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J , <br /> Pesticide Rinse Water Disposal Sites -5- <br /> 1. The example designated waste levels were exceeded for at least one pesti- <br /> cide at most of the sites investigated. Further testing may be required to <br /> determine the specific site factors and to determine if there is a threat <br /> to water quality and if remedial measures are necessary. <br /> 2. At two sites, some pesticides that were not detected in soil samples from <br /> 0-6" were present at low levels in the 18-24" samples. In particular, at <br /> site #6 diuron, atrazine, and cyanazine were so detected, and at site #11 <br /> dimethoate was so detected. Both diuron and atrazine have been detected in <br /> ground water in California. Also, at site# 6 diuron, monuron, methomyl , <br /> and 2,4,5 TP were found in a well water sample but were not detected in the <br /> waste disposal site soils. These findings indicate that for a few pesti- <br /> cides the example attenuation factor of 100 fold utilized in Dr. Marshack's <br /> report may be too high and more stringent disposal requirements may be <br /> necessary to prevent pesticide movement to ground .water. <br /> CONCLUSIONS <br /> At the majority of pesticide applicator sites investigated, past pesticide rinse <br /> water disposal has not resulted in any apparent significant threat to water <br /> quality. However, at some agricultural applicator sites where rinse water was <br /> discharged to land, pesticide residues were found at levels exceeding the <br /> criteria for hazardous waste ( i . e. , DDT levels greater than 1 ppm) and/or at <br /> levels that may require management as a 'designated' waste. At two sites ground <br /> water is impacted. Consequently, because some rinse water disposal sites do pose <br /> a potential threat to water quality, staff have formed two conclusions: <br /> 1. Pesticide rinse water that is 'hazardous ''"or 'designated waste' must not <br /> be discharged to land except at sites that comply with Titles 22 and 23 of <br /> the CAC. It is the discharger's responsibility to determine if the waste <br /> (including exterior rinse water) is 'hazardous' or 'designated waste' . Most <br /> applicators have not classified their rinse water. <br /> 2. At sites where rinse water disposal has occurred, the site operator and/or <br /> owner should be required to determine the levels of pesticide residues and <br /> the distribution of any pesticides that pose a •threat to water quality. <br /> (Other agencies may have concerns for other portions of the environment. ) <br /> With respect to conclusion 1. , the following observations are made: <br /> A. Due to the expense and difficulty of continually testing rinse water, a <br /> 'discharger may elect to manage his waste at the rnost restrictive level <br /> that could apply. In California this means managing rinse water as <br /> ' hazardous waste' . Most coninercial pesticide applicators contacted by <br /> staff .have indicated that the most viable method for managing rinse <br /> crater as hazardous appears to be discharge to above-ground tanks and <br /> subsequent reuse, treatment, or disposal at a Class I facility (new <br /> laws will prohibit such disposal in the near future) . A major problem <br />