## FMC Corporation

Agricultural Products Group

1735 Market Street

Philadelphia Pennsylvania 19103

215 299 6000

HAND DELIVERED

August 23, 2005

Public Information and Records Integrity Branch (PIRIB)

Office of Pesticide Programs (OPP)

Environmental Protection Agency

Crystal mall #2, Rm. 119

1801 S. Bell Street

Arlington, VA 22202

Attention: Docket ID Number OPP-2005-0162

Dear Sir/Madam:

Subject: Reregistration Eligibility Science Chapter For Carbofuran

Environmental Fate and Effects Chapter -- Environmental Risk Assessment

and Human Drinking Water Exposure Assessment

FMC Phase 3 Response Comments

FMC Corporation, Agricultural Products Group, under cover of this
letter, is submitting response comments to OPP-2005-0162, the U.S. EPA's
June 3, 2005 Environmental Fate and Effects Reregistration Eligibility
Science Chapter for carbofuran.

The following documents, in both printed (two copies) and electronic
(CD) form are enclosed herewith:

1\) FMC Response to: Docket ID No. OPP-2005-0162, JUNE 3, 2005 PHASE 3

REREGISTRATION ELIGIBILITY SCIENCE CHAPTER FOR Carbofuran

ENVIRONMENTAL FATE AND EFFECTS CHAPTER, Environmental Risk

Assessment and Human Drinking Water Assessment. (one CD).

2\) FMC Appendix A, Review Of Avian Risk Assessment In "Registration
Eligibility

Science Chapter For Carbofuran: Environmental Fate And Effects Chapter"
(June

3, 2005), Report date: August 16, 2005 (one CD).

3\) FMC Appendix B, Avian Modified Probabilistic Ecological Risk
Analysis for

Carbofuran, Report date: August 16, 2005 (one CD, multiple documents).

Public Information and Records Integrity Branch (PIRIB)

Office of Pesticide Programs (OPP)

Environmental Protection Agency

Attention: Docket ID Number OPP-2005-0162

August 23, 2005

Page 2

4\) FMC Appendix C, Toxicity and Risk of Carbofuran to Terrestrial
Vertebrates,

Report date: August 19, 2005 (one CD).

5\) FMC Appendix D, Review of Aquatic Risk Assessment in "Reregistration

> Eligibility Science Chapter for Carbofuran: Environmental Fate and
> Effects Chapter" (June 3, 2005), Report date: August 15, 2005 (one
> CD).

6\) FMC Appendix E, Toxicity and Potential Risk of Carbofuran to Aquatic

Organisms, Report date: August 18, 2005 (one CD).

7\) FMC Appendix F, Probabilistic Surface Water Exposure Assessment of
Carbofuran

> in Illinois for Corn, Report date: August 19, 2005 (one CD, multiple
> documents) (NOTE: PDF contains text and graphics, electronic Word
> Version contains only text).

8\) FMC Appendix G, Watershed Regressions For Pesticides (WARP) Model

> Estimates For Carbofuran In Illinois Watersheds, Report date: August
> 15, 2005 (Three CD's, one with report, with no CBI, second CD labeled
> CBI, third CD entitled Project Title: WARP Estimates for Carbofuran
> for Illinois Watersheds Geodatabase, Report date: August 11, 2005.

9\) FMC Appendix H, Evaluation of NAWQA Surface water and Groundwater

Monitoring Data for Carbofuran, Report date: August 18, 2005 (one CD)

10\) FMC Appendix I, Probabilistic Leaching Exposure Assessment of
Carbofuran in

Four Corn Growing States, Report date: August 18, 2005 (one CD multiple

Documents) (NOTE: PDF contains text and graphics, electronic Word
Version

contains only text).

11\) FMC Appendix J, Avian Monitoring Study on Curaterr GR5 in the
Netherlands,

Report date: July 2, 1996 (one CD).

12\) FMC Appendix K, Assessment of House Sparrow (*passer domesticus*)

> Consumption of Curaterr GR5 Granules Present on Soil Surface Following
> Simulated Application and Incorporation in a Laboratory Experiment,
> Report date: August 5, 2004 (one CD).

13\) FMC Appendix L, Furadan 5G Refined Avian Mammalian Risk Evaluation
for

Applications in Maize and Sugar beet, Report date: May 2, 2005 (one CD).

Public Information and Records Integrity Branch (PIRIB)

Office of Pesticide Programs (OPP)

Environmental Protection Agency

Attention: Docket ID Number OPP-2005-0162

August 23, 2005

Page 3

EPA's Phase 3 Environmental Fate and Effects Chapter for carbofuran
contained a Human Drinking Water Exposure Assessment. Subsequent to our
receipt of this chapter EPA provided FMC a Phase 1 HED document (dated
June 29, 2005, received by FMC on June 30, 2005) entitled "Carbofuran:
HED Revised Preliminary Risk Assessment for the Reregistration
Eligibility Decision (RED) Document, June 20, 2005. This HED document,
and one of the specific enclosures (Carbofuran Drinking Water Estimated
Concentrations, D. Young, 1/27/05), contain additional EPA carbofuran
assessment information relative to ground and surface water. Because
both the EFED and HED science chapters contain inputs relative to ground
and surface water, FMC is respectfully advising the Agency of our
reserving the prerogative to provide additional ground and surface water
comments at the time of our Phase 3 HED submission. Should those
comments have any implications specific to ecological risk assessments
we will, for the convenience of the Agency reviewers, supply those in a
separate EFED addendum response.

Should the Agency have any questions relative to the items submitted
herewith please contact me (215-299-6436 or
[don_Carlson@fmc.com](mailto:don_Carlson!@fmc.com)).

Sincerely,

Don Carlson, PhD

Registrations Manager

cc: S. Plummer, SRRD,