1,3-Dichloropropene (Telone) Storage — RUP Soil Fumigant Tank Selection

1,3-Dichloropropene (Telone) Storage — Restricted Use Soil Fumigant Tank Selection for Pre-Plant Nematode Control on Potatoes, Vegetables, Tobacco, Ornamentals, and Tree Crops

1,3-Dichloropropene (1,3-D, CAS 542-75-6) is a halogenated-hydrocarbon pre-plant soil fumigant supplied principally as Telone II (1,3-D alone, 97% ai liquid; Corteva) and Telone C-35 (1,3-D plus chloropicrin, 63% 1,3-D + 35% chloropicrin liquid; Corteva), with related products marketed under InLine, Pic-Clor 60, and other brand names from generic-and-formulator suppliers. Per EPA Soil Fumigant Toolbox documentation, 1,3-D is a Restricted Use Pesticide; use is limited to certified applicators applying through specialized tractor-drawn rigs that inject 1,3-D 12-18 inches beneath the soil surface, with mandatory soil-sealing (compaction, water seal, or tarp) immediately after injection to retain the fumigant in the soil profile during the 7-21 day pre-plant fumigation interval. Telone C-35 (1,3-D + chloropicrin) provides combined nematicide + fungicide + weed-seed-suppression activity and is the preferred formulation for high-value crop fumigation on potatoes, sweet potatoes, ornamentals, and tree-crop replant.

The six sections below cite EPA 1,3-D Soil Fumigant Toolbox; the Telone II and Telone C-35 product labels (Corteva); California Department of Pesticide Regulation (CDPR) 1,3-D Township Cap and Designated Use Area framework; 40 CFR 152 + 156 (registration and labeling); 40 CFR 165 (container disposal); 40 CFR 170 (WPS); 40 CFR 171 (applicator certification); OSHA 29 CFR 1910.1200; and Cole-Parmer + Plastics International compatibility tables.

1. Material Compatibility Matrix

1,3-D is a halogenated organic liquid with substantial solvent activity against natural rubber and many elastomers; the chemistry attacks polyethylene over multi-month exposure and is incompatible with most thermoplastic tank constructions for long-term bulk storage. Commercial 1,3-D bulk-storage uses 304L or 316L stainless steel tanks rather than polyethylene for primary product containment, with HDPE tanks reserved for the secondary-containment sump-and-berm function.

Commercial 1,3-D bulk-storage at the Corteva production-and-distribution facilities and at the field-application operating-fleet staging sites uses 304L stainless steel tanks with PTFE-lined hose, Viton elastomer seals, and PVDF-bodied valves and fittings. HDPE polyethylene tanks are NOT the appropriate primary-storage construction for 1,3-D — the halogenated-solvent permeation issue makes HDPE a multi-month service-life material at best, with progressive product-of-permeation contamination of the polyethylene wall and emission of permeated 1,3-D back into the surrounding atmosphere. HDPE tanks are appropriate for the secondary-containment-pan function around the primary stainless tank.

2. Real-World Use Cases — Pre-Plant Fumigation on Potatoes, Vegetables, Tobacco, Ornamentals, Tree Crops

Potato Pre-Plant Fumigation (Dominant Use). 1,3-D's largest use volume in North America is pre-plant soil fumigation ahead of seed-potato and table-potato planting. Application timing is the fall-after-harvest or spring-before-planting fumigation window with Telone II at 9-18 gallons-per-acre or Telone C-35 at 13-25 gallons-per-acre via shank-injection at 12-18 inch depth, immediately followed by soil-sealing (compaction roller, water seal via center-pivot pre-emergence application, or polyethylene tarp). Fumigation interval is 7-21 days before planting depending on soil temperature and moisture conditions. Idaho, Washington, North Dakota, Wisconsin, Minnesota, Maine, and Colorado seed-and-table-potato producers drive the US 1,3-D potato fumigation volume.

Sweet Potato Pre-Plant Fumigation. North Carolina, Mississippi, Louisiana, and California sweet-potato producers use Telone II at 9-15 gallons-per-acre for pre-plant nematode control (root-knot, reniform). Sweet potato production is highly dependent on soil-fumigation programs to manage cumulative nematode pressure in monoculture rotations.

Vegetable Pre-Plant Fumigation. California Central Valley, Florida, Georgia, North Carolina, and other vegetable-producing-region growers use Telone II and Telone C-35 ahead of strawberry, tomato, pepper, cucurbit, and brassica plantings for nematode + soil-borne-fungus + weed-seed control at 9-25 gallons-per-acre. Strawberry pre-plant fumigation is the highest-value vegetable use of 1,3-D, with Telone C-35 (the chloropicrin-augmented formulation) delivering the broadest pest-spectrum control needed for the high-value strawberry production system.

Tobacco Pre-Plant Fumigation. North Carolina, Kentucky, Tennessee, Virginia, Georgia, and South Carolina tobacco producers use Telone II at 9-15 gallons-per-acre for nematode control ahead of flue-cured and burley tobacco transplanting.

Ornamental and Tree-Crop Replant Fumigation. California, Oregon, Washington, and Florida ornamental-nursery, citrus-replant, stone-fruit-replant, almond-replant, and walnut-replant operations use Telone II and Telone C-35 at 18-30 gallons-per-acre for replant-disease and nematode management ahead of new tree-crop establishment in old orchard sites with cumulative pest-pressure history.

Forest-Nursery Fumigation. US Forest Service and state-forest-nursery operations producing tree seedlings for reforestation use Telone II for pre-plant fumigation of bareroot seedling beds at 13-25 gallons-per-acre.

Aerial vs Ground Application. 1,3-D application is exclusively ground-based via specialized tractor-drawn shank-injection rig. Aerial application of 1,3-D is impossible — the chemistry must be injected into the soil profile and immediately sealed.

California Township Cap. California Department of Pesticide Regulation (CDPR) maintains a 1,3-D Township Cap framework that limits 1,3-D use within each 36-square-mile township to a specified annual maximum (typically 90,250 lb adjusted-pounds per township per calendar year). Designated Use Area buffer requirements limit 1,3-D application proximity to schools and occupied structures.

3. Regulatory Framework — FIFRA RUP, Fumigant Management Plan, WPS, DOT

FIFRA Restricted Use Pesticide. All 1,3-D products registered in the United States are Restricted Use Pesticides per EPA classification. The FIFRA framework at 7 USC 136 with implementing regulations at 40 CFR 152 (registration), 40 CFR 156 (labeling), and 40 CFR 171 (certification of applicators) governs the RUP designation. Per 40 CFR 171, RUP use is limited to certified applicators or persons working under their direct supervision; 1,3-D shank-injection application is performed by certified-applicator operators on the specialized tractor-drawn injection rig.

Fumigant Management Plan. Per the 2008 EPA Soil Fumigant Risk Mitigation Decision and the Telone C-35 product label, soil-fumigant applications using chloropicrin-formulated products require a Fumigant Management Plan (FMP) prepared by the certified-applicator-in-charge before application. The FMP documents site characterization, weather monitoring, application equipment, soil-sealing method, buffer zone establishment, applicator-and-handler-and-bystander notification, and emergency response procedures. The FMP must be on-site during the application and post-application restricted-entry interval. Telone II (1,3-D alone, no chloropicrin) does not require FMP; only the chloropicrin-formulated Telone C-35 and equivalent generic formulations require FMP.

Buffer Zones. The Telone C-35 product label specifies application-rate-and-method-and-block-size-based buffer zones from non-handler bystander areas (residences, schools, occupied structures, hospitals, business sites). Buffer-zone calculations use the EPA Buffer Zone Calculator and follow the FMP-documented site-characterization. Buffer zones range from 25-2,750 feet depending on application rate, application method, block size, soil type, and weather conditions.

Worker Protection Standard. 1,3-D agricultural use triggers WPS at 40 CFR 170 with REI of 5-7 days post-fumigation depending on the specific product label, soil-sealing method, and weather conditions. Handler PPE per the label includes long-sleeved shirt + long pants + chemical-resistant gloves Category A per 40 CFR 170.607 + chemical-resistant footwear + protective eyewear + chemical-resistant apron during product transfer + NIOSH-approved full-face air-purifying respirator with organic-vapor cartridge during product handling and during early-post-application monitoring inspection.

Pesticide Container Disposal. Empty 1,3-D containers (drums, mini-bulks, IBCs, cargo-tanker pump-out residual) follow RUP-specific refillable-container rules at 40 CFR 165.40-65 with return-to-distributor for refillable containers; 1,3-D containers are NOT recycled through ACRC like non-RUP containers. Cargo-tanker bulk-product transfer to the application-rig nurse-tank uses dedicated 1,3-D-trained transfer crew with PPE and emergency-response equipment on-site.

DOT Shipping. 1,3-D ships under UN 2047, Dichloropropenes, Class 3 (flammable liquid), Packing Group II, with subsidiary risk Class 6.1 (toxic). Telone C-35 (1,3-D + chloropicrin) ships under UN 3290 (Toxic Liquid, Inorganic, NOS, Class 6.1, Packing Group II) due to the chloropicrin component.

OSHA Hazard Communication. 1,3-D SDS classifications include H225 (highly flammable liquid and vapor), H301 (toxic if swallowed), H311 (toxic in contact with skin), H315 (skin irritation), H317 (skin sensitization), H319 (eye irritation), H331 (toxic if inhaled), H335 (respiratory irritation), H350 (may cause cancer), H400 + H410 (very toxic to aquatic life with long-lasting effects). The carcinogen classification (H350) drives long-term occupational-exposure controls at the application-rig operator and product-handler positions.

4. Storage System Specification

Tank Sizing for Bulk Distribution. 1,3-D bulk-distribution in North America operates through Corteva's Telone II and Telone C-35 production-and-distribution network with regional warehouses serving custom-applicator and large-grower direct-purchase channels. Bulk-distribution warehouses maintain 5,000-15,000 gallon 304L stainless steel tanks fed from rail-tanker delivery. Mini-bulk-tote distribution to certified custom-applicator operators uses 250-gallon refillable stainless or fluoropolymer-lined IBC totes returned to the regional warehouse on a delivery-and-return cycle.

Tank Sizing for Custom Applicator Field Operations. Custom-applicator field operations cycle 250-gallon refillable mini-bulk totes from the dealer warehouse to the field staging site to the tractor-drawn shank-injection rig nurse-tank; the nurse-tank itself is typically a 250-500 gallon 304L stainless or fluoropolymer-lined-steel tank mounted on the tractor or on a separately-towed trailer. The nurse-tank feeds the application-rig manifold via PTFE-lined hose and PVDF-bodied flow-control hardware with Viton seals.

Stainless-Steel Primary, HDPE Secondary. The standard 1,3-D bulk-storage configuration is a 304L stainless-steel primary tank for product containment placed in an HDPE secondary-containment pan or curbed concrete berm sized at 110% of the primary tank capacity. The HDPE secondary pan provides leak-detection, spill-containment, and rainwater-management functions without primary-product-contact compatibility constraints — HDPE is appropriate for secondary containment because primary-product contact is intermittent and short-duration in a leak-or-spill event rather than continuous storage exposure.

Tank Venting and Vapor Capture. 1,3-D vapor pressure (28 mm Hg at 25°C) is high enough that bulk-storage tank venting requires controlled-emission management. Activated-carbon vapor-capture filters on tank vents reduce 1,3-D atmospheric emission during product transfer and during diurnal-temperature breathing cycles.

UV Stabilization. 1,3-D in 304L stainless storage is UV-protected by the opaque tank shell. The HDPE secondary-containment pan should specify carbon-black-pigmented resin for outdoor multi-year UV durability.

Temperature Control. 1,3-D tolerates 32-100°F without product degradation. Above 100°F sustained exposure, vapor pressure increases and tank-venting emissions increase; bulk-distribution warehouses provide shaded outdoor or climate-controlled indoor storage in southern-state warehouse locations.

Site Security. 1,3-D bulk-storage sites require enhanced site security per RUP best-management-practice and many state pesticide-bulk-storage rules: locked-and-fenced perimeter, signed access-restricted zone, and secure documentation of certified-applicator-only access to the bulk-fill and product-transfer points. Verify the controlling state pesticide-bulk regulation for site-security specifics.

5. Field Handling — Shank-Injection Rigs, Soil Sealing, FMP Buffer, PPE, Spill Response

Shank-Injection Application Equipment. 1,3-D application uses specialized tractor-drawn shank-injection rigs (manufactured by Yetter, Lilliston, custom-fabrication shops) with 6-12 ft swath width, 12-18 inch shank-injection depth, and integrated soil-sealing equipment (compaction roller behind the shank, water-seal manifold for center-pivot sealing, or tarp-laying-and-anchoring frame for tarped fumigation). Application speed is typically 3-5 mph with 9-25 gallon-per-acre product injection rate metered by PVDF-bodied positive-displacement pump from the nurse-tank to the shank manifold.

Soil-Sealing Methods. Three soil-sealing methods are commonly used: (1) immediate post-injection compaction roller for fall fumigation in adequate-moisture conditions, (2) water seal via center-pivot or solid-set sprinkler immediately post-application providing 0.25-0.5 inch water-application to seal the soil profile, or (3) polyethylene-tarp-laying behind the application rig for tarped fumigation in high-value crop replant or vegetable pre-plant operations. Tarped fumigation provides the longest in-soil retention time and is the highest-pest-control efficacy method.

Pump Selection. Positive-displacement metering pumps with 316L stainless and PVDF wetted parts and PTFE diaphragms cover 1,3-D nurse-tank-to-application-rig metering. Centrifugal pumps are NOT used for 1,3-D transfer due to the vapor-emission and product-loss concerns at centrifugal-seal interfaces.

Valve Specification. PVDF-bodied or stainless-steel ball valves with Viton seats cover the standard 1,3-D-service valve population. Bottom outlet on bulk tanks specifies 2-inch full-port ball with PVDF body, Viton seat, and stainless trim.

Gasket Material. Viton (FKM) is the standard 1,3-D-service gasket. EPDM, Buna-N, Neoprene, and natural rubber are NOT acceptable for 1,3-D contact service.

PPE per WPS. 1,3-D handler PPE per the label includes: long-sleeved shirt + long pants + chemical-resistant gloves Category A per 40 CFR 170.607 + chemical-resistant footwear + protective eyewear + chemical-resistant apron during product transfer + NIOSH-approved full-face air-purifying respirator with organic-vapor cartridge during product handling and during early-post-application monitoring inspection.

Spill Response. 1,3-D spills require dedicated emergency-response equipment per the FMP: vapor-suppression foam, PTFE-lined absorbent material, and 304L stainless or PTFE-lined recovery containers. Spills above the 100-lb CERCLA reportable quantity (40 CFR 302.4) require National Response Center notification within 24 hours. State pesticide-spill-reporting rules typically tighten this to any spill above 5-gallon thresholds. The flammable-liquid hazard class adds fire-prevention controls (no smoking, no open-flame, electrostatic-grounding for product transfer).

Container Triple-Rinse and Refillable-Container Return. 1,3-D mini-bulk and IBC totes are NOT triple-rinsed in the field; rather, they are emptied to the application-rig nurse-tank with residual product captured during the metering operation, and the empty container is returned to the distributor warehouse for inspection-and-refill cycle per 40 CFR 165.40-65 refillable-container rules.

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