Buffer Zones and Credits

1. Buffer Zones and Credits John Leahy, EPAPesticide Re-evaluation Division

2. Buffer Zones • Area around the application block or greenhouse • Bystanders must be excluded during buffer zone period except when in transit • “Buffer zone period” starts when fumigant is firstdelivered to soil and is in effect for 48 hours afterapplication ends • Product labels will display distances in look-up tables based on rate, method and field size • Credits for certain site conditions or applicationpractices that reduce emissions

3. Buffer Zone Updates 2011 • Will Consider New Flux Studies Including: • Temperature studies • Application method studies • Multi-chemical studies • Currently received over 20 new studies, more expected • EPA tarp testing • May result inperformance based standards

4. Transit Through Buffer Zones Vehicular and bicycle traffic on public and private roadways through the buffer zone is permitted. Bus stops or other locations where persons wait for public transit are not permitted within the buffer zone. Pedestrians are not permitted within the buffer zone. 4

5. Roads and Rights-of-Ways Buffers may NOT include roads and rights-of-way UNLESS, The area is not occupied during the buffer zone period Entry by non-handlers is prohibited Applicators comply with all local laws and regulations 5

6. Other Publicly Owned and/or Operated Areas Buffers may NOT include areas such as parks, sidewalks, permanent walking paths, playgrounds, and athletic fields UNLESS, The area is not be occupied during buffer zone period Entry by non-handlers is prohibited Applicators comply with all local laws and regulations AND Written permission to include the public area in the buffer zone is granted by the state/local authorities responsible for management and operation of the area 6

7. Buffer Zone Distances Product labels will display distances in look-up tables based on application rate field size application equipment and methods Buffer zone credits may be applied for certain site conditions or application practices that reduce emissions (e.g., certain tarps) 7

8. Chloropicrin Drip Tarped Buffer Zone Distances

9. Buffer Zone Credits 9

10. Buffer Zone Calculator Being developed by EPA to assist users determine buffer zone distances required by label Optional to use Internet accessible Ability to save, retrieve, edit, and print records No information will be collected by EPA Potential to integrate into EPA’s FMP web-based FMP program 10

11. Buffer Zone Calculator (sample screens) 11

12. Buffer Zone Calculator (sample screens) 12

13. Buffer Zone Calculator (sample screen) • Results: • Date and time of calculation: 3/23/2010 11:53 AM • Product Name: Pic-Brom Preplant Soil Fumigant • EPA Reg No: 8536-9 • Active ingredients in the product that will be applied: • MeBr (50%) and Chloropicrin (50%) • Application Method: Tarped bedded • Application rate: 240 lbs product/acre • Application Block Size: 20 acres • Buffer Zone Credits Applied: Pliant Blockade Tarp (60% reduction) • Total % of reduction with credits: 60% reduction • Minimum buffer zone distance without credits: 323 feet • Minimum buffer zone distance with credits: 130 feet Back Save Save as.. Print 13

14. Buffer Zones Questions and discussion 14

15. Buffer Zones • Extra Slides • Background and additional details

16. Recently Submitted Flux Studies Metam sodium shank and center pivot in WA (WSU) Telone and chloropicrin shank in PNW (Dow) Chloropicrin, 1,3-D, and metam potassium shank in FL (USDA Area-Wide) Chloropicrin, metam sodium and DMDS shank in GA (USDA Area-Wide) Flux Evaluation of a Metam Potassium Application Applied by the Drench Method (AMVAC) 16

17. Recently Submitted Flux Studies (cont) Metam sodium shank in MI (MI Growers) Metam sodium and chloropicrin shank in WI (WI Growers) Metam Sodium for Shank Injection/ Compaction on a Daytime and Nighttime Basis (Metam Alliance) Chloropicrin Bedded Shank in FL (CMTF) 17

18. Recently Submitted Flux Studies (cont) Methyl bromide and chloropicrin in San Joaquin Valley, CA (MBIP) Broadcast shallow tarped under standard HDPE Broadcast shallow tarped under VIF Broadcast shallow tarped under VIF with potassium thiosulfate soil spray Broadcast shallow tarped under VIF with other emissions reduction treatment Deep, tarped strip under VIF 18

19. Expected Flux Studies Methyl Bromide in Plant City, FL (MBIP) Bedded tarp shank injection with VIF Bedded tarp shank injection with VIF traditional emissions reduction treatment Bedded tarp shank injection with metalized film Broadcast shallow tarp under VIF 1,3-D and chloropicrin broadcast shank in a Florida sod production farm (USDA Area-wide) 19

20. EPA Tarp Permeability Testing EPA is testing several tarps determine mass transfer coefficient (MTC) for 1,3-D,MeBr, MeI, MITC, chloropicrin, DMDS, sulfuryl fluoride, and PPO MTC data may result in additional/revised buffer zone credits for 2011 labels Potential basis for development performance based credits (in lieu credits for specific tarp names) with a standard tarp testing protocol 20

21. Tarps Received by EPA AEP, Sun Film High Barrier AEP-One Berry Plastic, EVOH-High Barrier Berry Plastic, EVOH-High Barrier/improved toughness Berry Plastic, EVOH-Supreme Barrier Cadillac VIF - 1.25 mil Cadillac, HDPE Canslit Metallic - 1.25 mil, Black Canslit Metallic - 1.25 mil, White Canslit, Embossed HDPE, 0.6 ml Canslit, Embossed LDPE, 1.25 ml Dow SARANEX A Dow SARANEX B FilmTec VIF - 1.25 mil Ginegar, Ozgard - 1.25 mil Ginegar VIF - 1.25 mil Guardian Olefinas VIF - Black 1.2 mil, Embossed Mid South VIF - 1.25 mil Pliant, Embossed Polyethylene Film Pliant, Blockade Black - 1.25 mil Pliant, Blockade White on Black - 1.25 mil Pliant, Metalized - 1.0 - 1.25 mil Raven TIF “VaporSafeTM” 1 mil with EVOH core Raven TIF “VaporSafeTM” 1.4 mil LDPE with EVOH core 21

22. Expected Tarps Bromostop VIF - 1.30 mil Bruno Rimini IPM Clear VIF 1.38 Klerk Hytibar VIF - 1.30 mil 22

23. Buffers and Agricultural Areas Buffer zones may include agricultural areas owned/operated by someone other than the owner/operator of the application block IF The buffer zone will not overlap with a buffer zone from a nearby fumigation, and The owner/operator provides written agreement that they, their employees, and others will stay out of the buffer zone. 23

24. Buffers and Residential Areas Buffer zones may include residential areas IF The occupants provide written agreement to voluntarily vacate the buffer zone during the entire buffer zone period For applications of methyl bromide products with less than 20 percent chloropicrin, air monitoring inside residential structures is required after the buffer zone period ends 24