EPA-600 / R-94-126
July 18S4
EVALUATION OF
CONTAINMENT AND CONTROL OPTIONS
FOR METHYL BROMIDE
IN COMMODITY TREATMENT
Prepared By:
Glenn B. DeWoLf and Matthew R. Harrison
Radian Corporation
P.O. Box 201088
Austin, Texas 78720-1088
EPA Contract No. 68-D1-0031
Work Assignment No. 54
EPA Project Officer:
Robert V. Hendriks
Air and Energy Engineering Research Laboratory
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Prepared for:
U.S. Environmental Protection Agency
Office of Research and Development
Washington, D.C. 20640

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TABLE OF CONTENTS
Page
Abstract	ii
Table of Contents	iii
List of Tables	v
List cf Figures	vi
Conversion Factors 		vii
1.0 INTRODUCTION 		1
2.0 PHYSICAL CHARACTERIZATION OF METHYL BROMIDE EMISSION SOURCES IN
COMMODITY TREATMENT 		3
2.1	End Use Patterns		3
2.1.1	End Use Patterns by Purpose		3
2.1.2	End Use Patterns by Agricultural Commodity 		5
2.1.3	End Use Patterns by Application Configuration ....	10
2.1.4	End Use Trends		11
2.2	Space Fumigation Applications: Technical Descriptions ...	11
2.2.1	Fumigation of Bulk Grain		12
2.2.2	Commodity Fumigation Chambers 		14
2.2.3	Commodity Fumigation Under Sheets (Tarpaulins) ...	18
2.2.4	Individual Package Fumigation 		18
2.2.5	Field Fumigation Under Sheets 		21
2.2.6	Fumigation of Full Cargo Spaces		21
3.0 CONTAINMENT METHODS 		23
3.1	Physical Containment Methods 		23
3.2	Containment Procedures		24
3.3	APHIS Methods and Procedures 		25
4.0 EMISSION CONTROL TECHNOLOGY CONSIDERATIONS 		31
4.1	General Considerations 		31
4.1.1	Stream Characteristics 		31
4.1.2	Process Influences on Recoverable MeBr 		35
4.2	Technology Descriptions 		36
4.2.1	Capture of Methyl Bromide Vapors 		36
4.2.2	Collection of Methyl Bromide 		38
4.2.3	Recovery and Recycle		47
4.2.4	Destruction		48
4.2.5	Potential Technologies for Direct Vent Stream
Control		50
4.3	Control Costs		51
5.0 IDENTIFICATION OF CURRENT CONTROL RESEARCH EFFORTS 		54
6.0 IDENTIFICATION OF REMAINING INFORMATION GAPS 		56
6.1 Regulatory Issues 		56
iii

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TABLE OF CONTENTS
PoQ6
6.2	Stream Characteristics 		57
6.3	Fumigation Commodity Containment Options 		57
6.4	Achievable Recovery from Fumigation 		57
6.5	Technology Performance Characteristics 		58
6.6	Economic Issues 		58
6.7	Availability of Substitutes 		59
7.0 CONCLUSIONS 		60
7.1	Methyl Bromide Uses and Quantities		60
7.2	Emission Source Characteristics 		60
7.3	Process Economics 		61
7.4	Current Research and Development Activities 		62
7.5	Information Gaps		62
REFERENCES		63
APPENDIX A: DATA COLLECTION 		A-l
APPENDIX 3: METHYL BROMIDE PHYSICAL PROPERTIES 		3-1
APPENDIX C: CALIFORNIA CHEMICAL USE REPORT FOR METHYL BROMIDE .	C-l
APPENDIX D: OFFICIAL LIST OF GRAIN WAREHOUSES (UGSA) BY STATS
(SOURCE: USDA) 		D-l
APPENDIX E: FUMIGATION TREATMENT FACILITIES BY STATE
(SOURCE: APHIS) 		2-1
APPENDIX F: POTENTIAL DESTRUCTION TECHNOLOGIES
(SOURCE: REFERENCE 19) 		F-l
iv

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LIST OF TABLES
Page
1	Methyl Bromide Use (Million Pounds/Yr) 		2
2	Trade Data for Fruit and Vegetable Imports Treated by Methyl
Bromide Fumigation 		8
3	California MeBr Use on Post-Harvest Products -
Jan - Dec 1991 (lbs) 		9
4	California Total Use of MeBr		9
5	End Use Patterns by Application		11
6	Tarpaulin Aeration System Design 		27
7	California Methyl Bromide Test Results 		37
8	Vender Reported Control Cost Data		52
9	Stream Design Basis for Example Recovery System Cost Estimate . .	52
10	Major Equipment List		53
11	Estimated Costs for MeBr Recovery System 		53
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LIST OF FIGURES
Page
1	Percentage of Total U.S. Imports Fumigated with Methyl Bromide,
1369/1990 		6
2	Imports Treated with Methyl Bromide as a Percentage of Annual
U.S. Supplies, 1989/1990 		7
3	Permanent Installations for Fumigation of Grain in Silos
by Recirculation	13
4	Generalized Plan of an Atmospheric Fumigation Chamber 		16
5	Vacuum Fumigation Installation 		17
6	Fumigation of Bagged Grain ur.der Polyethylene Sheets Inside
a Warehouse	19
7	Outdoor Fumigation of Stacked Bags Under Sheets 		2 0
9	Tarpaulin Aeration Systems 		28
9 Process Concept for MeBr Recovery 		32
1C Process Concept for MeBr Collection and Destruction 		33
11	Process Concept for Ke3r Direct Destruction 		34
12	Typical Carbon Adsorption Configurations for MeBr Collection . .	40
13	Equilibrium Capacity Curves of Kenhyl Bromide on Carbon Ad-
sorbent Derived from Experimental Data at Various Temperatures .	42
14	Adsorption Rate Function for Laboratory Adsorption Bed
Derived from Experimental Data	42
15	Inlet ana Outlet Gas Concentration Curves Derived from Experi-
mental Data for Adsorption of MeBr on a Wheat Column	43
16	Inlet and Outlet Gas Concentration Curves Derived from Experi-
mental Data for Desorption of MeBr on a Wheat Column	43
17	Attachment of Mobil Adsorption Unit to Silo	44
vi

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CONVERSION FACTORS
Certain nonmetric units are used in this report for the reader's
convenience. Readers more familiar with metric units may use the
following factors to convert to that system.
Nonmetric
Multiplied by
Yields metric
atm
98.1
kPa
Btu/hr
0.293
W
cal
4.18
J
cfm
0.000472
m^/s
°F
5/9(°F-32)
°C
ft
0.305
m
ft2
0.0929

ft3
0.0283
m^
gal.
0.00379
m3
hp
0.746
kW
in.
0.0254
m
in. WC
0.249
kPa
lb
0.454
kg
mil
0.0000254
m
psi
6.89
kPa
ton
907
kg
vii

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SECTION 1.0
INTRODUCTION
Methyl bromide (Me3r) , with the chemical formula CH,Br, also called
bromomethane, is listed by the 1991 Montreal Protocol as an ozone depleting
chemical similar to the other halogenated hydrocarbons such as the chloro-
fluorocarbor.s (CFCs). The U.S. Environmental Protection Agency's (EPA's)
regulations authorized by the Clean Air Act (CAA) call for a phaseout of MeBr
by the year 2001: -This would mean an end to uses of MeBr where the material
is emitted to the atmosphere. In some applications, there is no apparent,
ready substitute for MeBr. Therefore, this study was undertaken to inves-
tigate possible means for MeBr recovery for reuse and for MeBr destruction to
prevent atmospheric emissions if its limited use were still allowed. A
summary discussion of the data sources used for this study is presented in
Appendix A.
MeBr is widely used in United States agriculture as a fumigantK'
fumigant is a material that can exist as a gas in a concentration lethal to a
pest organism. As a gas, it can penetrate the material being fumigated, and
then diffuse away after the fumigation ends. MeBr is a very useful general
fumigant since it is a permeating gas at ambient temperatures and pressures,
and since it has a very desirable toxicity to many pest populations. Physical
property data for MeBr are listed in Appendix B.
As Table 1 shows, the primary use of MeBr is in soil fumigation, where
it is usee to kill nematodes ar.d soil insects prior to planting. According to
Chemical Products Synopsis (CPS), approximately 75% of the 47 million lb of
MeBr consumed in 1591 in the U.S. was for this application.' An additional 8%
of MeBr consumption is as a chemical intermediate or as a solvent. The
remaining 16% of KeBr consumption is used in space fumigation. Half of that
space fumigation is structural fumigation, and half is for commodity
fumigation. This report is concerned mainly with the SI, or 3.8 million lb,
of MeBr used in commodity fumigation.
The National Agricultural Pesticide Impact Assessment Program (NAPIAP)
of the USDA also produced use numbers for MeBr that are different than the CPS
numbers.2 However, both sources show that approximately 4 to 5 million lb/yr
of MeBr is used for commodity/agricultural harvest space fumigation. The
1

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Table 1
Methyl Bromide Use (Million Pounds/Yr)

1991 Use from Chemical
Product Synopsis1
1990 Use from NAPIAP2
Total
47
64
Soil Fumigation
35
47
Chemical Intermediate
3.8

Structural Space
Fumigation
3.8
4 to 9
Commodity Space
Fumigation
00
m
5
Chemical Manufacturer's Association has also produced a methyl bromide use
report, but the report is not publicly available.
This study has gathered preliminary data that can be used to determine
if some of the essential agricultural commodity fumigation applications for
MeBr could be continued by the use of some emission control methods on those
commodity fumigation applications.
Physical characteristics of methyl bromide emission sources in commodity
treatment are discussed in Section 2. This includes statistics on end uses by
purpose of fumigation and configuration for various applications. Section 3
discusses specifics of various commodity containment methods. This informa-
tion is important in defining how recovery systems could be retrofitted or how
fumigation systems might have to be modified to accommodate an emission
control system. Basic design considerations for emissions control and
technologies currently being considered are presented in Section 4. Current
control research efforts are discussed in Section 5. Identification of
remaining information gaps is the subject of Section 6, and Section 7 presents
conclusions of the present study. Several appendices present supplementary
information.
2

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SECTION 2.0
PHYSICAL CHARACTERIZATION OF METHYL BROMIDE
EMISSION SOURCES IN COMMODITY TREATMENT
This section briefly describes the general uses and physical details of
each space fumigation application for commodity treatment. At this time, our
information suggests that MeBr fumigation for commodities' treatment is
limited to only a few of these specific configurations. However, since we
have only a sampling of applications rather than a complete inventory, a broad
range of applications is described. This information is fundamental for
characterizing the sources in order to establish potentially feasible emission
controls.
Space fumigation refers to a wide range of treatments in enclosed areas.
The "enclosed areas" can range from air-tight fumigation chambers, to
relatively air-tight structures such as sealed silos, to open structures such
as warehouses. The "areas" may be buildings or structures that are infested
themselves, and require structural fumigation to rid them of pests, such as
termites. However, half of all space fumigation is conducted to treat
harvested agricultural products with residual insect populations. Harvested
materials may be stored in bulk, such as in grain silos, or may be in shipment
containers, such as crates, bags, or boxes of fruit, nuts, or grain.
2.1 End Use Patterns
This section describes the specific areas of use, or "end use patterns"
for methyl bromide fumigation. The purpose of each use is outlined, and
quantified where possible. End uses are shown by purpose and by agricultural
product.
2.1.1 End Use Patterns by Purpose
MeBr is used for three main purposes in commodity fumigation:
1. Import/export quarantine fumigation as required by the importing
country. This use is usually to prevent entry of a pest that is
not native to the import country; the application is a regulated
and monitored process. An importing country often requires
certain crops to be fumigated even if there is no visual
indication of pests. This use is 416,000 lbs, or 11% of commodity
fumigation.
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2 Long term bulk storage of agricultural products to hold the
products for off-season demand. Long-term in this case means a
month or longer. Storage is often in stacks inside of warehouses
specifically built to store the products. Fumigation for long
term storage may occur in a chamber prior to placing the material
into cold storage warehouses, or may occur under tarpaulin either
outdoors or in a warehouse, where the tarp is left in place for
the duration of storage. This use is estimated to be 3.0 million
lbs/yr, or 80% of commodity fumigation.
3. Potentially infested harvested crops on their way to domestic
markets. Fumigation in this case saves the harvest from
destruction and prevents infestation of other products that the
cargo may contact. This use is estimated to be 340,000 Ib/yr, or
9% of commodity fumigation.
According to the Animal and Plant Health Inspection Services (APHIS),
the agency that monitors the quarantine fumigations in the U.S., there were
416,685 pounds of MeBr used in the U.S. (Oct 1991 to Sept 1992) for quarantine
fumigation. This represents only 11% of the 3.8 Mlb/yr commodity fumigation
use, and 0.88% of total MeBr consumption in the U.S. for 1992.2 This is a
small portion of the MeBr commodity use, since much of the U.S. agricultural
consumption is supplied domestically and there are relatively few imports
requiring fumigation.
Of the products that do require fumigation, quarantine fumigation can
occur in the exporting or in the importing country. Therefore not all of the
U.S. import fumigation occurs in the U.S. Some shipments are fumigated in the
transport containers during shipment. However, most quarantine fumigation has
to be monitored, so it occurs at a fixed location.
APHIS representatives and USDA inspectors claim that approximately 90%+
of all quarantine fumigations are performed in temporary enclosures (under
tarpaulin or other plastic-material sheets). The <10% exception is for some
chamber fumigation of fruit exported to Japan from the west coast.3
The second use of MeBr for long term storage is estimated to comprise
approximately 80% of the MeBr commodity use, and 6% of the total MeBr use
nationally. However, this number is purely based upon an estimate of the use
in bulk fumigation. No statistical data are yet available to validate this
assumption.
4

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The third use for potentially infested crop harvests constitutes 9% of
the MeBr commodity use and 0.7% of the total MeBr use nationally. It includes
many MeBr applications, including fumigation prior to packaging and emergency
fumigation of infested harvests or harvests with significant residual insect
populations. This number is also based only upon the judgement that this is a
small use nationally.
2.1.2 End Use Patterns by Agricultural Commodity
Commodity fumigation with MeBr is not performed on all agricultural
crops. MeBr is not suitable for many sensitive harvests; it burns plums and
pears, for example. Therefore, other fumigants are often preferred for
specific applications. Conversely, MeBr works extremely well on many crops
and insects; these crops receive a high amount of MeBr fumigation.
Data available from APHIS shows the percentage of various U.S. import
crops that are fumigated with methyl bromide (see Figure l).2 Over 90% of all
apricots, grapes, peaches, nectarines, plums, tangerines, and yams imported to
the U.S. are fumigated. Figure 2 shows that the amount of imports fumigated
is still a small percentage of the U.S. supply for most of those crops. Table
2 lists the numbers that Figures 1 and 2 were based upon.
Some additional specific data were available from the state of
California. The following end-use analysis in Table 3 shows MeBr fumigation
in California by product. This table was compiled from raw data on chemical
use reports supplied by the California Department of Pesticide Regulations.4
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Noie: Fumigaicd imports of Brassica Dicracca and Kiwi were less than 1% of total imports in 1989/1990.
Figure 1. Percentage of Total U.S. Imports Fumigated with Methyl Bromide,
1989/1990

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Figure 2. Imports Treated with Methyl Bromide as a Percentage of Annual U.S. Supplies,
1989/1990

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Table 2
Trade Data for Fruit and Vegetable Imports Treated by Methyl Bromide Fumigation
Commodity
Total Annual U.S. Imports
(1989/1990 Average)
U.S. Imports Fumigated with MB
(1989/1990 Average)
(Metric Tons)
($1000)
(Metric Tons)
($1000)
Apricots
901
892
806
702
Beans/Peas
33/. 34
37,313
3,343
3/3
Brassica Oleracea
65,278
17,783
23
27
Carlic
17,309
15,747
645
1 ,34 5
Grapefruit
4,9455
879
159
28
Grapes
327,135
250,493
302,502
22,422
Kiwi
26,587
33,213
34
75
Lemons
8,556
1,281
651
250
Okra
18,484
4,919
185
49
Oranges
9,418
4,14?
1,102
289
Peaches/Nectarines
47,968
31,5/8
46,024
29,999
Plums
22,052
14,036
21,740
13,844
Tange r i ne s
1? ,617
4,191
12,134
3,859
Yam
18,169
10,769
18,169
10,769
Note: 1989/1990 Trade Data for Cipollino, Ethnog, Horseradish, Roselle,
Thyme, and Tuna (fruit) was unavailable by country of origin.
Sources: Reference 5.

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Table 3
California MeBr Use on Post-Harvest Products
Jan - Dec 1991 (lbs)
Post Harvest Product
Lbs of MeBr Applied
% of Commodity
HeBr Use
Fruit
299080
46.7
Vegetables
8322
1.3
Nuts
155457
24.3
Grain
17795
2.8
Fibers
170
0.0
Other ag products
9210
1.4
Nursery Products (post
harvest)
29105
4.5
Commodity
(Non-Ag Product)
121840
19.0
TOTAL
640979
100.0
Source: Derived from Reference 4.
The California data in Table 4 also shows the split for other MeBr uses
Table 4
California Total Use of MeBr
Use
Lbs
% of Total Use
1
Post Harvest Crop
Fumigation
640979
3.4
2
Pre-Planting Soil
Fumigation
14331057
76.7
3
Structural/Area
Fumigation
3330834
17.8
4
Nursery-Greenhouse
(Post-Harvest)
292698
1.6
53
Other
80275
0.4
TOTAL
18675843
100.0
The data in Tables 3 and 4 were assembled by manipulating the California data
from Reference 4 (see Appendix C) using the following assumptions:
9

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1.	MeBr use attributed to an agricultural product, but with an
acreage or square foot designation under "units treated" actually
referred to pre-planting soil fumigation for that crop.
2.	For MeBr use attributed to agricultural products, all other unit
designations (pounds, Kilograms, Units, etc) referred to post
harvest crop quantities.
These California percentages are slightly different than those reported
in Chemical Products synopsis (CPS), cited in the Introduction. California
has more structural fumigation (17.6% of total use) than the 8% reported for
U.S. structural fumigation by CPS. This is not inconsistent with the CPS
data, since the temperate climate of California allows pests such as termites
to prosper all year and therefore requires additional structural fumigation of
households and buildings. The soil fumigation number (77%) from the Cali-
fornia data compares well to the CPS data of 75%.
The post harvest commodity and agricultural product fumigation that is
the subject of this report includes categories 1 and 4. For California, this
constitutes only 5.0% of total MeBr use, as compared to 8% suggested in CPS.
If some of the greenhouse fumigation attributed to pre-planting were actually
post harvest fumigation, then use in category 4 of Table 4 rises by 1.7
Mlbs/yr, or 9.1% of total MeBr use, and total commodity fumigation becomes
14.1% of total MeBr use in California.
2.1.3 End Use Patterns by Application Configuration
As is discussed in Section 2.2, Space Fumigation Applications, Technical
Descriptions, there are many methods of applying the MeBr fumigant to the
agricultural product. We have estimated the relative MeBr quantities for the
various commodity fumigation applications, as shown in Table 5. The split was
produced from estimates of populations and uses from various information
sources.
10

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Table 5
End Use Patterns By Application
Application
Population of Applications
in the U.S.
U>B/Xr of
KeBr Dsa •
Vacuum Chambers using MeBr
Approximately 100 Chambers
(59 Chambers are on the APHIS
list of contract fumigation
facilities)a
Assumed to be
< 100.000
Atmospheric Chambers using MeBr
Approximately 100 Chambers
(Cnly S Chambers are on the APHIS
list of contract fumigation
facilities, but there are many
private chancers)®
Assumed to be
< ICC,CCD
Tarpaulin for all uses
122 Companies3
711 Poets of Entry (Quarantine)3
3,000,000
(Only 400,000
for quarantine)
Agricultural products inside
Shipping Containers (Land/Sea
Trailers, Ship Hclds)
Number of containers unknown at
this time
Unknown at this
time
Grain Storage Warehouses
(silos, elevators)
10,123b
Assumed to be
<1GC,000
jj Reference i.
Reference 6.
* All quantities are based on engineering judgement.
2.1.4 End Use Trends
There has been some relocation of import product fumigation operations
from the U.S. to the exporting country for economic and other reasons. For
example, Nogales, Arizona used to use MeBr extensively, but all fumigation is
now done in Sonora, Mexico, across the border. If MeBr standards in the U.S.
under the Clean Air Act differ from those in other countries subject to the
Montreal Protocol, there could be relocation of fumigation operations to
countries with later MeBr phaseout dates.
Other fumigation applications shift from port to port in the U.S.
depending on the current local environmental concerns. The Port of San Diego
used to do fumigation, but most of that has shifted to the Port of Los
Angeles. The Port of San Diego has installed a new cold storage facility (for
post fumigation storage) and hopes to begin doing import fumigation again.
2.2 Space Fumigation Applications: Technical Descriptions
Most of the MeBr space fumigation applications in the U.S. do not have
air emissions control equipment. Therefore any fumigant that is not consumed
(hydrolyzed into the harvested commodity and insect population), will
eventually be emitted into the atmosphere during or after completion of the
fumigation process.
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The general process for any space fumigation consists of several steps:
1.	Enclosure of material to be fumigated,
2.	Fumigation (exposure of material inside the enclosure to the
fumigant gas),
3.	Aeration (removal of the fumigant gas from the enclosure and the
material),
4.	Removal of the material from the enclosure.
The various space fumigation techniques have different designs and procedures
for each of these steps.
Most of the MeBr space fumigation applications are well known, having
been used for many years and are as follows:7
1.	Bulk Grain Fumigation
2.	Commodity Fumigation Chambers
3.	Commodity Fumigation Under Sheets
4.	Individual Package Fumigation
5.	Field Fumigation Under Sheets
6.	Fumigation of Full Cargo Spaces
Categories 1 through 6 are all fumigation of foodstuff or other agricultural
products, which is estimated to be 8% of MeBr end use, or 3.8 million pounds
per year. The 3.8 million pounds consumed in 1992 for commodity space
fumigation are split among the 6 categories.
Each of the applications is described in more detail below.
2.2.1 Fumigation of Bulk Grain
Grain is stored in bulk in one of three structure types: 1) a vertical
silo, 2) flat, horizontal storage, or 3) farm-type bins. However, there is
great diversity even within a structure type. Silo storage can be constructed
of many materials, and may or may not have a roof (see Figure 3). Silo
storage can be made fairly air tight by application of a sealer to the
interior surface of concrete or brick. Horizontal storage is also called
"distress storage", and refers to temporary structures or freight cars or
trucks. Naturally, many of these structures have open tops. Finally,
12

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I Exhaust
Recirculation
Duct
YfeBr
Addition
TO) Blower
©w T©
Diffuser
Fresh Air
Intake
Fumigation Circulation. Valves 1 & 4 closed; valves 2 & 3 open
Aeration Venting: Valve 2 closed; valves 1.3, & 4 open
Figure 3. Permanent Installation for Fumigation of Grain in Silcs by
Recirculation
13

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farm-type bins and storage units are used as permanent storage, but are often
loosely constructed and not air tight.
Fumigation of grain in silos may skip some of the fumigation process
steps listed above. Generally, the grain storage silo is the fumigation
enclosure, so the grain is not removed after the fumigation. The fumigant may
be introduced at one end of the silo and pulled up by aeration fans.
Conversely, the grain may be directly fumigated as it is transferred into the
bin. The MeBr usually vents directly to the atmosphere at the top of the
silo.
2.2.2 Commodity Fumigation Chambers
Commodity fumigation chambers are vessels, one-room buildings, or sheds,
constructed specifically for product fumigation. Kost of the chambers are
stationary, with large doors for easy loading and unloading of goods. The
chambers are constructed to generally contain the gas and enclose the goods,
but not all chambers are gas-tight. The chambers usually have ports for
applying the fumigant, a fan circulation system to circulate and distribute
the fumigant, and an exhaust fan system to vent the fumigant during aeration.
Chambers can be air-tight pressure vessels (as in the case of vacuum
chambers) or can be any structure made of wood, masonry, plastic, or metal
where sufficient effort has been made to seal leaks at joint locations and
openings. The size of the chambers varies widely depending on the chamber
use.
Reference 2 lists many suggested specifications for the construction of
chambers for various purposes. However, there is no single standard, so the
construction of actual chambers may or may not use this guideline. Enclosures
used for quarantine do require certification, but this certification process
does not ensure that the application is gas-tight.3
The different types of fumigation Chambers are:
•	Atmospheric pressure,
•	Vacuum, and
•	Pressurized chambers.
Vacuum and pressurized chambers are not suitable for many tender fruits or
other tender agricultural products.
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Normal Atmospheric Pressure (NAP) Chambers
Most of these chambers are of the construction shown in Figure 4. These
chambers have wide doors and can be tight or fairly leaky. There are some NAP
chambers that are tent-type, barrel-type, or portable trailer furaigators, but
these are few in number and do not constitute a significant use of MeBr.
An additional atmospheric pressure fumigation "chamber" is a greenhouse
or glasshouse nursery, where the structure itself becomes the fumigation
chamber. Usually, other fumigants are used in greenhouses because greenhouses
are very leaky structures. However, if efforts are made to seal the leaks,
MeBr can be used for disinfestation purposes.7
Vacuum Fumigation Chambers
These chambers have to withstand an atmosphere (1 atm) of full external
pressure, so they are usually shaped cylindrically, and made of steel (see
Figure 5). They are air-tight. The support equipment includes a vacuum pump
(capable of pulling a vacuum in less than 15 minutes), an aeration fan, and
doors that can also take a full vacuum. Vacuum chambers operate slightly
differently than other chambers, pulling a vacuum to remove air before the
funiigant introduction. This allows the fumigant to better penetrate into the
stock when the fumigant is added. Another vacuum is pulled to remove the
fumigant after the exposure is complete, expediting the MeBr removal prior to
normal fan aeration at atmospheric pressure.
Vacuum chambers are expensive to construct and are usually used where
quick turnover is a key economic issue. Vacuum fumigation has a more
efficient permeation of fumigant than other techniques, and is therefore
faster for the same target exposure/fumigant penetration. Typical vacuum
fumigation is less than 4 hours, versus less than 24 hours for atmospheric
fumigation.7 Vacuum fumigation was originally developed when hydrogen cyanide
(HCN) was the primary fumigant; the greater penetrating ability of MeBr has
made vacuum fumigation less important for treatment of many commodities.
Pressurized Fumigation Chambers
Steel chambers capable of holding high pressures can be used to drive
the MeBr into the commodity's void spaces by holding a pressure higher than
atmospheric pressure. Although one such chamber is under construction at the
15

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Exhaust
System
Exhaust
Fan
Intakes
Heating
Element
Exhaust
11 u Vent
Loading
Door
Fumigation
Chamber
MeBr
Addition
Port
Figure 4. Generalized Plan of an Atmospheric Fumigation Chamber
16

-------
To Vacuum Pump ami F.itiaust	Vacuum V«ot Line
Seal Doo*
V*cuoff
, ,««« In5"1Uti°n
Figure 3•
17

-------
Port of Los Angeles, Radian could noc locate any complete working examples of
such chambers.
2.2.3	Commodity Fumigation Under Sheets (Tarpaulins)
This application is the single largest use of MeBr in commodity treat-
ment, since it is the easiest to apply (facility requirements are minimal),
and since it can be easily adapted to fit various size loads. Reference 7
states that most of the goods fumigated under sheets are cereals and other
plant products in bags that are stacked many layers high.
Fumigation under sheets refers to construction of a temporary enclosure
around a stack of agricultural products by laying sheets of polyethylene
plastic across them (see Figures 6 and 7). The floor must be a solid surface,
generally a cement foundation. However, the application may be indoors
(inside a large warehouse) or outdoors. The edges of the plastic are "sealed"
to the floor by sandbags, and sheets edges that meet one another on top of the
stack are "sealed" to each other by rolling and clamping the interface. The
pressure seal of this enclosure is generally weak.
Tarp applications usually have circulating fans and may or may not have
exhaust fans attached through ducts made of tarp material. For applications
with exhaust fans, the aeration step is vented through the exhaust duct. For
those without, the aeration may simply be performed by quickly removing the
sheets from the stack.
One of the largest tarpaulin applications is for long terra storage at
warehouses. For this application, the tarps are left in place for the full
duration of storage, and the aeration step never occurs. The user intends to
leave the fumigant inside the sheet seal as long as possible, to prevent
reinfestation for as long as possible during storage. The entire MeBr charge
is usually emitted by leakage if the load is stored for extensive time
periods.
2.2.4	Individual Package Fumigation
This use covers emergency application such as direct treatment without
an enclosure of small quantities of infested packages, as well as continuous
uses such as packaging line treatments, i.e. fumigation in processes where the
product is packaged for market. The processes covered are usually for dried
fruits and vegetables, where fumigant is added to the individual plastic
package before it is sealed. The package usually holds the fumigant just long
18

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Stacked Bags nf
Agricultural Products
Tarpaulin
2001b
Cylinder
of McBr
Concrete Pad
Volaliliur
Sandbags'
Sandsnaka
Figure 6. Fumigation of Bagged Grain Under Polyethylene Sheets Inside a
Warehouse
19

-------
Started Bap of
I / ^grfcuiJurai Products
i	_i
Ptauk j
St*«t« '
Cylinder
Figur. ,. Outdoor Fumtgacion o£ Stacked 8a8» "nder Sheet
20

-------
enough to deliver an effective treatment. All of the fumigant is eventually
leaked to the atmosphere. These uses are considered to be small consumers of
MeBr.
2.2.5	Field Fumigation Under Sheets
Preharvest infested crops are sometimes treated in situ. Lightweight
plastic sheets can cover a large area of land and hold the MeBr long enough to
effect a treatment of soil or growing crop.7 The best known application of
this technique is for California strawberries, where large beds of strawberry
plants infested with cyclamen mites are covered with sheets that are sealed at
the edges with earth or sand bags. MeBr is introduced under the sheets
through soaker hoses. Exposure is usually limited to a few hours, and all of
the MeBr is released to the atmosphere by permeation through the weak seals
and finally by removal of the sheets after exposure.
The California data cited in earlier sections shows that 4.5 million lbs
of MeBr was used on strawberries in 1991. This covers all types of appli-
cations including soil fumigation, post-harvest fumigation, and field use
under sheets. Use on strawberries is significant, since 4.5 million pounds is
24.3% of all of California's MeBr use. However, no data are available on the
amounts used for the individual applications on strawberries in the field.
2.2.6	Fumigation of Full Cargo Spaces
This application uses the cargo container as the fumigation chamber.
These are the large holds of ships or barges, in land/sea trailers, and rail
cars (the latter two applications being wheeled carriers). In some cases, the
container may be covered with a tarp and a fumigation under tarpaulin is
performed, but in most situations, the fumigation is more similar to an
atmospheric chamber fumigation or a bulk grain storage fumigation. One major
difference is that there is no controlled aeration step.
The application for cargo boxes introduces the MeBr to the interior
after the cargo has been loaded and the doors to the cargo space closed. The
structures can be leaky, especially at the doors. Generally, the aeration
occurs simply by opening the doors. However, much of the MeBr may have
escaped before this point.
As a final note, fumigation of empty structures such as Buildings/Mills,
Ship Holds (Empty), and Wheeled Carriers (Empty) is significant, but is not
considered as part of this commodity fumigation study.
21

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The following section examines the implications of these various
fumigation and containment methods from the point of view of potential control
systems.
22

-------
SECTION 3.0
CONTAINMENT METHODS
Containment refers to the method in which the fumigation area is
enclosed or contained. Procedures for containment are just as important as
the physical containment measures. Physical structure methods are discussed
first, and then a discussion of containment procedures follows.
3.1 Physical Containment Methods
There are very few fumigation applications where a completely air tight
structure is used. Therefore some MeBr is lost due to the inefficiency of the
chamber seal. A fumigation vacuum chamber is the only ready example of an air
tight chamber. One measure of structure tightness is the prolonged pressure
differential that it will hold. A vacuum chamber can indefinitely handle
pressure differentials up to 14.7 psi (33.9 feet of water) at full vacuum. In
the case of vacuum chambers, the leak is from the outside to the inside, so
there is no MeBr loss. MeBr is completely contained in these vessels,
however, they represent a very small fraction of the MeBr commodity fumigation
use .
Most structures and under-sheet uses are good barriers against mixing of
outside air currents with the internal gas, but are relatively weak as total
barriers or pressure seals. In fixed volume structures and chambers where
methyl bromide is added, the pressure increases proportionally to the amount
of MeBr added. The structure has atmospheric pressure inside when originally
"sealed" at the beginning of fumigation, and then additional gas molecules of
MeBr are added, slightly increasing the internal pressure. If all of the MeBr
is to be contained, the enclosed area must expand in volume (which does not
happen, since the structures have weight or are fixed), or the pressure must
increase and hold. In reality, neither usually happens, since the gas is not
completely contained. The pressure increase is leaked out of the chamber in
the form of the internal air and MeBr mixture.
In fact, most fumigation areas can only hold minute positive pressure
differentials (dP) of much less than two inches of water. Even for specially
constructed atmospheric fumigation chambers, a suggested pressure leakage test
starts at only 50 mm of kerosene manometer dP (approximately 1.6 inches of
water, or 0.058 psi). Furthermore, the recommended procedure allows a drop of
45 mm kerosene (1.4 inches of water, or 0.052 psi) in only 22 seconds.7 These
are very small pressures and fast leak rates that represent a relatively weak
seal. Therefore, most fumigation structures have some leakage.
23

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Fortunately, the leakage is usually small. The increase in pressure and
molecules due to the MeBr addition is low, since MeBr is only needed in part
per million level to kill pests. For example, say a dose of 2 pounds of MeBr
was added to a 10 foot cube (1000 ft3 chamber) at atmospheric pressure. The
chamber already contains 76 lbs of air (1000 ft3) before the fumigation
begins. The MeBr would only add 8.0 ftJ of space, forcing a loss to the
atmosphere of 8.0 ft3 of MeBr/air mixture when the leaks return the chamber to
atmospheric pressure. The air/MeBr mixture that is lost, however, may only
contain 0.1 lbs of MeBr, which is less than 5 percent of the MeBr added. This
assumes that the leaked material is not near the fumigant admission port.
In summary, most losses of MeBr in fumigation comes from the aeration-
purge step following the fumigation, rather than from leaks during fumigation.
A small amount of MeBr is lost due to inefficient chamber seals, but all of
the remaining MeBr is then purged to the atmosphere once the fumigation is
complete. Therefore, MeBr containment during fumigation is not a large issue,
given any of the standard enclosed fumigation methods. Most recovery options
must center on recovery of MeBr from the purge gas. The chamber seal
efficiency may become an issue only if the chamber or the purge apparatus
leaks during the purge operation.
The wide use of sheets to make any area into a temporary fumigation
chamber implies that this might be the "worst case" and most leak prone
containment system. In other words, any recovery/control operation that would
work for the low pressure seal of sheet applications is likely to work for all
applications.
3.2 Containment Procedures
Current procedures are usually set to effect an efficient cargo fumi-
gation exposure while limiting fumigation time and personnel exposure.
However, there are very few procedures that intentionally try to allow
recovery of all MeBr. Many of the techniques discussed in section 3 had no
means for collecting the MeBr since there was no single exit point for the
MeBr; it leaked during the fumigation and then exited through multiple
openings when the fumigation was finished.
As the following section will discuss, there are many ways that MeBr can
be lost: during the fumigation, during the chamber aeration, or from
inadequate removal (desorption) from the cargo. Physical systems must be in
place to ensure that all MeBr exits through a single point to allow recovery,
such as through a fumigation chamber's aeration exhaust fan
24

-------
stack, and procedures must ensure that this step is used every time. A sheet
fumigation application that has an exhaust fan, for example, must use it to
aerate rather than simply removing the sheets to aerate. Procedures that
contain the MeBr are as important as the physical containment measures.
3.3 APHIS Hethods and Procedures
The United States Department of Agriculture (USDA) Animal and Plant
Health Inspection Service (APHIS) publishes a Plant Protection and Quarantine
(PPQ) Manual for use by PPQ officers.5 The manual lists methods and
procedures specific to MeBr for tarpaulin fumigation, chamber fumigation, ship
fumigation, and bulk storage fumigation of grain, spices, or flour (which
APHIS calls "structure fumigation").
The following paragraphs outline the APHIS PPQ design and procedures for
tarpaulin fumigations.
Design Considerations for Tarpaulin Applications
•	Site Selection
Well-ventilated area,
Ability to heat area (to above 40°F), and
Impervious floor surface;
•	Load/Stack Arrangements
Break-up bulk cargo,
Containers: limit of eight under one tarp and only loaded
to 80% capacity each, and
Finely milled products: provide space every 5 feet in any
direction;
•	Distribution Fans
Throughput per minute should equal enclosure volume, using
one fan (of 2500 cfm capacity) for every 2500 ft3 of
enclosure, and
For containerized cargo under tarps, add at least one
additional fan of 2500 cfm at the top of the load;
25

-------
•	Tarpaulin Type
Minimum thickness is 4 mils, but must be 6 rails to be
reused, and
Large enough Co go 2 feet above and 1 foot beyond the sits
of the commodity;
•	Seal
Loose, wet sand, sand snakes, water snakes, adhesives, or a
combination can be applied where the tarp touches the
flooring surface.
Two rows of snakes on the side and three on the corners.
Snakes should overlap each other by one foot.
Use loose, wet sand in the areas where the gas introduction
line and electrical cords extend under the tar.
30 minutes: after MeBr is introduced, test for leaks using a
halide lead detector. Add sand to seal discovered leaks.
•	Aeration
Aeration procedures for tarpaulin fumigation varies depending on the
product and storage method. Table 6 lists some of the design criteria for
tarpaulin aerations. Figure 8 depicts the physical configurations of the
tarpaulin aeration operations.
As Table 6 shows, the outdoor tarpaulin FPQ fumigations do not use exha-
ust ducts. This procedure would have to be changed in order to allow recovery
of MeBr during fumigation.
The APHIS PPQ manual also lists methods and procedures for chamber
fumigation. Most of the text centers on dosage and aeration. The design and
operation are not covered, since the reader is referenced to the chamber
manufacturer's operating manual. Since all chambers have aeration fans, the
PPQ manual simply lists appropriate aeration times:
•	Normal Atmospheric Pressure Chambers:
4-15 minutes (4 complete changes of air); and
26

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Table 6
Tarpaulin Aeration System Design (USDA APHIS PPQ)5
Cargo Type
Minimum
Exhaust Fan
Requirements
Minimum Exhaust
Duct Diameter
Requirements
Minimum Air
Introduction Fan
Requirements
Aeration
Time*
Nonsorptive,
containerized
(indoor or outdoor)
1 @ 5200 cfin
>16"
1 @ 3750 cfm
plus a 12" duct
3 hours
Nonsorptive,
noncontainerized
(indoor)
1 @ 3500 cfm
Required,
but no size
spec ification
None specified
2 hours
Nonsorptive,
noncontainerized
(outdoor)
No exhaust method required since the tarps
are simply removed for the aeration step.
Fresh f rui ts,
vegetables,
cut flowers
2-3 @ 5000 cfin
36"
None specified
2 hours
Sorptive,
noncontainerized
(indoor)
1 (§ 3500 cfm
Required,
but no size
specjfication
None specified
4 hours
Sorptive,
noncontainerized
(outdoor)
No exhaust method required since the tarps
are simply removed for the aeration step.
Sorpt. i ve ,
containerized
(i ndoor)
1 16"
1 @ 3/50 cfm
plus a 12" duct
12 hours
Sorptive,
containerized
(outdoor)
No exhaust method required since the tarps
are simply removed for the aeration step.
*The aeration vent must read <5 ppm MeBr at the end of the venting period, or the procedure
will continue.

-------
11 OjflE»ir*n»d Cargo 
= -.	rl
Rnaoni at TarpMte
Figure 8. Tarpaulin Aeration Systems
28

-------
•	Vacuum Chambers:
Draw a vacuum of 15" WC with the vacuum pump and release it by
admitting air. Repeat four times.
Again, as with any fumigation, the gas concentration has to be <5 ppm to end
the aeration.
The PPQ manual covers fumigation of commodities inside ships for
storerooms and cargo holds. The rooms are treated as leaky NAP chambers, and
an effort is made to locate and seal all openings. Circulation fans are also
placed inside: at least two 1800 cfm fans in a storeroom, and 2500 cfm fans
for cargo holds. As with tarpaulin application, a halide detector is used to
test for leaks after all of the MeBr has been introduced.
Aeration of ship's holds does not always produce a single vent stream.
Aeration occurs by either 1) using an outside blower to force fresh air
through a portable duct and into the cargo space, or 2) using compressed air
hoses to force fresh air into the bottom of the hold. The MeBr may exit via
1) a suction fan with an exit duct or 2) the ship's ventilation system.
However, since the PPQ manual does not specify the fan and blower sizes, so an
oversized blower and undersized suction fan may force some leakage from the
chamber inside the ship.
The APHIS PPQ manual lists methods and procedures for bulk storage of
grain, spices, or flour in various storage structures. Options for this
fumigation are:
•	Complete enclosure of structure under a tarpaulin; and
•	Interior fumigation.
Interior fumigation is less desirable since the structures are rarely air-
tight. However, they are treated as NAP chambers (similar to ship holds), and
are made as air-tight as possible by sealing openings. Tarpaulin fumigations
for bulk storage proceed very similarly to the tarp procedure listed earlier.
Aeration for tarpaulin applications is achieved by partially removing
the tarp while using suction fans that exhaust through ducts to the outside.
A minimum of one 2500 cfm fan should be used.
The reader should note that APHIS conducts a minority of the commodity
fumigations in the U.S. Most fumigations are non-quarantine applications by
private companies. Therefore, the design and method details described in this
29

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section may not be representative of all of the U.S. applications. It is,
however, one of the few detailed references available.
30

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SECTION 4.0
EMISSION CONTROL TECHNOLOGY CONSIDERATIONS
4.1 General Considerations
The control options for MeBr are basically:
•	Collection, recovery and recycle;
•	Collection and destruction; or
•	Direct destruction.
These concepts are illustrated by the block diagrams in Figures 9, 10,
and 11, respectively. Figure 9 illustrates a process for recycle which also
shows destruction applied to a purge vent stream. Figure 10 shows a process
without recycle where destruction is applied to the MeBr after it is collect-
ed, by activated carbon adsorption, for example. This would occur in a
situation where, for some technical reason, recycle might not be possible.
Figure 11 shows a process where destruction might be employed directly on the
vent stream in a case where recycle is impossible. For all of these process-
es, the components of the individual process blocks and many of the design
considerations are similar and are discussed in the subsequent pages of this
section.
For design of such processes consideration must be given to each of the
following:
•	Stream characteristics;
•	Process influences on recoverable MeBr;
•	Fumigation vent stream capture;
•	MeBr Collection;
•	Intermediate MeBr storage; and
•	MeBr destruction.
4.1.1 Stream Characteristics
A fundamental design consideration for a system are the characteristics
of the stream being treated. Minimum information includes the following:
•	Flow rate;
•	Temperature;
•	Pressure; and
•	Composition (primarily MeBr and water vapor content).
31

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MeBr
Makeup
MeBr
Storage
Recycle
Vent
Destruction
Fumigation
Collection
Recovery
Recovered
MeBr
Storage
Figure 9. Process Concept for MeBr Recovery
32

-------
MeBr
Makeup
Fresh
MeBr
Fumigation
Vent
Collection
Destruction
Figure 10, Process Concept for MeBr Collection and Destruction
33

-------
MeBr
Makeup
Fresh
MeBr
Fumigation
Vent
Destruction
Figure 11. Process Concept for MeBr Direct Destruction
34

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In addition, information on other chemical constituents in the air would
be useful. This is especially important for adsorption processes.
All recovery applications except for vacuum fumigation have to deal with
air and moisture that will be mixed with the recovered MeBr. Also, various
organic vapors emitted from the commodities being fumigated may also be
present.
As was discussed in the previous section, the main recovery goal is to
collect the MeBr from the purge operation upon completion of fumigation. Many
fumigation systems employ induced draft fans to purge the fumigation space by
drawing outside air through the space after fumigation is complete. This is
to dissipate the toxic MeBr concentration so that people can enter the work
space.
4.1.2 Process Influences on Recoverable MeBr
Not all of the MeBr fed to the process will be available for final
recovery. As was discussed in the previous section, under current practices,
some MeBr is typically lost due to leaks because enclosures are not leak
tight. Even without leaks, some MeBr is absorbed, hydrolyzed, or converted to
other compounds from contact with the commodities being fumigated. Typically,
the MeBr available for collection can be represented by:
Collectable Mass » Inlet - Lossy - Lossc - Losst - Lossj
Where:
Inlet
Lossu
Lossc
Lossl
Lossj
Mass of MeBr input the fumigation space
Mass lost to unrecovered absorption/adsorption in the
commodity
Mass lost due to chemical interaction with chemical
constituents in the air or the commodity
Mass leaked to atmosphere
Mass lost due to inefficiencies in the recovery technique
Lossy is a term that can be reduced by designing post-fumigation
aeration to have sufficient volumes of exchange and time duration to allow the
maximum efficient amount of MeBr to rediffuse back from the commodity. The
commodity packaging and fill density in the fumigation chambers also affects
this term. An extended aeration time does hurt many processes where fast
turnover is a key economic issue. Expensive vacuum chambers, for example,
35

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were built to expedite turnover, but reduction of Lossy could extend the
fumigation time requirements.
Lossc is a term that may not be easily controlled since it will happen
no matter what the containment method or procedure. If the MeBr is chemi-
sorbed or actually reacts with the commodity or air, it cannot be readily
recovered.
Lossl can be easily reduced by using a tighter chamber. This may simply
mean making an existing "chamber" tighter by an inexpensive sealing of leaks,
or may involve an expensive switch to a new containment method.
Lossj refers to the efficiency of the recovery technology that is used
to remove the MeBr from the aeration exit stream. A lower efficiency lowers
the recoverable mass of MeBr by allowing some MeBr to escape. This can be
controlled by careful selection of recovery technique.
Several sources8,9 suggested that the typical MeBr loss was 20% per
application, mostly lost to chemical reaction such as hydrolysis (Lossc) . One
source on grain elevators suggests that the loss is 30% per application.i0,11
Other recovery vendor sources12 have suggested that Lossc is much lower, and
the 20% loss quoted is simply due to inadequate air turnovers that increase
LosslT. Regardless of the real loss number, any recovery system still requires
a constant make-up of MeBr. Therefore, if all production of MeBr ceases, none
of the fumigant recovery options will be viable if the current supply of MeBr
is expended.
Radian Corporation had the opportunity to make measurements on an MeBr
system in a previous program.*3 Data on losses from this work are shown in
Table 7. These data show that some of the systems had no controlled aeration
step, and that some of the systems had high leakage losses during fumigation.
4.2 Technology Descriptions
4.2.1 Capture of Methyl Bromide Vapors
For any of the process configurations, MeBr vapors vented from the
fumigation equipment must be captured for conveyance to the control process.
Capture devices may consist of hoods and ducting. Where the purge gas exits
through a single duct, as occurs with some enclosed chamber systems, this is
not a major design issue. For systems with multiple purge vents or sheet
36

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Table 7
California Methyl Bromide Test Results11
Fmigatiun
Type
TraiLer Truck
Land-Sea
Container
Aohient
Prossure
(uncertified)
Ftalgatian
Chanker
Anbient
Pressure
(uncertified)
Pusi gatiaii
Chambers (3)
Ambient
Pressure
(uncertified)
Ftmi gation
Chambers (2)
Certified Vacuus
Chambers (2)
Silo
Chambers
with Open
Tops
Silo
Chn#>ers
with Open
Tops
Trailer Truck
Land-Sea
Container
Cargo
Dried prunes,
dried fruit,
packaged for
shipment.
(86k 1 K>s)
Dried prunes
(108k lbs)
Raisins
(unknown lbs)
Raisins
(unknown lbs)
Walnuts
Wa lnuts
Walnuts
Drind,
uripackaged
prunes
MeBr Added
(lbs)
5
12 ~ 12
210 4 3
55,45
4,3*2
7.6 * 20
b.O * 8
6
Duration of
fumigation

17
20
24
24
2
2
2
24
Chamber
Volume (ft*)
2200
15000
143,382 * 3
55000, 45000
1430 * 2
2600 * 2
2000 • 8
22U0
Aeration
Time (hrs)
2
6
24
24
2
6
0.5 to
0.75
2
Ideal
Internal
Equilibrium
Concen-
tration
(ppnjv)
936*
5509
6048
4173 .



11204
Actual
Internal
Measured
(ppmv)
5300
108
3900, ;*)00,
not. av.ii 1 abi e
280, 84000
No data
No data
No data
630, 21000
HeBr Emi tted
During
Aeration
(lbs)
No data
0 33
No data
No data
No data
No data
No data
No data
Minimum MoBr
Lost, or
Consumed
Our i Tig
Furai gation
2 3 Lbs
(47Z3
11.67 lbs
(97?)
74.6, 0.0 lbs
(362). (02)
51.3, 0.0 lbs
(9323. (02)
No data
No data
No data
0 0, 5.6 lbs
(02), (942)
A«ration
Practi ce
Reai doors of
trai1er
opened. Ho
fan was used.
Exhaust fans
turned on.
Portable exhaust
fan connected to
fumigation port
Fan run for 30
minutes, then
doors to shed urn
opened while fans
continue to run
Chamber doors
opened, then
exhaust fans
turned on.
A new vacuum is pulled (the
addition of HeBr during the
fumigation eliminates the
first vacuum) Fans pulling
the vacuum to 2b" water
exhaust to thu atmosphere.
Vents are then opened and an
pulled thiough for 2 hours.
Vents «irr
opener!
and f;mr,
pu11 aii
through
for 2
hours
Vents are
opened
and fans
pu11 air
thiough
for 30 45
minutes.
Rear door;, ot
t r a i 1 e t
opened
Small house
hold fan
turned on.
Aeration
Exit
Rear doors
Exhaust fan
s tack
Exhaust stack on
portable fan
Doors. , exhaust
liiii ilack
Fan exhaust stack
Silo top?
Silo top?
Rear doors

-------
systems, application of a control device might require specialized capture
system designs or modification of the fumigation enclosure itself.
4.2.2 Collection of Methyl Bromide
Potential collection technologies to separate the MeBr from the air
stream in a manner suitable for easy recovery are:
•	Adsorption;
•	Condensation; and
•	Membrane separation.
Adsorption. Differences in chemical properties between the air and the
MeBr allow adsorption of the MeBr on a solid substrate while allowing the air
to pass through the adsorption medium. Activated carbon adsorption is a
common solid adsorption medium that has been tried experimentally for MeBr.
Other adsorbents are also being considered, but carbon is inexpensive and a
proven adsorption media with a high adsorptivity for many gases.
Another adsorption medium of interest is synthetic zeolites. The pore
sizes in these zeolites are of a more consistent size than those in activated
carbon, and the pore size can be "tailored" to the chemical to be adsorbed.
These zeolites can also be designed to be less hydrophilic than activated
carbon, which could reduce the costs of drying the regenerated solvent vapors
before condensation.
Carbon beds in vessels are used. The honeycomb-like, porous internal
structure provides an internal surface area of approximately 10,000 ft2 per
gram.13 The effluent aeration gas stream from fumigation passes through
carbon beds. The remaining air would flow to a destruction device or to the
atmosphere depending on the residual MeBr concentration in the gas. The
collection block illustrated in Figures 9, 10, and 11 might have a configura-
tion similar to that shown in Figure 12.
The adsorbed MeBr on the bed is then desorbed via fresh hot air. In a
standard configuration, used in other activated carbon applications, two
parallel beds would be used. One bed would operate for adsorption, while the
other was in the regeneration mode. For fumigation applications, where the
process may be intermittent, a single bed might suffice. For direct reuse,
the MeBr regenerant stream would be routed to the fumigation application or
condensed first and temporarily stored. In the destruction scenario, the MeBr
38

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might be desorbed directly into a separate destruction system or condensed and
temporarily stored for later destruction either on- or off-site.
For batch treatment, it might also be possible to "store" the MeBr on
the activated carbon and do a pressure swing regeneration to desorb directly
onto the next batch. This might work especially well with vacuum chambers.
Specific design criteria of a tested commercial system were not avail-
able. The needed data for a system would be:
•	Flow rate of aeration gas; and
•	Concentration profile of MeBr in the aeration gas.
In addition, data are needed on performance of the recovery system;
•	Adsorption capacity for MeBr (adsorption isotherms);
•	Affinity of activated carbon for MeBr (capacity to adsorb);
•	Residence time required to adsorb;
•	Space velocity limitations; and
•	Desorption characteristics of various carbons.
Specific data regarding performance of carbon adsorption for MeBr have
been generated, but little data appear to be published. One U.S. vendor of
carbon bed recovery systems reports that they have installed commercial MeBr
recovery systems for overseas fumigation chambers. The vendor claims to
achieve nearly 100% recovery of MeBr in the vent stream, but has not published
these results nor would they provide details to us for this report.12
However, as stated earlier, not all of the original MeBr is available in the
vent stream. Fumigation systems leaks and absorption and reaction in the
agricultural product cause losses. The vendor claimed to have eliminated
leaks, so that only 2-3% of the MeBr was unrecoverable as a result of absorp-
tion in the agricultural product.
Some technical papers on MeBr adsorption in carbon beds have been
published. Two papers from the University of Queensland, Australia were
published in the mid-1970's that described recovery of methyl bromide from
grain silo fumigation by carbon adsorption.1"11 The articles described
laboratory tests of activated carbon and proposed a commercial scale truck-
mounted carbon bed unit. They claimed a recovery of approximately 90% of the
MeBr that was left after the fumigation step. The article claims that 30% of
the total MeBr introduced to fumigation is "used" by reaction with the grain,
decomposition in the air, or loss to leaks.
39

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Clean
Exhaust Air
Blower
MeBr Laden Air
from Fumigator
Aeration
Particulate
Filter
Vent
Adsorber
Condenser
Accumulator
Regeneration
Air Line
Adsorber
Cooling
Brine
MeBr to
Storage
Air Heater
for Regeneration
Figure 12. Typical Carbon Adsorption Configuration for MeBr Collection

-------
The Australian data provided some information on carbon bed adsorptive
capacity, up to 20% by weight of MeBr. The laboratory tests subjected the
adsorbent to 30 cycles of adsorption/desorption without a measurable change in
bed capacity. Figures 13 and 14 show the equilibrium capacity of MeBr on the
carbon at various temperatures. Figures 15 and 16 show the adsorption and
desorption run times on a pilot scale wheat "silo" that was 1.8 m tall, 0,15 m
diameter, filled with 25 kg of wheat. These figures show the "breakthrough"
curves.
41

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05	l
Volume % MeBr
Figure 13. Equilibrium Capacity Curves of Methyl Bromide on Carbon Adsorbenc
Derived from Experimental Data at Various Temperatures
Source: Adapted from Reference 10
60
h 40
o
u.
0
jn
1	20
z
Bed Height = 370 mm
Gas velocity = 0.1 m/sec
i	I
0	50	100
Temperature, SC
Figure 14. Adsorption Rate Function for Laboratory Adsorption Bed Derived from
Experimental Data
Source: Adapted from Reference 10

-------
^ 6
>
e
¦i 4
r3
l.
5
U
c
a 2
Im
cs
u
2

V
		
\ inlet gas
»

%
exit gas

4
\


10
Inlet and Outlec Gas Concentration Curves Derived from Exper •'mental
Data for Adsorption of MeBr on a Wheat Column
Time, min
Figure 15.
Source: Adapted from Reference 10
exit gas
[i
inlet gas
Time, min
Inlet and Outlet Gas Concentration Curves Derived from Experimental
Data for Desorption of MeBr on a Wheat Column
Figure 16.
Data tor Desorptic
Source: Adapted from Reference 10
43

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Silo
Adsorption Unit
Fuel Gas
Adsorption Beds
Burner
Figure 17. Attachment of Mobile Adsorption Unit to Silo
Source: Adapted from Reference 10
44

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In addition to the lab tests, the Australians performed one silo test
where gas from the silo was drawn continuously through the adsorbent for 24
hours. This test checked for effects of poisoning from impurities in the
grain and from odorant (chloropicrin) used in full scale grain fumigations.
The capacity of the carbon was not measurably altered after regeneration.
The full scale truck system was estimated to cost 20,000 A$ in 1975,
which is equivalent to approximately 30,000 US $ in 1992. This is based upon
1975 and 1992 equipment cost indices from Chemical Engineering Magazine.^15
Design specifics are listed below:
• For a 2500 ton wheat silo, fumigated with 50-100 kg of MeBr:
Bed system operated in parallel
Air blower circulation of 1 m3 per second
50 mm WG pressure drop per bed
Charge: 2 m3 of carbon (2/3 per bed)
Inlet MeBr concentration: 1.2% by volume in air (12000 ppmv)
Cycle time: Adsorption < 10 minutes, Desorption < 10 minutes
Fuel Use: 5 kg of LPG per silo
Desorption of MeBr and regeneration of the carbon was accomplished by
heating the air entering the beds to 150°C. Adsorptive capacity is lower at
higher temperatures, so the MeBr desorbs into the air stream. The air stream,
which circulated through the grain, returned the MeBr to the silo for another
fumigation cycle.
Desorption occurred quickly, and the article stated that all of the MeBr
was desorbed before the first MeBr reached the top of the grain silo.
Usually the only equipment that must be added to a carbon bed recovery
system in order to accomplish the recycling step is a heating system. This
can be accomplished with any heating medium, but the Australian article
recommended a LPG tank with a burner inside the circulating air path. Combus-
tion of the circulating air could introduce PICs (products of incomplete
combustion) to the recycle loop, and should be avoided.
Condensation. Cold temperatures can condense methyl bromide out of the
effluent aeration air stream. At atmospheric pressure MeBr boils or condenses
at 3.46°C (38°F), a refrigeration system that can cool the entire aeration
45

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vent stream below 38°F will condense the MeBr. Appreciable quantities of MeBr
will not condense until much lower temperatures are reached where the vapor
pressure is very low. A very low temperature refrigeration system with
temperatures in the range of -10 to -30°F may be required. Depending on the
size of the overall recovery system, using delivered liquid nitrogen as a
coolant may be more economical than a mechanical refrigeration system.
Unfortunately, cooling the aeration vent stream will also condense
moisture (H20) , and MeBr forms a voluminous crystalline hydrate with cold
water15 Therefore, condensing operations would require drying capability
upstream of the condenser unit.
This can be an expensive and energy intensive operation, especially
given the high flow rates of air that occur during the aeration step. Data
from two chamber fumigation fans3 and from one silo fumigation circulating
fan14 had the following flow rates:
•	Chamber Fan:	320 ft3/min
•	Chamber Fan:	1985 ft3/min
•	Silo Blower:	2119 ft3/min
Cooling 2000 ft3/min of air from 100°F to 37°F consumes 531,000 calories/niin,
or 126,500 Btu/hr. This is based upon the heat capacity equation:
Del H - m * Cp * dT
where:
Cp - 0.237 Cal./g'C for air from reference 17, Table 3-180.
Dt - 63°F, or 35°C
m - 2000 ft3, or 64030 grams (assuming ideal gas laws)
The process could be made more energy efficient by the integration of
precooling feed/effluent exchangers, but those could add significantly to the
capital cost of the option.
Membrane Separation. In recent years, advances in synthetic polymeric
membrane technologies have made separation of certain components of gas
streams feasible. It might be possible that a suitable membrane material
could be found for separation of MeBr from air. At this time no data for such
a system are available, and during the course of this study no one we talked
to suggested that any work had been done with this technology.
46

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Membrane pore size and differences in molecular size and relative
diffusivities within the membrane pore structure determine selectivity. A
membrane system relies on a pressure differential across the membrane as the
primary driving force for mass transfer.
The pressure difference can be provided by a positive pressure applied
to the upstream side of the membrane or a vacuum applied to the downstream
side. For a process stream at essentially atmospheric pressure as would be
the case for the commodity fumigation aeration stream, a vacuum system could
be likely.
The separated MeBr vapor would then be condensed for recovery in the
same manner as for other separation technologies.
4.2.3 Recovery and Recycle
A condensation collection system provides MeBr directly available for
recycle. If a carbon adsorption system is used for collection, condensation
would be used as an auxiliary step for condensing concentrated vapors result-
ing from carbon bed desorption. The condensed MeBr would then be recycled.
Recovery for reuse appears to be the most economically attractive, since
it significantly reduces the net consumption of MeBr. It also fits well with
the Montreal Protocol and the U.S. Clean Air Act phaseout of MeBr production,
since recycling drastically reduces net consumption. However, recycling still
requires make up MeBr, since some MeBr is lost, and therefore recycle cannot
exist if all MeBr production stops. Recycling may also have some other
limitations.
Recycling may trap and concentrate certain other undesired compounds
along with the MeBr, such as various hydrocarbons (odor constituents) that are
unacceptable on agricultural products. This may require that a treatment step
be added to remove the other compounds, or that the recycled MeBr and hydro-
carbon mixture be destroyed after a limited number of recycle uses. In fact,
although MeBr is available as a pure chemical (99.5+%), manufacturers often
deliver MeBr mixed with an odorant to allow easy detection of leaks. The
odorant could build up during recycle steps if the recovery step is more
efficient at capturing the impurity than at capturing MeBr. A common odorant
mix with MeBr contains 2% of the pungent chemical chloropicrin (Cl3CN02) •
Chloropicrin condenses at only 112°C (234°F), so it should be more easily
recovered in a condensing operation than MeBr. No published data were found
47

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that quantified the buildup of odorants or other poisons during MeBr recycling
operations.
It is unlikely that condensation can be used directly as a recovery
technique because MeBr concentrations may not be high enough to provide for
efficient condensation at reasonable temperatures. A refrigeration system
would be required to provide a cold enough cooling medium for condensation of
a dilute MeBr stream. An intermediate storage tank would be needed to hold
the MeBr between fumigations. For a non-pressurized tank, maintaining
temperatures below 38°F would be necessary. A heating system would be
necessary to vaporize the condensed MeBr once a new fumigation begins.
4.2.4 Destruction
The final step in a MeBr control process is destruction. Destruction
options for MeBr depend whether the MeBr has been recovered from the aeration
stream, or is to be destroyed while still mixed with the aeration stream. In
the latter case, the entire aeration stream containing MeBr can be burned in
an incinerator or can be scrubbed with an appropriate chemically reactive
solution, such as caustic soda. In the former case, MeBr might be collected
and handled like other liquid hydrocarbon wastes, in waste drums for example.
Treatment in the Aeration Stream
Scrubbing with caustic solution is a direct treatment of the aeration
stream that can remove and destroy MeBr. This method employs a contacting
tower with a recirculating caustic solution to "scrub" the MeBr out of the air
stream. One published Russian article describes scrubbing tests with various
sodium solutions. The first test of 10-20% aqueous sodium sulfite (Na2S03)
neutralized the MeBr by forming the salts CH3S03Na and NaBr, both of which are
non-toxic to warm blooded animals, and are non-flammable.18 The article also
cited tests of a mixture of 7% ethylene diamine and 13% sodium carbonate
(Na2C03).
Operating commercial scale MeBr scrubbers could not be located during
this study, nor any data regarding cost or design specifications. One
scrubber was reported to have started up in the Los Angeles area, but an
accident (explosion) shut the facility down.9
Incineration of the entire aeration stream could be accomplished by
installation of a packaged incinerator on the aeration vent exit. This
technology is very similar to that of incineration of pure MeBr, and is
48

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covered in the following section. No data were available to estimate the
costs of such a system at this time.
Treatment after Recovery from the Aeration Stream
If destruction directly from the aeration stream were not practical,
then recovery followed by destruction might be required. Such destruction
would be useful for a system where recovery was being practiced anyway, and
some disposal of a recycle purge stream was required.
Destruction technologies for halogenated hydrocarbons have been studied
previously for recovered waste chlorofluorocarbons. Similar technologies
might apply for MeBr. Destruction technologies are discussed in the UNEP
Ozone Depleting Compounds (ODCs) Destruction Technologies Report.19
Destruction methods potentially applicable for MeBr include both on-line
process technologies and off-site bulk treatment technologies in the following
categories:
1.
Thermal Oxidation
2.
Catalytic Processes
3.
Chemical Destruction
4.
UV Pyrolysis
5.
Biological Processes
6.
Supercritical Water Oxidation
7.
Vet-air Oxidation
8.
Plasma Destruction
9.
High-Energy Radiation
10.
Thermal Pyrolyses
A brief description of each technology has been included in Appendix F.
Appendix F also states the limitations and advantages of the application,
along with the anticipated destruction efficiency for the method.
At this time, it appears that thermal oxidation (incineration) would be
the most viable approach for fumigation applications, followed by scrubbing.
Oxidation/incineration uses high temperatures and oxygen to destroy
organic compounds, producing C02, H20, HBr, and/or Br2. Incomplete combustion
products may also be produced. The exhaust's bromine gases, Hbr and Br2, are
acidic and very corrosive, and must be treated before discharge to the
atmosphere. Therefore incineration may also require coupling with scrubbing.
49

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Scrubbing with a caustic solution is the accepted method for this step. The
addition of NaOH in water solution forms NaBr, a more easily handled solid.
The general reactions are:
HBr + NaOH 	~ NaBr + H20 and
Br2 + 2 NaOH 	» NaBr + NaBrO + H20
The addition of incineration with caustic scrubbing can add considerable
expense to a small fumigation control application.
Most of the destruction techniques discussed in the UNEP report were
bulk destruction techniques based upon hauling recovered liquid CFCs to a
facility specially built for destruction or for another purpose where destruc-
tion could also be accomplished. None were applied directly to air streams
containing the wastes, as would be the case for the fumigation aeration vent
treatment. Therefore, use of these UNEP defined technologies implies that a
separation and recovery of MeBr liquid from the aeration stream has already
been accomplished. It also implies that spent MeBr would be stored temporari-
ly prior to destruction. It suggests further that a central destruction
facility might be employed that could receive contaminated MeBr from multiple
fumigation facilities in a region.
4.2.5 Potential Technologies for Direct Vent Stream Control
Some of the destruction technologies ruled out by the UNEP report for
bulk destruction of liquid halogenated hydrocarbons may be desirable for the
smaller scale treatment of MeBr in fumigation vents. Recovery and recycle
techniques even if used would likely require a destruction method because of
impurity buildups in the MeBr from the treated commodities.
The only method that appears to have been tested commercially at this
time is carbon bed adsorption. Other techniques have yet to be applied, show
promise, and would require some bench and pilot-scale test work to be devel-
oped for application.
For example, one company has proposed a unique ultraviolet (UV) destruc-
tion technique for the aeration gas vent stream. This might be an acceptable
method for a small scale application, even though UNEP rejected it for large
scale commercial destruction options.
50

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• 3 Control Costs
At this time, very little cost data specific to these systems, as
applied to MeBr destruction, are available. The UNEP report on Destruction
Technologies contained no cost data. Cost data from four recent MeBr recovery
proposals to the Port of San Diego and from two papersic•11 on recovery from
grain fumigation were available.
The control methods with known cost and design data are summarized in
Table 8. The range of control costs reported is quite wide.
In order to develop a rough estimate of economic feasibility of a KeBr
recovery system, calculations were based on the conceptual design of Figure 9
and the stream variables presented in Table 9. The system uses collection by
activated carbon adsorption, recovery by desorption and condensation, and has
intermediate storage. It also includes MeBr destruction. In this case we
selected a scrubber because of the likelihood that incineration would be
uneconomical for a relatively dilute stream containing MeBr. The general
specifications for major equipment are provided in Table 10. Costs were
obtained from the technical literature and a factored estimate was prepared.
The results of this estimate are presented in Table 11 which shows both the
capital cost and the annual operating and maintenance costs for the system.
At this time these estimates should only be treated as very preliminary
since no actual data were used in their preparation and they do not represent
costs for an optimized system. The stream basis for design is based on
assumed-or approximate values, especially with regard to the MeBr composition.
Actual costs will depend greatly on the exact flow rate of the stream
requiring treatment and the MeBr composition. They will also depend greatly
on equipment details and especially materials of construction. These costs
are useful, however, in focusing research needs in terms of defining key
design variables and factors that drive the economic feasibility.
51

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Table 8
Vendor Reported Control Cost Data
Control Option
Cost
Design Description
Carbon Absorption/Desorption
(Recovery/Recycle)
$960,000 $
by Vendor 1
10,000 cfm air flow, 300-1000
lbs MeBr per application, tent
application, 95+% recovery
100,000 $
by Vendor 2
No design description
available
Condensation
(Recovery/Recycle)
Cost not
defined
by Vendor 3
2 stage compression to 1000
psi, intermediate water
knockout, chamber application,
pressurized storage, 95 +%
recovery
Oxidizer and Scrubber
(Recovery/Destruction)
Cost not
defined by
Vendor 4
Thermal oxidizer followed by
limestone scrubber, 4643 cfra
air flow, 300 lbs MeBr per
application, 96% destruction
efficiency
Source: Control installation proposals provided from Reference 9.
Table 9
Stream Design Basis for Example Recovery System Cost Estimate
Stream
Carbon Bed
Inlet
Condenser
Inlet
Vaporizer
Inlet
Scrubber
Inlet
Flow rate, ft3/min
5,000
5,755
4,623
5,000
Temperature, °F
70
150
30
70
Pressure, atm
1
1


Composition
MeBr (ppm)
H20 (R.H.)
500
50
250,000
50
N. A.
N.A.
5 ,000
50
52

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Table 10
Major Equipment List
Activated carbon adsorber - 3 ft. deep, 147 ft3, carbon bed; FRP shell,
3.95 ft. diameter x 6 ft. length.
Condenser - shell and tube; process fluid shellside; chilled brine at
-30°F, 1300 ft2 tube area; shell material and tube material stress
corrosion resistant stainless steel or other alloy.
Brine Cooler - 13 ton, packaged brine cooler system, glycol/water, capable
of -308F chilled brine temperature.
Storage Tank - 50 gallons; stress corrosion resistant stainless steel or
other alloy; temperature rating 0"F; pressure rating 100 psig.
Vaporizer - 10 gallon; stress corrosion resistant stainless steel or other
alloy pressure vessel; electrically heated; temperature rating 300°F;
pressure rating 200 psig.
Scrubber - plastic packing packed bed; FRP shell, 10 ft total height, 6 ft.
packed bed, 10 inches diameter.
Scrubber recirculation pump - centrifugal pump; flow rating 10 gpm at 20
psig total head; 0.5 Hp motor; plastic construction.
V	fc	—J———			¦	——
Table 11
Estimated Costs for MeBr Recovery System Example
(January 1993 dollars)
Total Capital Cost
$
Major purchased equipment cost
121,000
Installation materials and labor*
121,000
Engineering, contingencies, and construction feesb
121,000


Total
363,000
Annual Operating and Maintenance Costs®
$/yr
Operating labor and materials
900
Maintenance labor and materials
12,000
Electricity
100
Total
13,000
* Installation at 100% of purchased equipment cost.
b Engineering, contingencies, and construction fees at 50% of installed
equipment costs.
c Based on operation of 40 hr/wk, 13 weeks/year.
53

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SECTION 5.0
IDENTIFICATION OF CURRENT CONTROL RESEARCH EFFORTS
Many of the potential technologies for control are untested on either a
development or commercial scale, since MeBr production phase-out under the
Clean Air Act has only recently become a concern. Some of the control options
have been tested on the bench or pilot scale. In fact, when the Port of San
Diego recently issued a request for proposals to construct a MeBr recovery
unit, eight of the twelve respondents only offered to study the matter further
for the Port. Only four of the proposals actually proposed construction of a
recovery unit, and several of those proposals were on technologies that had
not been commercially tested.
Research efforts at control appear to have been very limited. Although
there have been many conferences on MeBr phase-out, they have all centered on
finding an alternative replacement for MeBr, rather than on recovery and
emissions control. Examples of these technical meetings are:
•	UNEP Methyl Bromide Technical Options Committee meetings (held
around the world);
•	USDA Workshop on Alternatives for Methyl Bromide, June 29 - July
1, 1993, Crystal City, VA; and
•	Methyl Bromide Alternatives Conference, Sponsored by Alliance for
Responsible CFC Policy, and the U.S. Environmental Protection
Agency, March 8-9, 1993, Fresno, CA.
Currently, the California South Coast Air Quality Management District
(SCAQMD) has just jointly funded recovery research work along with the Port of
San Diego and one utility company. The project will perform a lab/bench scale
demonstration of a selected recovery technology. The budget is reported to be
approximately $50,000.20 The UNEP Methyl Bromide Technical Options Committee
has also sponsored a paper study on recycling options. Their data gathering
study is due out in early 1994.21 The data UNEP is gathering includes details
of:
•	Existing recovery installations;
•	Proposed installations;
•	Pilot testing of recovery or recycling technologies;
•	Other research conducted on recovery or recycling technologies;
and
•	Proposed research on recovery or recycling technologies.
54

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UNEP data gathered to-date were not available at the time this report was
written.
Other than the government agency sponsored work alluded to above,
research appears limited to small-scope proprietary work conducted at
individual recovery process vendors. These vendors appear to be reluctant to
release the details of their research at this time. With the exception of
carbon bed absorption, no commercial scale installations appear to exist for
MeBr, so most of the company research is on the laboratory or bench-scale.
The previous sections of this report have discussed research efforts on
MeBr recovery (i.e., the specific technology for removing MeBr from the
aeration stream). There has been very little work done on chamber or enclos-
ure modifications required to reduce emissions during fumigation and thus
increase the potential for MeBr recovery. In addition, some of the vendors of
the recovery processes claim to have developed proprietary improvements to
tarpaulin design and procedures that greatly reduce emissions. However, no
general, published research was found that covered fumigation emissions
reduction by better sealing systems.
55

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SECTION 6.0
IDENTIFICATION OF REJiAINING INFORMATION GAPS
The preceding sections of this report have discussed some of the major
technical factors involved in controlling emissions of MeBr and surveyed the
current status of work to find suitable controls. The feasibility of control
depends on these technical factors in the context of any of several possible
regulatory scenarios. These considerations are important as they influence
both the technical and economic feasibility of control and, hence, the
technologies that are viable for control.
Establishment of a viable control strategy and the corresponding
technologies requires additional information and further research. This
information and research can be defined by categories corresponding to the
regulatory, technical, and economic factors that will ultimately determine
feasibility.
6.1 Regulatory Issues
The exact regulatory scenario will have a direct bearing on the feasi-
bility of MeBr controls. This derives from a fundamental fact: some MeBr
losses will occur as a fundamental characteristic of the fumigation process
itself; a total ban implies that the total inventory of MeBr will eventually
be depleted if there is not more manufactured because of the ban. The rate of
depletion will depend on the loss rate in each recycle, but eventually the
MeBr inventory will run out. Therefore, collection and recycle technologies
will have a limited life. In some applications, such as those where consump-
tion reaches 30% per fumigation cycle, the use of MeBr will effectively be
impractical, since consumption of inventory will be rapid. Complete makeup is
required after only about 3 cycles. Therefore the fumigation process itself
becomes impractical if there is no longer a supply of MeBr.
For lesser rates of losses it can be readily shown that the inventory
would still be depleted relatively quickly, although it might take days,
weeks, or months. Controls would not be practical.
Therefore, if substitutes cannot be found, and some use of MeBr is
permitted, the exact permissible emission limits, equipment, or work practices
specified by the regulations would become the critical factor in the feasibil-
ity of specific controls.
56

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At this time, such policy issues cannot be established and the issues of
technical feasibility take precedence. From practical considerations, the
technical feasibility of various options must be considered in the context of
assumptions about regulatory scenarios. The fundamental assumption at this
time is that manufacturers would continue to meet industry needs even if the
use of MeBr is restricted to only a few specialized applications.
The fundamental information requirements for MeBr emissions controls are
the same as for any emissions control problem. These issues are discussed
below.
6.2	Stream Characteristics
As discussed in this report, limited information is currently available
on stream characteristics. These characteristics need to be established for
each major category of fumigation application. The basic stream variables
that need to be determined include typical flow rates, temperatures, pres-
sures, and compositions of aeration streams for each type of fumigation
application. Actual design for a given facility will require the correspond-
ing site specific information.
6.3	Fumigation Commodity Containment Options
To maximize capture, and to reduce MeBr losses prior to the collection
device, current designs and practices for fumigation may have to be altered.
Fumigation applications for which add-on controls can be easily applied roust
be clearly distinguished from those which would have to be altered to accept
control technologies. For example, current chamber applications might require
essentially no modification. The control device would be attached by ducting
directly to the outlet vent. Sheet applications might have to be abandoned,
or a means devised to ensure complete capture of the vent stream from the vent
opening. The practice of simply removing the tarp from the commodity contain-
er or stack after fumigation might no longer be possible. New temporary
containment methods require investigation.
6.4	Achievable Recovery from Fumigation
The quantities of MeBr consumed directly by contact with various
commodities must be established. Also, the pickup of organic vapors by the
aeration stream must be defined for various commodities since this will
influence the performance of MeBr controls for recovery and reuse when
57

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adsorption systems, either activated carbon or other adsorption systems, are
used.
6.5	Technology Performance Characteristics
The fundamental performance characteristics for each potential recovery
technology must be established. Removal efficiency from the aeration stream
must be established. This information must be obtained for:
•	Specific commodities and commodity classes;
•	Different containment options and fumigation applications; and
•	Different control technologies.
The most critical needs appear to be for adsorption systems, especially
with regard to contaminant effects from organics picked up from the commodi-
ties themselves and with regard to partial decomposition of the methyl bromide
on the adsorbent. In addition to activated carbon, data would be needed for
zeolites and other adsorbents that might be candidates for adsorption.
Research on combustion and condensation would appear to be less criti-
cal, although the destruction efficiency at different flame temperatures and
other combustion conditions would be required.
6.6	Economic Issues
Once appropriate design bases are adequately defined, the economics of
control in different applications must be determined. This will be based on
the costs of appropriate technologies for specific sizes of systems and type
of application. Process economic constraints must be clearly defined. Since
systems may in many cases be relatively small and used only intermittently,
cost impacts of recovery and recycle could be substantial.
A significant consideration here will be the availability and cost of
MeBr itself. Since commodity fumigation is a small fraction (ca. 8%) of
methyl bromide use, a selective ban could reduce the market for MeBr by 90% or
more. This would surely affect the economics of production and influence its
price.
58

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6.7 Availability of Substitutes
There is no single alternative to MeBr in all of the broad applications
where it is used. However, there are many alternative chemicals and procedur-
es for specific applications. Further identification and discussion of these
alternatives can be found in references 22 and 23. The discussion of MeBr
substitutes is a separate issue and not a part of this report on MeBr control.
59

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SECTION 7.0
CONCLUSIONS
This section summarizes conclusions of this study. The conclusions are
organized into the following subject areas:
•	Methyl bromide uses and quantities;
•	Emission source characteristics;
•	Potential control technologies;
•	Process economics;
•	Current research and development activities; and
•	Information gaps.
7.1	Methyl Bromide Uses and Quantities
Methyl bromide uses are relatively restricted, and MeBr can be viewed as
a specialty fumigant. The consumption of MeBr for space fumigation of
commodities represents about 8% of MeBr use. The primary use for MeBr in
commodity fumigation is for fruits and nuts. In the treatment of these
commodities, there are general commodity containment schemes which are common
throughout the industry, although some details may vary with individual
installations. The types of configurations for commodity containment are
relatively limited.
Fumigation is carried out extensively at a few primary locations, mostly
major sea ports. Two of the largest ports where MeBr is used are San Diego
and Philadelphia. Other major ports include Seattle and Miami, but any port
where fruit and nuts are imported is a candidate. Also, fumigation facilities
are reported to be present at some airports and military facilities.
7.2	Emission Source Characteristics
Emissions sources are characterized in terms of physical configuration
and emission stream characteristics.
Physical configurations are divided into two categories: sources with a
duct, pipe, or stack outlet, and sources with multiple, irregular outlets.
The former occur in chambers specifically built for holding the commodity
during fumigation. The latter occur with sheet or tarpaulin fumigation or
fumigation in vehicles where ordinary leakage or simply an open door is used
to vent the MeBr when fumigation is complete.
60

-------
The emissions arise when air is blown through the commodity to remove
the MeBr. Currently the emissions are vented directly to the atmosphere.
Little data are currently available for stream characteristics. This is
a key area for additional research. Information that is available suggests
flow rates in the range of no more than a few thousand to a few tens of
thousand of cubic feet per minute air flow with a MeBr content ranging from a
few hundred to a few thousand ppm.
Currently few control systems exist for MeBr emissions. Likewise,
research and development related to control system design has been extremely
limited.
Various vendors have proposed control technologies for MeBr control,
recovery and recycle. Few systems have been built. Currently, systems are
being investigated and the Port of San Diego is installing a MeBr treatment
system. Some systems have been installed overseas. Technical details of
these systems are not readily available at this time, so that further work
would be required to determine how extensively they control emissions and how
effective they may be at recovery.
In general, conventional vapor control technologies, such as activated
carbon adsorption systems appear to be applicable to MeBr emissions. However,
in the context of minimum or e\'en zero emissions, depending on the regulatory
scenario, control systems must also provide for recovery. Conventional
approaches using condensation and other methods appear to be applicable here.
The fundamental technologies required appear to exist, but the specifics of
the application of these technologies to the MeBr control issue require much
more investigation and design data acquisition.
7.3 Process Economics
Process economics of MeBr control and recovery are not well defined.
Scattered data on actual and possible costs of systems was skimpy. Because
many components of a control system would appear to rely on existing technolo-
gies, costs and the corresponding economics do not appear to be difficult to
estimate. Costs can be expected to be comparable to other vapor control
systems for similar flow rates of gas streams.
Preliminary economics of a conceptual design prepared specifically for
this report indicate that control will be relatively expensive. The relative
expense compared with control systems of similar nature in other applications
is because of the relatively small volumes of recoverable material that would
be handled and the intermittent nature of many of the fumigation operations to
61

-------
which the control system would be applied. At this time, there are riot
sufficient data available on either design or costs to make a definitive
statement.
A factor that might considerably influence the economics of MeBr control
is the availability of future MeBr supplies. This will be influenced by the
regulatory scenario. A total ban, but allowance of the use of existing MeBr
inventories with recycle would, in effect make recycle impractical for
technical reasons. Chemical reaction losses would quickly deplete the supply.
On the other hand, a selective ban that would allow some manufacture of MeBr
to continue might drive up the price, assuming a manufacturers were willing to
continue manufacture, because the use volume would be sharply reduced. Unit
manufacturing costs would increase sharply.
7.4	Current Research and Development Activities
Current research and development activities on the issues discussed in
this report appear to be limited at the present time. Much of the current
work appears to be under the auspices of various vendors of systems and
equipment. Some government agencies and industrial groups are showing
increasing interest in funding some research. UNEP has had a leading role in
addressing some of these issues.
7.5	Information Gaps
In general, information gaps fall into two fundamental categories: 1)
MeBr emission source characterization and 2) control technology characteriza-
tion. The fundamental focus needs to shift beyond mere reduction of emissions
and toward recovery and recycle. There also needs to be an effort to gather
some fundamental performance data related specifically to fundamental stream
characteristics. This is especially important because of the reported
potential for the accumulation of various commodity chemical components picked
up by the MeBr on each cycle of contact with the commodity being fumigated.
Detailed economic evaluations based on existing data should be carried out
early in order to better direct the research and maximize research efficiency.
62

-------
REFERENCES
1.	"Methyl Bromide," Chemical Product Synopsis. Mannville Chemical Products
Corp., Asbury Park, NJ, February 1992.
2.	The United States Department of Agriculture (USDA), National Agri-
cultural Pesticide Impact Assessment Program (NAPIAP), "The Biologic &
Economic Assessment of Methyl Bromide", April 1993.
3.	Telephone conversation with Jim Fons of Animal and Plant Health Inspec-
tion Services (APHIS), July 1993.
4.	California Department of Pesticide Regulations, "Annual Pesticide Use
Report by Chemical, January through December 1991," pp 118-192, January
1993.
5.	The United States Department of Agriculture (USDA), Animal and Plant
Health Inspection Services (APHIS), Plant Protection and Quarantine
Treatment Manual, 1992.
6.	The United States Department of Agriculture (USDA), "List of Warehouses
Approved Under the 1993 Uniform Grain Storage Agreement," Kansas City
Commodity Office, Kansas City, MO, 1993.
7.	Manual of Fumigation for Insect Control. Food and Agricultural
Organization of the United Nations, Rome, 1984.
8.	Telephone conversation with Ken Vick of USDA, July 1993.
9.	Telephone conversation with Ruth Kolb of the Port of San Diego, July
1993.
10.	White, E.T., Martin, D.F., Lee, G.W., Leung, L.S., "A Truck Mounted
Adsorption Unit for Fumigant Emission Control in Grain Silos," Proceed-
ings of the International Clean Air Conference, pp. 55-64, May 1978.
11.	Martin, D.F., Leung, L.S., White, E.T., "Recovery of Methyl Bromide from
Wheat Fumigation by Adsorption," Proceedings of the Third National
Chemical Engineering Conference, Mildura, Australia, pp. T121-124,
August 1975.
12.	Telephone conversation with Howard Slack of Slack Associates, July 1993.
63

-------
13
14
15
16
17
18
19
20
21
22
23
Test Data on Methyl Bromide Fumigation, Radian Corporation, Internal
Files, 1992.
Chemical Engineering Magazine, "Economic Indicators," McGraw-Hill
Publishing Company, New York, NY, January 1975.
Chemical Engineering Magazine, "Economic Indicators," McGraw-Hill
Publishing Company, New York, NY, January 1993.
The Condensed Chemical Dictionary, 9th Edition, Gessnc-r Hauiey, Editor,
1977 .
Chemical Engineers Handbook, Perry, R.H. and Chilton, C.H., ed., 5th
Edition, McGraw-Hill Publishing Company, New York, NY, 1973.
Kordkovich, Y.B., Menshikov, N.S., Luzan, N.K., "Modern Means & Methods
of Plant Product Fumigation in ihe USSR," OEPP/EPPG Bulletin, 1985.
United Nations Environment Programme (UNEP), "Ad-hoc Technical Advisory
Committee on O'OS Destruction Technologies," May 1992.
Telephone Conversation with Christine Brink of the California South
Coast Air Quality Management; District (SCAQMD) , June 1993.
Telephone Conversation with Don Smith of the 'JNEP Methyl Bromide
Technical Options Committee, June 1993.
United Nations Environment Programme (UNEP), "Methyl Bromide: Its
Atmospheric Science, Technology, and Economics," Montreal Protocol
Assessment Supplement, June 1992.
Civerolo, E.L., Narang, S.K., Ross, R., Vick, K.W., and Greczy, L.,
editors, "Alternatives to Methyl Erorniae: Assessment of Research Needs
and Priorities," Proceedings from the USDA Workshop on Alternatives to
Methyl Bromide, U.S. Department of Agriculture, June 29 - July 1, 1993.
64

-------
APPENDIX A
DATA COLLECTION
A-1

-------
Data for this project was collected from a literature search and from
telephone contacts with industry sources. The data search included an
electronic search of the following bibliographic databases using keywords
associated with methyl bromide and recovery:
1.
Biosis Previews (Biological Abstracts),
2.
Agricola (National Agricultural Library),
3.
CAB Abstracts (Commonwealth Agricultural Bureau)
4.
Food Science and Technology Abstracts,
5.
CRIS/USDA Database,
6.
AGRIS International,
7.
Agribusiness USA,
8.
CA Search (Chemical Abstracts),
9.
Pollution Abstracts,
10.
Enviroline,
11.
Environmental Bibliography,
12.
Water Resources Abstracts,
13.
El-Compendex Plus, and
14.
Energy, Science, & Technology (DOE).
Few published articles were found.
Information in the area of general fumigation is well developed.
Several key documents and texts were available that described the history of
fumigant uses and general applications of various fumigants. In the area of
fumigant recovery, however, Radian found very little published information.
This may be because regulations requiring recovery are few, and the market for
recovery is therefore small. For MeBr, there are a few older articles on
recovery techniques, but most of the details of the techniques described in
Section 4.0 have not been published.
Most of the data for this report was obtained from industry and
government contacts. The contacts included:
1.	Manufacturers of methyl bromide: Ethyl Corporation and Great Lakes
Corporation,
2.	Fumigation Operating Companies,
3.	U.S. Government Agencies, including U.S. Environmental Protection
Agency (EPA), Animal and Plant Health Inspection Services (APHIS),
and U.S. Department of Agriculture (USDA),
4.	United Nations Environment Programme (UNEP) Methyl Bromide
Technical Options Committee,
5.	State pesticide experts,
6.	Agricultural shipping ports, and

-------
7. Vendors of recovery processes.
Some additional data were obtained from art earlier Radian report on methyl
bromide fumigation emission measurements.
A-3

-------
APPENDIX B
METHYL BROMIDE PHYSICAL PROPERTIES
B-1

-------
Methyl Bromide Physical Properties
(From Reference 6 and 12)
Boiling Point: 3.46°C, (38.5°F)
Freezing Point: -94°C, (-137"F)
Vapor Pressure: 189.3 kPa @ 20°C
Flash Point: None
Autoignition Temperature: 998°F (at 10-16 mol% in air)
Solubility in Water: Low (1.34 g/100 ml (3 25°C)
Gas Density: 3.3 times heavier than air
Liquid Density: 14.4 lb/gal (specific gravity 1.732 @ 0°C)
Storage Methods: Stored as a liquefied gas in metal cylinders
Storage Grades: 1) Technical, pure (99.5% min)
2) Odorized (2% chloropicrin)
Effective Fumigation Temperature: > 40°F
B-2

-------
APPENDIX C
CALIFORNIA CHEMICAL USE REPORT
FOR METHYL BROMIDE
C-l

-------
STATE OF CALIFORNIA
DEPARTMENT OF PESTICIDE REGULATION
DATE: 01/25/93	PAGE 188
PROGRAM: PUSERO1A	ANNUAL PESTICIOE USE REPORT
a* CHEMICAL
JANUARY THRU DECEMBER 1991
CHEMICAL / COMMCOITY
N-GRNHS GRWN PLANTS IN CONTAINERS
N-GRNHS GRWN TRNSPLNT/PRPGTV MTRL
N-OUTOS CONTAINER/FLD GRWN PLANTS
N-OUTOR GRWN CUT FLWfiS OR GREENS
PUBLIC HEALTH PEST CONTROL
STRUCTURAL PEST CONTROL
• CHEMICAL TOTAL ¦
METHYL BROMIDE
ALFALFA (FORAGE - FODDER) (ALFALFA HAY;
ALMONO
ALMOND
ALMOND
ALMOND
ALMONO
ALMONO
ALMONO
ANISE (SWEET ALICE)
APPLE
APPLE
APPLE
APPLE
APRICOT
APRICOT
APRICOT
APRICOT
ASPARAGUS (SPEARS, FERNS, ETC.)
ASPARAGUS (SPEARS. FERNS. ETC.)
AVOCADO (ALL OR UNSPEC)
AVOCADO (ALL OR UNSPEC)
AVOCADO (ALL OR UNSPEC)
BEANS (ALL OR UNSPEC)
BEANS (ALL OR UNSPEC)
BEANS (ALL OR UNSPEC)
BEANS (ALL OR UNSPEC)
BEANS (ALL OR UNSPEC)
BEANS. DRIED-TYPE
BEANS. ORIEO-TYPE
BEANS, DRIED-TYPE
BEANS, DRIED-TYPE
BEANS. SUCCULENT (OTHER THAN LIMA!
BEEHIVES (ALL OR UNSPEC)
BEEHIVES (ALL OR UNSPEC)
BEVERAGE CROPS (ALL OR UNSPEC!
BEVERAGE CROPS (ALL OR UNSPEC!
BEVERAGE CROPS I ALL OR UNSPEC!
BROCCOLI
BRUSSELS SPROUTS
CABBAGE
CANTALOUPE
CARROTS. GENERAL
CAULIFLOWER
CAULIFLOWER
CELERY. GENERAL
CHERRY
CHERRY
CHERRY
CHERRY
CHERRY
CHESTNUT
CHINESE CABBAGE 
-------
DATE: 01/25/93
PROGRAM: PUSER01A
STATE OF CALIFORNIA
DEPARTMENT OF PESTICIDE REGULATION
ANNUAL PESTICIDE USE REPORT
BY CHEMICAL
JANUARY THRU DECEMBER 1991
PAGE
189
CHEMICAL / COMMODITY
NUMBER OF
POUNDS
ACRES/UNITS


APPLICATION
APPLIED
TREATED TYPE
CHINESE RADISH/OAIKON (LOBOK, JAPANESE RADISH)
3
1.?500
7,200.00
P
CITRUS FRUITS (ALL OR UNSPEC!
21
66.368.4900
157.75
A
CITRUS FRUITS (ALL OR UNSPEC)
1
57.0000
20.00
u
COMMERCIAL. INSTITUTIONAL OR INDUSTRIAL AREAS
1
1.700.0000
30.66
A
COMMERCIAL. INSTITUTIONAL OR INDUSTRIAL AREAS
a
451.0000
143.405.00
C
COMMERCIAL. INSTITUTIONAL OR INDUSTRIAL AREAS
1
27.8600
900.00
s
COt®*ODITY FUMIGATION
1
195.0000
144,500 00
r-
COMMODITY FUMIGATION
20?
121,844 8135
61,540.00
u
CORN (FORAGE - FOOOER )
1
17 8200
10
A
CORN, HUMAN CONSUMPTION
2
144.5000
291 .50
T
COTTON, GENERAL
1
2.834 3900
7 00
A
COTTON. GENERAL
2
60.0000
19,840.00
C
COTTON, GENERAL
1
110.0000
19,500.00
u
CUCUMBER I PICKLING. CHINESE, ETC.)
4
1.248.2290
4.63
A
DATE
1
12.0000
19.00
A
DATE
2
6.0000
600.00
C
DATE
37
1,238.8800
6. 176.469.00
p
OATE
13
7,078.4000
107,343.3S
T
OATE
1
179.4600
837.200.00
y
DRIED FLOWERS
3
98.4800
38, 197 00
c
DRIEO FLOWERS
1
6.8000
20,317.00
p
EGGPLANT 
-------
OATE: 01/25/93
PROGRAM: PUSER01A
STATE OF CALIFORNIA
DEPARTMENT OF PESTICIDE REGULATION
ANNUAL PESTICIDE USE REPORT
BY CHEMICAL
JANUARY THRU DECEMBER 1991
PAGE 190
HEMICAL / COMMODITY

NUMBER OF
POUNDS
ACRES/UNITS



APPLICATION
APPLIED
TREATED TYPE
GRAPES, PROCESSED

1
29.9100
108.200.00
P
GRAPES, PROCESSED

3
20.3751
21,000.00
S
GRAPES, PROCESSED

1
5,250.0000
3.500.00
T
GRAPES, PROCESSED

12
2.108.6188
1,908 00
U
GREENHOUSES 1EMPTY! (ENVIRONS, BENCHES,
ETC. :
1
98.0000
2 700.00
c
GREENHOUSES >EMPTY: (ENVIRONS, BENCHES,
ETC. :
1
s 27 4400
2.750.00
s
GREENHOUSES tEMPTY; (ENVIRONS, BENCHES.
ETC. I
1
9 828.2240
11.OOO.00
U
HORSERADISH 'ALL OR UNSPEC)

7
3.0400
375,00
p
KIWI FRUIT

1
S.3800
4 00
A
KIWI FRUIT

1
1,448.OOOO
144.800.00
s
KIWI FRUIT

1
852.7150
879.00
J
LANDSCAPE MAINTENANCE

4
7 428.8800
38 27
A
LANDSCAPE MAINTENANCE

2
192.03S0
14.688.00
s
LANDSCAPE MAINTENANCE

1 13
10,018.5877
.00
U
LEAFY VEGETABLES (ALL OR UNSPEC)

2
1 4924
2.00
A
LEAFY VEGETABLES (ALL OR UNSPEC1

i
4.4000
3 . 040.00
P
LEEK '

2
4.2000
195.00
P
LEMON

9
48.087.2910
168.74
A
LEMON

1
39.2000
4 000.00
s
LEMON

1
12.0000
20.00
u
LETTUCE. HEAD :ALL OR UNSPEC)

29
79,1OS.9075
377.59
A
LETTUCE, HEAO (ALL OR UNSPEC)

1
14 0000
7,200.00
P
LETTUCE, LEAF iALL OR UNSPEC)

20
78,177.5900
329.72
A
LETTUCE, LEAF (ALL OR UNSPEC)

2
11.4500
6,960.00
P
LIME (MEXICAN LIME, ETC.)

1
308 4SOO
310.00
U
MELONS

1
149 2500
1 .00
A
MUSHROOMS

3
45.0000
22,778.00
c
N-GRNHS GRWN CUT FLWRS OR GREENS

433
130.858.9933
428.71
A
N-GRNHS GRWN CUT FLWRS OR GREENS

S
53.7500
17 .620.00
C
N-GRKHS GRWN CUT FLWRS OR GREENS

8
1.232.0000
281.00
K
N-GRNHS GRWN CUT FLWRS OR GREENS

4 18
54,823.9819
5,328.888.74
s
N-GRMS GRWN CUT FLWRS OR GREENS

2
114 0000
22,000 00
u
N-GRNHS GRWN PLANTS IN CONTAINERS

27
21.871 3088
31 .48
A
N-GRNHS GRWN PLANTS IN CONTAINERS

4B
445.1300
14.97S.00
C
N-GRNHS GRWN PLANTS IN CONTAINERS

14
211.0200
57.277.01
s
N-GRNHS GRWN PLANTS IN CONTAINERS

5
28.890O
920.OO
u
N-GRNHS GRWN TRNSPLNT/PRPGTV MTRL

37
73,327.4000
265.82
A
N-GRNHS GRWN TRNSPLNT/PRPGTV MTRL

100
8. 134.8880
525.327.00
C
N-GR^S GRWN TRNSPLNT/PRPGTV MTRL

32
888.7500
112,971.50
s
N-GRNHS GRWN TRNSPLNT/PRPGTV MTRL

18
910.0850
30,701.00
U
N-OUTDR CONTAINER/FLD GRWN PLANTS

219
1,140,780.1130
4.439.41
A
N-OUTDR CONTAINER/FLD GRWN PLANTS

64
27,849.2050
1,203,848 00
C
N-OUTDR CONTAINER/FLD GRWN PLANTS

2
147 0000
4.05
K
N-OUTDR CONTAINER/FLO GRWN PLANTS

as
8.924.7150
878,703.34
s
N-OUTDR CONTAINER/FLD GRWN PLANTS

19
249.9800
7,104.00
u
N-OUTDR GRWN CUT FLWRS OR GREENS

272
315,286.4740
1.015.01
A
N-OUTOR GRWN CUT FLWRS OR GREENS

1
12.0000
49,248.00
c
N-OUTDR GRWN CUT FLWRS OR GREENS

84
8.284 8895
927 331 00
s
N-OUTDR GRWN TRNSPLNT/PRPGTV MTRL

1 25
218,745 8933
845.73
A
N-OUTDR GRWN TRNSPLNT/PRPGTV MTRL

31
847.3120
53,112.00
c
N-OUTDR GRWN TRNSPLNT/PRPGTV MTRL

1 17
15,058.3928
1.448.357.00
s
N-OUTOR GRWN TRNSPLNT/PRPGTV MTRL

17
5,192.8907
35.00
u
NECTARINE

1 1 1
348.298.4137
1 . 564.SO
A
NECTARINE

2
125.0000
24,000 00
£
NECTARINE

3
108.0000
108.00
P
NECTARINE

23
1 .247.3771
97.732.00
U
NUT CROPS, NUT TREES (ALL OR UNSPEC)

3
9 5000
2.810.00
c
NUT CROPS, NUT TREES (ALL OR UNSPEC)

1
465.0000
750.00
T
NUT CROPS, NUT TREES (ALL OR UNSPEC)

1
4 5000
453.00
U
OATS, GENERAL

3
12.708 8300
31 50
A
ONION (DRY SPANISH. WHITE, YELLOW, RED
ETC. ;
7
10.603 2000
31.13
A
ONIONS (GREEN)

8
17,784 1000
61 .00
A
ORANGE (ALL OR UNSPEC)

18
51 .525.0250
223.53
A
ORANGE (ALL OR UNSPEC)

4
3.592.3850
4.407.90
s
C-4

-------
DATE: 01/25/93
PROGRAM: PUSER01A
STATE OF CALIFORNIA
DEPARTMENT OF PESTICIDE REGULATION
ANNUAL PESTICIDE USE REPORT
BY CHEMICAL
JANUARY THRU DECEMBER 1991
PAGE
191
CHEMICAL / COMMODITY
NUMBER OF
APPLICATION
~RANGE (ALL OR UNSPEC1

3
ORCHARDS (FRUIT/NUT ETC)

1
PEACH

353
PEACH

2
PEACH

5
PEACH

1
PEACH

97
PEAR

3
PEAS, GENERAL

8
PEAS. GENERAL

3
PEAS, GENERAL

1
PEAS. GENERAL

1
PEPPERS tCHI LI TYPE) ( FLAVORING ANO
SPICE CROP)
3
PEPPERS (CHILI TYPE) (FLAVORING AND
SPICE CROP)
1
PEPPERS ( FRUITING VEGETABLE) , (BELL
.CHILI, ETC.)
30
PERSIMMON

2
PISTACHIO (PISTACHE NUT)

3
PISTACHIO (PISTACHE NUT)

21
PISTACHIO (PISTACHE NUT)

3
PISTACHIO (PISTACHE NUT)

1
PLUM (INCLUDES WILD PLUMS FOR HUMAN
CONSUMPTION)
86
PLUM (INCLUDES MILD PLUMS FOR HUMAN
CONSUMPTION)
1
POME FRUITS (ALL OR UNSPEC)

1
PRUNE

32
PRUNE

47
PRUNE

4
PRUNE

1
PRUNE

4
PRUNE

19
PRUNE

1 10
PUBLIC HEALTH PEST CONTROL

14
PUMPKIN

1
RADISH

9
RANGELAND (ALL OR UNSPEC)

2
RANGELAND (ALL OR UNSPEC!

1
RASPBERRY (ALL OR UNSPEC)

4
RASPBERRY (ALL OR UNSPEC)

8
RECREATIONAL AREAS, TENNIS COURTS.
PARKS, ETC.
1
REGULATORY PEST CONTROL

7
RICE (ALL DR UNSPEC)

21
RICE (ALL OR UNSPEC)

1
RICE (ALL OR UNSPEC!

4
RICE (ALL OR UNSPEC)

1
RICE (ALL OR UNSPEC)

2
RICE (ALL OR UNSPEC)

1
RIGHTS OF WAY

33
RUTABAGA (SWEDE, SWEDISH TURNIP)

2
RYE (ALL OR UNSPEC)

2
SEEDS (AGRICULTURAL & ORNAMENTAL) !
ALL OR UNSPEC)
S
SEEDS ( AGRICULTURAL & ORNAMENTAL) (ALL OR UNSPEC)
1
SEEDS (AGRICULTURAL & ORNAMENTAL) (ALL OR UNSPEC)
1
SILOS

1
SMALL FRUITS (ALL OR UNSPECIFIED)

2
SMALL FRUITS (ALL OR UNSPECIFIED)

1
SMALL FRUITS (ALL OR UNSPECIFIED)

8
SOIL APPLICATION (AS-CROP, ORN-PLANT SITUATIONS)
1
SOIL APPLICATION, PREPLANT-OUTDOOR
(SEEDBEDS.ETC.)
213
SOIL APPLICATION. PREPLANT-OUTOOOR
(SEEDBEDS.ETC.)
20
SOIL APPLICATION. PREPLANT-OUTDOOR
(SEEDBEDS,ETC )
8
SOIL APPLICATION, PREPLANT-OUTOOOR
(SEEDBEDS.ETC.)
4
SPINACH

2
SOUASH (ALL OR UNSPEC)

8
SQUASH (SUMMER!

1
STONE FRUITS (ALL OR UNSPEC)

t
POUNDS
ACRES/UNITS

APPLIED
TREATED TYPE
117.8000
35 00
U
2,437 7500
2 . 450 . 00
U
872,881.4397
3.802.16
A
185.0000
22.000.00
C
257.2480
31.839.80
P
88.5850
58.00
T
20 684.8088
113.242.00
U
2.054.7600
1 ,445.00
U
1,243.1920
445,576.00
c
203.2500
927,020.00
p
251.2440
84,000.00
s
765.0000
1,782.00
T
5.210.3100
18.75
A
.9800
100.00
S
146.659.5000
821 06
A
8.910.0000
22.00
A
1 .305.0420
716.00
A
5.028.0000
2.287.357.00
C
11.9400
2,880.00
s
244.0000
980.00
u
278.906.6600
478.94
A
35.9100
2,400 00
s
199.0000
50
A
110,870.4622
2,848.83
A
7,714.2500
4.161,257.30
C
4,828.0000
3,258.00
K.
10.OOOO
10.00
P
1,091.2250
197 . 90 00
S
613 OOOO
5.729.00
T
21.711.7083
115.143.00
U
16,573 1440
.00
U
2,924 8000
1 1 .00
A
4 2400
4,020.00
P
44B.3SOO
2.00
A
30.OOOO
4.000 00
s
3,731.5200
19.05
A
279.9000
968.OO
U
348.2500
50
A
29,129.OOOO
00
U
3.892 OOOO
1,923.115.00
C
13,283.0000
8.642.00
K
40.5500
225,312 00
P
8.0000
3,000.00
S
10.5000-
17S.00
T
2 OOOO
400.00
U
2.432.04SO
00
U
.5000
250 00
P
6.219.1800
18.49
A
17,184.7500
59.50
A
5.0000
2.400 00
f
16.0000
40,834 00
p
11 9400
1,250 00
£
105 2000
9,411.00
A
4 8000
2 . 400. 00
C
20.787.5000
51.462.00
U
238.8000
24.200.00
s
614,075.5340
1.656.31
A
599.9400
1,279.35
c
1,755.4975
88 683.00
s
868.8240
971 00
U
8.7000
90 00
p
5,585.5450
33 00
A
234.5000
1 00
A
37.0000
15,400 00
c
C-5

-------
DATE: 01/25/93
PROGRAM: SUSER01A
STATE OF CALIFORNIA
DEPARTMENT OF PESTICIDE REGULATION
ANNUAL PESTICIDE USE REPORT
8Y CHEMICAL
JANUARY THRU DECEMBER 1991
PAGE
192
CHEMICAL / COMMODITY
STONE FRUITS 1 ALL OR UNSPEC)
STORAGE AREAS 4 PROCESSING EQUIPMENT
STORAGE AREAS 4 PROCESSING EQUIPMENT
PROCESSING EQUIPMENT
(ALL OR UNSPEC)
(ALL OR UNSPEC)
(ALL OR UNSPEC)
[ALL OR UNSPEC)
(ALL OR UNSPEC)
(ALL OR UNSPEC)
STORAGE AREAS 4
STRAWBERRY
STRAWBERRY
STRAWBERRY
STRAWBERRY
STRAWBERRY
STRAWBERRY
STRUCTURAL PEST CONTROL
STRUCTURAL PEST CONTROL
SWEET POTATO
TANGERINE (MANDARIN,
TOMATO
TOMATO
UNCULTIVATED AGRICULTURAL AREAS
UNCULTIVATED AGRICULTURAL AREAS
UNCULTIVATED AGRICULTURAL AREAS
UNCULTIVATED NON-AG AREAS
UNCULTIVATED NON-AG AREAS
UNCULTIVATED NON-AG AREAS
UNCULTIVATED NON-AG AREAS
VEGETABLES (ALL OR UNSPEC!
'ALL/UNSPEC)
IALL/UNSPEC)
(ALL/UNSPEC)
SATSUMA, MURCOTT. ETC.
(ALL OR UNSPECi
.ALL OR UNSPEC)
(ALL OR UNSPEC)
(ALL OR UNSPEC!
(ALL OR UNSPEC)
I ALL OR UNSPEC !
(ALL OR UNSPEC)
(ALL OR UNSPEC!
(ALL OR UNSPEC!
VEGETABLES
VEGETABLES
VERTEBRATE PEST CONTROL
WALNUT (ENGLISH WALNUT.
(ENGLISH WALNUT.
(ENGLISH WALNUT.
[ENGLISH WALNUT.
(ENGLISH WALNUT.
(ENGLISH WALNUT,
(ENGLISH WALNUT.
walnut
WALNUT
WALMJT
WALNUT
WALNUT
WALNUT
WATERMELONS
WATERMELONS
WHEAT, GENERAL
WHEAT, GENERAL
PERSIAN WALNUT)
PERSIAN WALNUT)
PERSIAN WALNUT)
PERSIAN WALNUT)
PERSIAN WALNUT)
PERSIAN WALNUT)
PERSIAN WALNUT)
» CHEMICAL TOTAL «
NUMBER OF
APPLICATION
5
1
3
2
1	, 224
7
s
2
1
28
2
2	, 887
57
2
86
1
102
1
4
39
9
8
1
7
2
1
15
238
37
6
10
4
46
150
3
«
5
S
11,577
POUNOS
APPLIED
258 8910
1,050 0000
1,622.0000
335 0000
4,536.075.4147
489 2500
374.2000
378-4375
374 4000
7.106.3825
4,484 5000
3,271,987.7835
190.707.8480
5,977.4100
211,654.6325
27.4400
435.477.933S
2 0100
354 4088
257,093.9881
45.0025
668 9150
10.447S
3.906 8400
5.0000
3.9800
3,044.0875
281.931.4615
6.255.2735
1 741.3500
3.639.0000
341.6400
45.744.2970
23,151.9775
8,572.8000
75O0
14.5000
585.0800
18,675.842 6285
ACRES/UNITS
TREATEO TYPE
57.408.00	U
6100	A
189,573.00	C
187,000.00	S
33,226.47	A
177,300.00	C
284.980.00	P
76,379.25	S
34,371.00	T
561,236.00	U
17.00	A
.00	u
833 34	A
14.OO	A
.385.57	A
,800 00	S
,242.82	A
150.00	C
,728.00	S
738.02	A
8,948.00	C
54,600.00	S
7.00	U
15 90	A
1.550 00	C
3.952.00	P
.00	u
4.881.01	A
3,337.4t6.00	C
100.943.00	K
3,780,705.00	P
493,105.00	S
159,273.74	"
184,416.50	U
35.00	A
180.00	C
1,250.00	C
4,135.00	T
METHYL CELLULOSE
ALFALFA (FORAGE - FOOOER) (ALFALFA HAY)
almond
APPLE
APRICOT
CABBAGE
CAULIFLOWER
CELERY, GENERAL
CHERRY
CITRUS FRUITS (ALL OR UNSPEC)
COLLAROS
CORN (FORAGE - FODOER)
CORN, HUMAN CONSUMPTION
COTTON. GENERAL
CUCUMBER (PICKLING, CHINESE, ETC)
GRAPES
GRAPES. PROCESSED
LANDSCAPE MAINTENANCE
LEMON
N-OUTOR CONTAINER/FLO GRWN PLANTS
N-OUTDR GRWN CUT FLWRS OR GREENS
NECTARINE
OLIVE (ALL OR UNSPEC)
13
32
10
1
2
30
1
6
3
30
5
5
4
18
138
10
7
2
3
1 1
2
84
21 .
589.
113.
2
52
2
4
8
42
10
7
9
56
354
15
1
82
3
8
464
6593
4121
1227
6840
5859
.2711
0520
. 74S4
. 1560
.8540
.3698
.4300
.5068
.8101
.4840
.4571
. 1182
. 4405
7797
. 7961
8741
0999
789.
, 474.
550.
5
15.
678.
12.
63
12
866
199
216
241
555
.421
228
42
5
48
42
. 253
60
00
86
00
00
.50
.00
.00
.00
.00
.00
. 70
.00
00
71
.00
00
.00
.50
.53
.00
.00
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
A
U
A
A
A
A
A
C-6

-------
APPENDIX D
OFFICIAL LIST OF GRAIN WAREHOUSES (UGSA)
BY STATE (SOURCE: USDA)
D-l

-------
OFFICIAL LIST OF WAREHOUSES APPROVED
UNDER THE UNIFORM GRAIN STORAGE AGREEMENT
AS TRACKED BY THE USDA KANSAS CITY COMMODITY OFFICE
DATE: 5/3/93
1 AL
21
2 AR
171
3 AZ
9
4 CA
42
5 CO
170
6 DE
5
7 FL
7
8 GA
45
9 ID
202
10 IL
1395
11 IN
404
12 IO
1333
13 KN
33
14 KS
1134
15 LA
73
16 MD
13
17 ME
5
18 Ml
151
19 MN
766
20 MO
353
21 MS
59
22 MT
182
23 NC
65
24 NE
775
25 NM
18
26 NV
1
27 NY
15
28 OH
469
29 OK
363
30 OR
96
31 PA
4
32 SC
29
33 SD
346
34 TN
41
35 TX
634
36 UT
6
37 VA
28
38 WA
472
39 Wl
174
40 WV
1
41 WY
10
TOTAL U.S. COUNT	10120
D-2

-------
APPENDIX E
FUMIGATION TREATMENT FACILITIES
BY STATE (SOURCE: APHIS)

-------
TREATMENT FACILITIES IN THE U.S. (Source: APHIS PPQ)
NAP-MB =Norma! Atm Press- Methyl Bromide Use
VAC-MB = Vacuum Chamber - Methyl Bromide Use
Tarp = Tarpaulin Applications - Methyl Bromide Possible
No of Chambers	No of Chambers	No of companies
State NAP-MB	VAC-MB	Tarp
CA
2
10
9
AL


3
AZ

1
2
DE


2
FL
1
8
19
GA

2
7
HI
1
1
6
LA

2
5
MD

3
1
MA


3
IL


1
Ml


1
MN


1
MS


6
MO


1
NJ

13
2
NY

3
4
NC
3
6
3
OH


2
OR


5
PR


6
Rl


1
PA


4
SC


3
TN


2
TX

5
17
VA

14
2
WA
1

2
VI

1
1
Wl


1
Total:
8
69
122
E-2

-------
Treatment Facilities
Appendix 5
ALABAMA
Mobile
Commercial:
Tarpaulin
A&P Termite and Pest Control, 1704 Church Street
Atlas Exterminators, 106 N. Ann Street
Or kin Exterminating Co, Inc., 1764 S. Beltline Hwy
ARIZONA
m
Nogntes
PPQ:
Dry heal
18" * 12" — maximum 392"F
Hot water hath
16" x 18" x 9'A'
Vac fumigation • MB
9' * 4* = m ft*
Phoenix
Commercial:
Tarpaulin
Arizona Exterminating Co. 210 S 24th Street
Yuma
Commercial:
Tarpaulin
Truly Nolen, 840 South 5ih Avenue
IN.2
i*i k:
11/92-01
Appendix S
Treatment Facilities
CALIFORNIA
Lung Beach -- see Los Angeles
Los Angeles
Commercial:
NAP fumigation - MB
California Cotton Fumigation Co, Berth 155A, Wilmington
52* x 12.5* x 9 25' (wo)
P C. Fumigation, 909 Colon Street. Wilmington
Tarnaulin
Ag-Futne Services, Inc.. 9722 Washburn Rd , Downey
California Cotton Fumigation Co. Berth I55A, Wilmington
Capricorn Fumigations, 7020 Marcelle Street, Paramount
Harbor Pest Control, 3388 Channel Way, San Diego
P C, Fumigation, 909 Colon Street, Wilmington
Vac fumigation - CB. MB
7.2' x 4" x 5* = 144 ft'
California Cotton Fumigation Co, Berth 1S5A, Wilmington
52' x 12.5* * 9.25' (two)
P.C. Fumigation, 909 Colon Street, Wilmington
Vac fumigation - MB
40' x 8* = 2,010 ft1
r x 8' x 50' = 3,200 ft'
California Cotton Fumigation Co, Berth 155A, Wilmington
r«c
11/92-01

-------
Treatment Futilities
Appendix 5
CALIFORNIA (continued)
m
i
Los Angeles (continued)
PPQ
Dry heat
22'/t" x 19" x 18'A" = 2.6 H1
Sieam
38" x 20" x 20" = 8.73 -- maximum 60 psi
Vac fumigation - MB
SV/i" x V x 3' = 34 ft*
5 8* x 4- x 10 6" = 235.2 ft1
Sun Diego
Commercial:
Dry heal
18' x 9' x 6' - maximum 236°F
hquippeit with automatic temperature recorder
San Diego lixterminating Co, 3645 India Street
Three ovens:
18" x 12" x 24" - maximum 600*F (two)
18" x 12" x 24" -- maximum 2,000*F
Clarkson Lab and Supply, Inc. 1140 30th Street
Tarpaulin
Harbor Pest Control, 3388 Channel Way
PPQ:
Dry heat
14" x 15" x 25" -- maximum 550'F
Vac fumigation - MB
3'8" x 5' x 6'7" = 118.9 fr'
18.4
l'l)C
II/V2-0I
Appendix S
Treatment Facilities
CALIFORNIA (continued)
San Prune 1sto
(Commercial:
Tarpaulin
American Marine Fumigating and Warehouse Co, 6195 Coliseum
Way, Oakland
Rose Extermination Co, 1512 L'ast 12th Street-, Oakland
PPQ:
Dry heat
19" x 23" x 19" - maximum 392*F
Hot water
3" x 8" x 9'Am
Vac fumigation - EO FR. MB
22" x iS'/j" = 2.4 It'
Vac fumigation - MB
6'7" x 3'8" x 5' - 120 ft'
Sun Ysidro — see San Diego
Wilmington -- see Los Angeles
n»c
11/92 01
18.5

-------
Treatment Facilities
Appendix S

IX ft (litank)
i'i>c
11/92-01
Appendix 5
Treatment Facilities
CANADA
Quebec
Commercial:
Cold treatment One room
1665m' (58,800 ft')
JP and A Frappier Warehouse, Franklin Center
Operated by lames Leahy and Sons
DELAWARE
Dover AFB
Commercial:
Tarpaulin
Dower AFB, Building 789
Wilmington
Commercial:
Tarpaulin
Wilmington Marine Terminal, Port of Wilmington, P.O. Box 1191,
Warehouse B, Warehouse C
PIKT
11/92 01
18.7

-------
Treatment Facilities
Appendix 5
FLORIDA
m
i
OS
Fernandina Beach — See Jacksonville
Ft. Lauderdale
Commercial:
Tarpaulin
F & F Pest Control, 7880 NW 64th Street, Miami
G&PM Pest Control, 12232 SW 130 Street, Miami
Ft. Pierce
Commercial:
Tarpaulin
F & F Pest Control, 7880 NW 64th Street, Miami
Green Cove Springs -- See Jacksonville
Jacksonville
Commercial:
Tarpaulin
J.F. Yearly A Sons. Inc. 4717 Dellwood Avenue
Orkin Exterminating Co, Inc. Westside Branch, 529 W. Stuart Ln
Miami
Commercial:
Tarpaulin
FAF Pest Control, 7880 NW 64th Street
G&PM Pest Control, 12232 SW 130th Street
Orkin, 1960 NW 27th Avenue
Western Fumigation, 3541 W. Broward Blvd., Ft. Lauderdale^
18.8
PIJC
11/92-01
Appendix 5
Treatment Facilities
FLORIDA (continued)
Miami (continued)
PPQ:
Dry heat
18" x 18" x 23' - maximum 500°F
Hot water
36" x 18" x 9'A"
Steam
38" x 21" — maximum 60 psi
Vac fumigation - MB
40" x 30" x 36" = 25 ft* (two)
9'2" x 4' = 115 (two)
10' x 8' x 8' = 640 ft3
Orlando
Commercial:
Tarpaulin
Truly Nolen, 100 West Amelia Street
PPQ:
Dry heal
24" x 28" x 21" - maximum 450°F
Vac fumigation - MB
8' x 8' x 10' = 640 ft'
5'*5'x5' = I25°F (two)
NAP fumigation - MB
17' x 8'6" x 11 * 1,590 ft*
rix:
11/92 01

-------
Treatment Facilities
Appendix S
FLORIDA (continued)
Port Canaveral
Commercial:
Tarpaulin -- can be arranged (no regular facility at present)
Port Manatee
Commercial:
Tarpaulin
Genesis Exterminator, Brandenton
Western Fumigation, 1-800-542-1542 (New Jersey)
Tampa
Commercial:
Tarpaulin
Genesis Exterminator, Brandenton
Western Fumigation, 1-800-542-1542 (New Jersey)
West Pulm Bench
Commercial:
Tarpaulin
F&F Pest Control, 7880 NW 64th Street, Miami
G&PM Pest Control, 12232 SW 130th Street, Miami
PalmBeach Exterminating, P.O. Box 2788
Western Fumigation, 2800 NW 22nd Terrace, Pompano Beach
18.10
PI>C
11/92-01
Appendix 5	Treatment Facilities
GEORGIA
Atlanta
Commercial:
Tarpaulin
Bizzy Bee Exterminators, P.O. Box 954, Covington
Tcrminiz International Co., LP, 5373 Rivcrdale Rd, College P,»ik
B mas wick -- See Savannah
Savannah
Commercial:
Tarpaulin
Cargo Fumigations, Inc. 120 W Bay St, P.O. Box 1714
Degesch America Inc. 1233 Wilmington Islam) Road
Rid-A-Pest Exterminating Co, 506 E. Liberty Street
Town A Country Exterminating Co, Inc. 5106 Ogeechee Road
Yates Astro Termite Pest Control, 3007 Gibbons Street
State Facility:
Vac fumigation only - MB
77' x 9'6" x 10* - 7,315 ft* (two chambers)
Georgia Ports Authority, P.O. Box 2406
1'IK"
11/VMM
IK II

-------
Treatment Futilities
m
00
Appendix 5
111 II
i'ik:
11/92-01
Appendix 5
Treatment Facilities
HAWAII
Honolulu
Commercial:
Tarpaulin
Inter-Island Termite, Inc, 905C Kokeu Sireet
Island Termite Inc. 905 Kokea Street
No Ka Oi Termite and Pest Conirol, Inc, 99-1272 Waihona St.
Terminix International, 920 Sheridan Street
Vet's Termite Control, 500 Alakawa Sireet, Suite 220
Xtermco, 1020 Atiahi Sireet
PPQ:
Dry heat
18'/^" x 23" x 19" -- maximum 482°F
Steam
40" x 20" x 20" — maximum 60 psi
Vac fumigation - MB
6'7" x V8" x 5' = 120 ft'
NAP futnigalion - MB
5.15" x 2.41' - 24.87 ft*
Keaau -- See Hilo
I'DC
11/92-01
IK.13

-------
Treatment Facilities
Appendix 5
ILLINOIS
Chicago
Commercial:
Tarpaulin
Marks Pest Control Company, 1057 W. Grand Avenue
PPQ:
Steam
12" * 20" x 2*A'
LOUISIANA
m
i
\o
Baton Rouge -- see New Orleans
New Orleans
Commercial:
Dry heat
Import Sterilization, Inc., 1000 Edwards Avenue, Harahan
Tarpaulin
Mr. B. Services, Inc., 900 Jefferson Hyw, Jefferson
Redd Pest Control, 3801 Florida Ave., Kenner
D A A Exterminating Co., 4533 Clearview Pkwy, Metairie
All Phase Pest Control, 2801 S. Carrollton Ave.
Degesch America, Inc., 512 Rosenwald, Reserve
IK.14
PI>C
11/92-01
Appendix S
Treatment Facilities
LOUISIANA (continued)
New Orleans (continued)
PPQ:
Dry heat
2*6" x 1'6" x 2' — maximum 550°l;
I '3' * 1'2" x I'6" — maximum 536*I:
1 '7" x I'll" x I'7" - maximum 437°l-
Hot water
36" x 18" x 9'/t"
Steam
1'4" x 8" -- maximum 27 psi
Vac fumigation - MB
8*3" x 4* x 4' - 132 ft'
4' x 4* x 4* = 64 ft1
MARYLAND
Baltimore
Commercial:
Tarpaulin
Dundalk Marine Terminal, 2700 tiioening Highway, Shed 3A
Vac fumigation - MB
7.2' x 5.7* x 24.02* 985.78ft'
i»ix:
11.92-01
IH.I5

-------
Treatment Facilities
Appendix 5
MARYLAND (continued)
Bellsville
PPQ:
Dry heal
14" x 18- x 19* -- maximum 212*F
Hoi water
36* x 18* x 9'A"
Steam
24" x I5'A* — maximum 15 psi
Vac fumigation - EO-FR
16" x 16" x 26* = 3.9 ft'
Vac fumigation - MB
2.5- x 3' x J.S- = 26 IV
4 x5 x6 - 120 ft5
MASSACHUSETTS
Boston
Commercial:
Dry heat 10 ovens - various sizes to 2,2SO°F
6" x 12* to 5' x 10- x 5'
l.inc]berg Heal Treating Co, 475 Dorchester Avenue,
South Boston, 268-9255, Mr. Jack Rourick
Tarpaulin
Bam Pest Central, 1320 Middlesex Street, Lowell
Safely Fumigation, 197 Beal Street, Hingham
Walihain Chemical, 817 Mordy Street, Waltham
Charleston - see Boston
IN.16
pih:
11/92-II
Appendix 5
Treatment Kacililies
MASSACIIUSET1-S (jonnnur.i)
New Bedford
Commercial:
Cold treatment five rooms
Room l — l 13,088 ft'; Room 2-270,750 ft';
Room 3—274, 436 ft'; Room 4-267,159 ft';
Room 5 950,400 ft' (Wesl Terminal)
Maritime Terminal Incorporated, Whalers Wharf
MICHIGAN	
Detroit
Commercial:
Tarpaulin
Rose Exterminating Company, 4862 Greenfield Rd., Dearborn
PPQ
Dry heal
11" x 11" x 9" — maximum 300°F
MINNESOTA	
Duluth
Commercial:
Tarpaulin -- can be arranged (no regular tacilily at present)
HOC
11/92-01
18 17

-------
Treatment Facilities
m
i
Appendix S
18.If) (blank)
i'i»c
1 l/»2-OI
Appendix 5
Treatment Facilities
MISSISSIPPI	
Greenville
Commercial:
Tarpaulin
Orkin Pest Control, P.O. Hox 5026
Termini* Service, P.O. Hox 4672
Gulf port
Commercial:
Tarpaulin
Alias Exterminators, 106 North Ann Street, Greenville
Orktn Pest Control, 178 Commission Road, Long Beach
Redd Pest Control, P.O. Box 2245
Jackson
Commercial:
Tarpaulin
Redd Pest Control, 108 E. Northside Drive
Pascagoula - see Gulfport
MISSOURI	
St. Charles
Commercial:
Tarpaulin
Master Pest and Termite Control, 505 Cross Green Lane
I'lJC
11/92-01


-------
Treutmrnl Facilities
Appendix 5
NEW JERSEY	
Bound Brook
Commercial:
Vac fumigation - LO
40" x 69" x 146" = 231 ft'
58" x 67" x 209* = 470 ft'
71" x 76" x 395" - 1,2.13 1^
Griffith Micro Science Inc., Central Jersey Industrial Park, 8E,
Easy Street
Klizahtlh
Commercial:
Cold treatment
Two rooms •- 77,774 ft' and 278,628 ft'
At.ilunta Corporation, Atalanta Pla/ii
llohoken
PPQ:
Dry heat
19" x 2)" % 19" -- maximum 430*1"
Hot water
34" x 31" x 35" (two)
36" x 18" x 9>/i"
Steam sterilization
20" x 20" x 30" -- maximum 20 psi (autoclave)
6'3" x 2' x 4' -- maximum 20 psi (two)
5'6" x 4' x 5' -- maximum 20 psi
10' x 4' x 5' -- maximum 20 psi
16' x 5' x S' -- maximum 20 psi
IK :o
MX'
11/92 01
Appendix S	Treatment Facilities
NEW JERSEY (continued)
Huboken (continued)
PPQ: (continued)
Vac fumigation
6'3" x 2' x 4' = 50 It' (two)
5'6" x 4' x 5' -- 110 ft1
10' x 4' x 5' = 200 ft'
16' x 5' x 5' - 400 ft'
23' 9>/im x 6'11" x 6' = 987 ft'
Linden
Commercial:
Cold treatment
One rooin--l92,!28 ft'
Pig Tainer Express Corp., .140 South Shies Street
Dry heat (Iwo ovens)
15* x 6' x = 180 li' -- maximum 350°l-
ETO Sterilization, Inc., 250 Brunswick Avenue
Vac fumigation - EO
80' x I0'6" x T =r- 5,880 It'
40' x 9' x 7' - 2,752 It5
40' x 5' x 7' = 1,400 It'
44' x T x 12' - 3,696 ft'
ETO Sterilization, Inc., 250 Brunswick Avenue
Newurk
Commercial:
Tarpaulin
Vanguard Pest Control Co., Inc.. Port Authority, Building 122,
Port Newark
rue
11/92-01
IK.21

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Treatment Futilities
Appendix 5
NEW YORK
PI
I
Albany
Commercial:
Tarpaulin
Terminex International, 10 Walker Way (Port Authority, Shed 05)
Brooklyn
Commercial:
Cold treatment
Two rooms — 20,884 ft' each (availability limited)
William Knpke, Jr., Inc., 676 Longfellow Ave., The Bronx
Tarpaulin
Red Hook Terminal, Pier 11
Bronx, The -- see Brooklyn
Buffalo
Commercial:
Tarpaulin -- can be arranged (no regular facility at present)
Jamaica
Commercial:
NAP fumigation - MB
88" X 90" X 474" = 2,160ft'
Agra-Services LTD, 221-20 147 Street, Spring Gardens
18 22
rwc
11/92 01
Appendix 5
Treatment Facilities
NEW YORK (continued)
Jamaica (continued)
PPQ:
Dry heat
25' x 19" - maximum 500°F
Hot water
36' x 18* x 9'V
Steam
36" x 20" - maximum 15 psi
Vac fumigation - MB
38" x 30" x 36" - 24 ft' (two)
Vac fumigation - MB
127" x 48" x 68" - 240 ft'
Rochester
Commercial:
Tarpaulin
Sawyer, 201 Monroe Avenue
NORTH CAROLINA
Charlotte
Commercial:
Tarpaulin
Terminiz Service, 2001 South Tymn Street
Wilson Pest Control Co, P.O. Box 1398, Winston-Sulern
l*»C
11/92 01
18.' <

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Treatment Facilities
NORTll CAROLINA (continued)
Appendix 5
Morehead City
PPQ:
Tarpaulin as needed
Stale Facility:
Vac fumigation only - MB
82'5- * 101" x 10*10" = 9,000 ft' (two)
North Carolina Slate Ports Authority
Wilmington
Stale Facility:
Tarpaulin ¦ MB
North Carolina State Ports Authority -Wilmington State Port
Vac fumigation only ¦ MB
76'8" x 9'6" x 10' = 7,284ft' (two)
North Carolina Slate Ports Authority—Wilmington Slate Port
Wilson
Commercial:
NAP fumigation - MB
40' x 27' x 21* = 22,680ft'
40' x 62' x 21' = 52,080 ft'
40- x 97'8' x 21' = 82,034 ft'
Export Leaf Tobacco Co., P.O. Box 636, Old Slantonsburg Rd
Vac fumigation only - MB
10' x 10* x 40' = 4,000 ft' (two)
Tobacco Processors, Inc., Storage Division, P.O. Box 1089,
2107 Old Black Creek Road
IK.24
pix:
1I/92-OI
Appendix S
Treatment Facilities
OHIO
Cleveland
Commercial:
Tarpaulin
Progressive Pest Control Co., 2883 Pasadena Drive
PPQ:
Dry heat
11 % " x 11" x 8 3/4" -- maximum 392°F
U.S. Navy:
Steam
23'A' x 15 3/4" -- maximum 60 psi
U.S. Navy Finance, 2693 New Federal Building
Toledo
Cominerc lal:
Tarpaulin — can be arranged (no regular facility at present)
OREGON	
Portland
Commercial:
Tarpaulin
DICO/Pacific Fumigation, 12011 NE 95ih Street, Vancouver, WA
Larsen Pest Control, 5625 SE 85th
Orkin Exterminating Co., Inc., 4410 SW Beaverton-Hilldale Hwy
Paramount Pest Control, Inc., 5207 NE Portland Highway
PCO Services (Ardee Pest Control), 12013 NE Marx
i-ik:
11/92-01
18 25

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Treatment Facilities
Appendix S
PENNSYLVANIA
Philadelphia
Commercial:
Cold treatment One room (118,800 ft*)
Holt Marine Terminal, 701 North Broadway
Dry heat
Stanford Seed Co., P.O. Box 320, Muddy Creek Rd, Denver, PA
Tarpaulin
Holt Marine Terminal, 701 North Broadway, Gloucester City, NI
Tioga Marine Terminal, Tiogo Marine Terminal #2, Pier 84,
Delaware Avenue
Broadway Terminal, North Bioadway, Camden, NJ
Penn Terminal, Chester
PUERTO RICO
Ponce
Commercial:
Hot water
65' x 8' x 9
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Appendix S
SOUTII CAROLINA
Treatment Facilities
Charleston
Commercial:
Tarpaulin
Mooreguard Exterminating Company, 803-884-7162, Mt. Pleasant
National Exterminating Company, 803-766-1217
Willard Exterminating Company, 803-571-6909
TENNESSEE
Memphis
Commercial:
Tarpaulin
Taylor Enterprises, 5813 Leisure Lane
U.S. Pest Protection Co., Inc., Hendersonville
1'IIC
11/92 01
18.29

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Treatment Facilities
Appendix S
TEXAS
Brownsville
Commercial:
Tarpaulin
Abash Insect Control Service, 509 N. Commerce, Harlingen
PPQ:
Dry heat
23* * 19" x 19" - maximum 43?'F
Hot water
36" * 18" x 9>Am
Vac fumigation - MB
6' x 4" * 5' = 120 ft'
10' x 4* x 6- 240 ft1
Corpus Chrlsli
Commercial:
Pest Fog, 1424 BomU
IK III
PIC
11 /92-01
Appendix S	Treutmeni Futilities
TEXAS (continued)
Dallas
Commercial:
Tarpaulin
Industrial Fumigation Co, Wolfe Cily
Southwestern Fumigation Co., DesoU
PPQ:
Dry heat
18" x 12" x 16" -- maximum J92*F
El Paw
PPQ:
Dry heat
19* x 19* x 23" -- maximum .192 *F
Hot water
36" x 18" x 9'4"
Vac fiimigation - Mil
9*1* x 4' = 144 ft'
Galveston -- see Houston
Harlingen
Commercial:
Tarpaulin
Abash Insect Control .Service, 509 N. Commerce
The Bug-Man System, 1017 W Tyler
i'ik:
11/92-01
18.31

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Treatment Facilities	Appendix 5
TEXAS (continued)
Hidutyo
Commercial:
Tarpaulin
Abash Insect Control Service, 509 N. Commerce, McAllen
State Facility:
Dry heat cast iron iray, with cover
16" x 25" * 4* 6 open gas burners
Texas Soil Lab, one-half mile East Highway, McAllen
Houslon
Commercial:
Dry heat
12" * 12" x 18" maximum 392°F
Professional Services Industry, 6913 Hwy 22S, Deer Park
Tarpaulin
Anchor Fumigation & Pest Control, Inc., 4209 Dahlia l-ane.
Deer Park
Coastal Fuimgators, Inc. 1119 W. 34th St,
Degesch America, Inc., 14802 Park Almeda
International Fumigaioni, 9139 Becker
National Fumigation A Termite Service, 2101 Hazard
Orkiii Exterminating Co.. 6500 Long Drive
18.12
!»«>€
Il/W-01
Appendix 5
Treatment Facilities
TEXAS (continued)
Houston (continued)
PPQ:
Dry heat
12* x 18* x 16" — maximum 392 °F
18" x 14" x 14" - maximum 400°F
15* x IT/i" x \mm - maximum 520*F
Hot water
36" x 18* x 19% *
Steam
10" x 15'A" -- 45 psi
Vac fumigation - MB
4'6" x 9' x 6' — 243 ft*
Laredo
Commercial:
Tarpaulin
Asash Termite and Pesl Control, Inc., 1102 Clark
PPQ:
Dry heal
16" x 18" x 12" -- maximum 392°F
Hot water
36" x 18" x 9>Am
Vac fumigation - MB
6*7" x 5' x 3'8" » 120 ft*
fix:
11/92-01
I *.33

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Treatment Facilities
Appendix S
TEXAS (conrinutd)
m
i
VO
McAllen -- see Hidalgo
Port Arthur
Commercial:
Tarpaulin
International Fumigalors, ISO Marine St., Lake Charles, LA
Big State Pest Control, 1679 Lindbergh Dr., Beaumont, TX
Roma
PPQ:
Prv heat
12" x 16" * 18" - maximum 392*F
San Antonio
Commercial:
Tarpaulin
ABC Pest Control, 10022 IH 3SN
PPQ:	*
Dry heat
22" x 18" x 19" - maximum 500'F
VIRGIN ISLANDS
St. Croix
Commercial:
Tarpaulin
Oliver Exterminating, 6x, Peter's Rest, Christainsted
18.34
PI)C
11/92-tl
Appendix 5	Treatment Facilities
VIRGINIA
Dulles International Airport
Commercial:
Tarpaulin — tail he arranged (no regular facility at present)
Newport News
Commercial:
Vac fumigation only - AN-CTC. MB
42' x 10' x 10' = 4,200 ft' (two Chambers A & B)
67'3" x 5* x 9* = 3,026 ft' (two Chambers 7 A 8)
Newport News Marine Terminal, 18th Street
Norfolk
Commercial:
Tarpaulin
129' x 19' x I4'6" - 35,539 ft1 (three) (other sizes can be
arranged
Vac fumigation only - AN-CTC. HCN. MB
79* x 12* x 12' = 11,376 ft4 (six)
I.ambert's Point Dock, Inc., Foot of Orapax Avenue
83* x !0'6" x 12' = 10,458 ft' (two)
Norfolk International Terminal, 7737 Hampton Blvd.
Petersburg
Commercial:
Vac steam flow process only
5' x I3'8" x 5'6" = 375.8 ft4
Mad in, 7.iinnier, McGill, Tobacco Co., P.O. Box 550
PI)C
11/92-01
18 n

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Treatment Facilities	Appendix 5
VIRGINIA (continued)
Portsmouth
Commercial:
Vac fumigation - AN-CTC
44' x 9'6' * 10'6" - 4,389 ft' (hvo)
Portsmouth Marine Terminal, P.O. Box 7161
Richmond
Commercial:
NAP fumigation - Phosphine tPH 3)
I5'8" x 3T3- x 68' = 33,291 tt»
Alleghany Warehouse #2, 12th & Gordon Streets
™ WASHINGTON
Longview see Portland, Oregon
Seattle
Commercial:
Cold treatment
24- x 100' x 120' = 288,000 ft'
Maritime Terminals Division, Poit of Tacoma, P.O. Box 1837
NAP fumigation - MB
26' x 9'4" - 1.778 ft1
Paramount Pest Control, 423 Horton Street
Tarpaulin
Paramount Pest Control, 423 Horton Street
W B Sprague Co, 2139 S Fawsett Avenue," Tacoma
18.16
I'UC
11/92-01
Appendix S
Treatment Futilities
WASHINGTON (continued)
Seattle (continued)
PPQ:
Dry heat
18" x 14'A" x 14" - maximum 380'F
Hot water
20'4" x 2TA" x 35-
Vac fumigation - EO-FR. MB
4 5' x 2.5' - 22.1 tt3
Titcninu
Commercial:
Cold treatment
24' x 100' x 120' - 288,000 ft' (fruit treatment capacity limited
140,000 ft'
I'UC
11/92-01
IK..17

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Treatment Facilities
Appendix S
WISCONSIN
Milwaukee
Commercial:
BrxJtll
Si* ovens, various iiies from 2" * 2* * 2" lo 8' * 8* x 6' «
maximum 500*F
Commercial Heat Treating Corp., 1952 So. First S(ree(
Ten ovens, various sizes from 2' * 2" * 2' to 20' x 20' x 10' --
maximum 500* F
Steam
2* * 3* x 5* - maximum 60 psi
Tarpaulin -- can be arranged (no regular facility at present)
m
i
K>
ift.Jg
pik:
11/92^1
Appendix 5
Treatment Facilities
APPENDIX 5—DIRECTORY OF TREATMENT FACILITIES
The following is a list of abbreviations used in the Appendix.
CB--Carboxide® which is a mixture of 10 percent ethylene oxide and 90
percent carbondioxide
EO-FR A mixture of 10 percent ethylene oxide and 88 percent Freon*
MB methyl bromide
NAP—normal atmospheric pressure
SF -sulfuryl fluoride which is registered under the name Vikatie*
Vac Fumigation-vacuum fumigation (also approved for NAP)
Vac Fumigation only-not approved for NAP
ft^-tuhic feet
I)-diameter
I.--length
m-meters
m'-cubic meters
psi-'pounds per square inch
kg/cm1-kilograms per square centimeter
ItPa-kilnpascals (6.8947S7 x psi)
/--volume is larger than figures indicate -includes external duct volume
F-Fumiscope* available
i'ik:
11/92-01

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APPENDIX F
POTENTIAL DESTRUCTION TECHNOLOGIES
(SOURCE: REFERENCE 19)
F-l

-------
APPENDIX F. POTENTIAL DESTRUCTION TECHNOLOGIES
-n
i
NJ
General
Category Name
Subcategory
DE
Recovery of
By-products
Status
RecoeiMnd
for
Approval
Country
Source
A. Thermal
Oxidation
1. Gaaeoua Liquid Thermal
Oxidation/Hydrolysis







• Liquid Injection Incin-
eration 99.99X
Occasionally
Commercial
Yes
Several


¦ Reactor for cracking
CFCs/BCFCs/RFCs
>99.99Z
Yes
Conmercial
Yes
Germany
Hoechst. AG

• Gaseous/Fume Oxidation
>99.991
Occasionally
Commercial
Yes
Several
AK 20

2. Rotary Kiln (On-Site or
Off-Site Commercial)







• Hazardous Waste
Incinerator
>99.991
Occasionally
Commercial
Yes
Several


3. Multipurpose (MSHE)







• Incineration of FUF with
MSWI
>99.991
No
Full- scale
testing
Yes
Several
Kernforschung&zentrum

4 . Cement Kiln;,
>99.991
No
Connie rc i al
fox other
wastes
Yes
Swveral


Miscellaneous







• FluLdized Bed
Unknown
Unknown
Cumne r c i a 1
for other
wastes
No
USA
Ogden Environ.
(Circul. Bed)

* Waste Gasification
Not
reported
Nu
Mobile demo
unit
No
Austria
Voest-Aipine

• Controlled Combustion
99Z
No
Conmnrcial
for other
wastes
Nu
USA
Ai1ied-Signal
Industrial
Catalyst

* Direct Catalytic
Oxidation
>99Z
No
Development
No
Japan
NIRE

• Catalytic Decomposition
Approx. 1002
Nu
Lab Scale
No
Japan
Kyoto University

• Catalytic Hydrolysis
Approx. 1002
No
Lab Scale
No
Japan
NIRE

2. Hydrogenation







• Selective
Hydrodechlorination
8D-100Z
Yes
Lab Seal*
No
Japan
Hokkaido
University

• Dlract Contact
Hydro*enation
Unknown
Unknown
Bench Scale
No
USA
UOP
C. Pyrolysis
Rotary Kiln
Unknown
Possible
Unknown
No
Germany
FBD/BKM1
D. Chemical
Destruction
1. Reaction with Elemental
H*tals







-------
T1
Li
General
Category Nanw
Subcategory
DE
Recovery of
By-products
Status
Recocvoend
for
Approval
Country
Source

* Chemical Destruction of
CFCa with Sodium
>992
Not present-
ly
Lab Scale
No
Germany
Dogussa

• Reductive Destruction by
Dehalogenation
>992
No
Lab Scale
No
Japan
Kyoto Institute of
Technology

• Steal Smelter
Unknown
Ho
Unknown
No
Germany
Hornier

* Molten Iron Reactor
>99.99991
Ye*
Bnnch Scale
No
USA
MMT, Inc. (Molten
Metal Technology)

• P-CIG (Molten Iron)
Unknown
No
Pilot
plant/deao
plant
No
Sweden
MEFOS

2. Reaction with Metal Oxides







• Chemical-thermal
destruction with CaAl,0,
or SiO,
>99-99.999-9*
Yea. HCI
Pilot plant
No
Germany
Nukum

• Metal Oxide Conversion
(pebble bed)
>99.9992
No
Lab Scale
No
Australi a
CSIRQ
K Stipe rcr itical
Water
Ox j dflti on
1. Supercritical Water
Hydrolysis
Appiox. 1001
No
Lab Scale
No
Japan
NCLI

2. Supercritical Water
Oxidation
>972
No
No demo
unit
No
USA
ABB Ltuzxsus-
Crest/HODAR
F. Wet Air
Oxidation
Wut Air Oxidation
>992
No
Commercial
No
USA
Z1HPRO
G. Plasma
Destruction
1. Corona Discharge
Unknown
No
Pilot Scale
No
USA
US EPA

2 Inductively-Coupled R.F.
Plasma
>99.92
Ho
Pilot Scale
No
Japan
NIKE

3. Thermal Plasma
Unknown
No
Lab Scale
No
Japan
Tokyo Institute of
Technology


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4. TITLE AND SUBT TLE
Evaluation of Containment and Control Options for
Methyl Bromide in Commodity Treatment
TECHNICAL REPORT DATA
IPlease read iniiructiors on the reverse before comple
1. REPORT MO.
E PA-600/R-94-126
5. REPORT DATE
July 1994
6. PERFORMING ORGANIZATION CODE
7. AUTrtORIS)
Glenn B. DeWolf and Matthew R. Harrison
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME ANO ADDRESS
Radian Corporation
P.O. Box 201088
Austin, Texas 78720-1088
10. PROGRAM ELEMENT NO.
11. CONTRACT/GRANT NO,
68- Dl-0031, Task 54
13. TYPE OF REPORT AND PERIOD COVERED
Task Final; 4~9/93
14. SPONSORING AGENCY CODE
12. SPONSORING AGENCY NAME AND ADDRESS
EPA, Office of Research and Development
Air and Energy Engineering Research Laboratory
Research Triangle Park, NC 27711
is. supplementary notes AEERL project officer is Robert V. Hendriks, Mail Drop 62B,
919/541-3928.
EPA/600/13
16. abstract report gives results of an investigation of means for methyl bromide
(MeBr) recovery, reuse, and destruction to prevent atmospheric emissions if its
limited use were still allowed. (NOTE: MeBr is an ozone-depleting chemical sched-
uled to be phased out by the Clean Air Act by the year 2001. For agricultural com-
modity fumigation, there is no ready substitute for MeBr.) Approximately 4-5 mil-
lion lb/yr (1.8-2.3 million kg/yr) of MeBr is used for commodity/agricultural har-
vest fumigation. Commodity fumigation is carried out extensively at a few locations,
mostly major seaports. Fumigation is conducted in chambers built for holding the
commodity during fumigation and in temporary enclosures, such as under tarpaulins
and in vehicles. The emissions are vented to the atmosphere. Few control systems
exist for MeBr emissions. Likewise, control system research and development has
been limited. Vendors have proposed control technologies for MeBr control, reco-
very, and recycle, but few systems have been built. Conventional vapor control tech
nologies, such as activated carbon adsorption systems, appear to be applicable to
MeBr emissions. These systems must also provide for recovery. Control will pro-
bably be expensive due to the small volumes of recoverable material and the inter-
mittent nature of fumigation operations.
17.
KEY WORDS AND DOCUMENT ANALYSIS
a. DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS
c. COSATi Field/Group
Pollution Fumigation
Containment Activated Carbon
Bromohydrocarbons
Emission Adsorption
Agricultural Products
Bromides
Harvesting
Pollution Control
Stationary Sources
Methyl Bromide
Agricultural Commo-
dities
13 B 06F
14G 11G
07 C
02 D
07B
13. DISTRIBUTION STATEMENT
Release to Public
19. SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
108
20. SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
it

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