1178
14,131
156
2,4-D
868
680
840
784
2000
1852
1164
1300
3552
3590
1032
1028
1558
18,690
Days
2,4,5-T
480
320
488
440
1124
920
632
720
1740
1902
608
500
823
9,879
Total loss/
day (percent)
2,4-D 2,4,5-
.44
.46
.47
.43
.42
.43
.41
.36
.41
.43
.41
.44
.42
.44
.50
.51
.45
.47
.47
.45
.43 .
.48
.48
.43
.51
.43
Total value for esters and acids of 2,4-D.
Total value for esters and acids of 2,4,5-T.
109
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samples of lowest concentration were .42 and .46, respectively, and are
therefore not significantly different.
One observation that was apparent in all degradation studies which
have been performed is the relatively rapid hydrolysis of the n-butyl esters
of the herbicide due to contact with the alkaline Utah soils. Table 6 gives
the percentage saponlficatlon of the n-butyl esters of 2,4-D and 2,4,5-t
to the acids over a period of 282 days for two different application rates.
It was found that 1n all samples, the rate of hydrolysis of n-butyl 2,4-D
, ,was greater than that of n-butyl 2,4,5-T. Moreover, it is likely that at
*'the higher concentrations (e.g., 4,000 Ib ai/A), the add salts formed
could not be removed at a sufficiently rapid rate (via degradation and/or
penetration), causing the chemical equilibrium to shift to the left.
Data concerning herbicide penetration in Utah soils are shown in Table 7.
Samples from lower soil increments were taken from those plots where it was
expected that herbicide concentrations would be most likely to penetrate
into the soils. With one exception, both 2,,4-D and 2,4,5-T residues were
found at all levels sampled. In all cases the total herbicide concentration
in levels greater than 18 inches was made up entirely of the free acids.
Butyl esters were not detected at depths greater than 12 inches for 2,4-D or
18 inches for 2,4,5-T. It is also interesting to note that the penetration
of 2,4-D is greater than that of 2,4,5-T. Apparently this is due to the
greater water solubility of the free acid of 2,4-D. This may also explain
why 2,4-D appeared to degrade more slowly in laboratory samples where there
was no loss from the sample due to penetration.
In June 1973, a composite soil core from one of the 4,000 Ib ai/A
plots was selected for TCDD analysis. The Interpretive Analytical Services
Laboratory, Dow Chemical U.S.A. performed the analysis using a modification
of the method developed by Baughman and Meselson (published in Environmental
Health Perspectives, Experimental Issue No. 5, September 1973). The following
data were obtained:
2,3,7,8-tetrachlorodibenzo-p-dioxln
Sample parts per trillion parts per billion
Control (0-6 inches) <10 <10
Plot 5 (0-6 inches) 15,000 . 15.UO
Plot 5 (6-12 inches) 3,000 3.00
Plot 5 (12-18 inches) 90 0.09
Plot 5 (18-24 inches) 120 0.12
Thus, within the four samples from the plot 5 core (4,000 Ib ai/A) a
total concentration of 18,210 ppt (18.21 parts per billion - ppb) was found.
Undoubtedly the lower two depths (12-18 and 18-24 inches) represent contamin-
ation from the upper two increments, via the use of the hand auger.
110
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TABLE 6. Percentage saponification of the n-butyl esters of 2,4-D and
2.4,5-T at selected time periods, days, following soil incor-
poration 1n alkaline soils.
Application
Rate of
Formulation 0
1
4
,000 Ib ai/Ab
Esters 100
Acids 0
,000 Ib ai/A
Esters 100
Add 0
Days After Incorporation3
110 220 282
24 13 3
76 87 97
77 40 32
23 60 68
a Data are the percent acid and esters of herbicides found in top 0-6 of
soil profile.
Ib ai/A = pounds active ingredient per acre.
Ill
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TABLE 7. Herbicide (2,4-D and 2,4,5-T) penetration (ppm) in the 4,000 Ib ai/A
plots 282 days after soil incorporation.
Depth
(inches)
0-6
6-12
12-18
18-24
25-30
30-36
2,4-Da
(ppm)
4262
1093
126
158
230
161
2,4,5-Ta
(ppm)
2982
752
101
70
50
21
Percent
of total
Herbicide
72.4
18.4
2.3
2.7
2.9
1.8
Data are an average of two analyses and represents the total of both the
ester and acid components.
112
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Since the TCDD concentration of the formulation was known (see Methods),
and since its determination in the soil core was performed by the same lab-
oratory and instrumentation, an estimation of the degradation of TCDD can be
obtained by comparison to the expected value based on the known concentration
of herbicide at time of sampling. Subsamples of the soil core analyzed for
TCDD were also analyzed for 2,4-D and 2,4,5-T. The total concentration of
herbicide In the 0-6 and 6-12 inch increments was approximately 14,000 ppm.
Therefore, the actual concentration should have been approximately 51.8 ppb TCDD
(14,000 x 3.7 x 10-3 = 51.8) if degradation of the TCDD was at the same rate
as 2,4-D and 2,4,5-T. If the~~theoretical values for herbicide concentration
at day 0 (time of incorporation) are used, then the initial concentration of
TCDD would have been 148 ppb (40,000 x 3.7 x 10~3 = 148 ppb). The percent
loss of TCDD over a period of 265 days was 87.7% (18.21/148 = 12.3%; 100% -
12.3% = 87.7*). The value 87.7% would represent 3 half-lives for TCDD
persistence. Therefore a rough estimate for the half-life of TCDD would be 88
days in these alkaline soils, under desert conditions, and in the presence
of massive quant1t1es~bf 2.4-D and 274~,5-T.
These preliminary data suggest that TCDD degrades at a more rapid rate
than 2,4-D or 2,4,5-T. Moreover, the movement of the TCDD to the 6-12 inch
depth probably represents co-movement with the massive amounts of esterified
herbicide, rather than independent penetration into the soil profile.
113
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COMMENTS ON WORK GROUP RECOMMENDATIONS
-------
COLORADO
STAT E college of veterinary medicine and biomedical sciences
UNIVERSITY department of microbiology
FORT COLLINS
COLORADO . , im-,
May 18, 1973
Mr. David A. Wagone,"
Director
Categorical Programs Division
Ujjited States Environmental
^Protection Agency
1860 Lincoln Street
Denver, Colorado 80203
Dear Mr. Wagoner:
I' have reviewed the recommendations of the two work groups attending the Pesticide
Container Disposal Conference, and have the following comments.
The state legislation and regulations guidelines are a good start, but lack the
throughness that is necessary if this problem is to be solved. Solutions to the
safe disposal of pesticides wastes and containers based on current technology
will probably follow procedures currently developed and in use in solid wastes
programs. These will have to include farm-ranch premises storage, transport
to centrally located transfer stations and to a final disposal or container
refurbishing site. Most states in region six will be fortunate if they can main-
tain a few areas in a state for hazardous materials disposal. These sites
.should pass scrupulous inspection, have hydrologic, geologic, and detailed
-engineering studies done prior to use. Operators at the disposal sites should
' undergo rigorous training, the sites and operators should also be monitored
for pesticides during the operating season. All disposal sites should be recorded
at the county clerks office and a detailed list of materials disposed in the site
should be maintained for inspection of the enforcing agency.
Concurrently a great deal of effort should be put forth by the Environmental
Protection Agency to improve packaging and containerization of hazardous materials,
I think you will have to also face the problem that the disposal of pesticide
wastes and containers will be expensive, and frankly I don't see how some
sparsely settled states can afford it. Revolving funds might work, but their
'use has some inherrent problems. If you recall the experience in Montana re-
cently-I believe the cost of disposal of materials in one epidode was over two
thousand dollars.
r
I think your idea of establishing a state/federal hazardous waste committee
is good, but would suggest that you place a limited number of consumers on
the committee.
U4
-------
r«-v
jOivid A. Wagoner
1973
" &>J
'#«$
-. 1 (. J-'J *
not overlook the possibility of using some of the extension people
tate Agricultural Schools in trying to carry out the mission. There
excellent state wide network available and I am sure you would receive
|ent cooperation from them in all states in the region.
, as you well know new methods of pesticides wastes disposal must be
I think the time is ripe for renewed interest and funding in this
The research should be removed out of the laboratory to the applied
n at hand. If this is done vigorously we should have improved answers
; most important problem in the immediate future.
"oup is to be congratulated on coming to grips with the pesticides
Jisposal problem.
Sincerely,
Eldon P. Savage, Ph.D.
Chief, Chemical Epidemiology Section
Institute of Rural Environmental Health
i*Lr* '*"!
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L'.!':,$!M
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115
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