1. Western Regions Pesticide Meeting May 2010 Buffer Overlap Limitations & Exceptions

2. 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. 3 Overlap Prohibitions

4. 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. 5 Ground Rig Exception Large 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. 6 Ground Rig Exception Split 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

7. 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 property within 300 feet of each buffer zone, emergency preparedness and response measures have been implemented.

8. 8 Center Pivot Exception To Overlap Prohibitions Low release height-solid stream systems allowed to treat simultaneously.

9. 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. 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