dispose
0,
                      icide

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An environmental  protection publication (SW-519)  in the solid waste
management series.  Mention of commercial  products does not constitute
endorsement by the U.S.  Government.   Editing and  technical  content of
this report were the responsibilities of the Hazardous Waste Management
Division of the Office of Solid Waste Management  Programs.
                                                                          4
Single copies of this publication are available from Solid  Waste
Information, U.S. Environmental Protection Agency, Cincinnati, Ohio 45268.

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DISPOSAL OF DILUTE PESTICIDE SOLUTIONS
   This report (SW-519) was prepared
           by Harold R. Day
 U.S. ENVIRONMENTAL PROTECTION AGENCY

                  1976

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                             TABLE OF CONTENTS


Summary                                                              1

Summary Table of Disposal Methods                                    3

I.    Introduction                                                   4

II.   Identification of Sources                                      4

       A. Container Rinsate
       B. Equipment Washing
       C. Water From Fires
       D. Pesticide Spills
       E. Reconditioning Operations

III.  Potential Impacts of Improper Disposal                         7

IV.   Current Disposal Practices                                     8

       A. Use as Diluent
       B. Holding Tanks, Disposal Pits, and Dry Wells
       C. Soil Injection
       D. Chemical Detoxification
       E. Incineration
       F. Photodecomposition
       G. Batch Biodegradation
       H. Special Disposal Sites

V.    Economic Considerations                                       12

VI.   Regulations                                                   13

VII.  Current Studies on Rinsate Disposal                           15

       A. Chemical Degradation
       B. Soil Injection Studies
       C. Incineration
       D. Filtration Studies

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                                 Summary






     Disposal of dilute pesticide solutions has, in the past, been




addressed only in a general way.  This report seeks to highlight the




problem, identify sources of dilute solutions, describe current disposal




practices, and consider factors which influence a choice among them.




     These dilute solutions are generated by container rinsing, equipment




washing, water from pesticide fire-fighting operations, spill clean-ups,




and drum reconditioning operations.  If disposed of carelessly, the




contained pesticides can build up to toxic levels in soils, deactivate




sewage treatment plants, etc..




     Nine disposal methods currently in use have been identified and are




discussed.  These methods together with their characteristics are




summarized in Table 1.




     Incineration and batch biodegradation are limited by high cost,




complexity, and low availability.  For these reasons, they are generally




restricted to treating process waste from manufacturing operations.




     Photodecomposition and chemical degradation can be effective under



correct conditions, but neither provides complete assurance of degradation




for all pesticides and their degradation products.  Lagooning is one




method used principally by manufacturers to provide light for photo-




decomposition to occur.  Chemical degradation requires specific reactants and




procedures for each pesticide, but reaction products also must be disposed




of safely.



     Soil injection and gravel-filled pits are primarily biodegradation




methods.  Given enough time, organic pesticides degrade to innocuous products,

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However, the conditions needed for optimum decomposition of all pesticides



and their metabolites are extremely variable and not well defined.  A potential



for water contamination through leakage or leaching from a disposal site



exists unless its location and method of operation will reduce mobility,



avoid contact with groundwater, and promote biodegradation.  Because no



pretreatment is needed, this method is low cost.



     Long term storage in special land disposal sites offers a last resort




to the disposer.  In addition to being costly,  this option may not lead




to degradation of the pesticide, but merely isolate it from the environment.




Special land disposal sites are generally unavailable and user fees may be




high; however, for some pesticide solutions, particularly the inorganic




and heavy metal types, this option may be the best answer.



     Whenever possible, use of dilute solutions as a diluent for making




up spray mixtures, is the most reliable and desirable method for disposal.



Other methods discussed here are potentially valuable and should be explored.



The choice of method will depend on the nature  of the pesticide, the concentration,



local disposal costs, and destruction assurance.  The reliability, safety,



and disposal parameters for dilute pesticide solutions are the subject of



current studies.

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Method
Use as diluent
in spray tank

Incineration
Soil Injection
                                           TABLE 1
                        SUMMARY OF CHARACTERISTICS OF DISPOSAL METHODS
                                FOR DILUTE PESTICIDE SOLUTIONS
Cost
Availability   Ease of Method  Environmental Hazards and Comments
None
High
Low
    High
    Low
    High
Photodecomposition
Chemical
degradation
Batch Biodegradation


Disposal pits




Special landfills


Storage
None
Moderate
    High
    Variable
High
    Low
Moderate    Low
Moderate    Low
Moderate    High
  Easy
None(if used according to label)
Moderately,  None(if incinerator is adequate)
difficult

  Easy       Miniraal(at low rates); requires
             variable time for destruction,
             and may restrict crop rotation.
             Water contamination possible
             at improper sites.

  Easy       Unreliable and generally incomplete
             degradation.  Soil  erosion may
             transport pesticides to surface
             waters.

Moderate     Chemical method must be specific
             for the pesticide in question.
             Reaction may not be complete.
             Disposal of reaction products
             necessary.

Difficult,   Not generally available; too
complex      complex for present general use.

  Easy       May be more effective than soil
             injection.  May contaminate ground
             or surface water if not constructed
             or sited properly.

Moderate     May not degrade pesticides;
             landfills may not accept liquids.

Easy         Merely delays disposal.

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I.  Introduction
     This paper draws together current information on the subject of disposal
of excess dilute pesticide solutions.   Such solutions are comprised of unused
spray, container rinsate, equipment washings, spill  clean-ups, etc., and
are defined as equal to or less than the recommended application concentration.
This effort seeks to identify the sources of these solutions, current disposal
practices, environmental hazards, and  costs of disposaJmethods available.
Federal regulatory efforts regarding pesticide disposal  and current research
on disposal methods are briefly summarized.
     This paper reflects the current state-of-the-art and has been
gathered from sources within and outside the U.S.  Environmental Protection
Agency (EPA).  Information presented is intended for information only,
and should not be construed as Agency  policy.
II. Identification of Sources
     There are five major sources of dilute pesticide solutions requiring
disposal:
A.  Container Rtnsate
     Residues from rinsing of noncombustible pesticide containers are a large
source of excess pesticide solutions.   It has been estimated that farmers
used 630 million pounds of pesticides  and 20 million noncombustible
containers in 1966, the latest estimates available.    Current EPA and industry
recommendations call for triple-rinsing of such containers prior to
disposal.   The procedure is to make three successive rinses each with
a volume of the normal diluent equal to 10 percent of the container volume.
Assuming that all applicators rinsed their 1-, 5-, 30-,  and 55-gallon
containers in 1966, 6 million gallons  of solution  containing some
pesticide would have been generated.
                                       4

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With current pesticide use in this country estimated at about 1 billion

pounds, the number of pesticide containers has probably increased

significantly.

     In real practice, few applicators rinse their containers prior to

disposal.  In a recent survey of Iowa cooperatives, for example, it was
                                                           1
estimated that only five percent of  the applicators did so.  In these cases,

the most common method of rinse disposal was to drain to the soil surface.
                                                 2
     In recent years, through the efforts of EPA,  the U.S. Department

of Agriculture (USDA), the National  Agricultural Chemicals Association

(NACA), the Western Agricultural Chemcals Association (WACA), and some

container reconditioners, the applicator has been urged to triple-rinse

containers so they will be safer to  handle for reuse, recycling, or disposal,

Only a very small amount of  pesticide residue remains within the containers

which  are triple-rinsed immediately  after being emptied.  Hence triple-

rinsed containers are considered acceptable for disposal in a sanitary

landfill.  Applicators are being told it is economically advantageous

to rinse containers; all the pesticide is utilized and the container

can be sold more easily or disposed  of in a sanitary landfill.  Some

container recondtioners will not take unrinsed containers.

     Other recent developments of a  regulatory nature will promote

triple-rinsing.  State laws  may require it.  New label directions will

require it as party of the reregistration process, and certification

training will increase the applicator's awareness and stress the

advantages to be gained.

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B.  Equipment Washing
     Another source of dilute pesticide solution is the washing or rinsing
generally with water, of application equipment including spray tanks, mixing
tanks, holding tanks, trucks, and airplanes.   The volume generated is
difficult to estimate because rinsing practices  and equipment differ with
each applicator.   One source has estimated that  aerial  applicators in the
United States use 100 million gallons of water for washing  per year and
another 2,500 custom applicators use about 6  million gallons  of water.3
Various estimates indicate that about a million  farmers are users  of
pesticides; most generate waste water containing some pesticide in washing
out their application equipment.  According to the Iowa survey, most farmers
allow the rinsate to drain on to the soil surface.
C.  Water f ran Fires
     An uncommon but real problem which can arise is a fire associated
with stored pesticides.   Water in large volumes  from a firefighting
operation becomes contaminated after contact  with uncombusted or partially
combusted pesticides.  Recent cases of such fires in Minnesota and West
Virginia have highlighted this potential source  of large volumes of water
containing pesticide.4'5  In the Minnesota case, 40,000 gallons of contaminated
water were recovered.  The disposal was complicated because many different
pesticides were present, each with its own hazards and degradation
characteristics.   In some cases absorbents can be used to hold the waste,
but then such materials  will need disposal.  The West Virginia case
generated 750,000 gallons of water which was  sealed at the  site with
concrete.
                                    6

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D.  Pesticide Spills

     Spills of pesticide often demand quick action, particularly if the

pesticide is highly toxic.  Applications are made of lime, absorbents,
                                                      5
or other chemicals including liberal amounts of water.    Contained spills

often are cleaned up, and residues and solutions placed in containers for

disposal.  Between 1971 and 1973, 35 spill incidents involving pesticides

were reported to EPA.

E.  Reconditioning Operations

     A drum reconditioner uses chemical rinses, fire, shot blasting,  and

special machinery to clean and straighten old steel drums for reuse,

including some which formerly contained pesticides.  The reconditioner

usually first deheads the drums and washes the interior prior to

burn-out.  It is estimated  that about 5 million pesticide drums are

reconditioned per year requiring 5 million gallons of water.   This

wash water, containing some pesticide and other chemicals, is commonly

disposed of via the sewer system.  However, the Federal Water Pollution

Control Act regulations will limit this practice and Federal  Insecticide,
                                                     g
Fungicide and Rodenticide Act, as amended, regulations   will  prohibit it.

Therefore, safe alternatives will have to be found for  disposal  of these

solutions.

III.  Potential Impacts of Improper Disposal

     Improper disposal of dilute pesticide solutions can present a

hazard to man, livestock, crops, and the environment.  Dilute solutions

have been shown to result in fish kills and destruction of other aquatic

fauna.

                                     7

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     Contamination of surface water by directly emptying rinsate into
ponds, lakes, and rivers could result in a concentration of pesticide
lethal to fish and other aquatic life.
     Indiscriminate dumping in soil could indirectly contaminate wells,
water supplies, and flora in an area.   Soil  microorganisms could also
be adversely affected.  Such contamination can be difficult and expensive
to correct.
     Pesticides which are persistent (resisting degradation) could
accumulate in soil and serve as a reservoir for chronic contamination.
Additionally, metabolites of pesticides can  be as toxic as the pesticide
and resist degradation.   These factors emphasize the need for great care
in disposal to avoid polluting surface and subsurface waters.
IV.  Current Disposal Practices
A.  Use as Diluent
    Using dilute pesticide solutions as a diluent for spray mixtures
is the most economical,  easiest, and most desirable disposal method. With
this practice, the material is utilized for its original intended purpose.
It has long been recommended by Government and industry authorities, and
assures that the pesticide is used according to label directions.  Economically,
the applicator benefits  because he is able to utilize the quantity of
pesticide that normally remains in the container after draining (a cup or
more; enough for 1/2 acre in some cases).  The rinsed container can then
be recycled, reused, or scrapped and is safer to handle.  Costly methods
of disposal are avoided  since this preferred disposal method can be accomp-
lished on-site where the spray mix is prepared.
                                     8

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B.  Holding Tanks, Disposal Pits, and Dry Wells
     Methods of disposal utilizing a receptacle in the ground have
been used by some applicators for pesticide solutions.  In some cases  ,
a dry well filled with aggregate rock is used.  The rinsate is allowed to
drain from equipment, flow over aggregate, and eventually seep into the soil.
A variation of this is a concrete-lined pit filled with stones, gravel, etc.
The spraying equipment is placed directly over the rocks and rinsed.   The
rinsate is held in the pit, and the water evaporates.   Biodegradation
may also take place, but no firm evidence of how or at what rate this
process occurs is available.  Buried septic tanks and leaching fields
are also used.  Lagooning is less desirable because volatile pesticides
are exposed on the surface.  In this method, rinsate is stored in an
impoundment and allowed to evaporate; some degradation (by photolysis)
may take place.
     None of these methods have been shown to be completely reliable
or safe.  Concentration by evaporation can lead to dangerously potent residues.
Holding tanks and pits may contaminate subsurface water, and lagooning
exposes the environment directly to pesticide wastes.   More testing
of these methods is needed to establish parameters for biodegradation
by these methods.
C.  Soil Injection
     Injection of dilute organic pesticide solutions by ordinary farm
implements (plows, harrows, etc.) beneath the surface of the soil into the
plow layer takes advantage of the biodegradation ability of soil microorganisms
If the concentration is dilute and spread over a large area, degradation of
                                    9

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many organic pesticides occurs rapidly.  Soil microbes such as fungi and
bacteria can be acclimated to use toxic organic substrates as energy sources.
The variables affecting this process are difficult to measure and quantify;
soil moisture, organic matter content, base exchange capacity, and temperature
are all important to the biodegradation process.   Further, a mixture of
pesticides can effectively reduce a soil micro-flora population.  More
hard data are needed to obtain a clearer picture  of the variables involved
in soil degradation.  Potentially, the soil injection method is the least
expensive option open to applicators.  No special equipment is needed; no
transportation costs are incurred.  Hie most desirable fact is that many
organic pesticides are eventually destroyed, although the time required will
vary with the conditions and the chemical characteristics of the pesticide.
D.  Chemical Detoxification
     Dilute pesticide solutions also can be degraded chemically, Organophos-
phates, carbamates, and other pesticide classes are susceptible to chemical
action such as acid or alkaline hydrolysis and chemical oxidation or
reduction.  Most pesticides can be degraded chemically but many require
exotic reactants and conditions.
     The problems encountered in chemical degradation are two-fold.  First,
each pesticide possesses specific chemical characteristics, and a chemical
method must be specific to it.  Edgewood Arsenal  reports that  no universal
chemical is effective against all pesticides . A second problem is that
chemical action is not complete, thereby leaving  unreacted pesticide.  In
some cases, reaction byproducts formed are as hazardous as the original
pesticide.
                                    10

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      Pursuant to FIFRA registration  and  label  regulations,  pesticide

 producers  will  be asked to  find  simple methods  for  disposal  of

 their pesticides, and  put appropriate directions  on  the  label of  the

 container.   In  some  cases,  where chemical methods are dangerous (e.g., where

 highly toxic  products  are formed or  dangerous  reactants  and  conditions are

 used),  specific  warnings also  should be  made.

 E.   Incineration


      Destruction of  dilute  organic pesticide solutions by incineration

 is an  effective  method if sufficiently high temperatures and suitable
                       I O
 dwell  times are  used.  IIL  Also,  adequate emmission controls  (scrubbers, etc.)

 must  be present.   The  largest  drawback to this method is the large

 expenditure of energy  needed to  drive off the solvent (commonly water).
                 "I o
 Few incinerators10 in  this  country are capable of meeting the stringent

 requirements  of  a  pesticide incinerator  (1000 C, 2 seconds dwell-time),

 and their  availability  to most applicators is low.

 F.  Photodecompos i ti on

     Studies  have  shown that some pesticides exposed to  light may be degraded

 or altered.   When  placed on the  soil surface or in a lagoon, photode-

 gradation  reactions  produce materials which are undefined in many cases

 as well as reactions which often are incomplete.  However, in some cases

 (e.g., atrazine),  it may be a desirable first step before soil  degradation.

 6.  Batch  Biodegradation

     Biological  degradation of pesticides in solution has been  the subject

of previous investigations.   Results indicate that Parathion and 2,4-D

can be completely degraded in controlled culture media.   Major drawbacks

                                     11

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are slowness, expense, and complexity of the system.  Cultures of micro-
organisms, which can produce enzymes that degrade pesticides, are subject
to contamination and mutation limiting their activity. '4>15  jne cultures
must be isloated and maintained; generally, only one pesticide can be
degraded at a time with a specific microorganism.  Expense and complexity
has restricted this method to laboratory experimental units and pesticide
production and formulation plants.
H.  Special Land Disposal Sites
     Dilute pesticide solutions may be disposed of in a land disposal site
which is designed and approved to accept hazardous wastes.  Such sites are
designed to avoid groundwater contamination, are secure,  and any leachate
generated is confined to the site unless it is subsequently detoxified.
     A common method used by drum reconditioners is to place old containers
filled with rinsate in a separate part of a disposal site and surround
them with cover material.  As the containers corrode, the rinsate is absorbed
by the ground cover'6; however, little is known about the eventual fate of the
pesticide, and many disposal site operators, as well as State and local
officials, are reluctant to permit the practice.  Studies of leachate from
these specific areas of disposal site would yield useful  data.
V.  Economic Considerations
     Although improper disposal of pesticide solutions constitutes a threat
to man,  livestock,  crops, land and water, applicators, faced with the
disposal  of dilute  pesticide solutions, will seek the least expensive
                                    12

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and most convenient method available. Use as  a diluent is  the preferred


and least cost method.  The pesticide saved is worth (on the average)


about one dollar per drum, and the applicator does not have to pay disposal


costs.


     Container rinsate, water from fires, and water from spills  which


are difficult to recover and may be contaminated are usually buried or


allowed to drain to the ground.  While inexpensive initially (only the


disposer's time is considered) and convenient, this method  can be


hazardous and costly in the long term because of possible environmental


damage requiring an expensive cleanup.


     Other methods such as incineration (about $75-100/ton), chemical


degradation ($50-100/ton), and special landfill disposal (about  $30-50/ton)


are more expensive, and also may not be available to the disposer.  Some


landfills will not accept liquids.


     Soil injection and disposal pit costs are difficult to estimate.


A concrete-lined disposal pit can be constructed for about  $4500, and


may last for 5 to 10 years depending on quantities disposed.  Unlined


pits cost less. Soil injection can be accomplished with ordinary  equipment


at variable costs, ranging from $10 to 20 per hour; typically, not more


than 15 to 20 minutes would be required to inject one day's accumulation


or rinsate.


VI.  Regulations


     Over the past 2 years Federal regulatory effort relating to pesticide


disposal have been made under the authority of FIFRA, as amended.


A.  Disposal Regulations and Recommended Procedures


     On May 1, 1974, EPA published "Recommended Procedures  for Disposal

                                                  2
and Storage of Pesticide and Pesticide Containers" .  The disposal of
                                   13

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dilute pesticide solutions is addressed in a general way; the same

procedures that apply for pesticides are recommended for dilute solutions.

The procedures state that pesticide waste should be disposed (on a priority

basis) by: use as a diluent in the spray tank, incineration (organics only).

emplacement in a specially designated landfill, soil injection with EPA

Regional office guidance, chemical degradation, or storage.  These options

are regulatory for Federal agencies, but not for the public.
                                                                 8
     On October 15, 1974, EPA proposed prohibitionary regulations  which would

prohibit the worst acts of pesticide disposal—open dumping, open burning,

water and ocean dumping—and would restrict well injection ,and storage next

to food and feed.  These regulations, when final, will apply to everyone;

the disposal of pesticide containers, pesticides, and related residues

(including dilute pesticide solutions such as excess spray solutions and

rinsate) will be impacted.

B. Registration and Labeling Regulations

     New regulations for registration and reregistration of pesticides

require that labels on containers include instructions for disposal,

and manufacturers must submit proposed labels and appropriate documentation

by October, 1977.  To comply, companies will be forced to supply information

on how to dispose of the specific pesticide, the container, and the residues

thereof.  Directions for disposal will vary with the chemical  nature of the

pesticide and the size and type of container.  Open dumping, water contamination,

and food/feed contamination will be prohibited in all cases; triple
                                         14

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rinsing (or equivalent) will be a common requirement.  Disposal in
approved landfills will be required if the waste pesticides, rinsate,
or containers cannot be disposed of otherwise.
VII.  Current Studies on Rinsate Disposal
A.  Chemical Degradation
     Currently, EPA has a contract with TRW, Systems Group,Inc.,to
gather information from the literature and pesticide manufacturers on
chemical disposal of 20 widely-used pesticides.  The report
will discuss the results of reacting pesticides with common chemicals,
such as caustic soda and hypochlorite, and identify those products that
applicators can safely degrade.  Equally important will be the
identification of products that can be safely handled only by experts.
The output will be in language and terms that can be readily understood
by applicators, and will furnish basic guidance and precautions to be
observed.
B.  Soil Injection Studies
     Oregon State University (OSU) recently completed an EPA-sponsored study
on the effectiveness of triple-rinsing and residue disposal.    The soil
injection study utilized a pesticide manufacturing waste (mainly 2,4-
dichlorophenol), and the results are indirectly applicable to soil
injection of dilute pesticide solutions.  The work indicated that
the method is more effective when low rates (500 pounds per acre or less)
are injected and sufficient time (18 months or more) is allowed for
degradation to occur.
                                   15

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C.   Incineration

                                                                12
     Midwest Research Institute (MRI) recently completed a study


on  combustion of pesticides.   The study shows that high temperatures


(1000 C) over sufficient time (2 seconds)  effectively decompose organic


pesticides and destroy intermediate products formed at lower temperatures.


Adequate emission control devices must be  present to prevent release of


hazardous combustion products (e.g., HC1)  to the environment and to prevent


damage to equipment.  Limiting factors are temperature, time, excess air,


and turbulence.


D.   Filtration Studies


     OSU, as part of their final report, included a study on deactivation


of dilute pesticide solutions by filtration.  Preliminary results  indicate


that activated carbon, dried  sewage sludge,  pine bark dust,  and synthetic


resins can be used to reduce  pesticide concentrations in aqueous solutions


to one part per million or less.  Major advantages are transfer of


contaminants to a solid phase and volume reduction.  Filtration material


can be disposed of by regeneration, incineration, by burial  in a designated

                                   18
landfill, or by soil incorporation.   None of these filtration methods has


been investigated in detail.
                                16

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                                REFERENCES
1.  Arthur D. Little, Inc. Economic analysis of pesticide disposal methods;
      final report. Washington, U.S. Environmental Protection Agency, Strategic
      Studies Unit, Mar. 1975. various pagings. (Unpublished report.)

2.  U.S. Environmental Protection Agency. Pesticides and pesticide containers;
      regulations for acceptance and recommended procedures for disposal and
      storage. Federal Register, 39(85):15235-15241, May 1, 1974.

3.  Personal communication. A. Johnson, Air Enterprises, Inc., to H. R.  Day,
      Office of Solid Waste Management Programs.

4.  Personal communication. Region V, U.S. Environmental Protection Agency,
      to H. W. Trask, Office of Solid Waste Management Programs.

5.  Personal communication. Fire Marshall, Charleston, W. Va., to H. R.  Day,
      Office of Solid Waste Managment Programs.

6.  Moore, E.E. Disposal of unwanted excess pesticides and empty containers.
      Journal of Environmental Health, 36(3):238-243, Nov.-Dec. 1973.

7.  Personal communication. National Barrel and Drum Association to H. R. Day,
      Office of Solid Waste Management Programs.

8.  U.S. Environmental Protection Agency. Pesticides; EPA proposal on
      disposal and storage. Federal Register, 39(200) :36847-36950,
      October 15, 1974

9.  Guenzi, W. D., ed. Pesticides in soil and water. Madison, Wis.,
      Soil Science Society of America, Inc., 1974. 562 p.

10. Personal communication. H. J. Stockdale, Iowa State University, to
      H. R. Day, Office of Solid Waste Management Programs.

11. Dennis, W. H., Jr.  Methods of chemical degradation of pesticides and
      herbicides—a review.  Edgewood Arsenal, Md., Army Medical Environmental
      Engineering Research Unit, Oct. 1972.  36 p.  (Distributed by National
      Technical Information Service, Springfield, Va., as AD-752 123.)

12. Ferguson, T. L., et al. [Midwest Research Institute]. Pilot scale
      incineration of pesticides, v.2. Washington, U.S. Environmental
      Protection Agency, Office of Research and Monitoring, 1975.
      Iv.(various pagings). (Unpublished report.)
                                   17

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13. Farb, D., and S.D. Ward. Information  about  hazardous  waste management
      facilities, Environmental Protection  Publication SW-145.
      [Washington], U. S. Environmental Protection  Agency,  Feb.  1975.
      130 p.

14. Munnecke, D. M., and D. P- Hsieh. Microbial decontamination
      of parathion and p-nitrophenol in aqueous media.  Applied
      Microbiology, 28(2):212-217, Aug. 1974.

15. Stanford Research Institute. Unpublished data.

16. Pierce, R. H., C. E. Olney, and G.T.  Felbeck, Jr.  Pesticide
      adsorption in soils and sediments.  Environmental  Letters,
      1(2) :157-172, 1971.

17. Goulding, R. L. Waste pesticide management;  July  1, 1969-June 30, 1972,
      and Jan. 17, 1974-June 30, 1974.  [Washington],  U.S. Environmental
      Protection Agency, Office of Solid  Waste  Management Programs,
      June 30, 1974. 269 p. (Unpublished  report.)

18. Personal communication. U.S. Environmental  Protection Agency
      Laboratory, Edison, N.J., to H. R.  Day. Office  of Solid  Waste
      Management Programs.
                                                            MCT1299
                                                            SW-519
      -& U.S. GOVERNMENT PRINTING OFFICE: 1976- 625-55/434
                                      18

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