Emergency Permit for Blue Diamond Growers to Treat Spent Aluminum Phosphide Pesticide Residues
Summary
SCH Number
2007068175
Public Agency
Department of Toxic Substances Control
Document Title
Emergency Permit for Blue Diamond Growers to Treat Spent Aluminum Phosphide Pesticide Residues
Document Type
NOE - Notice of Exemption
Received
Posted
6/15/2007
Document Description
Blue Diamond Growers (BDG) fumigates its nut products with pesticides containing the active ingredient aluminum phosphide. These products come in the form of small pellets. The fumigation is conducted in enclosed structures such as warehouses, storage bins and silos; these structures are tightly sealed during the fumigation. When the fumigation is complete, the spent pesticide residues are removed from the warehouse, bin or silo.
The spent materials remaining after fumigation are then classified as wastes. The residues are allowed to "dry deactivate", i.e., are allowed to be held in drums while most of the residual phosphine gas is released. When this process is complete, the residuals are then submerged in a solution of water and detergent and allowed to stand, stirring periodically, until no more phosphine gas is being produced. This phase is called "wet deactivation." While the above processes are not inconsistent with the applicable hazardous waste management requirements; clarifications are needed. It is essential that the pesticide residues be managed in compliance with all applicable regulations, as well as the technical guidelines specific to pesticides containing aluminum phosphides.
Contact Information
Name
Jan Smith
Agency Name
Department of Toxic Substances Control
Contact Types
Lead/Public Agency
Phone
Location
Cities
Modesto
Counties
Stanislaus
Notice of Exemption
Exempt Status
Emergency Project
Type, Section or Code
Section 15269(b)(c)
Reasons for Exemption
1. DTSC determined that, for public safety reasons and to minimize exposure of the BDG employees and the public to the hazards posed by the partially-spent waste aluminum phosphide pesticide residues, it is essential that BDG be able to, on an ongoing basis, immediately place these hazardous wastes into the deactivation treatment process. DTSC is only recently aware of the activities at BDG, and is issuing this emergency permit as interim authorization to store and treat these wastes, while a permanent regulatory or statutory means of authorization is identified. Because of the nature of the partially-spent wsate residual, it cannot be shipped to another facility for treatment. The partially-spent residuals continually produce phosphine gas. This gas must be allowed to escape, or the gas pressure may build up to dangerous levels. The MSDS for Phostoxin, one of the widely-used of such products, states: "The phosphine [gas], if it is allowed to concentrate in a confined area, may be toxic and/or flammable." This characteristic makes the waste residuals unsafe to containerize for offsite shipment.
2. The BDG facility is located in a light industrial zone, near Highway 99. The treatment area is in the central area of the facility. The closest non-industrial land use is the miniature golf course complex south of the BDG facility. It is about 600 feet from the treatment area. The closest residential area is northwest of the BDG facility, and is about 1,700 feet from the treatment area. None of these land uses expose users to hazards from the treatment area. The "store" indicated on the facility diagram is a BDG store selling only BDG products.
3. The emergency permit includes control measures in order to ensure that project impacts will be insignificant.
4. Blue Diamond Growers will be allowed to treat or store a maximum of 150 tons of hazardous waste during the three-month term of this permit.
5. The only hazardous waste treatment activities allowed under this permit are dry deactivation and wet deactivation.
Disclaimer: The document was originally posted before CEQAnet had the capability to host attachments for the public. To obtain the original attachments for this document, please contact the lead agency at the contact information listed above. You may also contact the OPR via email at state.clearinghouse@opr.ca.gov or via phone at (916) 445-0613.