Curious what the school of thought is out there regarding Phase I conclusions (REC vs no REC) on a site that is comprised of former farm land, primarily a larger acreage tract that was a candidate for crop dusting (I could be mistaken, but understand DDT products were most commonly applied via crop dusters.) I used to work for a national consulting firm that pretty much wrote this scenerio off by including canned language in the Phase I report that acknowledged former agricultural land use but stated "This firm has no reason to suspect that the former application of pesticides or herbicides was performed contrary to labeling requirements."
I tend to be more conservative now and the proposed land use is also a driver. For smaller tracts that were not subject to crop dusting, I believe the concern of past agricultural use is not as great. However, for larger tracts (greater than serval hundred acres), where crop dusting was a feasible option or was known to occur, would not there be some level of justification for limited soil sampling, espcially if the proposed land use is residential?
We have had discussions with clients on this issue with varying preferences and outcomes. If you have some insight into this situation, I would greatly appreciate a reply!
Hang in there folks, things are bound to pick up soon for us Phase I providers!!!
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DDT's half life varies from 2-15 years.... Do you know when the last application was? Some stuff was used under the table after it was officially banned in 1972...
To be honest.... I've always been a little wary of the 'manufacturer's instructions' thing when it comes to this stuff.
First off, the instructions were usually pretty vague, like "mix with 500-1000 gallons of water, do not put on cabbages." Maybe the guy does that once a week rather than once a month, or maybe he mixes it double-strength and really soaks one area that has some kind of bug eating his potatoes.
Second, it's virtually impossibly to document that they were always used according to the labeling, short of getting the farmer to sign an affidavit, and even then you're taking him at his word. The farmer might also be dead, in which case you'd need a particularly large medium to get an affidavit out of him. You're basically assuming they were used properly because you haven't any info to the contrary.
DDT magically becomes nontoxic because it was applied according to what a sticker on the bottle says?
The big hole in the canned language you cited appears to me to be the client saying "well, what did you do to actually investigate that?"
We usually note the 'manufacturer's instructions' thing and then recommend testing, since the labeling thing is a regulatory or legal issue, and doesn't really affect whether or not there's a dangerous amount of the stuff in the soil-- it only governs what you'd have to do about it and how much trouble you could get in, and only under certain laws.
If you need to get a stormwater or drinking water permit for the site, congrats.... you'll be monitoring for DDT.
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I've noted before that, in Virginia, the DEQ considers residual herbs and pests which are the result of the "proper application of a registered pesticide" a non-issue. DEQ has also indicated that
"The only way that these materials would become regulated would be if they were released from the site (and caused a problem off-site) or if they were managed as a “new” waste. Under certain conditions, lead or arsenic residues may be mobilized from soil piles generated on-site and could cause a problem off-site. Also, if the property owner selectively digs up the contaminated soil (and ends up with lead or arsenic concentrations above the regulatory limits), a new “waste” has been generated and could not be buried on-site or transported to another property to be used as clean fill."
When we encounter a farm, we note this and basically say that, as it sits, potential residual contamination is not a concern, however, if development were to take place which involves disturbance of soils, those soils may become regulated waste. Also, we'll note that if exposure to humans is a concern (if, for example, the farm were going to be subject to an easement and used as a park or something), engineering controls could used to limit exposure, if warranted.
If the farmer has stated that the application was "proper," we'll go on to say that, if those conditions exist, we recommend sampling to determine the presence...
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The California Department of Toxic Substances Control has some helpful background information about different kinds of historical pesticide applications in their soil sampling guidance.
http://www.dtsc.ca.gov/Schools/upload/Ag-Guidance-Rev-3-August-7-2008-2.pdf
We don't call pesticides RECs, but we do recommend sampling.
Patrick
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You may want to watch out for old apple and pear orchards. In the good old days, before modern chemistry, they sprayed lead arsenate from horse drawn wagons. I heard one fellow say they put bags over the horses mouths so the horses would not eat the grass in the orchard while they were spraying. I guess the overspray on the grass was harmful.
The lead issue could be worse than the synthetic organics when it comes to child contact areas although everyone I know that grew up in orchard country thinks otherwise. They remind me it was the purchasing public that wanted maggot free apples and the farmers just did what the market wanted. In any event,........
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Ah good ol' lead arsenate..... Thank you so much, codling moth....
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I agree with Goldbarfellow - Lead a_rsenate was applied as a pesticide at orchards before the use of DDT became prevalent. We have seen very high concentrations of lead and a_rsenic (and dieldrin....) in shallow soils at former orchard properties. Although typically just shallow soils are impacted - it can be over such a large area that it can pose a pretty substantial cost if the property is to undergo development as a residential use (either as a remedy to address risks posed by the levels present; or just for special management considerations of soils requiring removal as a result of routine site grading).
With regard to DDT - I have seen in the literature where application rates for DDT for row crops would be anywhere from 1 to 30 lbs/year per acre - potentially accumulating to levels ranging from 20 to 100 pounds per acre. I have not seen many agricultural sites where the remaining concentrations would be of concern - primarily due to the 1/2-life as noted by Tom above; and perhaps as a function of the limited number of investigations of this type I have been involved with. I haven't evaluated crop dust application vs. other forms of application though.
Sampling of former Orchards that may convert to residential use seems a must - primarily due to the potential for lead arsenate and dieldrin impacts. Land that was formerly used for row crops is perhaps less of concern - but I would still consider it prudent to sample. At least a few States have guidance to this effect (California, Oregon).
Check out the attached to see how perceptions change over time with regard to what is considered acceptable and perfectly safe!
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Ok, why does the CG website not like the word a r s e n a t e?
That poster is hilarious....
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In California, pretty much SOP to sample shallow soils at planned residential developments when there is former ag use. Of course that was back in the day when we were actually building new homes in California :)
Matt
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I typically look for the following as indicators of agicultural use that could adversely affect residential users:
1. nut orchards (selenium and cadmium are common micronutrients, and lead and arsenic usually come along for the ride)
2. greenhouses (mercury and arsenical chemicals)
3. fruit orchards (ditto to greenhouses)
4. cotton (lots of nasty stuff associated with cotton cultivation, because weevils are sturdy critters)
5. uses that required "scorched-earth" herbicide application to remove intrusive species (remember Agent Orange and its dioxin content?)
Other agricultural uses don't usually have so much persistent impact.
I understand that most states regard "properly-applied" agrichemicals as not being RECs. But I remember a farm chemical storage shed becoming a serious dioxin cleanup site on an industrial "greenfield" development, so I tend to be cautious.
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I would classify early to mid-20th century (the "better life through chemistry" age) agricultural application of pesticides/herbicides a REC in the absence of additional information regarding past pesticide types, crop types, application, common historical practices for the area, or other information.
I would virtually guarantee that you'll find some trace concentrations of DDT and its breakdown products (DDE, etc.) on just about any piece of land used for agricultural purposes during the mid-20th century. It's unbelievably persistant and ubiquitous. If you look for it, you'll find it.
Be wary of small air strips in agricultural areas, especially reviewing historical aerial photographs. These are the places where the pesticides were stored, mixed, rinsed, and loaded on to the crop dusters. I can think of at least one location in the Phoenix area where this was a problem. Any place where pesticides were stored, mixed, rinsed, and loaded is a big red flag.
Lead arsenate applied to the orchards of central Washington is a huge issue.
Yakima schoolyard cleanups
Oregon, among other states, has been proactive and has published a guidance on residual pesticides.
Guidance for Evaluation Residual Pesticides on Lands Formerly Used for Agricultural Production
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Thanks for taking the time to comment. I truly appreciated everyone's insight!
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One more thing to add. We have found relatively high levels of pesticides under asphalt paved parking lots. These properties were previously used for row crops or orchards and were developed into commercial. Some paved for 20 years or more. These are flat properties that were likely not graded and the paving essentially prevented breakdown.
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The Oregon guidance posted by Stones has been incredibly helpful!! Anyone who comes across the agricultural land use issue on a large acreage multi-use development project should have a copy of the Oregon guidance. It is has been a valuable document to present to clients who initially tought I was being too conservative. The approach and rationale now sit a bit better with the naysayers after seeing the Oregon guidance. Yes, this can be a real problem and some State governments have spent valuable resources to get a handle on it. Thx again
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Glad you found it helpful.
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Here's a link to information on an orchard site in Waynesville, NC that was a superfund site (I guess this would be worst case scenario). I understand this facility has a very elaborate spray application system for pesticide with underground piping:
http://www.epa.gov/region4/waste/npl/nplnc/barbernc.htm
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I used to work in research and development in the pesticide industry. I have actually collected crops and soil for residiue analysis. You have little fear from the currently registered pesticides, as you can't get a label if the product is persistent. That doesn't mean someone can't create a problem by being stupid. I don't get too worried about row crop frarms that haven't been farmed for a while. An orchard or fields intensively used for agriculture are different. I have sampled a few orchards that were in production the year before we did our assessment and found little to nothing. I have heard of groundwater issues in areas (mid west) that use a lot of atrazine and lasso (alachlor, I think).
You will rarely get to interview a farmer that was around when DDT and aldrin, etc was sprayed. And he probably wouldn't say he did if he did. Another problem is in the old days, chemicals were known by their trade name. DDT- Toxaphene could be called Atomic Six or anything. Small companies could buy tank truck loads of peticides and reformul and repacakge it in 5 to 55 gallon container under their own name.
You seem to focus on "crop dusting" (aerial application). Around here much more is put out with ground rigs. There is not real diference except ground rigs may actually get more on the target. However, airstrips that had an aerial applicator operating from it are prime problem sites. I know of one personally. The pilot used to do our test plots and he had a "dump pond" at hsi parking pad. It's now a state superfund site.
The real problems with farms are the storage, mixing and disposal areas. I've never been on a farm that was inoperation before the 70s that did not have a dump somewhere. Its usually as far as it can be from the house, in an area that can't be used for anything else (ie wetland or swamp) Also look for gullies. They are great places to throw stuff.
In short, I don't get too worked up over row cropped fields where I am. An orchard that is going to be used as a subdivision might warrant furher investigation. Look for dump sites on all farms.
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It is a REC if the land is not going to be continued to be used for the same agricultural purposes. Don't forget, just because something may be considered a REC doesn't mean it requires cleanup - it has the "potential" for concern.
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Dr. DDD....I think the vast majority of EPs would disagree with both of your statements above.
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Can you expand a bit on your disagreement with these statements Matt?
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A) That former agricultural use is automatic REC. In vast majority of cases it is not.
B) That something that is a "potential" concern is a REC. The definition of REC sets much higher bar than "potential" for concern. A 10,000 gallon above ground tank of PCE is a huge "potential" concern. However, it's not a REC.
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Thanks Matt. I interpreted DDD's comment to mean that although a REC may be a potential concern to a property, that a REC unto itself does not mean that cleanup will be required. I didn't interpret the comment to mean that all "potential concerns" with a property would be a REC. I agree with you that all potential concerns are not RECs and I agree with DDD that all RECs do not require cleanup.
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Now that I read it again, I see you're point.
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In response to Dr. DDD, I'm not sure I agree that an REC can be determined based on the proposed land use. I agree that the cleanup of an REC is based on the proposed land use, such as a residential development versus continued agriculture. However, identifying the RECs should be independent of the proposed land use.
Technical side note brought up in other discussion threads - the application of pesticides in accordance with labels is not an REC based on CERCLA regulations, even if it was the historical application of inorganic pesticides, chlorinated herbicides, or organochlorine pesticides. I'd recommend either bringing it to the attention of the client as a BER or "other environmental condition".
Patrick
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Just FWIW, I'm currently doing a cleanup on a mixing area at an orchard. The geometric mean of our pre-excavation arsenic concentrations is about 80 mg/kg.
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Wow, CG still doesn't like the word a r s e n i c....... *rolls eyes
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We found another problem at orchards.....Pentachlorophenol. The PCP was applied to "prop poles" - sticks that hold up fruit laden branches. The farmers would make dip tanks to treat the poles. The dip tank and pole storage areas were impacted.
Farms also treat livestock with bio-cides. Like a "hog-dip" operation, whereby the animal is walked through a trough containing chemicals.
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