Office of Mater Planning and standards
U. S. Environmental Protection Agency
401 M Street, s.w.
Washington, D. C. 20460
June 1976

This is a report on wastewater management and associated
costs at facilities formulating the pesticides aldrin/dieldrin,
DDT, er.drin and/or toxaphene. The information included was
developed under EPA Contract No. 68-01-3524 (MRI No. U1227-C)
by the Midwest Research Institute and particularly Section V by
the Environmental Protection Agency.

Sections	Pa-ire
I.	Summary	1
II.	Industry Characterization	5
The Pesticide Forirulation Industry	6
Designated Pesticide Fornulations	11
Aidrin/Dieldrin	24
DDT	25
Er.drin	26
Toxaphene	27
ill. Wastewater Characterization	29
Water Use	29
Wastewater sources	34
Wastewater Characteristics	39

Sections	Pane
IV.	Wastewater Management- yethcd
A "i
In-Plant Control Technology
r j
Current Wastewater Management
V.	Technology and Estimated Costs	^ 1
Options fcr Compliance	6 2
Selection of Operation Moiels	6 5
for Cost Estimation
Estimate cf Model Plant	^8
Compliance Cost Impacts
References	72

Estimated Poet Area, Xodel
Formulation Plant, Li .raid
and Dust Operaticr.3
Estimated Installed Capital
Equipment Costs, Model
Formulation Plants, Roof,
Slabs and Curbs
Estimated Total Annual
Operating Costs, Model
Formulation Plants, Roof,
Slabs and Curbs

Larqe formulation plant
Product distribution for
large formulation plants
Distribution of plants by
Liquid formulation unit
Typical sulfur grinding
Process for formulating
Aldrin/dieldrin formulation
plants (197 J)
DDT formulation £:lant (1973)

Endrin formulation plants
Toxaphene formulation plants
Formulation plants using
evaporation treatment systems

Holding-Evaporation Systems Design,
Technology and Estimated Associated
Costs, Worst Case Situation
Summary of Contracts with Pesticide
Formulators (January-February 1976)
iMemoranda of Plant Visits
Stauffer Chemical company, Omaha, Neb.
Triangle Chemical Company, Macon, Ga.
The Helena Chemical Ccrp., Cordele, Ga.
Parrainore and Griffin Co., Valdosta, Ga
FMC Corporation, Jacksonville, Fla.
Asgrow Florida Company, Plant City, Fla
Helena Chemical Company, Tampa, Fla.

Control of the four pesticides designated as toxic
pollutants affects only a small segment of the total pesticide
formulation industry. In 1975 5,300 plants produced pesticide
formulations nationwide. Only 182 plants produced formulations
of the designated pesticides: aldrin/dieldrin, 9 plants; DDT, 1
plant; endrin, 39 plants; and toxaphene, 133 plants.
Unlike manufacture of the technical pesticides, formulation
of products containing aldrin/dieldrin, DDT, endrin or
toxaphene cannot be segregated readily from the rest of the
pesticide formulation industry. It is necessary, therefore, to
characterize the entire pesticide formulation industry as well
as that segment formulating products containing the specified
pesticides in order to assess applicable wastewater treatment
This report provides a discussion of the pesticide
formulation industry and is divided into four sections: (a)
industry characterization; (b) wastewater characterization; (c)
wastewater management methods; and (d) formulation wastewater
management costs. Sections (a), (b) and (c) discuss both the
total formulation industry and the segment of the industry to

be affected by proposed standards. Section (d) presents
estimated costs of wastewater management technology determined
by this study to be the most feasible methods for controlling
discharges of the designated pesticides to the navigable
(a) The industry is characterized according to its
structure, the number and types of formulations and the kinds
of formulating processes. The structure study shows the
ownership patterns, the geoqraphic distribution of the total
industry and the geographical location of the affected
The total number of formulated products produced in 1975
was 23,633, including emulsifiable cpncentrates, powders,
granules and aerosols. These formulation processes are
discussed in general along with examination of products and
processes applicable to the four pesticides of particular
interest here.
Formulated pesticide products registered in 1973 included:
37 containing aldrin or dieldrin, of which 35 to 40% were
emulsifiable concentrates and 35 to 40'A were granules; 5
containing DDT, about 9054 of which were wettable powders; 27
containing endrin, about 90% of which were emulsifiable

concentrates; and 161 containing toxaphene, about 90% of which
were emulsifiable concentrates and wettable powders.
(b)	The usage of water and the sources of wastewater in
formulation plants are examined and methods for their reduction
or elimination discussed.
(c)	Wastewater treatment methods used throughout the
pesticide formulation industry are examined. A discussion is
presented of in-plant control technology to eliminate use of
water and to minimize contamination of any wastewater
generated. Past and present practices such as evaporation
systems, sewer systems, landfill, contract disposal, activated
carbon adsorption, and incineration, are described. Process
wastewater management methods are described which are intended
to achieve zero discharge of aldrin/dieldrin, DDT, endrin, or
toxaphene. These systeirs include (1) elimination of process
water, (2) evaporation systems, and (3) contract disposal.
Kainwater runoff management methods are described which are
intended to achieve zero discharge of the designated
pollutants. These include the covering over of all formulation
operations, the removal or paving over of contaminated soils,
and diversion of "clean" runoff.
(d)	Model formulating plants are developed using the
technology of complete elimination of wastewater generation

combined with roof cover requirement over all processes to
prevent contamination of stormwater runoff. Estimates of
installed capital equipment and annual operating costs, based
upon the models, are presented.

Pesticide formulation is the segment of the agricultural
chemical industry (SIC 2879) that transforms bulk technical
active ingredient into packaged forms ready for use. Two major
operations are required to effect this transformation: the
technical material must be blended (formulated) with the
additives and inert carriers appropriate for each registered
use; and the formulated material must be packaged in
appropriate containers for each kind of user. The term
"formulation industry" is used here to include both of these
operations because they are sequential steps normally conducted
in the same plant.
For purposes of evaluating wastewater treatment technology,
however, formulating that is done at the same plant site as the
production of the active ingredient (i.e., satellite units of a
production facility), has not been included here. Such
activity is considered as part of a pesticide manufacturing
plant since the wastewaters are normally treated together.

Unlike manufacture ot the technical pesticide, formulation
of products containing a specific pesticide cannot be readily
segregated from the rest of the pesticide formulation industry.
It is necessary, therefore, to characterize the total pesticide
formulation industry as well as that segment formulating
products containing aldrin/dieldrin, DDT, endrin, or toxaphene
in order to assess applicable wastewater treatment technology.
Much of the general industry characterization contained
herein has been taken from Ferguson (1975). Information
developed during this study has been used to characterize the
appropriate segment of the formulation industry.
The formulation industry characterization is discussed in
two sections; (a) the overall pesticide formulation industry;
and (b) formulation of products containing aldrin/dieldrin,
DDT, endrin and toxaphene. Major considerations in each of the
two sections are: industry structure; pesticide formulations;
and formulation processes.
Industry Structure

Historically* the formulation industry has been such a
dynamic one that detailed characterization of its organization
and operation is difficult. The question, "Who formulates a
given active ingredient, and in what quantity?," will have a
different answer almost every year. According to Shiroishi
(1975), there are currently about 5,300 plants producing
pesticide formulations. The companies owning these facilities
range in size from those who have one registered product to
those who have hundreds.
Ownership Patterns - Formulation plants can be categorized into
three groups: the active ingredient producer-formulator, the
independent formulator, and the small packager-
The producer-formulator is also referred to as an
integrated producer. Such a company not only manufactures the
pesticidal chemicals, but also formulates them in its own
facilities. Frequently, formulating is done on the same plant
site as the production ot the active ingredient. Such
formulation plants (i.e., satellite units of a production
facility) have not been included in this study because their
wastewater, if any, is treated with the manufacturing
wastewater. Producer-formulator plants may also be located

away from the production site of the active ingredient, e.g.,
close to or within the -regions where the company's products are
used. These companies may formulate the company's own products
exclusively, or may formulate ether products on accustom basis.
The independent formulator typically produces a number of
different products for sale under his own brand name and may
also formulate products under a contractual arrangement. A
number of th
In addition to contract formulation for basic active
ingredient manufacturers, the independent formulator frequently
has contracts with independent companies to formulate under
their private labels.
The last major category of formulator is the small
independent packager for whom pesticide formulations are only a
small part of his business. According to Ferguson (1975),
these companies typically have one to five registrations in
their own name. Many of these small packagers actually
formulate their labeled products in their ovn facility. A more
practical arrangement for many, however, is to contract with
one of the local independent formulators to do the actual
Geographical Distribution - The locations of large pesticide
formulation plants identified during a study by Ferguson (1975)
are shown in Figure 1. These plants were identified in 1973
from information provided through the National Agricultural
Chemicals Association (NACA) as well as from two earlier
studies of the formulation industry and do not include those
formulation plants that are integral parts of pesticide
manufacturing facilities.

Individual Formulation Plant. Characteristjcs - Individual
formulation plants are designed to meet the specific needs of
the company and location. A wide range exists in the type of
products formulated, the rates of production and the age of the
facilities in which they are manufactured.
The types of pesticides produced can be classified in two
ways: by the chemical class of pesticide processed, or by the
fcrm of the product. Both measures are important when
considering wastewater characteristics and volumes.
A recent study (Lawless, Ferguson, and Meiners, 1975)
categorized 550 pesticidal chemicals into seven major
categories, which were further divided into 42 subcategories.
For the purpose of characterizing formulation plants, however,
pesticidal chemicals can be classed as: inorganics,
organophosphates, nitrogen-based, chlorinated hydrocarbons, and
all others. Figure 2a illustrates the distribution of product
mixtures found for 96 large formulation plants.
Pesticide formulations can also be classified as liquids,
granules, dusts and powders, and all other forms. Figure 2b

shows the distribution of 92 major formulation plants according
to this classification.
The scale on which pesticides are formulated varies greatly
among companies. Many of the small firms that have only one or
two product registrations produce only a few hundred pounds of
formulated pesticides each year. In contrast, at least one
plant has been identified by Ferguson (197 5) that made about
100 million pounds of formulated product per ysar. The bulJc of
pesticide formulations is apparently produced by independent
formulators operating in the 20 to U0 million pounds per year
The ages of formulation plants identified during the study
by Ferguson (1975) ranged from 1 to 53 years. Distribution
according to age for 10 2 large formulation plants is shown in
Figure 3.
Pesticide Formulations

Pesticidal chemicals are nonrally manufactured in high
concentration (80 to 99 + fa) that cannot be used without being
further processed into other forms. The usable forms
(formulations) of pesticides must be biologically effective as
well as safe for the applicator to handle and use. These
characteristics are obtained by dilution of the technical
active ingredient with ir.ert materials and conversion to
appropriate physical forms designed for a particular method of
application and end use.
The? number and types of pesticidal products sold, as well
as the major types of formulations, are briefly discussed in
the following.
Number of Products - The number of pesticide formulations
produced and sold in the United States is difficult to
determine accurately. Estimates have been made by Mrsk (1969)
that as many as 900 pesticidal chemicals are formulated into
over fi0,000 products. A more recent survey by Lawless* et al.
(1375) identified 550 pesticidal chemicals that are currently
or have recently been commercially available in the United

Accurate data are available on the number of pesticidal
products having Federal registration for interstate sale. In
1975 there were 23,633 products being produced under Federal
registration (Carlton, 1975).
Emulsifiafcle Concentraten - Emulsifiable concentrate (EC)
formulations are solutions ot active ingredients and
ecnulsifiers in a solvent. These formulations are diluted with
water or oil before application. Concentrations are typically
15 to 50 percent for a single active ingredient, to as high as
80 percent tor formulations containing an active ingredient
mixture. The concentration of emulsifiers is generally 5
percent or less.
Organic solvents which are used include deodorized
kerosene, xylenes, methyl isobutyl ketone, and amyl acetate.
The specific solvent selected for use depends on many factors
including solvency, specific gravity, flash point, safety to
plants and animals, volatility, compatibility, odor,
corrosiveness, and cost (Hersey, 1966).
Water is used as the solvent for some of the water-soluble
pesticides. The use of water is limited, however, and normally

only certain herbicides are formulated with a water base. No
water is used as a solvent for any formulation of
aldrin/dieldrin, DDT, endrin, or toxaphene.
Powders - Wettable or water-dispersifcle pcwders are mixtures of
active inqredients, inert carriers, surfactants, and adjuvants
that can be suspended in water for application. These powders
generally contain a high concentration of active ingredient (15
to 95%), with 1 to 5 percent concentration of surfactant to
improve wetting and susper.aability characteristics.
Soluble powders are similar to wettable powders except that
they will completely dissolve in the appropriate diluent used
in spraying. Normally, this diluent is water.
Dusts - The active ingredient concentration in dust
formulations is usually low (0.1 to 20%), and therefore, the
toxicity ot these formulations is relatively low.
Dusts have long been used becaused they are relatively
inexpensive and simple to apply. Winchester and Yeo (1968)
report that in the past few years, however, dust has become a
less important formulation because of its inherent dependence

on climatological factors that cause variability in
performance, as well as problems with drift.
Granules - Granules are prepared by the impregnation of active
ingredient on inert granular carriers such as clay,
vermiculite, bentonite, sand, ground corncobs, carbon or
diatomaceous earth. The granules are uniform in size, ranging
from 15 to 60 mesh (15 to 30, 24 to 48, or 30 to 60 m-ash) in
diameter. The content of fine particles is tightly controlled
in order to avoid creation of dust during application.
Aerosols - Aerosol formulations normally contain low
concentrations (less than 2%) of active ingredient in a
suitable solvent solution with the necessary adjuvants.
Solvents commonly used are organics such as deodorized
Miscellaneous Formulations - In addition to these major
pesticide formulations, a wide range of smaller volume products
are manufactured. These other forms include baits (strips,
grain, cubes, etc.), pastes, vapor and smoke generators,
impregnated fertilizer, tablets, and treated seed.

Formulation Processes
Most pesticides are formulated in mixing equipment that is
used only to produce pesticide formulations. Generally, the
same formulation equipment is used to produce products
containing a number of different active ingredients. The most
important unit operations involved are dry mixing and grinding
of solids, dissolving solids, and blending. Formulation
systems are virtually all batch mixing operations. Formulation
units (lines) are usually completely or partially enclosed
within a building, but may be out in the open, depending
somewhat on the geographical location of the plant.
Individual formulation units are normally^not highly
sophisticated systems that require design and construction by
an outside engineering firm. Rather, they are comparatively
uncomplicated batch-blending systems.
Liquid Formulation Units - A typical liquid unit is depicted in
Figure «. Technical pesticide is usually stored in its
original shipping container in the warehouse section of the
plant until it is needed. When technical material is received
in bulk, however, it is transferred to holding tanks for
storage. The technical material is transferred {frequently by
gravity) to a scale, where the proper quantity is weighed out

for a batch. The technical material is ther. pumped into a
batch mixing tank. This tank is frequently an open-top vessel
with a standard agitator. The mix tank may or may not be
equipped with a heating/cocling system. When solid technical
material is to be used, a melt tank is required before this
material is added to the mix tank- Solvents are normally
stored in bulk tanks located well away from the operating area
of the plant. The necessary quantity of an appropriate solvent
is either metered into the mix tank or determined by measuring
the tank level. Necessary adjuvants (emulsitiers, synergists,
etc.) are added directly from their original container to the
mix tank through the open t.op or manhole. The components of
the formulation are blended in the mix tank using its agitator
and heating/cooling system as required. From the mix tank, the
formulated material is frequently pumped to a hold tank before
being put into containers for shipment. Before being packaged
many liquid formulations must be filtered by conventional
cartridge or plate-and-frame filters.
Air pollution control equipment used on liquid formulation
units typically involves an exhaust system at all potential
sources of emission. Storage and holding tanks, mix tanks, and
container-filling lines are normally provided with an exhaust

connection or hood to remove any vapors. The exhaust from the
system normally discharges to a scrubber system or to the
Dusts and Wettable Powders - Ousts and powders are manufactured
by mixing the technical material with the appropriate inert
carrier, and grindinq this mixture to obtain the correct
particle size. Mixing can be effected by a number of rotary or
rihbon blender type mixers. Grinding is done in hammer,
impact, roller or fluid energy (air) mills. As is the case
with liquid formulation units, the exact configuration of a
specific dust or powder unit depends on the production
characteristics of the individual plant site.
Sulfur powder, for example, can be prepared in a rather
simple unit (see Figure 5). Crude sulfur is transported from
storage in open pits or in a warehouse, and loaded into a
feeding hopper which feeds a roller mill. The material is then
finely ground. The combustible nature of sulfur in air
requires that the mill system be blanketed with an inert gas.
The milled sulfur then goes to a cyclone collector from which
the finished product is discharged into holding bins before
being packaged.

Some production methods involve the use of a volatile
solvent to impregnate the active ingredient on an inert
carrier. After impregnation, the active ingredient-carrier
mixture is ground, separated in a cyclone, and packaged.
One formulation process that has been used for DDT is a
good example of more extensive processing required to produce
some products: a two-stage process is used (see Figure 6).
The first part of the process is the initial grinding of the
active ingredient (Figure 6) with silica. Flakes of technical
material are emptied from bags into a hopper, conveyed into a
crusher and mixed with finely grcund silica before being
pulverized. The coarse silica-active ingredient mixture is
then mixed in a ribbon blender. This DDT formulation requires
aging at this point before further grinding. The mixture is
then fed into a ribbon blender where additional silica as well
as wetting agents are added. This mix is conveyed to a
high-grinding mill. A. pneumatic system conveys the material to
a cyclone separator which discharges into another blender. The
blended material is finely ground by a high-pressure air mill
and conveyed to a reverse-jet bagtiouse that discharges into
another blender. Final air grinding is repeated before the
finished product is packaged.

Air pollution control in dust formulation units is
accomplished primarily by baghouse systems. In some plants,
however, water scrubbers are used. Pazar (1970) reports that
water requirements for these systems are very low because the
scrubbing water can be largely recirculated.
Granules - Granules are formulated in systems similar to the
mixing sections of dust plants. The active ingredient is
adsorbed onto a sized, granular carrier such as clay or a
botanical material. This is accomplished in mixers of various
capacity that generally resemble cement mixers.
If the technical material is a liquid, it can be sprayed
directly onto the qranules. Solid technical material is
usually melted or disolved in a solvent in order to provide
adequate dispersion on the granules. The last step in the
formulation process, prior to intermediate storage before
packaging, is screening to remove fines.
Packaging and storage - The last operation conducted at the
formulation plant is packaging the finished pesticide into a
marketed container. This is usually done in conventional
filling and packaging units. Frequently, the same liquid

filling line is used to till products from several formulation
units; the filling and packaging line is simply moved from one
formulation unit to another. Packages of almost every size and
type are used, including 1-, 2-, and 5-gal. cans, 30- and
55-gal. drums, glass bottles, bags, cartons, and plastic jugs.
On-site storage, as a general rule, is minimized. The
storage facility is very often a building completely separate
from the actual formulation and filling operation. In almost
all cases, the storage area is at least located in a part of
the building separate from the formulation units in order to
avoid cross contamination and other problems. Technical
material, except for bulk shipments, is usually stored in a
special section of the product storage area.
A few formulators are able to ship formulated products in
bulk containers to users in their immediate area. This
technique, however, is limited to a few agricultural
Formulation Processes
The formulation processes used in the general pesticide
formulation industry as described in the preceding discussion

are applicable to aldrin/dieldrin, DDT, endrin, and toxaphene
formulations. formulation plants produce a number of
registered products. A given formulation line is rarely
dedicated, that is, used for one product only. In fact, the
same line is often used to process all products formulated in a
small plant. Even in large plants, multiple products are often
formulated in "the same equipment. Thus, the formulation
processes and equipment in general use by the pesticide
formulation industry are applicable to the production of
products containing aldrin/dieldrin, DDT, endrin, and

Formulation Wastewater
Ferguson (1975) did not report data on the quantity or
quality of wastewater generated by aldriri/dieldrin, DDT, endrin
or toxaphene formulation. Contacts with appropriate Federal
and state regulatory agencies failed to yield any specific data
on the quality or quantity of wastewater generated by the
formulation plant identified by David (157 5) and mentioned
Industry structure
In 1975, as previously noted, 9 plants formulated products
containing aldrin/dieldrin, one plant formulated DDT-containing
products, 39 plants formulated endrin-containing products and
133 plants formulated toxaphene-coritaining products. The
geographical distribution of the plants is shown in Figures 7a
thru 7d which also indicate the relative amounts of these
products made at the plant shewn. (The Shell Ch-amical Company
facilities at Denver, Colorado; the Montrose Chemical
Corporation of California facility at Torrence, California; and
the Velsicol Chemical Corporation facilities at Memphis,
Tennessee, are not included because these plants manufactured,
as well as formulated, aldrin/dieldrin, DDT and endrin,

Figures? 7a thru 7d are, however, a static representation of
a dynamic industry. Production rates, products formulated, and
the formulation plants have apparently changed annually in
recent years. Fa rm Chemica Is Kar.clbcok, for example, shows the
dynamic nature of the industry: the 1973 edition lists 19
formulators of aldrin/dieldrin products, 16 of DDT products, 11
of endrin products and 20 of toxaphene products; the 1975
edition, however, lists 13 formulators of aldrin/dieldrin, 1 of
DDT, 3 of endrin and 13 of toxaphene-containing products. To
depict the current status of an industry as dynamic as this one
is thus virtually impossible, but Figures 7a thru 7d present
the best information available at this time. Precise
information on the age of these plants, their size, and their
total production is not available.
The Farm Chemicals Handbook (197 3) snows that
aldrin/dieldrin products were available in seven types of
formulations: emulsifiable concentrates, wet-table powders,
granules, dusts, seed dressings, oil solutions, and fertilizer
mixtures. The data supplied by David (1975) indicated that the

relative amounts (by weight) of aldrin/dieldrin products, by
type of formulation in 197 3 v;erP as follows:
Percent of total
Type of formulation
Emulsifiable concentrate
lettable powder
Seed dressing
Oil solution
Fertilizer mixture
formulated products
100 5
David; (1975) further reported that formulators produced 37
registered products containing aldrin or dieldrin in 1973.
Th- Farm Chemicals Handbook (1973) shows the DDT products
were available in six types of formulations: emulsifiable
concentrates, wettable pcwdcrs, granules, dusts, oil solutions,
and aerosols. The data supplied by David (1975) indicated that
the relative amounts (by weight) of DDT products, by type of
formulation in 1973 were as follows:

Percent of total
Type of formulation
formulated oroduct
Emulsifiable concentrate
Wettable powder
90 +
Oil solution
David (1975) further reported that formulators produced
five registered products containing DDT in 1973.
The Farm Chemicals Handbook (1973) and Handbook of Aldrin,
Dieldrin, and Endrin Formulations (195 9) show that endrin
products were available in three types of formulations:
emulsifiable concentrates, wettable powders, and granules. The
data supplied by David (1975) indicated that the relative
amounts (by weight) of endrin products, by type of formulation
in 197 3 were as follows:

Percent of total
Type of formulation
formulated products
Emulsifiable concentrate
VJet.table powder
David (1975) further reported that formulators produced 27
registered products containing endrin in 1973.
The Farm Chemicals Handbook (1973) shows that toxaphene
products were available in four types of formulations:
emulsifiable concentrates, wettatle pov/ders, dusts, and oil
solutions. The data supplied by David (1975) indicated that
the relative amounts (by weight) of toxaphene products, by type
of formulation in 1973 v;ere as follows:

Typ'3 of formulation
Emulsifiable concentrate
Wettable powder
Oil solution
Percent of total
formulated products
David (19 75) further reported that formulators produced 161 registers
products containing toxapher.e in 1973.

The quantity and quality of wastewater generated by a
pesticide formulation plant are determined by factors such as
the type of formulations produced, the active ingredients used,
the age and size of the facility, the plant's production
schedule, and the company's operating philosophies and
procedures. The ranges ever which these factors can vary have
been previously discussed. In this section, the effects these
factors have on wastewater generation and the characteristics
of the wastewater produced are reviewed. The discussion in the
following subsections addresses water use, wastewater sources,
and wastewater characteristics.
Water has been used for a number of purposes in pesticide
formulation plants. The trend is to use less water to avoid
water pollution problems and to control loss of active

ingredients. The goal id to eliminate the discharge of water
that might become contaminated in torrrulating processes.
Formulation Equipment Cleanup
Formulation lines, including tilling equipment, are cleaned
out periodically to prevent cross contamination of one product
with another. Infrequently, equipment must also be cleaned out
so that needed maintenance may be performed. Water or steam
has been commonly used for these cleaning operations, but
solvents are also used as a substitute for water.
Liquid formulation lines are cleaned out most frequently.
All parts of the system that potentially contain pesticidal
ingredients must be cleaned. More than one rinsing of process
vessels and piping is required tc get the system clean. As a
general rule, the smaller the capacity of the formulation unit,
the more critical cleanup becomes in order to avoid cross
contamination. Thus, larger volumes of wash water and solvents
are required, relative tc production quantity, for smaller

Granule as well as dust and powder lines also require
cleanup. Liquid washouts are generally required; however, only
in that portion of the units where liquids are normally
present, that is, the active ingredient pumping system, scales,
and lines. The remainder of these production units can
normally be cleaned out by "dry washing" with an inert
material, such as clay.
Drum Washing A few formulation plants still process used
pesticide drums so that the drums can be sold to a drum
reconditioner or reused by the formulator for appropriate
products, or simply to decontaminate the drums before
disposal. Drum washing procedures have ranged from a
single rinse with a small volume of caustic solution or
wat^r, to complete decontamination and reconditioning
processes. Awareness of the water pollution control
problems caused by use of drums has led to use of less
costly, disposable, smaller containers as well as direct
transfer from tanks (truck and railroad) to on-site storage
in bulk.

Building Washdown
For housekeeping purposes, most formulators clean out the
buildings housing formulation units on a routine basis,
frequently once each year. This could be accomplished by
careful dry vacuum cleaning and in proper circumstances,
solvents instead of water.
Air Pollution Devices
Water scrubbers are often used to control emissions to the
air, but particulates can be removed by other ireans such as bag
Spills of technical material cr process material are
normally absorbed by dry clean materials, but are sometimes
cleaned up by washing down the contaminated area. The latter
practice is being phased out as management and labor become
aware of its limitations.

Boiler Water
Stsam is frequently used for (a) space heating, (b)
formulation processing, and (c) formulation equipment cleaning.
In some cases steam is used to accelerate the evaporation of
stored wastewater.
Cooling Water
Cooling water is used by several processes found in
pesticide formulation plants. Cne of the most common uses is
to cool air compressors used in conjunction with air mills that
produce wetrahle powders. Cooling water is also required by
many of the roller mills used for dust production.
Control Laboratories
Most of the larger formulation plants have some type of
control lab on the plant site. The control analyses performed
range from simple determinations of specific gravity to
complete spectrophotometry analyses. Water use in the control
laboratories can range from an insignificantly small amount to
a rather large amount, depending upon many circumstances.

Sanitary Wastes
Sanitary wastes are generated at virtually all formulation
plants. This category may include not only toilet and sink
wastes, but also the wastewater generated from shower
facilities and wash water from work clothes processed on the
plant site.
Formula Water
Some liquid formulations contain water as their base.
Primarily, herbicides are formulated in this manner. The
formula water used in these formulations accounts tor a major
part of the water consumed by many formulation plants.
However, aldrin, dieldrin, endrin, DDT and toxaphene are not
marketed as water-based formulations.
The sources of wastewater produced by a formulation plant
include not only the plant's use of water, but also the natural
occurrence of rain water runoff. Both can be significant
sources of contamination that must then be disposed of without

causinq water pollution. Each of the water uses given above
and runoff are examined below tc shew the pollution potential
of each wastewater source.
Formulation Equipment Cleanup
The major source of contaminated wastewater from pesticide
formulation plants has been equipment cleanup. Solvents
instead of water can be used to clean mixing tanks, formulation
lines, filling equipment, etc.
Drum Washing
Wastewaters from drum washing operations are contaminated
and must be added to other processing wastewater for treatment.
The volume of water for this operation is not usually large,
but the water is usually highly contaminated with pesticide,
highly caustic solutions have been used for some washing
operations, and this factor must be considered in disposing of
the wastewaters. As stated earlier, reuse of drums or other
containers requiring cleaning is disappearing.

Building Washdown
New, higher standards of cleanliness and general good
housekeeping are being accepted in plants thereby reducing the
need to wash down formulation unit space following thorough
sweeping and vacuuming.
Air Pollution Control Devices
Water scrubbing devices generate a wastewater stream that
is potentially contaminated with pesticidal materials. One
type of widely used air scrubber is the roto-clone separator.
In this device, air is cleaned by the combined action of
centrifugal force and mixing. Although the guantity of water
in the system is relatively high (about 20 gal/1,000 cfm)r
Pazar (197 0) reported that water consumption can be kept low by
a recycle-sludge removal system. Effluent from air pollution
control equipment should be combined with other contaminated
wastewater for ultimate disposal.

If the spill area is dry cleaned instead of washed down, an
increment, to plant wastewaters is eliminated.
Boiler Water
Blowdown water from the boiler system, as well as steam
condensate that is not recycled, is generally free of toxicant
contamination. These streams, if kept isolated, can be
disposed of with other noncor.taminated streams.
Condensate from steam cleaning equipment is not returned to
the heating cycle, since it is contaminated and must be managed
properly to preclude water pollution. Solvent cleaning is one
substitute for steam cleaning.
Cooling Water
Effluent from the cooling water loop is generally free from
significant contamination, and if kept isolated, can be
discharged from the plant site in the sanitary waste or
conventional drainage system.

Control Laboratories
Wastewater from the control laboratories can be discharged
into the sanitation system provided the noncontaminated
wastewater (sanitary facilities, water fountains, etc.) is
segregated from the contaminated wastewater (laboratory sinks,
floor drains, etc.). The contaminated wastewater must be
managed to avoid discharge to water courses.
Sanitary Wastes
Normally, this waste stream is treated as conventional
sanitary waste and discharged into municipal sewage treatment
or septic tank systems. It is usually uncontaminated.
Natural runoff from the plant sites can be significant. In
some plants, formulation units, filling lines, and storage
areas are located in the open. The runoff from these
potentially contaminated areas, as a rule, cannot be assumed to
be free of pollutants and should not be allowed to flow freely
from the plant site. Runoff from areas previously contaminated

can contain high levels of pesticide even when the particular
product is no longer being formulated.
Runoff presents a problem even it it is intercepted and
diverted into a holding-evaporation or treatment facility since
it can readily overburden the system because of hydraulic
Areas demonstrated to be free of contamination can be
allowed to drain naturally from the plant site.
This section of the report summarizes available information
on the wastewater characteristics of pesticide formulation
General characteristics
Data on the volume and quality cf process wastewater from
pesticide formulation plants are virtually nonexistent. Only
two literature sources were found in this study that
specifically address the subject cf wastewater characteristics

of pesticide formulation plants. Ferguson (1975) performed a
study on formulators and packagers for the Environmental
Protection Agency.
Ferguson (1975) examined 10 formulation plants and found
that these plants generated from less than 1 to more than 25
gal. of wastewater per ton of formulated product. Volumes of
wastewater near the top of this range were generated by plants
that isolated the runoff as well as those who did not. Details
of the methods used to conserve water are lacking.
Formulation Process Wastewater
Ferguson (197 5) did not report data on the quantity or
quality of wastewater generated by aldrin/diellrin, DDT, endrin
or toxaphene formulation. Contacts with appropriate Federal
State Regulatory agencies failed to yield any specific data on
the guality or quantity of wastewater generated by formulation

Rain Water Runoff
The volume of runoff that might need to be intercepted,
held and disposed of is influenced by several natural factors.
These include:
(a)	Areas subject to runoff
(b)	Balance between long-term rainfall versus evaporation
(c)	Extraordinary, heavy precipitation events
(d)	Surface imperviousness of runoff area
The degree of contamination of runoff by pesticides is
largely a factor of surfaces that have been contaminated and
the extent of that contamination.
Some idea of the larqe volume of rain water runoff involved
can be gained by examination of the table below. For each inch
of stormwater falling on each acre (net rainfall plus a design
storm event occurrence of precipitation during a 24-hour period

once every 10 years) 75 gallons of water would accumulate and
need to be disposed of on an everage day.
4 3,560 sq. ft. x 1__ ft. x 7.5 gal/cu ft
acre	12	 = 75 gal/day/acre/inch

Riverside, TX
Denver, CO
Los Angeles, CA
8. 0
Vicksburg, MS
Jacksonville, FL
7. 5

The methods of treating the wastewater produced by
pesticide formulation plants are examined in this section. The
discussion is divided into the following sections: In-Plant
Control Technology; Current Wastewater Treatment Practices;
Potential Wastewater Treatment Methods; and Comparison of
Treatment Methods.
Good operational techniques and careful consideration of
equipment design and use dramatically affect the quantity and
quality of wastewater generated in a pesticide formulation
plant. The need for wastewater treatment systems can be very
substantially reduced and in most cases eliminated if excellent
in-plant controls are established tc accomplish these two
goals: (a) reduce the quantity of contaminated wastewater to
absolute minimums; and (b) reduce the raw waste loading of the
wastewater requiring disposal. In most cases, the degree to

which good control techniques are applied is a more significant
factor in determining the wastewater volume and raw waste
loading than is the 3cale of production.
A number of techniques can help minimize wastewater
treatment requirements, if they are made a part of the routine
operation of a formulation plant. These techniques involve
water conservation and contaminant minimization and the more
important are noted below.

Water Conservation
Minimization of the water usage and wastewater effluent in
a formulation plant reduces the contaminated effluent discharge
and necessary treatment and disposal requirements. Seme of the
more common methods of reducing water usaqe and water effluent
Eliminate all direct contact condensers (as in a vacuum
jet system where water is sprayed into the jet outlet) and
replace them with surface condensers.
Replace water cooled heat exchangers with air heat
Eliminate stripping operations that use sparged steam as
the heat source and use an indirect heat source such as a
Use organic solvents for cleaning equipment, instead of
water. The solvent can be stored in drums and added to the
next production batch as part of the material input.

Schedule production runs to minimize the number of
equipment cleanups required. Technique is limited,
however, because of the frequency with which formulation
plant production schedules are revised.
Dry clean solid product formulation units by processing
an appropriate inert carrier through the system to reduce
the need for wash water. The inert carrier can be retained
for use in the next similar batch, or can be disposed of
with other potentially toxic solid wastes.
Consolidate formulation by producing all of a given
product at one or two plant locations, thereby simplifying
overall operations and reducing the number of cleanouts
required (this applies to a company having several
formulation plants). The economic disadvantage of
increased transportation costs may be balanced by reduced
disposal requirements.
Dedicate certain formulation lines, where possible, to
specific formulations or active ingredients, to reduce
cleanout requirements.

. Install sumps to collect, and contain contaminated
wastewater. When used in conjunction with curbing around
formulation units, sumps minimize area cleanup and wash
water requirements as well as contain the wash water.
In general, every measure should be used to keep water out
of all operations. When water is used for cleanup or washdown
of the equipment and facilities, the use of specified volumes
of water, rinsing out rather than filling and flushing, and use
of timers on water lines should be employed to minimize the
volume of water required.
Contaminant Minimization
A most obvious consideration is to keep the toxic material
confined within the process equipment. Some of the most common
methods of reducing the areount of active ingredient that is
discharged in the wastewater effluent are:
Segregate the "cleaxi" streams, such as cooling water,
boiled water, and sanitary wastes, from those streams which
are contaminated. These streams should be kept isolated
from contaminated areas and should not come into contact

with the active ingredient so that they can be discharged
directly from the plant site without treatment.
Prevent spills and leaks of active ingredient. Spills
and leaks can be minimized by overdesigning process equipment
to allow for higher safety valve discharge pressure; carefully
choosing and installing pump seals and gaskets; installing
curbs and drainage systems around all process equipment;
providing emergency dumping capacity if the need to empty the
process equipment arises; keeping storage and handling of
formulated products to a minimum; and installing r.o process
lines less than 1-1/2 in. to prevent leakage from lines damaged
by maintenance or operating people stepping or standing on
Reduce equipment cleanout to a minimum by the same
methods previously described.
Prevent escape of dusts in solid product formulation
plants by using vacuum conveying systems, by keeping solids
handling equipment inside an enclosure that operates under
several inches of water vacuum; and by delaying complete
drying of the solids until immediately before packaging.

Dusts which escape the process equipment and fall to the
ground at the plant site are then potential contaminants of
wash water and runoff.
Collect wash water used to clean drums and formulation
equipment, and when prossible, recycle it back into the
process as a material input, if feasible.
Maintain constant vigilance on the process to detect any
leaks that may occur and correct them immediately.
Inform all employees of the constant need for good
housekeeping practices to minimize losses of active
ingredient into the surrounding environment.
In summary, the preceding techniques must be used to
minimize the wastewater effluent of a formulation plant, and at
the same time, rrinimize the airount of active ingredient.
Constant attention to achieving these two goals will greatly
reduce or eliminate the pollution potential and wastewater
treatment and disposal requirements for pesticide formulation

Wastewater treatment techniques being usad in formulation
plants have been reviewed by Ferguson (1975). These techniques
can be qrouped into several general categories: evaporation,
sewer system, landfill, contract, disposal, activated carbon
adsorption, incineration, and miscellaneous pretreatment
processes. The following discussions of these techniques are
arranqed according to their decreasing frequency of use by
large formulation plants, as reported by Ferguson (1975).
Evaporation is the wastewater treatment technique most
frequently employed. Evaporative systems range from those that
just concentrate wastes by partial wastewater evaporation, to
processes that evaporate all wastewater produced.
Evaporative systems can be used in most parts of the
country (see Figure 8) , depending primarily on the
characteristics of the individual plant*s operation. Systems
range in size from 2,000 to over 1 million gallons of
wastewater evaporation per year.

Designs of the systems vary with the plant. General
considerations in all designs, however, revolve around the need
to maintain an adequate evaporation rate.
h pretreatment step is sometimes required to break
emulsions. This is usually done by batch-wise addition of a
demulsifying agent followed by gravity separation of the
organic layer. This layer is usually disposed of by
After pretreatment, the wastewater is pumped into an
evaporation pond where it is allowed to evaporate. These range
from shallow, concete pads to large (1 acre or more) man-made
earthen ponds. When earthern ponds are used, they should be
sealed with bentonite, plastic, or other lining materials to
prevent percolation into the soil.
The natural rate of evaporation is normally not adequate to
accommodate all process wastewater in a pond of reasonable
size. In addition, few parts of the country have net annual
evaporation of rain water, for these reasons, almost all
wastewater evaporation systems employ additional techniques to
obtain adequate evaporation.

Roofs - Many of the small evaporation ponds {up to 50 ft x 50
ft) use roofs to keep out rain water. Permanent roofs, even
those made of "transparent" plastic materials, however, reduce
the rate of natural evaporation.
Awning-type coverings, that can be moved when not needed,
overcome this deficiency, but obviously aid to installation and
operation costs.
Aeration Systems - To aid natural evaporation, aeration systems
are frequently used. These are normally simple, low cost
pumping systems used to spray the wastewater into the air. A
number of variations are possible, including the use of burlap
strips, waterfalls, etc., to increase the effective evaporative
area. Aeration has the added advantage or oxygenating the
water and thereby accelerating the decomposition of many
pesticide chemicals.
Supplemental Heat - Supplemental heating also is used to aid
the evaporation rate. Most frequently, this is done by the
addition of conventional electrical or gas powered immersion
heat exchangers to the evaporation pond. Supplemental heat is
normally required for only a few months each production season.

One of the major limitations of this system is the uncertainty
ot air pollution problems that may be created. Transfer of a
water pollution problem to an air pollution problem cannot be
tolerated. Some areas have established legal air emission
limits for the pesticides of interest.
Sewer Systems
Many smaller and a few large formulation plants discharge
into local municipal or industrial sewer systems. Pretreatment
techniques used by the formulation plant in conjunction with
these systems are presently irinimal. ptf of the effluent is
normally adjusted to neutrality. Effluents from a few plants
are filtered before discharge. Limitations have been
established by some local authorities on the concentration as
well as the daily quantity of toxicants that can be discharged.
Some municipal sewer systems, however, have not established
criteria on the toxicant (pesticide) content of wastewater that
can be discharged to their treatment systems.

Small formulation plants as well as larger plants producing
small volumes of wastewater (less than 10,0C0 gal/year) are
frequently able to dispose of their wastewater in landfills.
The landfill facilities in use include cut-and-fill operations
located on the plant site as well as a wide range of
municipally and industrially operated sites.
The actual disposal procedures used at the landfill also
are quite varied. Most frequently, the small volume of
wastewater is sealed in used 55-gal. drums. The wastewater
drums are then treated like any other item of solid waste.
Sites in which formulation wastewaters are disposed of
normally have not established criteria on the quality of
wastewater allowed and do not maintain records of the quantity
or location of wastewater in the fill.
Almost all of the landfill sites apparently operate under
some type of permit, either local or State. Very few, if any,
of these sites, however, qualify as "specially desiqned
landfill" operations that have been defined by the

Environmental Protection Agency (1974) for use in pesticide
waste disposal.
Contract Disposal
The next most frequently practiced method for disposing of
process wastewater is the use of a contract disposal service.
The availability of this service in the immediate area, as well
as the cost involved, are major factors in its selection. The
user of such services must be aware that the wastewater is
processed by the contractor in accordance with State and local
requirements and be prepared to take alternative measures
promptly in the event the service system fails.
Activated carbon Adsorption
The effectiveness of activated carbon in removing low
concentrations of many pesticides in water has been well
documented by Edwards (1970) f Robeck, ^et al. (1965) , and
Goodrich and Monke (1970). A limited number of formulation
plants have attempted to apply activated carbon adsorption
technology to treatment of their effluent streams according to
Ferguson (1975).

Most of the plants using carbon, however, apparently are
doing so only on an experimental basis. None of the
formulation plants identified during the study by Ferguson
(1975) are considered by the operating firms to be in full-
scale operation; rather, they are in various stages of
Incineration in appropriate facilities is the method which
was prescribed by the Environmental Protection Agency (1974)
for disposal of all pesticides except for organometallics and
inorganic compounds. Adequate facilities, however, are
generally not available to the independent and contract
pesticide formulators. In fact, the only formulation plants
identified by Ferguson (1975) as using incir.eration to dispose
of tneir process wastewaters were those in chemical
manufacturinq complexes. Incinerators used by contract waste
disposal services are subject to approval by State and local

Miscellaneous Pretreatment Processes
According to Ferguson (1975), a small number of plants are
using an assortment of miscellaneous unit operations to treat
their formulation wastewater. None of these, however, can be
considered a complete treatment process; rather, they are
pretreatment processes used to treat wastewater before it is
disposed of. Only four of these are practiced to any
significant degree by the pesticide formulation industry.
Neutralization - Many plants treat their wastewater with
caustic before it is discharged. This has been done primarily
to produce a neutral effluent, or because it is thought that
this will help detoxify the pesticidal chemicals. The
frequently used generalization that alkaline conditions reduce
the toxicity of pesticidal chemicals by hydrolysis, however, is
not universally true according to Lawless, Ferguson, and
Meiners (1975). The formulator should determine the
desirability of high alkalinity based on the active ingredients
being formulated before adopting this practice.
Chemical Precipitation - Many inorganic's can be removed from
wastewater by precipitation. Lawless, von Ruirker, and Ferguson

(1972) reported that one plant that formulates primarily
mercurial pesticides, for example, uses sodium hydrozide to
precipitate the mercury, which is then filtered and recovered
for reprocessing. Use of chemical precipitation processes,
however, is not commonly practiced.
Solids Separation - Some plants filter their wastewater before
discharge, when used in conjunction with precipitation or
tlocculation, this process apparently can effect some reduction
of pesticide content of the wastewater.
Equalization - Equalization, i.e., elimination of wide
variations in wastewater quantity and quality before discharge,
is practiced by some plants. As this is essentially a
retention and dilution system, it does not effect a significant
reduction in the total quantity of toxic pollutants that is
eventually disposed of. It can, however, prevent short slugs
of hiqhly toxic wastes.
zero Discharge of Pollutants
The complete elimination of contaminated process wastewater
resulting from formulation of pesticide products can be

affected by combinations of the following techniques as
appropriate to the specific formulation plant.
Elimination of Process Uses of Water - The elimination of
practically all, if not all, uses of water in the formulation
plants that generate pesticide-containing wastewaters can be
achieved by using the in-plant control techniques previously
Segregation of contaminated Wastewater - When generation of
contaminated wastewater cannot be completely eliminated, these
waters can be isolated from the wastewater produced by all
other formulation operations, and can be separately disposed of
without discharge to surface waters. Such segregation might
effect a proportionate reduction of the amount of contaminated
wastewater; i.e., only about 20% of the process wastewater
would be contaminated by a pesticide from a formulation plant
for which that pesticide constituted only 20% of its
Evaporation - Evaporation of process wastewater is the
treatment technique most frequently practiced, according to
Ferguson (1975). However, natural evaporation is normally not
adequate to accommodate all formulation wastewater. Almost all
process wastewater evaporation systems studied by Ferguson
(1975) employed additional techniques to obtain adequate

evaporation, such as roots, aeration, etc. These evaporation
systems have been previously described in detail.
Contract Disposal services - Contract disposal, especially
for small quantities of wastewater, is a method of achieving
"zero" discharge used by many lormulators. Ultimate disposal
methods used by service contractors include incineration and
landfill. The feasibility of the method for use by a specific
tormulation plant depends on the availability and nature of the
service at that location and its cost.

This section discusses the current status of technology
employed by the formulators of aldrin/dieldrin, DDT, endrin and
toxaphene; identifies available technology for eliminating
certain discharges by fcrmulators; and presents the estimated
cost of employing such technology. ¦ To support standards
proposed under Section 307, technology and associated costs are
largely a matter of carefully avoiding the use of water in
operations and preventing losses of pesticide in certain areas
subject to stormwater runoff. The technology to effect these
measures is relatively uncomplicated and presently in use.
The standards will be applicable to registered formulators
of aldrin/dieldrin, DDT, er.drin and toxaphene, both existing
and new sources. The registered formulators or the four
pesticides who were active in 1975 are listed below:

Actually Formulated in 1975
These formulators comprise only a small segment of the
total pesticide formulation industry, and the major effect will
be imposed upon formulators of endrin and toxaphene.
Technology is available and presently in use to avoid
discharge of aldrin/dieldrin, DDT, endrin and toxaphene in
process water and stormwater runoff. Individual situations at
applicable formulation plants will dictate a variety of
Process Water:
Technology is available which, by avoiding the use of water
in production processes, will eliminate contaminated process
Operating methods are available which can reduce water use
and pesticide losses. These include (a) segregation of "clean"

cooling water, boiler water and most sanitary wastes,
(b) scheduling production runs tc reduce the need to clean
equipment between runs or to dedicate equipment to specific
formulations, (c) strict management and accountability of water
use and disposal, (d) use of solvents for washouts,
(e) installation of sumps to collect and dispose of
contaminated water and spills and (f) methods for dry cleaning
of spills and equipment. In some cases where water use or
spill potential has not been eliminated entirely, it will be
necessary to segregate, collect and dispose of contaminated
process water, equipment and area cleaning wastes, drum washing
wastes, safety shower water, air pollution control scrubber
water and laboratory sink drainage without discharge to
navigable waters.
Disposal-without-discharge options include evaporation of
all water, on-site and oftsite incineration, landfill and
disposal by commercial contractors. Solar and "assisted"
evaporation are in use extensively, but are subject to
limitations such as (a) climatological conditions,
(b) groundwater and air pollution potential, and may be fuel
use intensive in seme situations. Incineration ot large
volumes of wastewater is impractical except in some exceptional
instances. Contract disposal of pesticide formulation

wastewaters is not generally feasible for runoff but is an
option at plants where volume of water is minimal and where
transportation costs are not prohibitive. Careful
determination should be made that contract disposal is carried
out in compliance with Federal, State and local regulations.
Runof f;
Available to the forirulator is technology capable of
essentially eliminating contamination of stormwater runoff.
The alternative to such elimination is to collect, hold and
dispose of runoff that is contaminated by the specified
pesticides. Among the most obvious runoff preventive measures
that can be taken singly or in combination are:
(a)	conduct all operations under cover on curbed slabs or
within roofed, walled structures,
(b)	avoid losses of pesticide dust, mist or vapor to the air,
(c)	eliminate the pollution in areas which have been
contaminated in the past by such measures as removal and
replacement of contaminated soil and paving of contaminated
areas, and
(d)	divert "clean" runoff around contaminated areas.
The alternative to the prevention concept of compliance
is the interception of contaminated stormwater runoff, storage
and disposal without discharge of pesticides to the air or

water. The large volume of runoff water is the principal
deterrent to general use of the method, particularly in
locations where long-term net precipitation far exceeds the
rate of evaporation. Also major storm events impose hydraulic
conditions which require design of the system to allow for
available, dry storage capability to intercept runoff from
these storms. Ia addition, the large volumes of water must be
disposed of by spray or other systems that require equipment,
operation and significant power and/or fuel.
Dismissed from consideration is the treatment and direct
disposal of runoff because of the cost of treating large
volumes of water to acceptable levels of pesticides.
Incineration is also dismissed because of cost
considerations in managing contaminated stormwater runoff
without direct discharge. Large volumes are involved in
storage, pretreatment and final thermal destruction.
Incineration may be useful and practical for disposal of
accumulated aqueous spill cleanups and other contaminated
wastewater in some instances, especially where this method will
be used to dispose of spent solvents, dry spill cleanup#
contaminated packages and unrecoverable off-quality product.

Incineration may be the method selected by commercial contract
disposal firms for off-site disposal of these wastes.
Costs of two major options tor managing stormwater runoff
are considered here: (a) holding and evaporation; and (b)
Holding and Evaporation
The following tabulation shews the estimated cost of a
stormwater runoff holding-evaporation system. A study
(Appendix A) , made on a "worst case" basis, selected a location
where net annual rainfall was 11 inches and storage allowance
was made for a ma"jor storm event of 9 inches. The system would
consist of a plastic filin-lined, roofed earthen holding pond,
and a spray-evaporation system. Costs for various watershed
areas are indicated below:
Area	Installed Capital Equipment Total Annual Operation
1/2 Acre	$60,000	$11,700
1/U "
1/8 "
1/16 «

The roofing/cover option appears to be a favorable one
which can be effected at least cost to formulators. This
option also will serve here to estimate cost of compliance
based upon model plants devised for that purpose.
The roofing/cover option requires that all formulation
activities including receiving, shipping, packaging and
warehousing be conducted under cover and within curbed or
walled spaces. This option also requires the complete control
of the subject pesticides such that all active ingredients and
products are eventually packaged for sale or recovered for
proper disposal in order to achieve compliance. Ideally the
operations would be completely housed and a mass balance of
active ingredient input and output achieved consistent with
worker safety and spillproof, safe storage of materials.
A model formulation plant as herein conceived would provide
for an integrated, single roofed structure equipped with curbed
concrete surfaces which would prevent stormwater runoff from
loading and unloading areas, storage areas, formulating and
packaging areas. Contaminated process water and water used for
routine cleanup or cleanup of spills wculd be reduced to
minimum quantities and collected for disposal of the pesticide
without aqueous discharge, probably by evaporation.

The costs to control contamination resulting solely from
fallout from air emissions will not be applicable to costs for
compliance with standards proposed under Section 307. Other
sections of PL 92-500 will be applied to gain control over soil
and other surfaces that have been contaminated in the past.
Any equipment outdoors such as cyclones and baghouses must be
protected from runoff by roofing and curbing as necessary which
will be applicable to costs included in the model. Also the
cost of air pollution controls such as the scrubber systems is
included in the model.
As stated earlier, technology is available and applicable
by which discharges of process wastewaters and water for
cleanup and cleanup of spills can be eliminated through
preventive operational techniques and excellent housekeeping.
Such costs will be considered to be applicable in compliance
with Section 30 7 proposed regulations, but can be kept to
inconsequential levels.
Costs incurred to control or correct the contamination (via
air pollution fallout) of surface areas open to stormwater
runoff will not be considered to be applicable to proposed
standards under Section 307. Reference is made here only to
fallout remaining in air emissions from exhaust and stack

systems after required air pollution controls have removed
these pesticides by filters or scrubbers using water. It is
expected that elimination of scrubbers using water would be of
advantage to formulators in avoiding discharge of contaminated
process wastewaters.
Because reliable plant-by-plant data are lacking, cost
estimates herein are based upon small, medium and large "model"
formulation plants and an approximation of roof areas required
to avoid contamination of stormwater runoff. Roof areas are
then used to calculate estimated costs in avoiding discharge to
navigable waters. Costs developed are ultimately related to
the added cost of production for each model.
No industry-wide data exist which indicate how many
formulation operations are actually conducted outdoors, or
conversely, how many operations are conducted under cover, or
any combination of the two. Ferguson reported that formulation
units, filling lines and storage areas located outdoors cannot
be assumed to be free of pollutants. In a recent survey,
Ferguson and Meiners (Appendix B) reported, upon inspection,
that all liquid and dust formulation operations at a one
million pound (technical ingredient) per year plant were
accomplished indoors in a portion of a UO'xfcO1 building.

tfo industry-wide data exist concerning the number of
formulation units operated outdoors and without a concrete or
other satisfactory working surface. It seems certain, however,
that only a few such situations exist.
The cost estimates developed below do not apply to any one
formulator. Three models have been selected as means of
broadly visualizing the roof area that might be needed to
protect a model plant from contamination of stornrwater runoff
by the subject pesticides. The selection of small, medium and
large models was made by examining the smallest and largest
rates of production among registered plants formulating endrin
and toxaphene in 1975, and adding a medium level of production
between the two extremes. The models visualized basic
formulation operations common to liquid formulation and
incremental areas were added for dust formulations to account
for grinding, pulverizing and tor added air pollution control
facilities. The principal reckoning factors considered in the
visualization are shown in Table 1. A small allowance for the
cleanup of '•spills" is included to account tor accidents which
occur despite all precautions taken. In summary, the model
roof areas in square feet for the three models are shown below.

250 qal/yr (A.l.) 85,000 qal/yr (A. 1.) 100.000 aal/vr (A.
Liquid:	1175 sq. ft*	2050 sq. ft.	4550 sq. ft.
Dust:	1375 sq. ft.	2600 sq. ft.	5750 sq. ft.
The roof areas for the models were then used to estimate
the cost of roof, concrete slat and curbing using 1975 costs.
Sample calculations are based upon a steel roof supported by a
light steel frame at a total cost of $1.00 per square foot.
The costs shown on Table 2 were derived from the second edition
of Plant Design and Economics for Chemical Engineers by
M.S. Peters and K.D. Timirerhaus, (McGraw-Hill Book Co., N.Y.
.1968) .
The slab thickness selected is six inches of concrete with
a six inch by six inch curbing around the perimeter of the
slab. Cost of concrete is the delivered cost quoted at
$77.5 5/cubir: yards in late April 1976 in Northern Virginia.
Labor cost is considered in these estimates to be equal to the
cost of the concrete per cubic yard.
Table 3 shows the total annual operating costs.

Blacker, H. G., and T. M. Nichols, "Capital and Operating Costs
of Pollution Equipment Modules - Vol. II - Data Manual,"
EPA-R5-7 3-023b, July 1973.
Carlton, R., EPA, Washington, Telephone Conununication will
Gary Kelso, MRI, October 26, 1975.
Chemical Engineering, July 7, 1975.
Cohen, J. M., L. J. Kamphake, A. E. Lamke, C. Henderson, and R.
L. Woodward, "Effect of Fish Poisons on Water Supplied,
Part I, Removal of Toxic Materials," Jj, Amer. Water Works
Assoc., 52:1551, December 1960.
Cornell, Howland, Hayes, and Merryfield, "Process Design Manual
for Carbon Adsorption#" EPA Technology Transfer, October
197 2.

Danielson, J. A. (Editor), Air Pollution Engineering Manual,
Publication No. 999-AP-UO, U.S. Department ot Health,
Education and Welfare, Cincinnati, Ohio (1967).
David* D., Personal Communication with Thomas Ferguson, MRI,
September 1975.
Edwards, C. A., Persistent Pesticides in the Environment.
Chemical Rubber Company, Cleveland, Ohio (1970).
Engineering News Record, May 1, 1975.
Engineering Mews Record, December 19# 197U.
Environmental Protection Agency, "Pesticides and Pesticide
Containers: Regulations tor Acceptance and Recommended
Procedures for Disposal and and Storage," Federal Register,
39(85:15236-15241, May 1, 197ft.
Farm Chemicals Handbook 1975 , fiesiter Publishing Company,
Willouqhby, Ohio (1975).

Ferguson, T. L., "Pollution Control Technology for Pesticide
Formulators and Packagers," Final Report under EPA Grant
Mo. R801577 for the National Environmental Research Center,
Office of Research and Development, U.S. EPA, January
Goodrich, P. R., and E. J. Monke, "Insecticide Adsorption on
Activated Carbon," Transactions of the American Society of
Agricultural Engineers, 13 (1) :56-57, 60 (1970).
Guthrie, K. M., Process Plant Estimating Evaluation and
Control, Craftsman Book Corrxany of America, Solana Beach,
California (1974).
Handbook of Aldrin. Dieldrin and Endrin Formulations, Shell
Chemical corporation, New York, New York, June 1959.
Hersey, J., "Choosing a Solvent for Insecticide Formulations,"
Farm Chemicals, 129 (10):42-46, October 1966.
Hutchins, R. A., Development Associate with ICI United States,
Inc., Wilmington, Delaware, in Written Communication with

Mr. Charles Mununa, Senior Cr.emical Engineer with MKI,
October 24, 1975.
Jelen, F. C. , Cost and Optimization Engineering, McGraw-Hill
Book Company, New York (1970).
Lawless, E. W., T. L. Ferguson, and A. F. tfeiners, "Guidelines
for the Disposal of Small Quantities of Unused Pesticides,"
EPA-6 70/2-75-057, June 1975.
Lawless, E. w., R. von Rurnker, and T. L. Ferguson, "The
Pollution Potential in Pesticide Manufacture," EPA
Technical Studies Report TS-00-7204, O.S. Government
Printing Office, Washington, C.C., June 1972.
Monthlv Labor Review, Vol. 98, No. 5, May 1975.
Monthly Labor Review, Vol. 98, No. 1, January 1975.
UraK, E. M. (Chairman) , Report to the secretary1 s Commission on
Pesticides and Their Relationship to Environmental Health,
U.S. Government Printing Office, Washington, C.C., December

Nicholson, H. P., A. R. Grzerda, and J. I. Teasley, "Water
Pollution by Insecticides," Amer. Water Works Assoc..
32(1) : 21-27 (1 968) .
Pazar, C., Air and Gas Cleanup Equipment. 1970, Noyes Data
Corporation, Park Ridge, New Jersey (1970).
Perry, R. H., and C. H. Chilton, Chemical Engineer's Handbook,
5th Ed., McGraw-Hill Book Company, New York (1957).
Raymond Division, Raymond Mills for Insecticides. Bulletin
Nc. 84, Combustion Engineering, Inc. (1957).
Robeck, G. G., K. A. Dostal, J. M. Cohen, and J. F. Kreissl,
'•Effectiveness of Water Treatment Processes in Pesticides
Removal," Ji Amer. Water Works Assoc., 57(2):181, February
Shiroishi, K., EPA, Washington, Telephone Communication with
Gary Kelso, MRI, October 21, 1975.
Weston, Roy F., Inc., "Development Document for Effluent
Limitations Guidelines and Standards Performance -

Miscellaneous Chemicals Industry," Draft Report, EPA
Contract No. 68-01-2932, February 1975.
Whitehouse, "A Study of the Removal of Pesticides from Water,"
University of Kentucky Water Resources Institute, Research
Report No. 8, December 1967.
Winchester, J. M., and D. Yeo, "Future Developments in
Pesticide Chemicals and Formulations," Chemistry and
Industry, (4):106-108, January 27, 1968.

2000 gal/yr Product
250 gal/yr A.1.
Roof Area	Reckoning
(sq. ft.)
Receiving &
Shi ppi ng
Dus t
(i ncrement):
Grinding &
pulveri zing
Air Pollut.
20x20 * 400
15x 5 = 75
10x10 » 100
10x60 ¦ 600
10x10 = 100
10x10 = 100
1 truck
(5) 55 gal.
1 mixer
1 yr Inv.
Estimated Roof Area
Model Formulation Plant
Liquid and Dust Operations
550xl03 lb/yr Product
68*xl03 lb/yr A.l.
85,000 gal/yr A.l.
Roof Area
(sq. ft.)
20x40 8 800 2 trucks
15x15 = 225 Tank car
15x15 = 225 1 mixer
40x20 ¦ 800 1 yr inv.
6.5x10® lb/yr Product
.8xl03 lb/yr A.l.
100«000 gal/yr A.l.
Reckoni ng
20x80 * 1600 4 trucks
15x15 « 225 RR Tank car
15x15 * 225 1 mixer
50x50 * 2500 1 yr 1nv.
Reckoning Roof Area
(sq. ft.)
20x20 = 400
10x15 = 150
TQSAL — 2600
50x20 * 1000
10x20 = 200

Estimated Installed Capital Equipment Costs
Model Formulation Plants
Roof, Slabs and Curbs
Roof	$1,175	$2,050	$ 4,550
Slab	3,372	5,884	13,058
Curb		510	680	884
TOTALS:	$5,057	$8,414	$18,492
Roof	$1,375	$2,600	$ 5,750
Slab	3,946	7,462	16,503
Curb	612	833	1 ,224
TOTALS:	$5,933	$10,895	$23,477
S77.55/cu. yd. concrete
x2 labor & concrete
>155.10 formal finished concrete/yd.
Slab: sq. ft. x 0.5* deep x 1 cu. yd. x $155.10 * sq. ft. x 2.87 = $
27 cu. ft.
Curb: .5' x .5* x 1* » 0.25 cu. ft/linear ft. of curbing
.25 cu. ft. x linear ft. x 1 cu yd. x $155.10 x (forms 1.20) a
27 cu. ft.
(*25 x 155 x 1.20) linear ft. B cost * 1.7 x ft.
Roof: light steel frame and support 0 Sl.OO/sq. ft.

Estimated Total Annual Operating Costs
Model Formulation Plants
Roof, Slabs and Curbs
Liquid:	SMALL
Roof	$ 225
Slab	506
Curb	77
Spills	25
TOTAL;	$1,033
5% G&M Costs --- 52
S 410
$ 910
$1 ,445
Koof	$ 275
Slab	592
Curb	.92
Spills	25
5% O&M Costs ---	49
$ 520
1 ,119
SI ,814
53 ,909
*1 ,905


Source: Jexgason ClW)
Figure X. targe
formulation pU« locations.

40 r—
c 30
J? 20
£ 10
1 2 3 4 5
Number of Classes Formulated
Classes: Organophosphate, inorganic, chlorinated
hydrocarbon, nitrogen based,and all
a) Distribution by chemical class of pesticide formulated
80 —
c 60
1	40
<£ 20
12 3 4
Number of Types Formulated
Types: Liquids,powders and dusts, granules,and
all others (strips, baits, etc)
b) Distribution by type of formulation
Source: Ferguson (1975)
Figure 2. Product distribution for large formulation plants.

24 r—

1-5 6-10 11-15 16-20 21-25 26-30 31-35 36-40 41-45 46-50 51-55
Age in Years
Source: Ferguson (1975)
Figure 3. Distribution of plants by age,

(55 GAL. DRUM)
(55 GAL. DRUM)
Adapted from: Handbook of Aldrin, Dieldrin, and Endrin Formulations (1959)
Figure 4. Liquid formulation unit.


-i, . // DRIVE
Source: Raymond Division (1957)
Figure 5. Typical sulfur grinding unit.

d) Pretnlx Grinding
high smo
HIGH rmsu?E
b) Final CrlndlitK and Blending
Adaptec! from: Daniclson (1967)
Figure 6. Process for formulating dust.


Source: Davis (1975)
Figure 10" Aldrin/dieldrin formulation plants


Source: Davis (1975)
Figure lb bDTformulation plan

Source: Davis (1975)
Figure 7£ Endriri formulation plants (1973)


Source: Davis (1975)
Figure 7JL Toxaphene formulation plants (1973)

Source: Ferguson (1975)
Figure 8. Formulation plants using evaporative treatment systems.

Anper.dix A
Holding - Evaporation System
Technology and Estimated Associated Costs
Worst Case situation
Selected Location; Vicksburg, Miss,
Select 1/2 acre area:
Net. annual precipitation
Design storm (2^ hrs/10 yrs)
=	S_
Cu. ft. Gallons
$20,000 $150,000
$16.300 S122.500
$30,300 $272,500

Installed Equipment Costs:
Pond excavation	:
1333 yd 3 3 $5/yd
Inlet structures a) 10%
contingencies 3) 103
Pond liner	:
Hypolon, 30 mil 12,338 ft
a> S0.70/ft Clay liner +
surface dressing as $.25 yd
Ditching and Anchoring
d> $.30 ft. Installation
12,338 3 S.30
Evaporation System
Pump, water, piping
spray heads
Light/steel fraire
+ cover, $l/ft
Land at $7500/acre
Bounded Estimates
$ 6,000
$ 3.800

Indirect Const, at 10"	$ a,270
Contingency	at 30%	$12.810
Round to
36 0,000

Annual Operating costs
Payroll charges
Round to
Property taxes
Plant overhead
$ 600
$ 64 0
Found to

Total Annual Operating Cost: 311,700

Adjust Costs to Lesser Watershed Areas:
Use Perry and Chilton's, Chemical Engineers Handbook,
5th Ed. McGraw-Hill (1970)
New plant cost = (new capacity)	0.6 x previous plant cost
old capacity
Area Installed Capitol Equipment	Total Annual Operating Cost
1/2 acre 360,000	$11,700
1/4 acre 539,600	$ 7,720
1/8 acre 326,100	$ 5,090
1/16 acre $17,200	3 3,360

Appendix H-1



to public

and treats
Voolfolk Chemical Company
Fort Valley, Georgia
Triangle Chemical Ccrapany
Macon, Ceorgla
Helena Chemical Conpany
Cordcle, Oorgin
Paramore and Crlffln
Valdosta, Georgia


Kerr KcCce
Jacksonville, Florida

FMC, Inc.
Jacksonville, Florida
Asgrou Florida Ccrapany
Plant City, Florida
Helena Chemical Company
Tampa, Florida
No .
Pill Cordon
Kansas City, Kansas
Patterson Creen-up
Kansas City, Kansas
Southern Agricultural
Klngstree, South Carolina
Chemicals, Inc.

FMC. Inc.
Los Fresnns, Texas
Texas Agricultural, Inc.
Mission, Texas
FMC, Inc.
Ennls, Texaa
Sova products
Kansas City, Kansas
Scauffer Chemical Company
Oraaha, Nebraska
a/ 4 « over 100,000 gal.
3 • 50.000 to 100.000 gal.
2 ¦ 10.000 to 50,000 sal.
I » lest than 10,000 gal.
b/ Only portions of plant were touted.
cj Vas unablo to arrange to meet our schedule,
d/ Asked for later visit alter they complete nev construction.,
e/ No ErA figure* available, but toxaphene capacity vas large.
7/ Formerly had N1>DES Permit.

Appendix B2
Memoranda of Plant Site Visits

425 Volker Boulevard
Kansas City, Missouri 64110
Telephone (816) 561-0202
March 1, 1976
BY: Thomas L. Ferguson
DATE OF VISIT: October 27, 1975
COMPANY: Stauffer Chemical Company
4111 11th Street
(P.O. Box 7222)
Omaha, Nebraska 68107
(402) 733-3200
Visit Arrangements
Our arrangements to visit this formulation plant were made by
Mr. Frank Porter at the Stauffer Chemical Company headquarters in Westport,
Connecticut 06880, (203) 226-1511.
After preliminary authorization had been obtained from Mr. Porter,
I made final arrangements with Mr. Norm Lamb, the Omaha plant manager.
Plant Information
This plant was selected because (a) it had been identified in an
earlier study of pesticide formulation as using the "best practicable con-
trol technology currently available" for formulation plant wastewater, and
(b) it was identified by EPA as having formulated "medium" volumes of both
dieldrin and toxaphene during calendar year 1973.
I also visited this plant site on July 2, 1973. Information ob-
tained from that visit has been attached (Case No. 7 in EPA-660/2-74-094,
dated January 1975).
Mr. Lamb indicated that this site no longer produces dieldrin
(or toxaphene) formulations. Further, they do not analyze their effluent
for any of the five pesticides of interest (aldrin, dieldrin, endrin, DDT,
and toxaphene). The effluent from the treatment system is now normally
greater than 5 gpm, and contains <0.01 ppra thiocarbamates and organophosphate.

Although effluent from the treatment plant is discharged into the Omaha
city sewer system as authorized by a city permit dated June 23, 1971
(Mr. Charles A. Geisler, City Sanitary Engineer; 733-5465), the City of
Omaha does not monitor the effluent.
Unfortunately, the plant had no additional data on the performance
of the wastewater treatment system pertinent to our current study beyond
that already reported in the attached case study. Comprehensive analyses
of the effluent have not been conducted since 1971. No "material balance"
data have been developed.
This formulation plant was also visited by Roy F. Weston, Inc.,
during their study of effluent limitations guidelines (EPA Contract 68-
01-2932). Samples of the effluent were taken, but apparently were not
analyzed for active ingredient content.

General Information
This plant is operated by a large agricultural chemical manufacturer to
formulate products for sale under the company's own label. The plant is
located in the West North-Central United States, and has been in operation
since 1955. This facility operates year round, and produces about
40,000,000 lb of formulated products each year. Active ingredients used
include a number of thiocarbamate herbicides and organophosphate insecticides.
No inorganics or metal-containing pesticides are formulated. Production
is about evenly split between liquid and granule products.
Wastewater Characterization
The primary source of process wastewater is equipment washout. Dye is used
for one of the major solid formulations, and is one of the main reasons for
water-washing. All water from inside the dikes that surround technical
material storage tanks also goes to the wastewater treatment system.
Effluent from the plant's wastewater treatment system has been analyzed
by the local municipality into whose sewer system the water is discharged,
and the quality of this water has been found to be acceptable. These
analyses, however, were not available.
Where possible, solvent is used to clean out formulation equipment in
order to minimize the volume of wastewater generated.
Wastewater Treatment System
The wastewater treatment in use at this plant site is depicted in Figure
A-5. The system is still considered to be in the pilot plant phase,
however, and for that reason complete design and operational data were not
available. A general description of the system is given below.
Wastewater from the production units is collected in a sump and is pumped
into a settling tank. Here, flocculating and deemulsifying agents are
added. The wastewater is then continuously pumped to a vacuum filter unit.
Sludge from the filter is disposed of with the other solid wastes. From
the filter, the water is pumped to an aeration tank for secondary treatment.
If necessary, water from the ^aeration tank can be"recycled to the settling
In the next step, the aerator effluent is passed through an activated car-
bon column and then into a 100-ft long x 6-ft wide "fish pond." The system
effluent can be discharged to a garden plot, the city sewer, or to a re-
cycling system.

Fi Iter
Cake to
Sani tary
City Sewer <
Figure A-5 - Pilot Absorption System

The design retention time for the system is about 30 days. The carbon
column has been used up to 6 months between rechargings (about 540 lb of
carbon). At the reported continuous flow rate of 2 to 5 gpm, a carbon
capacity of 500 gal. per lb is indicated. This system has reportedly
operated for short periods at a rate of 15 gpm.
Specific data on the quality of influent and effluent water for this sys-
tem were not made available. However, data indicate that typical operation
yields a reduction in total toxicants from an initial concentration of
140 ppm to an effluent containing <0.1 ppm.
The actual capital cost of this plant is not significant because of its
developmental status. Operational costs, however, are meaningful. This
system requires the full-tima attention of two people to operate the
equipment and provide analytical services.
Miscellaneous Information
Solid waste is disposed of by shipping it to an approved landfill at a
cost of about $1.25 per cubic foot (including freight). The disposal of
drums and bags is not a problem as most technical materials are received
in tank cars or tote tanks.

425 Volker Boulevard
Kansas City, Missouri 64110
Telephone (816) 561-0202
March 4, 1976
BY: Alfred F. Meiners
DATE OF VISIT: February 11, 1976
COMPANY: Triangle Chemical Company
206 Lower Elm Street
Macon, Georgia
Mr. Richard M. Maddux, President
Telephone Contact
Mr. Maddux said that they do not generate any liquid waste nor do
they have any runoff. They simply mix their formulations in a kettle, and
mix the solvents back next time they generate in that kettle. Evidently he
has dedicated equipment.
He said that he no longer manufactures very many products. They
do not discharge to the City of Macon Sewage Treatment System. He believes
that they are on a septic tank. They have no evaporation system to handle
wastes, nor do they discharge to a navigable waterway (for this reason they
do not need a NPDES permit). He said they have very few labels for cotton
pesticides anymore. They make them in kettles, and do not have waste liquids.
Formerly their business was large in formulated dusts, and they
still make a few granular products. But this business, the dusts and gran-
ules, has decreased 75 to 857.. Most of their business now is in the distri-
bution of other products.
Plant Visit
I met Mr. Richard M. Maddux, President of the company. Mr. Maddux
was very much more cordial than he was over the phone. He indicated that
he was very suspicious of persons who call by telephone. He is much more
ready to speak to them when they visit him in person.

Mr. Maddux said that their formulation facilities consist of two
large kettles, which sometimes are used to formulate the same product for
months at a time. When they switch from one product to another, the kettles
are washed out, and the wash either goes into the next product or is placed
in a drum and is stored until that product is formulated again.
The major products sold by Triangle include a product called 6-2-1,
which contains toxaphene, ethyl parathion, and methyl parathion; 6-3, which
is methyl parathion and toxaphene; and a third formulation which consists
of EPN and methyl parathion.
Mr. Maddux says that they do have a contamination problem, and a
very small amount of washwater is needed. They are not on city sewers but
they have septic tanks which receives their sanitary discharges. They do
not have a discharge to any stream. They formerly discharged their boiler
blowdowns, but this is now recycled.
Mr. Maddux said that water is very inefficient in cleaning up
spills (therefore, I presume that they use organic solvents to clean up
their spills). He indicated that they use granules (specified for the par-
ticular pesticide formulation) to absorb the spill. These are placed in
containers, usually paper bags, and these are taken to the city dump.
Mr. Maddux indicated that his plant has no more spillage than would occur
by the proper use of the pesticide by three or four farmers.
They have in the past formulated endrin, but they will probably
not formulate it this year. He indicated that they can buy it cheaper in
the formulated form from Vesicol, even though they have labels of their own
for endrin and an endrin/methyl parathion formulation. He indicated that
they have only formulated 200 or 300 gal. of this product in the last few
years. Triangle currently has no endrin in the plant.
The company formulates an aldrin product used for termite control,
although they do not formulate any dieldrin product. (They have a label for
a dieldrin formulation.) He indicated that some aldrin might be imported at
the present time, even though it is not presently manufactured by Shell.
Aldrin was never a big dollar volume for Triangle.
He indicated that toxaphene was not useful for termite control;
it had little more termite preventive control than fuel oil itself.
Triangle is, currently not formulating any toxaphene. As indi-
cated previously, they do not use any water in the manufacturer of these
formulations, even for the cleaning up of their kettles.
I gave Mr. Maddux a blank copy of the EPA formulators report that
Roy Clark had given me.

Triangle receives toxapherie (from llerculcs) in tankcars and this
is transferred to their storage tanks. They receive methyl and ethyl para-
thion and EPN in drums. They put their finished products in the same drums.
He indicated that a major problem was disposal of the drums by the farmer.
He indicated that Triangle has no drums to dispose of themselves.
Triangle makes no toxaphene dusts, although they do make a Sevirf^
dust. He indicated that no one is using a dust type of toxaphene formula-
tion at the current time. (According to our visit to Woolfolk, there is a
demand for a toxaphene dust, apparently for home and garden products. Our
subsequent visit to Parramoreand Griffin confirmed the present demand for
toxaphene dusts.) He indicated that liquid toxaphene is sprayed into the
dust when the formulation is prepared. He indicated that Hercules makes
their own dust formulation. Triangle could purchase the dust as a concen-
trate, which could be diluted with additional dusting material. However,
they apparently purchase the dust formulation at the concentration they
The only reason that they make a dust formulation from Sevin® is
that Sevirf© is difficult to formulate as a liquid.
During the tour of this plant, Mr. Maddux showed me his entire
facility. Most of his buildings (about three) were warehouses filled with
already formulated pesticides, as he had indicated. The growing season is
about to begin ^nd these warehouses looked very well filled with a wide
variety of formulated pesticide products.
He showed me the kettles which are used to formulate liquid
copper napthenate and the toxaphene formulations. There were two kettles,
approximately 10 ft in diameter and 15 ft high. These were located inside
a building. If there were any spills or liquid washes from this building
they would be conducted through a drain to a small continuously moving
stream which is located just outside this building. This stream is gene-
rated by a concrete block manufacturing facility located upstream (next
door). The stream leads to a large swamp area.
Outside this formulation building were two large tanks, about 8 ft
in diameter and 20 ft high. Mr. Maddux said they were owned by Hercules.
I mentioned that it may become necessary for him to have these tanks diked;
this comment touched a nerve. He said that no government authority or even
his own insurance company could provide him with adequate specifications
for such a dike. He would earnestly like to build a dike for these tanks,
and for the four xylene tanks (8 ft diameter by 18 ft loag, stored outside),
but he does not want to build these dikes and then have some government au-
thority say that they are inadequate.

Mr. Maddux showed me his dust manufacturing facility and again
indicated that most of his dust products were purchased already formulated.
I took a picture (1-5) of the Triangle Chemical Company which
shows the toxaphene storage tanks and the building (to the left of the
tanks) in which the liquid formulation processes take place.

425 Volker Boulevard
Kansas City, Missouri 64110
Telephone (816) 561-0202
March 4, 1976
BY: Alfred F. Meiners
DATE OF VISIT: February 11, 1976
COMPANY: The Helena Chemical Corporation
Cordele, Georgia
I called Mr. Tom Mock, Plant Manager, on Wednesday morning,
February 11. He stated that his plant was very modernistic and:up-to-date
and would probably meet any EPA specifications. They produce toxaphene
dust and concentrates (50,000 to 100,000 gal/year). He said we were wel-
come to visit the plant. However, he indicated that visits to this plant
must be cleared through his supervisor, Harold Speer, Columbia, South
Carolina 803-796-4830. We had already received permission from Mr. Speers1
boss, Mr. Bobbie Pace, in Atlanta.
I told Mr. Mock I would be in Cordele Thursday, but he was un-
available that day.
Because of my fairly tight schedule, I was unable to schedule a
visit to this plant. However, driving from Macon to Valdosta, I stopped
by the Cordele plant and took a few pictures (1-6, 1-7, 1-8, and 2-1). The
plant is located out in the country and does look like a very neat modern-
istic plant.
Mr. Mock said that their facility in Cordele was very similar to
the facility in Tampa, which we will visit Friday (see below). I told
Mr. Mock that we might telephone for some additional details after we had
visited his Tampa plant. Mr. Mock seemed to be very cooperative.
During our visit to Helena in Tampa', Mr. David Lawhon stated that
the evaporative system at Cordele was similar, but larger than the Tampa
system. (Photographs of the system are available; see MRI report on Helena,
Tampa, visit February 13, 1976.)
The Cordele system operates entirely by gravity flow from the
floor of the formulating area to the evaporation system. About one-fourth

of the Cordele tank is used for sedimentation to remove most of the sus-
pended solids before the evaporation step. The Cordele system operates in
the same manner as the Tampa system; circulation and some aeration is pro-
vided by a pump which discharges through a manifold system consisting of
nozzles directed straight down toward the water surface.

425 Volkcr Boulevard
Kansas City. Missouri 64110
Telephone (816) 561-0202
March 4, 1976
BY: Alfred F. Meiners
DATE OF VISIT: February 11, 1976
COMPANY: Parramore and Griffin Company
(Pee Gee Chemicals)
Valdosta, Georgia
(The plant is located off Interstate 75 on 84 Exist, about 1/4
mile east of the junction)
I visited Mr. R. A. (Rusty) Griffin, who is the owner of the
plant and its president. Mr. McCloud is the plant sales manager.
The company no longer prepares the dust product called "sulphene"
or a "sulphene with copper." These were toxaphene formulations; the copper
formulation containing copper oxide and was used on peanuts.
The company's major toxaphene formulations are a 6-E and 8-E for-
mulation. The company also formulates ethyl and methyl parathion; they are
also equipped to formulate chlordane.
Like most of the formulators visited to date, this company does
not generate any wastewater. The kettles in which the toxaphene formula-
tions are prepared are rinsed with xylene and the xylene solvent is stored
until the next time that toxaphene is formulated.
The companies formulating facilities are all enclosed in a build-
ing; therefore, their runoff problems are minimized. Mr. Griffin said that
spills are a problem, but he did not elaborate on how they handled spills.
The company has waste pesticide bags to dispose of, and they take
these bags to the city dump for burial in an approved landfill. Mr. Griffin
was concerned with the problem of container disposal by the farmer.
The company takes no procedures to prevent runoff. The company
area consists of about four modernistic buildings located near a major high-
way interchange.

Mr. Griffin said that the EPA has not been very cooperative to
date. They have been more "Gestapo-like" with an attitude that they will
"burn you or not burn you." They appear to be looking for violations. He
said that the EPA representatives apparently do not realize that formula-
tors are also good Americans interested in protecting the environment.
Mr. Griffin said that he has requested informal visits to this plant by EPA
representatives in order to determine what things were wrong, but has never
received a visit of this kind. He would appreciate the opportunity to be
informed of any procedures that are objectionable and have the opportunity
of responding to EPA concerning his company's solution to these objections.
The company carries its own trash to the dump. This trash con-
sists of many things, predominantly things that are not involved with pes-
ticides. It would be very hard to segregate the company's trash from pes-
ticide waste. The trash includes pesticide bags, broken pallets, and other
I agreed to send Mr. Griffin a copy of the report we will send to
EPA concerning his company. I also agreed to send him a copy of Ferguson's
formulators report.
The company has just recently attached to the city sewer. They
formerly used a septic tank. There is no plant drainage to the sewer, other
than sanitary waste, and there is no way for this waste to get into the
sewer. Mr. Griffin mentioned that the health department of valdosta has
been interested in the same problem and has satisfied themselves that there
is no pesticide discharge to the sewer.
The company receives toxaphene by tankcar and by tanktruck and it
is stored in two large containers which are outside the plant. These con-
tainers are made of aluminum and are approximately 10 ft wide and 20 ft high.
There are two of these storage bins. There are also four tanks which con-
tain xylene storage. These tanks are not diked, but Mr. Griffin would like
to have them diked in order to prevent loss of valuable material, plus a
very bad pesticide spill. He would like someone at EPA to tell him what
kind of diking would be acceptable.
Mr. Griffin took me on a touy of his plant. The warehouses and
formulation areas were in the same building. The building was quite modern.
All preparation of dust formulations and liquid formulations is performed in
this building. Mr. Griffin mentioned that completely formulated pesticides
are becoming a larger proportion of his business.
Mr. Griffin said that they use xylene exclusively, because other
solvents such as kerosene are not as clean or as convenient to use.

The toxaphene liquid formulation equipment consists of a mixing
tank about 8 ft wide and 6 ft high. This tank is equipped with mixing fa-
cilities and is located in a pit which is about 6 ft deep. Completely
mixed formulation is pumped from this equipment to a reservoir which is
about three times the size of this equipment. This reservoir is equipped
with three or four spigots from which 1 and 5 gal. containers can be filled.
The company has some large modernistic new equipment for the prep-
aration of dusts. In this equipment, 90% toxaphene is sprayed into the dust
in a large cylindrical piece of equipment which has a 5-ton capacity. The
company formerly purchased 407, concentrated toxaphene dust from Hercules,
but Mr. Griffin says that Hercules does not offer this dust concentrate any-
more. This equipment is fairly standard, but Mr. Griffin would not like to
have competitors obtain pictures of this equipment because of some new
"wrinkles" that they have added.
The formulated dusts from the large mixer are transferred to a
reservoir and are conducted to an automatic dust weighing device. This
equipment is very modernistic and provides a relatively high degree of worker

I took two photographs (2-2 and 2-3) of this plant which show
the large modern buildings in which pesticides are formulated and warehoused.

425 Volker Boulevard
Kansas City, Missouri 64110
Telephone (816) 561-0202
March 1, 1976
BY: Alfred F. Meiners and Thomas L. Ferguson
DATE OF VISIT: February 12, 1976
COMPANY: FMC Corporation
Agricultural Chemicals Division
1200 Talleyrand Avenue
(P.O. Box 1709)
Jacksonville, Florida 32201
(904) 353-9041
Visit Arrangements
Our arrangements to visit this plant were made by Mr. Edward E.
(Gene) Hodges, Production Manager, Agricultural Chemicals Division, Southern
Department, 6065 Roswell Road, N.E., Suite 737, Atlanta, Georgia 30328,
(404) 256-9333.
After we made preliminary arrangements for this visit, we received
a call from Mr. Neil C. Elphick of the FMC Chemical Group Headquarters,
2000 Market Street, Philadelphia, Pennsylvania 19103, (215) 299-6000.
Mr. Elphick said that it would be necessary for us to write a letter of in-
tent stating our purpose for visiting the plant, what we wish to see, and
who was going to make the visit. We sent this letter of intent to Mr. Elphick
by Special Delivery Service in order to obtain his decision in time to con-
form with our travel schedules.
Mr. Elphick called on Monday, February 9, and said that it would
be acceptable for us to visit the plant as planned on February 12, but that
we would need to sign a plant visit agreement for nongovernmental compliance
officials. We agreed to sign this letter of intent and visited the plant
on Thursday morning, February 12, 1976. Mr. Tom Ferguson and Dr. Alfred
Meiners visited with Mr. Hodges, Mr. James D. Green, Plant Manager, and
Mr. Frank Snowden, Assistant Plant Manager, and toured the complete plant
site (*, 9.8 acres in size) which has been actively formulating pesticides
for about 30 years.

Toxaphene and Cotton Production
We first discussed our reason for selecting this FMC site as a
plant to visit. We told him we were looking for companies who are actually
formulating toxaphene and therefore had chosen the Florida area and the
Texas area. In regard to the Texas area, it was our understanding that
less toxaphene was now being formulated there because of a recent switch
by the farmers from primarily a cotton crop to primarily a railo crop.
Mr. Hodges noted that FMC has a plant in Los Fresnos, Texas, in the Rio
Grande Valley and corrected our impression by stating that the production
of cotton had decreased from approximately 300,000 acres in 1974 to 70,000
acres in 1975. However, in 1976 he expected the cotton acreage to again
reach 300,000 acres.
Mr. Hodges said that if we were interested in the cotton planting
industry of the United States, we should be. interested in an area compris-
ing a 90 mile circle around Greenville, Mississippi. He said that this
area would also include a representative portion of toxaphene formulators--
from those that are very large to those that are very small. He also in-
dicated that we could probably see all of them within a short time.
Mr. Hodges indicated that, in his opinion, DDT had been a very
important pesticide for the cotton industry. DDT apparently gave consid-
erable extension to the insect-killing lifetime of methyl parathion.
Mr. Hodges did not speculate whether the extended insect-killing capability
was due to the longer killing action of DDT or whether there was indeed a
synergistic action. He considered toxaphene a less efficient insecticide
than DDT, but in combination with methyl parathion it can replace some of
the uses of DDT on cotton.
Mr. Hodges mentioned that toxaphene is the backbone of some
company's operations and that if stringent discharge regulations concern-
ing toxaphene were placed into effect, a company of this kind might be
able to spend the money required to meet the toxaphene discharge standard.
However, Mr. Hodges believes that most companies to whom toxaphene repre-
sents only a small part of their business would not spend this money, but
would cease toxaphene formulation.
Production at the FMC, Jacksonville Plant
Mr. Green said that production of toxaphene at this site was for-
merly about 1 million pounds per year of the technical ingredient. This has
leveled off to at present 120,000 lb/year and represents about 2 to 47. of
their total volume. Their major toxaphene product, which constitutes 90 to
99% of the toxaphene they sell, is an 8 lb/gal emulsifiable concentrate.
This site only produces about 10,000 lb of dust per year.

116	^
Mr. Hodges mentioned that it is tricky to manufacture toxaphene
to WHO specifications. A few years ago, FMC and a number of other formu-
lators in this area had very large contracts under which large amounts of
toxaphene were shipped to Egypt.
We asked about the apparent discrepancy in that this site's major
toxaphene product consists of toxaphene alone, but that the material ac-
tually applied to crops contains toxaphene along with parathion or methyl
parathion. Evidently, these active ingredients are mixed together in tank-
mix operations prior to application to crops. A major advantage of toxa-
phene, according to Mr. Hodges, is that it extends the insect-killing
capacity of parathion. Parathion alone might provide insect protection for
as much as 1 day, but with added toxaphene this protection can be extended
up to about 4 days.
Mr. Hodges said that the total number of FMC products, i.e.,
labels, has decreased from 1,700 to approximately 47 at the present time.
Mr. Hodges indicated that the only formulations of toxaphene
prepared at this plant are the dusts and the eraulsifiable concentrate.
This plant does not formulate any aldrin, dieldrin, endrin, or DDT, nor
do they produce any treated seed.
Mr. Hodges indicated that the "bread and butter" of this site's
operations is the sale of their own proprietary products. Losing the tox-
aphene business would not constitute an economic disaster to this company
and is not of major concern to them. He indicated that products produced
at this plant other than FMC's own proprietary products are "me too" pro-
ducts and the profit margins are not large for these products.
He said that there was a general trend away from secrecy among
formulators. Basically they are all now selling the same formulation and
the equipment is basically the same also. However, although the equipment
is standard, each formulator modifies the equipment to meet his specific
Mr. Hodges observed that all new pesticide products that have
been placed on the market within the last few years had been put out in
finished, formulated, packaged form.
Plant Tour
Mr. Hodges took us on a tour of his entire plant and we were
joined during this tour by Mr. Frank Snowden, Assistant Manager. He showed
us the Munson mixers where dusts are formulated at FMC. He indicated that
FMC once made a 40% toxaphene dust for Hercules. He indicated that some
407. dust formulations wore still made.

Mr. Hodges said that the plant is equipped with a septic tank
and only sanitary wastes are disposed to this tank.
The dust formulation unit at this site is located in the same
building as the warehouse. While we toured this building, they were blend-
ing captan with talc using a ribbon blender followed by an attrition mill;
the formulated product was loaded into 50-lb bags. Dusts escaping from
the dust unit were picked up by a vacuum system which went into a central
collecting system.
Dusts are formulated at this site in 1,000-lb batches. The equip-
ment includes a Raymond roller mill and a ribbon blender.
FMC had a fugitive dust collection piping system which carried
dusts from all potential emission points within the dust unit to a central
cyclone collection system. The cyclone was located outside the building.
The collected dust is periodically removed from the bottom of the cyclone.
Mr. Hodges said that this dust, along with other trash, is disposed of in
a city dump; they have specific permission to dispose of this material in
the dump. Under this agreement, however, they can dispose of no Class B
poisons. The waste material is transported to the dump in their own trucks.
The amount of waste dust averages 200 to 300 lb/day.
Mr. Hodges stated that the fugitive dust collected from the for-
mulation of Class B poisons, such as parathion, is handled separately in a
special collection system, and decontaminated before disposal.
Toxaphene is received by this company as the 90-10 technical
material primarily by tanktrucks. It is stored in two large toxaphene
tanks which contain approximately 10,000 gal. each. These tanks are
surrounded by a soil dike.
Aluminum is the accepted material of construction for toxaphene
storage tanks because of the corrosive properties of toxaphene.
Evaporative Waste Treatment System"
The area of the plant where the liquid formulation takes place
is a large roofed (but open) building approximately AO x 60 ft. It has a
concrete floor. Toxaphene is pumped to the mixing tanks by means of a
dedicated pumping system. The equipment for pumping parathion is also
dedicated. Spills in this area are decontaminated with caustic, lime or
hypochlorite and are then washed with water to a drain which leads to a
sump. Liquid from this sump is pumped to an evaporator constructed of an
old converted boiler tank which has a capacity of about 4,000 gal. The
tank is made of three-quarter inch steel. The tank has an opening at the

top (about 6 x ID ft) and is covered with a semitransparent roof. The
purpose of the roof is to keep out most of the rain water. The tank is
equipped with a steam coil to accelerate the evaporation rate. Mr. Hodges
indicated that this site has excess steam capacity, and therefore the op-
erating cost is negligible.
Mr. Hodges indicated that the contents of this tank were acidic.
He indicated that when toxaphene decomposes, hydrochloric acid is generated,
accounting for the acidity.
Mr. Hodges indicated that he had not sampled the contents of this
tank nor was there any easy way for it to be sampled. The water in this
tank was approximately 1 to 2 ft deep. We took pictures of this piece of
equipment (Photos 3-4 and 3-5).
Mr. Hodges indicated that in some of the other FMC plants, burlap
wicks are used to accelerate the evaporation of the water in tanks of this
kind. Mr. Hodges indicated that the type of system used at the Jacksonville,
Florida, plant was the type most commonly used at other FMC formulation
Plant Runoff and NPDES Permit
In regard to water pollution, Mr. Hodges indicated that 15 years
ago formulators had very considerable water pollution problems. However,
approximately 8 years ago, most formulators did away with the use of water
in their processing. Many formulators formerly used a fire hose to clean
an area and washed wastes into a nearby stream.
During the plant tour we passed over a ditch through which a
small quantity of water was running. Mr. Green indicated that all of this
water was generated on site, e.g., a stream was not flowing through the
plant site. He also said that FMC has monitored the flow of this stream
and has been required to send data to Atlanta. It was then determined that
these data had been submitted in support of an NPDES permit (No. FL0025615),
dated September 4, 1973. The most recent data were submitted on October 9,
1975, but consisted only of the time of monitoring, the pH of the water, and
its temperature. The report was submitted to Mr. Thomas Rouzie, Engineer,
Northeast Region, State of Florida, Department of Pollution Control, 3426
Bills Road, Jacksonville, Florida. Mr. Green said that the water that goes
into this ditch includes tap water and cooling water. The major portion
of the surface runoff from the plant also goes into this ditch. The NPDES
permit indicated the flow rate of this stream to be 5 gal/min. However,
Mr. Green stated that for a week or two at a time there would be no flow in
this ditch at all. However, there would be considerable runoff in the
event of a rain.

Mr. Green says that FMC has sampled the soil and the water la and
around the ditch. He indicated that they have found toxaphene on their
property, but did not find toxaphene outside their property. He indicated
that the sensitivity of the method used for toxaphene was 100 ppm.
Mr. Hodges said that they occasionally check their runoff water
but have not found any toxaphene in it.
The site has "clean" and "dirty" shower facilities for workers.
The contaminated water from these showers and lavatories (and from the
control laboratory) is sent to a separate septic tank and is not discharged
to any sewer.
We told Mr. Hodges that we would get a copy of our report to EPA
to them so that they could review it and suggest clarifications or addi-
tions. Copies of the agreements that Tom Ferguson and Dr. Meiners signed
are attached to this report.

1. Report No.
3. Recipient's Accession No.
4. Title and Subtitle
Wastewater /Treatment Technology Documentation,
Formulation of Aldrin/Dieldrin, DDT, Endrin, Toxaphene
S. Report Date
Pub. June 1976
7. Author(s)
A. F. Meiners, C. E. Mumma , T. L. Ferguson and G. L. Kelso
S. Performing Organization Rept.
N°- 4127-C
9. Performing Organization Name and Address
Midwest Research Institute
425 Volker Boulevard
Kansas City, Missouri 64110
10. Project/Task/Work Unit No.
11. Contract/Grant No.
12. Sponsoring Organization Name and Address
Office of Water Planning and Standards
U. S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460	
13. Type of Report & Period
Interim Report, Editec
15. Supplementary Notes
Some editing was performed by EPA
16. Abstracts
This report was prepared to provide technologic supporting information for toxic
pollutant effluent standards proposed by EPA under S307(a) of the Federal Water
Pollution Control Act Aineiidments of 1972. The report identifies potential
technologies, assesses implementation feasibility, estimates final effluent
characteristics and estimates installation and operation costs for Aldrin/Dieldrin,
DDT, Endrin, Toxaphene formulation.
17. Key Words and Document Analysis.
Waste water
Waste Treatment
Cost Analysis
Cost Comparison
17a. Descriptors
17b. Identifiers/Open-Ended Terms
Toxic pollutant effluent standards
Federal Water Pollution Control Act
17c. COSATI Field/Group
19.. Security Class (This
20. Security Class (This
21. No. of Pages
18. Availability Statement
mam ntis-sb tncv. io-7») ENDORSED BY ANSI AND UNESCO.
USCOMM-OC (2«8>P74

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