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pesti manuf's NESHAP, turf hardiness
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- Subject: pesti manuf's NESHAP, turf hardiness
- From: email@example.com (Tony Tweedale)
- Date: Wed, 26 Nov 1997 12:51:04 -0600
(dioxin-l: the 2nd item concerns ED's)
turf management: there may be a new info nugget in this even for those of
you who already know about this. having recently read a syndicated
newspaper column (a scripps howard gardening writer) on gardening w/ less
pesticides, i'm reminded to share the message of a great MT extension
service talk on same that i attended this summer.
their take home message, "water infrequently (but deep); cut high" is based
on some UNIVERSAL real world observations. constant cropping of the grass
blade makes it put all its energy all the time into blade growing, not root
establishment, which makes the lawn drought & weed resistant. as to
watering seldom, but deep, which also encourages root growth downwards,
with the same hardiness benefits (to weeds, drought).
but the beautiful application of an empirical observation is that
infrequent watering creates a desert in the top 1/3 - 1/2 inch of soil --
where the weed seeds must germinate! with this kind of management &
synnergy, who needs toxic chemicals?
in case the major pesti activist groups aren't up to speed on the CAA, let
me give you a heads up & my 2 cents worth on the recent F.R. notice,
'Proposed Ntl Emission Standard for Haz's Air Pollutants (NESHAP),
Pesticide Active Ingrdient Production' (p. 60,565 - 65,602; Nov. 10th).
HAPs are the 188 non-criteria (non-major) pollutant part of the CAA, kicked
into high gear by the '90 ammndments, industry by industry.
-only herbicide, insecticide & fungicide ai manufacturers are proposed to
-new, unspecified, chemicals have been added to the list for this source
-the basic requirement of the act, that maximally achievable control
technology (MACT) be iinstituted for HAPs, is definded as the best 20% of
surveyed sources in your industry, but in control level was chosen from
only 20 of 78 facilities identified!
-ED: tho there are 22 potential endocrine disruptors among the 188 HAPs,
none are being proposed for control in this source category. --> epa seeks
comment on this. recall that epa has authority to add chemicals to the
list of 188 (or delete, it was originally 189), so maybe ED's, e.g. 2,4-D
can be added (i assume it isn't currently listed).
-"every effort" has been made to keep the rule simple, including making the
same rule apply to the 10 previously ID'd source categories in the
industry, ie making them 1 source category. looks like a red flag to me.
-alternative requirements for facilities "proving" source reduction, but as
usual the verification of reduction is weak.
-->epa requests comment on various compliance issues.
-as per the new compliance monitoring rule, continous emission monitoring
is not required, instead, one surrogate parameter has to be continually
Tony Tweedale (Causality is a concept not subject to empirical
demonstration. -David Hume)