Last Load of the Day: Rinsate, a Pond, and a Wellhead

Rank by consequence, not by convenience.

1. The rinsate dumped near the pond. That is a point-source discharge toward waters of the state, and a 1-inch rain will carry whatever is left. Stop any further dumping immediately. Under the label, rinsate goes into the spray tank and out through the nozzle on a labeled site at a labeled rate - not on the ground.
2. The uncapped, unrinsed jugs in the truck bed. An open container, uncapped, in an open truck bed with rain coming, is a spill waiting to happen on a public road. Rinse them properly (triple rinse or pressure rinse, with the rinse water going into the tank), cap them, and store them so they cannot tip or leak. Save them for a container-recycling collection - check with the state agriculture department about collection events rather than putting them in the farm dumpster.
3. The 40 gallons left in the tank. Options: apply it to a field that is on the label, at the labeled rate, respecting the seasonal maximum - or return it to a legal mixing/loading area. Never dump it, never leave it in the tank overnight with the valve cracked.
4. The nurse tank on the trailer. Valves closed, caps on, tank secured against shifting, no leaks, and a spill kit in the truck. Forty miles of highway is where a small drip becomes a roadside spill and a phone call.
5. The mixing/loading site itself. The nurse tank parked 60 feet from a pond is a chronic risk, not a one-time one. That is where the next spill will happen.

The judgment: all five items take about 30 minutes and none of them is optional. The "we're tired" pressure is exactly how point-source contamination happens.

The current storage arrangement is not acceptable, and the wellhead is the reason.

Problems, in order of how badly they can go wrong:

• Pesticides stored around a wellhead put a spill directly into the water supply with no soil or distance to buffer it. Storage must be sited away from wells and surface water, and any well inside or beside a chemical storage area should be treated as a violation waiting for a spill.
• Feed and seed in the same space creates both a contamination route (product on bags, dust on feed) and a regulatory one - pesticide storage is not a feed-storage room.
• No containment: with no liquid-tight floor or secondary containment, a tipped jug becomes a floor-wide puddle that follows the slope, which is usually toward the door and then the yard.

Plan to propose:

• Move the chemicals to a dedicated, lockable, ventilated structure or cabinet with a liquid-tight floor and containment capacity for the largest container, sited away from the well, downhill draining away from it, and with a posted sign.
• Nothing in storage but pesticides and application equipment: no feed, no seed, no food, no PPE stored in a way that gets contaminated.
• Keep an inventory list, keep everything in original labeled containers, and keep absorbent material and a shovel on hand.

What to tell the owner: a short, factual explanation of the water-supply risk, a specific alternative location, and a date. Offer to help move it. Framed as protecting his well and his livestock water, not as a lecture, it usually gets done.

Before the truck moves:

• Secure the load. Nurse tank valve closed and capped, tank strapped so it cannot shift or roll, nothing unsecured in the bed - an uncapped jug bouncing out at 55 mph is a spill with your name on it.
• Check for leaks and drips at every fitting before departure, not at the first stop sign. Carry a spill kit: absorbent, a shovel, bags, and a way to notify.
• No food, feed, or seed in the same compartment as the pesticide. Not in the cab, not in the bed.
• Know your paperwork and placarding obligations before you leave. Whether shipping papers and placards are required depends on the specific product, its hazard class, and the quantity being moved; a partially loaded nurse tank is not automatically exempt. Verify against the product's shipping description and the current DOT rules rather than assuming, and remember that a farm vehicle exemption does not cover an off-farm commercial applicator hauling product down a public highway.
• Driver fitness: it has been a long, hot day. If the driver is not fit, the truck stays.

If something goes wrong on the road: stop, keep people away, contain the spill with absorbent, keep it out of ditches and storm drains, and notify the appropriate authorities per the product's emergency instructions on the label and SDS. Then document everything - time, location, quantity, what was done - because the first written record is the one that governs how the incident is handled.