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Pesticide Rinse Water Disposal Sites -6- with assuming the waste is hazardous is that insurance costs and permit fees for hazardous waste generators and treaters are prohibitively high for the applicators . The California Department of Health Services (DHS) is evaluating regulatory program modifications that may resolve this problem. B. Some applicators have been able to eliminate the production of rinse water by field rinsing tanks, wiping the exterior of equipment with rags, and disposing of rags at a Class I facility. As long as field rinsing complies with -pesticide application requirements of the appropriate County Agricultural Commissioner, such a management program is acceptable to Regional Board staff. The burning of wipe rags (and bags and plastic bottles used as pesticide containers) at applicator sites is not acceptable unless it is demonstrated that such disposal complies with regulations administered by the. Regional Board and other regulatory agencies. With respect to conclusion 2. , the following observations are made: A. Evaluation of pesticide residues at rinse water disposal sites requires careful selection of sampling sites , proper sample collection and handling, correct choice of analytical procedures, and knowledgeable review of analytical results. It is beyond the ability of most opera- tors to conduct a complete sampling program on their own, and most operators should select a consultant capable of characterizing a disposal site. Whether the evaluation be done by the operator or a consultant, a sampling program should be submitted to Regional Board staff for review prior to implementatibn. The sampling program should explain the rationale behind site selection, detail sample collection methodology, justify the analytical tests selected, and describe a quality control program to evaluate the adequacy of the laboratory work. B. For protection of water quality, those pesticides most likely to migrate should be included in the analytical scheme. The "standard" pesticide scans offered by analytical laboratories are not adequate at many sites. The Pesticide Contamination Prevention Act (Article 15, Chapter 2, Division 7 of the Food and Agricultural Code) was introduced as Assembly Bili (AB) 2021 and approved by the Governor 30 September 1985. The Act requires the State Department of Food and Agriculture to establish criteria to evaluate the potential for a pesticide to impact ground water, and to establish a list of pesticides that have the potential to pollute ground water. Although the list will not be available until December 1987, the information developed under the Act should be considered in selecting analytical schemes at old rinse water disposal sites. ji � l C� A C; - ;-- L_.