Western Regions Pesticide Meeting

May 2010

Buffer Overlap Limitations

&

Exceptions

2

Overlap Prohibitions

• Buffer zone in effect 48-hours

• To reduce the potential for off-site movement from multiple fumigated fields, buffer zones from multiple…application blocks may not overlap…

3

Overlap Prohibitions

4

Buffer Zone Overlap• Buffer zones may overlap IF

– a minimum of 12 hours have elapsed from the time the first application ends until the second application begins, and

– If there are homes, businesses, or property within 300 feet of each buffer zone, emergency preparedness and response measures have been implemented.

5

Ground Rig ExceptionLarge Treatment Areas

(400 Acres / 4 days / Buffer Based On 100 Acres)

Field 1

100 Acres

10 Hours To Treat

Wait 12 Hours

Field 3

100 Acres

10 Hours To Treat

Wait 12 Hours

Field 2

100 Acres

10 Hours To Treat

Wait 12 Hours

Field 4

100 Acres

10 Hours To Treat

6

Ground Rig ExceptionSplit Fields / Smaller Buffers

(400 Acres / 4 Days / Buffer Based on 33 Acres)

Day 1

33 Acres

3 1/3 Hrs. to Treat

Day 2

Day 1

33 Acres

3 1/3 Hrs. to Treat

Day 2

Day 1

33 Acres

3 1/3Hrs. to Treat

Day 2

Day 3

Day 4

Day 3

Day 4

Day 3

Day 4

Buffer Zone Overlap• Buffer zones may overlap IF

– If all fields use a low release height-solid stream center pivot systems, and

– If there are homes,businesses, or propertywithin 300 feet of each buffer zone, emergency preparedness and response measures have been implemented.

8

Center Pivot Exception To Overlap ProhibitionsLow release height-solid stream systems allowed to treat

simultaneously.

9

Center Pivot Exception To Overlap Prohibitions low release height-solid stream systems

• Buffer based on 30 Acres• Total Fumigation = 4 days

– 72 hours fumigation– Add in 36 hour shut downs– 108 hours total fumigation

…2 mph at start…5 mph during

...maximum wind speed 25 mph.

10

Request For Exception To Overlap Prohibitions For Shank Applications

• Circular Fields• Diagonal But Adjacent Square Fields

– Shank has low emissions and should be encouraged– Large size of fields provides some buffer– Minimal contact between fields– Synchronize equipment to ensure maximum distance

between equipment so emissions are dispersed

• EPA Will Consider in Revised Risk Assessments