**UNITED STATES ENVIRONMENTAL PROTECTION AGENCY**

WASHINGTON, D.C. 20460

![](media/image1.png){width="0.78125in" height="0.78125in"}

+-------------------------------------------+--------------------------+
|                                           | OFFICE OF                |
|                                           |                          |
|                                           | PREVENTION, PESTICIDES   |
|                                           | AND TOXIC SUBSTANCES     |
+-------------------------------------------+--------------------------+

Date: February 03, 2006

Chemical: ADBAC/DDAC

PC Codes: 069105/069149

Barcode: D322872/D325481

[MEMORANDUM]{.underline}

SUBJECT: Ecological Risk Assessment in Support of the Antimicrobials
Division's Reregistration of ADBAC and DDAC

FROM: Brian D. Kiernan, Biologist

Marietta Echeverria, Environmental Scientist

Environmental Risk Branch IV

Environmental Fate and Effects Division (7507C)

THRU: Elizabeth Behl, Branch Chief

Environmental Risk Branch IV

Environmental Fate and Effects Division (7507C)

TO: Jacqueline Campbell-McFarlane

Tracy Lantz

Chemical Review Managers

Antimicrobials Division (7510)

[]{.mark}

**Risk Assessment Summary and Conclusions**

The Environmental Fate and Effects Division has completed its ecological
risk assessment for the outdoor uses of ADBAC and DDAC in support of the
Antimicrobials Division Reregistration Eligibility Decision (RED) for
these chemicals. DDAC is an active ingredient in only one of the
formulations assessed, and it does not appear to pose high risk to
wildlife when used according to the label. Several ADBAC uses pose acute
and chronic risk to aquatic and terrestrial wildlife. Risk to
terrestrial and aquatic plants cannot be evaluated due to a lack of
data, but risk is presumed. Based on this screening-level assessment,
risk to Federally listed species also cannot be precluded. Further work
is necessary to develop a refined risk assessment evaluating endangered
species. Although primarily used as antimicrobial agents, uses which are
not assessed in this document, outdoor applications of ADBAC and DDAC
included in this assessment were ornamental nurseries, residential and
commercial turf, mosquito larvicide and algacide in ornamental pools and
puddles.

Data gaps identified include chronic toxicity studies of
estuarine/marine fish and invertebrates, as well as avian wildlife. The
toxicity of ADBAC to terrestrial and aquatic nontarget plants is not
assessed either, due to lack of data.

#  {#section .unnumbered}

#  {#section-1 .unnumbered}

# 1 Problem Formulation {#problem-formulation .unnumbered}

## Stressor Source and Distribution

The Environmental Fate and Effects Division (EFED) has evaluated the
outdoor uses of the quaternary ammonium compounds being considered for
reregistration by the Antimicrobial Division (AD). The compounds being
considered are alkyl dimethyl benzyl ammonium chlorides (ADBAC) and
didecyl ammonium chlorides (DDAC). ADBAC and DDAC are used primarily as
disinfectants, sanitizers, and microbiocides/microbiostats. They are
also used as algaecides, bacteriocides/bacteriostats,
fungicides/fungistats, insecticides, miticides, virucides, and feeding
suppressants. Use sites for ADBAC and DDAC include agricultural premises
and equipment, food handling equipment, commercial, industrial and
institutional settings, residential areas or areas of public access,
pets and kennels, medical facilities, swimming pools, aquatic areas, and
industrial water systems. Although primarily used as antimicrobial
agents for these diverse uses, several labeled outdoor uses are being
assessed by EFED because of the potential for environmental exposures
and ecological effects. Specifically, ADBAC uses include ornamental
plants and shrubs in nurseries, residential lawns and commercial turf
(not sod farms) and golf course greens, tees and fairways. Both ADBAC
and DDAC are labeled for use in puddles and decorative pools to control
algae. ADBAC is also labeled for use as mosquito larvicide in standing
waters, including decorative ponds and pools, inactive spas and hot
tubs, as well as 'old tires, empty tin cans, puddles and water drains
around buildings' (RD 20 label). Only the ADBAC and DDAC uses that
appear likely to result in environmental exposures and effects are being
evaluated in this assessment (Table 1.1).

Table 1.1. ADBAC and DDAC products and uses being evaluated.

  ----------- ----------- --------- --------- ----------------------------
  **Class**   **Trade     **Reg.    **% ai**  **Agricultural/Outdoor
              Name**      \#**                Uses**

  DDAC        TC 192      499-482   12        Decorative ponds, pools,
                                              puddles

  ADBAC       TC 192      499-482   8         Decorative ponds, pools,
                                              puddles

  ADBAC       Consan      58044-3   20        Nursery/ornamentals

                                              Turf, golf courses

  ADBAC       RD 20       53642-1   20        Decorative ponds, pools,
                                              puddles

                                              Nursery/ornamentals,

                                              Turf, golf courses,

                                              Mosquito control

  ADBAC       Timsen      507-3     40        Nursery/ornamentals

  ADBAC       PT 2000     499-368   20        Decorative ponds, pools,
                                              puddles
  ----------- ----------- --------- --------- ----------------------------

## Receptors 

Ecological effect endpoints are derived from registrant-submitted
guideline studies as required for registration under the Federal
Insecticide, Fungicide and Rodenticide Act (FIFRA; 40 CFR Part 158), as
well as a review of acceptable open literature (ECOTOX), when available.
The most sensitive endpoints (described below) from each study of
surrogate species are used to estimate risk to the taxonomic group(s)
represented by the surrogate tested. Toxicity testing reported in this
document represents all terrestrial and aquatic organisms. However, only
a few surrogate species for both freshwater fish and birds are used to
represent all freshwater fish (2000+) and bird (680+) species in the
United States. In addition, neither reptiles nor amphibians are tested.
Birds are used as surrogates for reptiles and terrestrial-phase
amphibians; fish are used as surrogates for aquatic-phase amphibians.
The Norway rat is typically the surrogate for all mammal species.

## Identification of Assessment Endpoints

Assessment endpoints are defined, per Agency guidelines, as "explicit
expressions of the actual environmental value that is to be protected"
which are "operationally defined by an ecological entity and its
attributes" (USEPA, 2004). The ecological entity can be a species, a
functional group of species, a community, an ecosystem, or another
entity of importance or concern. An attribute is the characteristic of
the entity that is important to protect and is potentially at risk.

Defining an assessment endpoint involves two steps: 1) identifying the
valued attributes of the environment that are considered to be at risk,
and 2) operationally defining the assessment endpoint in terms of an
ecological entity (*e.g.*, a community of fish and aquatic
invertebrates) and its attributes (*i.e*., survival and reproduction).
Therefore, selection of the assessment endpoints is based on valued
entities (*i.e.*, ecological receptors), the ecosystems potentially at
risk and the routes by which ecological receptors are exposed to
pesticide-related contamination. The selection of clearly defined
assessment endpoints is important because they provide direction and
boundaries in the risk assessment for addressing risk management issues
of concern.

Typical assessment endpoints for screening-level pesticide ecological
risk assessments include reduced survival and/or reproductive impairment
for both aquatic and terrestrial animal species from direct acute or
direct chronic exposures. Aquatic animal groups that are typically
characterized in the risk assessment include: freshwater fish and
invertebrates, estuarine/marine fish and invertebrates. Terrestrial
animal groups include birds, mammals, and beneficial insects. All
assessment endpoints are characterized at the individual level in order
to protect threatened and endangered species. However, risks to higher
biological levels (*i.e.*, populations and communities) can be inferred
from this approach (*e.g.*, pesticide effects on individual survival and
fecundity may impact both population stability, growth, and habitat
carrying capacity). Indirect effects to listed species and critical
habitat must also be characterized in a species-specific assessment
conducted after the screening-level risk assessment is completed.

For terrestrial and semi-aquatic plants, the screening assessment
endpoint is the perpetuation of populations of non-target species (crops
and non-crop plant species). Existing testing requirements only evaluate
emergence of seedlings and vegetative vigor of annuals. Although it is
recognized that the endpoints of seedling emergence and vegetative vigor
may not address all terrestrial and semi-aquatic plant life cycle
components, it is assumed that impacts on plant emergence and/or on
active growth have the potential to impact individual competitive
ability and reproductive success, from which population effects can be
inferred.

For aquatic plants, the assessment endpoint is the maintenance and
growth of standing crop or biomass. Measurement endpoints for this
assessment endpoint focus on algal and vascular plant (*i.e.*, duckweed)
growth rates and biomass measurements.

The ecological relevance of the assessment endpoints assumes that
complete exposure pathways exist for these receptors, that the receptors
may be sensitive to pesticides in affected media and/or forage items and
that the receptors could potentially inhabit areas where pesticides are
applied, or areas where runoff and/or spray drift may impact the sites
because suitable habitat is available.

Ecological measurement endpoints for this screening-level risk
assessment are based on a suite of registrant-submitted toxicity studies
performed on a limited number of organisms, supplemented by the open
literature where applicable, in the following broad groupings:

1.  Birds (bobwhite quail), also used as surrogate species for
    terrestrial-phase amphibians and reptiles,

2.  Mammals (laboratory rat),

3.  Freshwater Fish (bluegill sunfish, rainbow trout and fathead
    minnow), also used as a surrogate for aquatic-phase amphibians,

4.  Freshwater invertebrates (*Daphnia magna*),

5.  Estuarine/marine fish (sheepshead minnow, inland silverside),

6.  Estuarine/marine invertebrates (*Mysidopsis bahia*, Eastern oyster),

7.  Terrestrial plants (no data available)

8.  Algae and aquatic plants (no data available).

Within each of these very broad taxonomic groups, an acute and chronic
endpoint is selected from the available test data. The selection is made
from the most sensitive species tested within a particular surrogate
group. If additional toxicity data are available from other sources, the
selection of an endpoint may not be limited to the surrogate species
listed above, but may be expanded to include those data for other groups
or species which has been deemed of sufficient quality by OPP scientists
for use in the risk assessment.

## Conceptual Model 

In order for a chemical to pose an ecological risk, it must reach
ecological receptors in biologically significant concentrations.
Exposure pathways are defined as the means by which a contaminant moves
in the environment from a source to an ecological receptor. For an
ecological exposure pathway to be complete, it must have a source, an
environmental transport medium, a point of exposure for ecological
receptors, and a feasible route of exposure.

Ecological receptors that may potentially be exposed to ADBAC include
terrestrial and semiaquatic wildlife (*i.e.*, mammals, birds, amphibians
and reptiles), terrestrial and semi-aquatic plants, and terrestrial soil
and aquatic sediment invertebrates. Additionally, aquatic organisms
(*i.e.*, freshwater and estuarine/marine fish and invertebrates,
amphibians, and aquatic plants) are potential receptors in adjacent
water bodies through the off-site transport of ADBAC from the
application site through runoff, erosion and spray drift. The primary
route of wildlife exposure to DDAC appears to be through drinking
treated water, though amphibians may be at risk from these applications.

### *Risk Hypothesis* 

At maximum application rates for the previously described uses exposure
of terrestrial, aquatic and semi-aquatic wildlife and plants to ADBAC
and/or DDAC may be sufficiently high to result in direct effects (i.e.,
mortality due to acute exposure or impaired reproduction, growth, or
survival from chronic exposure). Additionally, endangered and threatened
species may be indirectly affected by ADBAC and/or DDAC due to a loss of
food resources and/or changes to critical habitat resulting from
proposed uses.

## Analysis Plan 

This screening level ecological risk assessment characterizes the
environmental fate and transport of ADBAC to assess the extent to which
non-target organisms may be exposed through the current proposed uses of
these pesticides. EFED relied on AD's evaluation of the environmental
fate and transport of ADBAC and DDAC, which can be found in the AD RED
document. The toxicity of ADBAC is also characterized, based primarily
on registrant-submitted guideline toxicity tests and additional
information from open literature available through the Agency's ECOTOX
database (<http://www.epa.gov/ecotox/>), and evaluated by AD scientists.
Estimated exposure and effects are integrated to calculate risk
quotients (RQs) for non-target Federally listed endangered/threatened
and other non-target animals and plants. RQs are compared to
pre-determined levels-of-concern (LOCs) to screen out those taxa to
which ADBAC is not likely to pose unacceptable risk. Because of the
limited use and low expected exposure of wildlife to DDAC, as detailed
later in this document, ADBAC is primarily considered in this document.

Although risk, in the context intended here, is often defined as the
likelihood and magnitude of adverse ecological effects, the risk
quotient-based approach does not provide a quantitative estimate of
likelihood and/or magnitude of adverse effects. Such estimates may be
possible through a more refined, probabilistic assessment. However, this
is beyond the scope of this screening-level assessment.

**1.6 Routes of Exposure**

Routes of exposure to terrestrial and aquatic organisms can occur from
direct deposition, spray drift and/or runoff. Exposure may be through
ingestion of contaminated food or water sources, dermal contact or
absorption, and inhalation. The Agency assumes terrestrial organisms are
present and feeding on the use site. All routes of aquatic exposure are
assumed to be accounted for.

This assessment does not take into account atmospheric transport in
estimating environmental concentrations, nor does it account for
ingestion of ADBAC or DDAC residues by animals in contaminated grit,
ingestion through preening activities, or uptake through inhalation or
dermal absorption by terrestrial animals. Exposure to terrestrial
animals is based primarily on dietary consumption of foliar residues
and, in this case, drinking water. Aquatic assessments assume that all
potential routes of direct exposure are accounted for. While ADBAC and
DDAC are registered for use in greenhouses, this use is typically
conducted indoors and, thus, exposure to non-target animals is limited
and is therefore not considered in this assessment.

# Analysis

## Use Characterization

ADBAC and DDAC are used primarily as antimicrobial agents; evaluation of
these uses can be found in the Antimicrobials Division risk assessment
in support of the reregistration eligibility decision (RED) for these
compounds. Additionally, ADBAC is used on ornamental plants and shrubs,
residential lawns and commercial turf and golf course greens, tees and
fairways. Both ADBAC and DDAC are labeled for use in puddles and
decorative pools to control algae. ADBAC is also labeled for use as
mosquito larvicide in standing waters, including decorative ponds and
pools, inactive spas and hot tubs, as well as 'old tires, empty tin
cans, puddles and water drains around buildings' (RD20^®^ label). Only
the ADBAC/DDAC uses which could result in potential environmental
exposures and effects are being evaluated in this assessment. These uses
are described below.

*Puddles, Ornamental Ponds and Pools*

Three products are labeled for the control of algae in puddles and
ornamental ponds and pools, RD20^®^, TC192^®^ and PT2000^®^. All three
products contain ADBAC; TC192 also contains DDAC (the only DDAC use
considered in this assessment). These uses are labeled for direct
application to water with a target maximum concentration of 5 ppm for
the first application. Subsequent applications can be made weekly at
concentrations of 2.5 ppm. There are no label limits on the number of
applications that can be made in a year. These applications can be a
source of exposure to terrestrial wildlife making use of the water for
drinking or bathing, as well as amphibians making use of these
waterbodies for all or part of their lifecycle. Because the product is
applied directly into the water, exposure via forage items is not
expected (emergent vegetation is assumed not to be present). The labels
specifically state that application should not be made where fish are
present; therefore exposure to fish is not expected when used in
accordance with the label. However, because there is no explicit
prohibition on the labels, exposure to amphibians is possible,
especially during the aquatic phase. Because of the persistence of ADBAC
and DDAC, the weekly maintenance applications could, at least in some
instances, result in increased concentrations throughout the year,
leading to the potential for exposure at concentrations greater than 5
ppm. This assessment assumes, as suggested on the labels, that the
target waterbodies are ornamental or periodic and disconnected from the
larger watershed. The label should be more explicit regarding this
assumption. Further work would need to be done to evaluate potential
wildlife exposure if the registrants do not support this assumption.

*Mosquito control*

The mosquito control uses (RD20^®^ product label) specify that treated
bodies of all sizes receive an initial treatment at a target
concentration of 200 ppm and allow weekly maintenance dose at a
concentration of 100 ppm. There are no label limits on the number of
applications that can be made in a year. Because of the types of
standing waters indicated on the label (from empty tin cans to
decorative ponds), this use could be a source of exposure to terrestrial
wildlife making use of the water for drinking or bathing, or by
amphibians for completion of a lifecycle phase, such as tadpoles. Since
the product is applied directly into the water, exposure via forage
items is not expected (emergent vegetation is assumed not to be
present). The label specifically states that application should not be
made where fish are present; therefore, exposure to fish is not expected
when used in accordance with the label. However, because there is no
explicit prohibition on the labels, exposure to amphibians is possible,
especially during the aquatic phase. Because of the persistence of
ADBAC, the weekly maintenance applications could, at least in some
instances, result in increased concentrations throughout the year,
leading to the potential for exposure at doses far greater than 200 ppm
for other wildlife. This assessment assumes, as suggested on the label,
that the target waterbodies are ornamental or periodic and disconnected
from the larger watershed. The label should be more explicit regarding
this assumption. Further work would need to be done to evaluate
potential wildlife exposure if the registrants do not support this
assumption.

*Turf and Golf Courses*

Two ADBAC products (Consan^®^ and RD20^®^) are labeled for use on
residential lawns, commercial turf and golf courses. These uses control
algal build-up and fungal diseases such as fusarium blight (*Fusarium*
spp.) and brown patch (*Rhizoctonia* spp.). Smaller use sites, such as
residential lawns, are labeled for a concentration of 790 ppm which is
equivalent to a rate of 6.8 lb ai/A. This rate is also used for golf
courses and commercial (nonagricultural) turf unless a commercial power
sprayer is used. If a commercial power sprayer is used, the application
rate is reduced to 512 ppm (0.82 lb ai/A). Presumably, as implied on the
labels, smaller areas would be treated at the higher rate, while
larger-scale applications would be treated at the lower rate. However,
this assumption is not fully clear from the label and should be
explicitly expressed. Further assessment would be required if this
assumption is not supported.

The product labels do not specify seasonal or yearly limits on the
maximum number of applications or pounds per acre. The label does
specify 10-14 days between applications. The label states applications
should be made during the warm growing season, so the number of
applications may vary depending on the geographic area where it is used.
Without a limit, a hypothetical Florida golf course could apply ADBAC
every ten days all year long. Without data indicating otherwise, this
seems plausible given the wide range of target organisms for which ADBAC
controls (semi-terrestrial alga species, numerous species of fungi).
These organisms are generally a greater problem under warm wet
conditions, so some use sites may need appreciably fewer applications to
achieve desired control. However, it is unclear what a typical number of
applications would be; maximum applications per year should be
explicitly stated on the labels.

[]{.mark}

Terrestrial wildlife exposure could occur from these uses, whether
through foraging in the treated area or by feeding on organisms affected
by spray drift, runoff and or erosion. Aquatic organisms could be
affected by spray drift, runoff and/or erosion. This assessment
evaluates these potential routes of exposure.

[]{.mark}

*Nursery Uses (bedding plants, ornamental shrubs and trees)*

The products Timsen^®^, Consan^®^ and RD20^®^ are all labeled for
nursery uses to control various fungal and bacterial pathogens that can
cause damage to ornamental plants. The uses appear to be limited to
spray and drench applications, and are assessed accordingly. However,
the intended application methods should be explicitly stated on the
labels. In 2002, there were 68,214 acres of floriculture (bedding/garden
plants, cut flowers and cut florist greens, foliage plants, and potted
flowering plants) grown in 14,579 outdoor nurseries in the US
([www.nass.usda.gov/census/](http://www.nass.usda.gov/census/)). The
labels allow for use on a variety of herbaceous annuals, such as fuchsia
and snapdragons, as well as larger perennials such as ash and sycamore
trees. Because different ornamental species have different pathogen
pressures, different rates are recommended for each pathogen targeted.
For instance, palms needing protection from heart rot and *penicillium*
leaf base rot are treated with Consan^®^ at a concentration of 1563 ppm
while crepe myrtle and fruit trees being treated for fireblight are
treated at a concentration of 781 ppm. Differences in amount of product
that will potentially be available for exposure to non-target organisms
depends on the quantity of solution applied. The palm treatment uses a
small amount of solution poured into the 'cup' formed at the base of the
leaves; this treatment is repeated weekly until control is achieved. For
fireblight control, the entire tree is sprayed at two-week intervals,
with some phenological limitations (e.g., early spring and fall after
harvest; Consan^®^ label only). For some larger ornamentals, such as ash
or sycamore, the label states that 50-60 gallons of solution (528 ppm)
may be required to achieve full coverage. These applications can be
repeated up to three times, at intervals determined by leaf emergence
and development. These treatments are equivalent to application of 0.25
lbs ai/tree/treatment. If 40 gallons is assumed to be required for
adequate coverage of somewhat smaller trees, such as fruit trees (781
ppm), the mass applied is also 0.25 lbs ai/tree/treatment. Wildlife
could be exposed through runoff or drift contaminating food or water
sources, or foraging on either the treated plant or nontarget plants in
the vicinity of the treatment.

## 2.2 Exposure Characterization {#exposure-characterization .unnumbered}

### 2.2.1 *Environmental Fate and Transport Characterization* {#environmental-fate-and-transport-characterization .unnumbered}

ADBAC is immobile and persistent; while it is not likely to leach in to
groundwater, it may enter surface water through erosion. The available
soil mobility study shows that ADBAC has a strong tendency to bind to
sediment/soil with Freundlich K~ads~ values of 6,172 for sand soil,
10,797 for silt loam, 5,123 for sandy loam soil, and 32,429 for clay
loam. The corresponding K~oc~ values are 6,171,657 for sand soil,
2,159,346 for silt loam, 640,389 for sandy loam soil, and 1,663,039 for
clay loam (MRID 424148-01). There are no guideline data for aerobic soil
degradation of ADBAC. Because of its strong adsorption to soils, the
potential to reach aquatic water bodies via runoff or leaching is
limited. ADBAC may, however, be transported off-site to aquatic water
bodies as entrained sediment or via spray drift during aerial or ground
spray applications. Once in aquatic environments, ADBAC is
hydrolytically stable under abiotic and buffered conditions over the pH
5-9 range (MRID 408356-02). ADBAC is also stable to photodegradation in
pH 7 buffered aqueous solutions (MRID 408356-03).

Aquatic metabolism studies under aerobic and anaerobic conditions
indicate that ADBAC is stable to microbial degradation. ADBAC did not
degrade in flooded sand loam soil that was incubated at 24-27°C in the
dark for up to 30 days in an aerobic aquatic metabolism study (MRID
408356-04). Under anaerobic conditions, ADBAC was found to be very
resistant to degradation with a calculated half-life of 1,815 days (MRID
424151-01).

Bioaccumulation of ADBAC in freshwater fish is not likely to occur.
Maximum bioconcentration factors (BCF) were 33X for edible tissues
(muscle, skin), 160X for nonedible tissues (viscera, head, carcass), and
79X for whole fish tissues (MRID 410268-01). ADBAC is not expected to
pose a concern for bioconcentration in aquatic organisms.

Major degradates were not identified in any of the available studies.
The environmental fate and physical-chemical properties, based on
submitted guideline studies, are summarized in Table 2.1. Details of
individual studies can be found in the ADBAC Environmental Fate
Assessment conducted by the AD.

**Table 2.1 General fate and physical-chemical data for ADBAC.**

+----------------------------+-------------------+---------------------+
| **Parameter**              | **Value**         | **Source**          |
+----------------------------+-------------------+---------------------+
| Molecular Weight           | *377.83*          | Product chemistry   |
+----------------------------+-------------------+---------------------+
| Solubility (25º C)         | Completely        | Product chemistry   |
|                            | Soluble           |                     |
+----------------------------+-------------------+---------------------+
| Vapor Pressure (25º C)     | 3.53 x 10^-12^    | Product chemistry   |
|                            | torr              |                     |
+----------------------------+-------------------+---------------------+
| Hydrolysis Half-life (25º  | 150 d             | MRID *408356-2,     |
| C)                         |                   | 424152-01*          |
|                            | 183 d             |                     |
| pH 5                       |                   |                     |
|                            | 379 d             |                     |
| pH 7                       |                   |                     |
|                            |                   |                     |
| pH 9                       |                   |                     |
+----------------------------+-------------------+---------------------+
| Aqueous Photolysis         | stable            | MRIDs 411055-01,    |
| Half-life                  |                   | 424152-01           |
+----------------------------+-------------------+---------------------+
| Soil Photolysis Half-life  | no data           |                     |
+----------------------------+-------------------+---------------------+
| Aerobic Soil Metabolism    | no data           |                     |
| Half-life                  |                   |                     |
+----------------------------+-------------------+---------------------+
| Aerobic Aquatic Metabolism | stable (sand      | MRIDs 408356-04,    |
| Half-life                  | loam)             | 424149-01           |
+----------------------------+-------------------+---------------------+
| Anaerobic Aquatic          | 1,815 d (sandy    | MRIDs *411055-01*,  |
| Metabolism Half-life       | loam)             | 424150-02           |
+----------------------------+-------------------+---------------------+
| Organic Carbon             | 6.2 x 10^6^, 2.2  | MRID *408356-05*    |
| Partitioning Coefficient   | x 10^6^, 6.4 x    |                     |
| (K~oc~, L/kg~oc~)          | 10^5^, 1.7 x      |                     |
|                            | 10^6^             |                     |
+----------------------------+-------------------+---------------------+
| Soil Partitioning          | 6172, 10797,      | MRID *408356-05*    |
| Coefficient (k~d~, L/kg)   | 5123, 32429       |                     |
+----------------------------+-------------------+---------------------+
| Bioconcentration Factors   | 33X               | MRID 410268-01      |
| (BCF)                      |                   |                     |
|                            | 160X              |                     |
| Edible tissue              |                   |                     |
|                            | 79X               |                     |
| Nonedible tissue           |                   |                     |
|                            |                   |                     |
| Whole fish tissue          |                   |                     |
+----------------------------+-------------------+---------------------+

*2.2.2* *Measures of Aquatic Exposure*

This assessment involves Tier II modeling (PRZM/EXAMS) for selected
scenarios representing all proposed outdoor uses. Monitoring data were
not considered because national-scale monitoring studies were not
identified. For Tier II, two models are used in tandem. The Pesticide
Root Zone Model, (PRZM, Carsel et al., 1997) simulates fate and
transport on the agricultural field. The version of PRZM used was PRZM
3.12 beta dated May 24, 2001. The water body is simulated with Exposure
Analysis Modeling System (EXAMS), version 2.98, dated July 18, 2002
(Burns, 1997). Simulations are run for multiple (usually 30) years and
the estimated environmental concentrations (EECs) represent peak values
that are expected once every ten years based on the thirty years of
daily values generated during the simulation.

For aquatic endpoints, the exposure is estimated for the maximum
application pattern to a 10-ha field bordering a 1-ha pond, 2-m deep
(20,000 m^3^) with no outlet. Exposure estimates generated using this
standard pond are intended to represent a wide variety of vulnerable
water bodies that occur at the top of watersheds including prairie pot
holes, playa lakes, wetlands, vernal pools, man-made and natural ponds,
and intermittent and first-order streams. As a group, there are factors
that make these water bodies more or less vulnerable than the standard
surrogate pond. Static water bodies that have larger ratios of drainage
area to water body volume would be expected to have higher peak EECs
than the standard pond. These water bodies will be either smaller in
size or have large drainage areas. Smaller water bodies tend to have
limited storage capacity and thus tend to overflow and carry pesticide
in the discharge whereas the standard pond has no discharge. As
watershed size increases beyond 10-ha, it becomes increasingly unlikely
that the entire watershed is planted with a non-major single crop that
is all treated with the pesticide. Headwater streams can also have peak
concentrations higher than the standard pond, but they tend to persist
for only short periods of time and are then carried downstream.

OPP standard PRZM crop or orchard scenarios, which consist of soils,
weather and cropping practices that are location-specific, are used in
the simulations to represent labeled uses of ADBAC. These scenarios are
developed to represent high-end exposure sites in terms of vulnerability
to runoff and erosion and subsequent off-site transport of pesticide.

2.2.2.1 Aquatic exposure modeling

Tier II EECs are estimated using EFED's aquatic models PRZM and EXAMS
(described in previous section). PRZM is used to simulate pesticide
transport as a result of runoff, erosion and spray drift from a 10-ha
agricultural field and EXAMS considers environmental fate and transport
of pesticides in surface water and predicts EECs in a standard pond
(10,000-m^2^ pond, 2-m deep), with the assumption that the small field
is cropped at 100%. Simulations are carried out with the linkage program
shell, PE4V01.pl (dated 8/13/2003), which incorporates the standard crop
and orchard scenarios developed by EFED. Additional information on these
models can be found at:
[[http://www.epa.gov/oppefed1/models/water/index.htm]{.underline}](http://www.epa.gov/oppefed1/models/water/index.htm).

All horticultural or aquatic ADBAC/DDAC uses are considered in this
assessment (puddles, ornamental ponds and pools; mosquito control; turf
and golf courses; ornamental shrubs and trees). For aquatic exposures,
it is assumed that the direct applications to puddles, ornamental ponds
and pools and the mosquito control uses result in minimal exposure to
aquatic environments since the labels specify that applications should
not be made where fish are present and it is implied on the label that
the application sites are ornamental or periodic and disconnected from
the greater watershed. However, even small, ephemeral puddles can be
used wildlife for drinking water and, as in the case of amphibians, for
critical life stages. Labels need to explicitly state any restrictions.
For the turf and golf course uses, two standard scenarios were used for
PRZM/EXAMS modeling, FL turf and PA turf. For the ornamental uses, two
standard scenarios were used as surrogates for ornamental trees, OR Xmas
tree and GA pecan. A summary of the crop scenarios used to estimate
ADBAC concentrations in the aquatic systems for ecological risk
assessment are listed in **Table 2.2**, along with some characterization
of why the scenario was chosen.

Table 2.2. Summary of crop scenarios used in estimating EECs.

+-----------------+---------------+--------------+---------------------+
| **ADBAC Uses    | **Crop        | **MLRA/ Met  | **Scenario          |
| (EPA Reg. #)**  | Scenario**    | Station**    | Characterization**  |
+=================+===============+==============+=====================+
| Turf and golf   | **FL turf**:  | MLRA 156A;   | Selected based on   |
| courses         | Osceola       | W12834       | geographical        |
| (58044-3,       | County,       |              | location,           |
| 53642-1)        |               |              | agricultural        |
|                 | Adamsville    |              | practices, and use  |
|                 | sand          |              | patterns.           |
+-----------------+---------------+--------------+---------------------+
|                 | **PA turf**:  | MLRA 148;    |                     |
|                 | York County,  | W14737       |                     |
|                 |               |              |                     |
|                 | Glenville     |              |                     |
|                 | silt loam     |              |                     |
+-----------------+---------------+--------------+---------------------+
| Ornamental      | **OR Xmas     | MLRA A2;     | Selected as a       |
| trees           | tree**:       | W24232       | surrogate for       |
|                 | Benton        |              | ornamental trees in |
| (58044-3,       | County,       |              | Pacific northwest   |
| 53642-1, 507-3) | Pilchuck fine |              |                     |
|                 | sand          |              |                     |
+-----------------+---------------+--------------+---------------------+
|                 | **GA pecan**: | MLRA 133A;   | Selected as a       |
|                 | Mitchell      | W93805       | surrogate for       |
|                 | County;       |              | ornamental trees in |
|                 | Greenville    |              | the southeast       |
|                 | fine sandy    |              |                     |
|                 | loam          |              |                     |
+-----------------+---------------+--------------+---------------------+

PRZM/EXAMS modeling of ADBAC uses four PRZM scenarios identified in
Table 2.2 at the current maximum label rate, maximum number of
applications per year and the minimum application interval of the ADBAC
use represented by each scenario. For the turf/golf course uses
application rates for use with a commercial sprayer and for more limited
residential use are both modeled at 0.8 and 6.8 lbs ai/A, respectively).
The maximum number of applications per year is currently not specified
on product labels for the turf/golf course use. Therefore a number of
application scenarios, ranging from 1 application per year to 26
applications per year (Table 2.3), are simulated to cover the range of
possibilities. Although, the label specifies a maximum of 3 applications
per year for the ornamentals use, the minimum application interval is
not specified. A minimum application interval of 7 days is assumed
(Table 2.3). The modeled application rate for the ornamental use (302
lbs ai/A) assumes a tree spacing of 6' x 6' and a maximum application of
60 gallons (0.25 lbs a) per tree. For both the ornamental and
residential turf uses the default 10 ha (25 A) field scenario is modeled
in addition to a number of smaller fields (10, 1, and 0.5 A) since it is
possible that these uses are limited in area and the default 25-A
scenario may result in unrealistically high exposure concentrations.

Where applicable, modeling input parameters are selected according to
current guidance (*Guidance for Selecting Input Parameters in Modeling
the Environmental Fate and Transport of Pesticides Version II*, EFED,
February 28, 2002). Application-specific and chemical-specific input
parameters for PRZM/EXAMS modeling are listed in **Table 2.3** and
**Table 2.4**, respectively. All scenarios simulate aerial spray
applications (PRZM chemical application method, CAM = 2), with
corresponding application efficiency and drift fractions equal to 0.95
and 0.05, respectively. The condition for disposition of the pesticide
remaining on foliage after harvest (PRZM variable IPSCND) is set to 1
(pesticide remaining on foliage is converted to surface application) for
all uses consistent with turf and nursery practices. Application dates
are chosen based on the label information when available.

A soil organic carbon partitioning coefficient (K~oc~) of 2.7 x 10^6^
L/kg~oc~, the mean of four soils, is used. The aerobic soil metabolism
is assumed stable since there are no available guideline studies. The
aquatic metabolism and aerobic aquatic metabolism are assumed stable as
indicated by the submitted guideline studies. Since there is only one
study for the anaerobic aquatic metabolism, three times the half-life
was used to account for variability in the environment (5445 days). The
hydrolysis half-life of 183 days is used since the ecological water body
is a constant pH 7.

**Table 2.3 PRZM/EXAMS application-specific input parameters.**

+--------------+---------+-------+---------+--------+-------+-------+
| **ADBAC      | **PRZM  | **Ma  | **No.   | **App. | **A   | **    |
| Use(s) (EPA  | scen    | ximum | of app. | me     | pplic | First |
| Reg. #)**    | arios** | app.  | per     | thod** | ation | a     |
|              |         | rate  | year/   |        | tim   | pplic |
|              |         | (lbs  | i       | **     | ing** | ation |
|              |         | a.i.  | nterval | drift/ |       | d     |
|              |         | /A)** | (       | app.   |       | ate** |
|              |         |       | d)^1^** | effici |       |       |
|              |         |       |         | ency** |       |       |
+--------------+---------+-------+---------+--------+-------+-------+
| Turf and     | FL turf | 0.8   | 26/10   | aerial | Warm  | June  |
| golf courses |         |       |         | spray  | gr    | 1     |
| (58044-3,    | PA turf |       | 10/10   |        | owing |       |
| 53642-1)     |         |       |         | 0.05/  | s     |       |
|              |         |       | 5/10    | 0.95   | eason |       |
|              |         |       |         |        |       |       |
|              |         |       | 1       |        |       |       |
+--------------+---------+-------+---------+--------+-------+-------+
| Ornamental   | OR Xmas | 302   | 3/7     | aerial | Not   | May   |
| trees        | tree    |       |         | spray  | spec  | 10    |
|              |         |       |         |        | ified |       |
| (58044-3,    | GA      |       |         | 0.05/  |       |       |
| 53642-1,     | Pecans  |       |         | 0.95   |       |       |
| 507-3)       |         |       |         |        |       |       |
+--------------+---------+-------+---------+--------+-------+-------+

^1^ Number of applications not specified on label for turf uses; four
scenarios considered: 26, 10, 5 and 1 application per year. Minimum
interval between applications not specified on labels for ornamental
uses; a 7 day interval was assumed.

Table 2.4 Chemical-specific PRZM/EXAMS inputs.

  -------------------------------------------------------------------------------
  **Parameter**                  **Value**    **Source (MRID \# **Comment**
                                              or citation)**    
  ------------------------------ ------------ ----------------- -----------------
  Soil Partition Coefficient     2.7 x 10^6^  MRID *408356-05*  average value
  (K~oc~ mL/g)                                                  

  Aerobic Soil Metabolism        0            no data           stable to aerobic
  Half-life (days)                                              soil metabolism

  Molecular Weight (g/mol)       *377.83*     Product chemistry 

  Vapor Pressure (torr)          3.53 x       Product chemistry 
                                 10^-12^                        

  Henry's Law Constant           7.76 x       Product chemistry 
  (atm-m^3^-mol)                 10^-13^                        

  Solubility in Water at 25^o^C  Completely   Product chemistry 10X solubility
  (ppm)                          sol.                           

  Aerobic Aquatic Metabolism     0            MRIDs 408356-04,  stable to aerobic
  Half-life (days)                            424149-01         aquatic
                                                                metabolism

  Anaerobic Aquatic Metabolism   5445         MRIDs             one study: 3x
  Half-life (days)                            *411055-01*,      1,815 d
                                              424150-02         

  Hydrolysis Half-life @ pH 7    183          MRID*408356-02*   water body
  (days)                                                        constant pH 7

  Aquatic Photolysis Half-life   0            MRIDs 408356-03,  stable to aquatic
  (days)                                      424152-01         photolysis

  Foliar extraction              0.5          Default           

  Foliar decay rate              0            Default           stable to foliar
                                                                degradation
  -------------------------------------------------------------------------------

Simulated EECs for all scenarios are presented in Table 2.5. Copies of
the input and output files are in Appendix A. Acute EECs range from
0.67 - 1473 µg/L, 21-day chronic EECs range from 0.37 - 920 µg/L and
60-day average EECs range from 0.36 - 903 µg/L.

Table 2.5 Estimated Aquatic Exposure Concentrations Calculated with
PRZM/EXAMS.

  ------------------------------------------------------------------------------------------------------------
  **ADBAC      **Scenario**   **App. Rate   **\#      **Interval**   **Area    **Acute   **21-day   **60-day
  Uses/EPA                    (lbs ai/A)**  Apps.**                  treated   (g/L)**   Chronic    Chronic
  Reg. \#**                                                          (A)**               (g/L)**    (g/L)**
  ------------ -------------- ------------- --------- -------------- --------- --------- ---------- ----------
  Turf         FL turf        0.8\*         26        10             25\*\*    15.6      9.4        9.1

                                            10        10                       6.0       3.6        3.5

                                            5         10                       3.1       1.8        1.8

                                            1         \--                      0.67      0.37       0.36

  Turf         PA turf        0.8\*         26        10             25\*\*    20.6      10.9       10.6

                                            10        10                       7.8       4.2        4.1

                                            5         10                       3.9       2.1        2.0

                                            1         \--                      0.80      0.43       0.41

  Turf         Fl turf        6.8\*\*\*     10        10             25\*\*    49.2      26.5       25.5

                                                                     10        19.7      10.6       10.2

                                                                     1         1.97      1.06       1.02

                                                                     0.5       0.98      0.53       0.51

  Turf         PA turf        6.8\*\*\*     10        10             25\*\*    62.5      30.3       29.3

                                                                     10        25.0      12.1       11.7

                                                                     1         2.50      1.21       1.17

                                                                     0.5       1.25      0.61       0.59

  Ornamental   GA pecan       302\*\*\*\*   3         7              25\*\*    1473      920        903

                                                                     10        589       368        361

                                                                     1         58.9      36.8       36.1

                                                                     0.5       29.5      18.4       18.1

  Ornamental   OR Christmas   302\*\*\*\*   3         7              25\*\*    557       361        339
               tree                                                                                 

                                                                     10        223       144        136

                                                                     1         22.3      14.4       13.6

                                                                     0.5       11.2      7.2        6.8
  ------------------------------------------------------------------------------------------------------------

\* Golf course tees, greens and fairways and commercial turf
applications

\*\* Standard default scenario, 10 ha field, 100% treated

\*\*\* Residential turf applications

\*\*\*\* Assumes 6' x 6' spacing of trees, 0.25 lbs ai/tree

2.2.2.2 Aquatic exposure monitoring data

No monitoring data are identified for either ADBAC or DDAC.

2.2.3 Terrestrial Exposure Assessment

Application methods for ADBAC include spray and drench treatments of
individual plants and flats as well as turf spray. Both ADBAC and DDAC
are labeled for direct application into small waterbodies, such as
puddles, ornamental ponds, old tires, etc. The combination of many uses
and assorted application methods can potentially result in various
routes of non-target exposure to terrestrial organisms. However, the
only use of DDAC is labeled for 5 ppm formulated product (3 ppm ai
DDAC).

The EEC values used for terrestrial exposure from direct application are
calculated using the TREX model (Version 1.2.3), and are derived from
the Kenaga nomograph, as modified by Fletcher *et al.* (1994), based on
a large set of actual field residue data. The upper limit values from
the nomograph represent the 95th percentile of residue values from
actual field measurements (Hoerger and Kenaga, 1972). The Fletcher *et
al.* (1994) modifications to the Kenaga nomograph are based on measured
field residues from 249 published research papers, including information
on 118 species of plants, 121 pesticides, and 17 chemical classes. These
modifications represent the 95^th^ percentile of the expanded data set.
Risk quotients are based on the most sensitive LC~50~ and NOAEC for
birds (in this instance, bobwhite quail) and LD~50~ for mammals (based
on lab rat studies). Dietary EECs, unadjusted for organism type or size,
range from 42 ppm on fruits/pods/large insects for turf application,
five times per year at 10-day intervals to 180,814 ppm on short grass
for ornamental applications three times per year at 10-day intervals
(Table 2.6). Since the labels do not limit the number of applications
for most uses, modeled exposure scenarios may not represent the most
conservative assumptions. More scenarios are considered in the Risk
Description section of this document.

Table 2.6. Unadjusted dietary-based EECs for two possible application
scenarios.

  ------------------- -------------------------------- --------------------
  **Use Pattern**     **Forage Item**                  **Upper bound EEC
                                                       (ppm)**

  Turf                Short Grass                      1062

  0.8 lbs ai/A        Tall Grass                       487

  26                  Broadleaf plants/sm insects      598
  applications/year                                    

  10 day interval     Fruits/pods/seeds/lg insects     66

                                                       

  Ornamentals         Short Grass                      180713

  302 lbs ai/A        Tall Grass                       82827

  3 applications/year Broadleaf plants/sm insects      101651

  10 day interval     Fruits/pods/seeds/lg insects     11295
  ------------------- -------------------------------- --------------------

Since direct application to small waterbodies is prescribed for some
uses, drinking water is likely to be a route of exposure for wildlife of
various sizes. Therefore drinking water exposure is estimated using
allometric equations (Appendix C) from The Wildlife Exposure Factors
Handbook (USEPA 1994). Because birds and mammals have different water
requirements, estimates of exposure are considered separately (Table
2.7). The modeled concentrations are those resulting from initial direct
application of ADBAC/DDAC to small waterbodies according to the labels.
Additionally, amphibians may be exposed at critical stages in their
lifecycle. Exposure may be greater following subsequent applications due
to the persistence of the chemicals.

Table 2.7. Estimated exposure to total active ingredient to wildlife
through drinking water.

  --------------------- -------------- ----------------- -----------------
                        **Avian Daily                    
                        Exposure                         
                        Estimate                         
                        (mg/kg-bw)**                     

  **Concentration       **20g**        **100g**          **1000g**
  (ppm)**                                                

  **5^\*^**             1.1            0.6               0.3

  **200**               43             25                12

                        **Mammalian                      
                        Daily Exposure                   
                        Estimate                         
                        (mg/kg-bw)**                     

                        **15g**        **35g**           **1000g**

  **5^\*^**             0.8            0.7               0.5

  **200**               30             28                20
  --------------------- -------------- ----------------- -----------------

\*Formulation is 12% DDAC, 8% ADBAC

**3 Ecotoxicity**

The ecotoxicological endpoints used in this assessment are those used by
AD in their assessment. The endpoints are summarized and briefly
described here. Greater detail is provided in Appendix B. Only ADBAC is
considered in this section, as DDAC endpoints were not provided.
However, a previous EFED assessment of DDAC (Review of Data Submitted to
Support the New Use of BARDAC MOLLUSCICIDE^®^ (Didecyl dimethyl ammonium
chloride) for Salt Water Cooling Systems; DP Barcode: D215429) suggests
similar toxicity to wildlife. Nevertheless, the toxicity of DDAC remains
an uncertainty in this assessment. As described in other parts of this
document, wildlife exposure to DDAC is expected to be limited.

**3.1 Toxicity to Terrestrial Animals**

*3.1.1 Avian, Acute and Chronic*

An acute toxicity study was conducted with Bobwhite quail (*Colinus
virginianus*; MRID 428859-01). The results of one acute oral toxicity
study, submitted for ADBAC established an LD~50~ of 136 mg/kg-bw. The
results from the acceptable study indicate that ADBAC is moderately
toxic to avian species on an acute oral basis. The study fulfills
guideline requirements. No data are available to assess the toxicity of
ADBAC on a subacute dietary exposure basis though and this represents a
data gap.

No data are available regarding the chronic toxicity of ADBAC to birds.
Chronic risk to avian species cannot be precluded in the absence of
data; chronic risk to birds is presumed.

*3.1.2 Mammals, Acute and Chronic Toxicity*

The endpoints used in this risk assessment were chosen by AD and used
without details of the studies available. The acute LD~50~ for rats
exposed to ADBAC is *304.5* mg/kg-bw (MRID *451092-04*). Based on these
data, ADBAC is classified as slightly toxic to mammals on an acute oral
exposure basis. The NOAEL from a chronic toxicity study with rats (MRID
41947501) is 44 mg/kg/day (*1000 ppm*).

**3.2 Toxicity to Aquatic Animals**

The Agency requested that aquatic toxicity studies be conducted with
ADBAC since, under typical use conditions, it may be introduced into the
aquatic environment.

*3.2.1 Freshwater Fish, Acute*

The most sensitive result from freshwater fish acute studies submitted
for ADBAC established an LC~50~ of 280 µg a.i./L (fathead minnow; MRID
437401-03). The results indicate that ADBAC is highly toxic to on an
acute exposure basis.

*3.2.2 Freshwater Invertebrates, Acute*

An acceptable study (MRID 419472-03) with the freshwater invertebrate,
*Daphnia magna,* established an LC~50~ of 5.9 µg a.i./L. Results of the
studies indicate that ADBAC is very highly toxic to freshwater
invertebrates on an acute exposure basis. The guideline requirement has
been fulfilled.

*3.2.3 Estuarine and Marine Organisms, Acute*

The most sensitive estuarine/marine fish to acute exposure to ADBAC was
the inland silverside (*Menidia beryllina*), selected from open
literature (Dobbs, M.G. et al., 1995), with an LC~50~ = 310 µg a.i./L.
The most sensitive invertebrate was the Eastern oyster (*Crassostrea
virginica*), with an EC~50~ = 55 µg a.i./L (MRID 424795-03).

*3.2.4 Aquatic Organisms, Chronic*

The results from an early life stage study with the warmwater fathead
minnow (*Pimephales promelas*) indicate that exposure to ADBAC on a
chronic basis results in measurable effects at a concentration of 32.2
µg a.i./L (MRID 423021-02). This study fulfills guideline requirements
for a fish early life stage chronic test (72-4(a)/OPPTS 850.1400). In a
chronic study with the waterflea (*Daphnia magna*), no measurable
effects were noted at a concentration of 4.15 µg/L (MRID 423021-01).
However, an MATC could not be determined in this study. Therefore, the
study was classified as supplemental and does not fulfill guideline
requirements for an aquatic invertebrate life cycle test (72-4b/OPPTS
850.1300). The lack of chronic toxicity data on ADBAC represents a data
gap.

No data on the chronic toxicity of ADBAC on estuarine/marine organisms
are available for this assessment. The potential chronic toxicity of
ADBAC is uncertain; therefore, chronic toxicity is presumed.

> *3.2.5 Non-target Plants*
>
> No data regarding the toxicity of ADBAC to non-target plants were
> available for review.

**4 Risk Characterization**

**4.1 Risk Estimation**

In a screening-level deterministic (point estimate) approach to
evaluating potential risk to non-target organisms from the proposed uses
of ADBAC, risk quotients (RQs) are calculated from the ratio of
estimated environmental concentrations (EECs) to ecotoxicity values. RQs
are then compared to levels of concern (LOCs) used by OPP to indicate
potential risk to non-target organisms and the need to consider
regulatory action. For studies on taxa where no effects are observed
(with no endpoint established), the highest dose tested is used in RQ
calculation. As discussed in other sections, DDAC is not expected to
occur at biologically relevant concentrations in the environment when
applied according to the label directions, IF the toxicity of DDAC is
similar to ADBAC.

Chronic risk to estuarine/marine organisms, chronic risk to birds and
risk to non-target plants cannot be estimated due to lack of data. When
data are absent, risk to the organism in question in presumed.

[]{.mark}

*Nursery Ornamentals*

Use of ADBAC on ornamentals can lead to wildlife exposure via direct
ingestion of contaminated food items, drift exposure to food items or
water sources, and through runoff to adjacent waterbodies. Therefore,
exposure is possible to both aquatic and terrestrial organisms. The
maximum label rate, calculated assuming a 6' x 6' spacing of trees, is
302 lbs ai/A. There are annual limits on some applications; some
applications have no annual limits. It is beyond the scope of this
document to assess all possible exposure scenarios; therefore risk to
wildlife for this use may be underestimated.

Aquatic Risk

Acute RQs are calculated by dividing the peak EEC by the LC~50~/EC~50~
for the most sensitive species tested. Acute risk LOCs (0.5) are
exceeded by four- to 500-fold for both freshwater and estuarine/marine
fish and invertebrates for both scenarios modeled (Table 4.1.). The LOC
for acute risk to endangered species (RQ[\>]{.underline}0.05) is
exceeded by factors as high as 5,000X.

Table 4.1. Acute RQs for aquatic organisms resulting from use of ADBAC
on nursery ornamentals at the maximum rate of 302 lb ai/A, applied three
times at seven day intervals, assuming entire 10-ha area is treated. All
RQs exceed LOCs.

  -------------- -------------- -------------- -------------- --------------
  **Scenario**   **FW fish**    **FW invert**  **Est/Mar      **Est/Mar
                                               fish**         invert**

  GA pecan       5.26           249.66         4.75           26.78

  OR Christmas   1.99           94.41          1.80           10.13
  tree                                                        
  -------------- -------------- -------------- -------------- --------------

Chronic RQs are calculated by dividing the 21-day EEC (for
invertebrates) or the 60-day EEC (for fish) by the LC~50~/EC~50~ for the
most sensitive species tested. Chronic LOCs (1.0) are exceeded by 10- to
over 200-fold for freshwater organisms for both scenarios modeled (Table
4.2). Due to lack of data on the chronic toxicity of ADBAC to
estuarine/marine organisms, risk cannot be estimated and therefore
chronic risk to estuarine/marine organisms is presumed.

Table 4.2. Chronic RQs for aquatic organisms resulting from use of ADBAC
on nursery ornamentals at the maximum rate of 302 lb ai/A, applied three
times at seven day intervals. All RQs exceed LOCs.

  -------------- -------------- -------------- -------------- --------------
  **Scenario**   **chronic FW   **chronic FW   **chronic      **chronic
                 fish**         invert**       Est/Mar fish** Est/Mar
                                                              invert**

  GA pecan       28.04          221.69         unknown        unknown

  OR Christmas   10.53          86.99          unknown        unknown
  tree                                                        
  -------------- -------------- -------------- -------------- --------------

Terrestrial Risk-Avian

The avian acute LOC (0.5) is exceeded 38- to 4200-fold for all forage
items for all size birds (Table 4.3). Chronic risk to birds cannot be
estimated due to lack of toxicity data. In the absence of data, chronic
risk to birds is presumed.

Table 4.3. Acute RQs for avian wildlife resulting from use of ADBAC on
nursery ornamentals at the maximum rate of 302 lb ai/A, applied three
times at 10 day intervals.

  ------------------------------- ------------------- ------------------ ------------------
                                  **20 g**            **100 g**          **1000 g**

  **Short Grass**                 **[2101]{.mark}**   **[941]{.mark}**   **[298]{.mark}**

  **Tall Grass**                  **[963]{.mark}**    **[431]{.mark}**   **[137]{.mark}**

  **Broadleaf plants/sm insects** **[1182]{.mark}**   **[529]{.mark}**   **[168]{.mark}**

  **Fruits/pods/seeds/lg          **[131]{.mark}**    **[59]{.mark}**    **[19]{.mark}**
  insects**                                                              
  ------------------------------- ------------------- ------------------ ------------------

**[Exceeds acute risk LOC (0.5)]{.mark}**

***Exceeds restricted use LOC (0.2)***

**Exceeds listed spp LOC (0.1)**

Terrestrial Risk-Mammalian

The acute LOC (0.5) for mammals is exceeded 3- to 360-fold in all size
classes for all forage items. The chronic LOC (1.0) is exceeded for
mammals in all size classes for all forage items 10- to 1780-fold (Table
4.4).

Table 4.4. Acute and chronic dose-based RQs for mammalian wildlife
resulting from use of ADBAC on nursery ornamentals at the maximum rate
of 302 lb ai/A, applied three times at 10-day intervals.

  ----------------------- ------------------ ------------- ------------------- ------------- ------------------- -------------
                          **15 g mammal**                  **35 g mammal**                   **1000 g mammal**   

                                                                                                                 

                          **Acute**          **Chronic**   **Acute**           **Chronic**   **Acute**           **Chronic**

  **Short Grass**         **[182]{.mark}**   **1782**      **[156]{.mark}**    **1522**      **[83]{.mark}**     **816**

  **Tall Grass**          **[84]{.mark}**    **817**       **[71]{.mark}**     **698**       **[38]{.mark}**     **374**

  **Broadleaf plants/sm   **[103]{.mark}**   **1002**      **[88]{.mark}**     **856**       **[47]{.mark}**     **459**
  insects**                                                                                                      

  **Fruits/pods/lg        **[11]{.mark}**    **111**       **[9.73]{.mark}**   **95**        **[5.22]{.mark}**   **51**
  insects**                                                                                                      

  **Seeds**               **[2.5]{.mark}**   **25**        **[2.2]{.mark}**    **21**        **[1.2]{.mark}**    **11**
  ----------------------- ------------------ ------------- ------------------- ------------- ------------------- -------------

**[Exceeds acute risk LOC (0.5)]{.mark}**

***Exceeds restricted use LOC (0.2**)*

**Exceeds listed spp LOC (0.1) or chronic risk LOC (1.0)**

*Turf and Golf Courses*

Use of ADBAC on turf and golf courses can lead to wildlife exposure via
direct ingestion of contaminated food items, drift exposure to food
items or water sources, and through runoff to adjacent waterbodies.
Therefore, exposure is possible to both aquatic and terrestrial
organisms. The maximum label rate for ground commercial power spray
application is 0.8 lbs ai/A. A higher rate is allowed for non-commercial
sprayers (6.8 lbs ai/A) and is presumably intended for smaller areas
such as residential lawns.

Aquatic Risk

Acute RQs are calculated by dividing the peak EEC by the LC~50~/EC~50~
for the most sensitive species tested. Acute risk LOC
(RQ[\>]{.underline}0.5) is exceeded for freshwater invertebrates for
both scenarios modeled (Table 4.5.), and for estuarine/marine
invertebrates for the higher rate. The acute risk to endangered species
LOC (RQ[\>]{.underline}0.05) is exceeded for freshwater fish in both
scenarios and the restricted use LOC (0.1) is exceeded at the higher
rate for both freshwater and estuarine/marine fish.

Table 4.5. Acute RQs for aquatic organisms resulting from use of ADBAC
on golf courses and turf applied 26 times at 10 day intervals for the
0.8 lbs ai/A rate and 10 times at 10 day intervals for the 6.8 lb ai/A
rate.

  --------------- ------------ -------------- -------------- --------------
  **Scenario**    **FW fish**  **FW invert**  **Est/Mar      **Est/Mar
                                              fish**         invert**

  FL turf (0.8    **0.06**     **2.64**       **0.05**       **0.28**
  lbs ai/A)                                                  

  PA turf (0.8    **0.07**     **3.49**       **0.07**       **0.37**
  lbs ai/A)                                                  

  FL turf (6.8    ***0.18***   **8.34**       ***0.16***     **0.89**
  lbs ai/A)                                                  

  PA turf (6.8    ***0.22***   **10.59**      ***0.20***     **1.14**
  lbs ai/A)                                                  
  --------------- ------------ -------------- -------------- --------------

**[Exceeds acute risk LOC (0.5)]{.mark}**

***Exceeds restricted use LOC (0.1)***

**Exceeds listed spp LOC (0.05) or chronic risk LOC (1.0)**

[]{.mark}

Chronic LOCs (1.0) are exceeded for freshwater invertebrates for both
scenarios modeled and for freshwater fish at the higher application rate
(Table 4.6). Due to lack of data on the chronic toxicity of ADBAC to
estuarine/marine organisms, risk cannot be estimated and is therefore
presumed.

Table 4.6. Chronic RQs for aquatic organisms resulting from use of ADBAC
on golf courses and turf applied 26 times at 10 day intervals for the
0.8 lbs ai/A rate and 10 times at 10 day intervals for the 6.8 lb ai/A
rate.

  --------------- ------------------- -------------- -------------- --------------
  **Scenario**    **FW fish**         **FW invert**  **Est/Mar      **Est/Mar
                                                     fish**         invert**

  FL turf (0.8    ***0.28***          **2.27**       unknown        unknown
  lbs ai/A)                                                         

  PA turf (0.8    ***0.33***          **2.63**       unknown        unknown
  lbs ai/A)                                                         

  FL turf (6.8    **[0.79]{.mark}**   **6.39**       unknown        unknown
  lbs ai/A)                                                         

  PA turf (6.8    **[0.91]{.mark}**   **7.30**       unknown        unknown
  lbs ai/A)                                                         
  --------------- ------------------- -------------- -------------- --------------

**[Exceeds acute risk LOC (0.5)]{.mark}**

***Exceeds restricted use LOC (0.1)***

**Exceeds listed spp LOC (0.05) or chronic risk LOC (1.0)**

[]{.mark}

Terrestrial Risk-Avian

At the 0.8 lb ai/A rate, the avian acute risk LOC is exceeded for all
forage items for all size birds (Table 4.7), except for the 1000g size
class foraging on fruits/pods/large insects. Chronic risk to birds
cannot be estimated due to lack of toxicity data. In the absence of
data, chronic risk to birds is presumed.

[]{.mark}

Table 4.7. Acute RQs for avian wildlife resulting from use of ADBAC on
nursery ornamentals at the maximum rate of 0.8 lb ai/A, applied 26 times
at 10 day intervals.

  ------------------------------ -------------------- ------------------- -------------------
                                 **20 g**             **100 g**           **1000 g**

  **Short Grass**                **[12.35]{.mark}**   **[5.53]{.mark}**   **[1.75]{.mark}**

  **Tall Grass**                 **[5.66]{.mark}**    **[2.54]{.mark}**   **[0.80]{.mark}**

  **Broadleaf plants/sm          **[6.95]{.mark}**    **[3.11]{.mark}**   **[0.99]{.mark}**
  insects**                                                               

  **Fruits/pods/seeds/lg         **[0.77]{.mark}**    ***0.35***          **0.11**
  insects**                                                               
  ------------------------------ -------------------- ------------------- -------------------

**[Exceeds acute risk LOC (0.5)]{.mark}**

***Exceeds restricted use LOC (0.2)***

**Exceeds listed spp LOC (0.1)**

[]{.mark}

At the 6.8 lb ai/A rate, the avian acute risk LOC is exceeded for all
forage items for all size birds (Table 4.8). Chronic risk to birds
cannot be estimated due to lack of toxicity data. In the absence of
data, chronic risk to birds is presumed.

Table 4.8. Acute RQs for avian wildlife resulting from use of ADBAC on
lawns/turf at the maximum rate of 6.8 lb ai/A, applied 10 times at 10
day intervals.

  ------------------------------ -------------------- -------------------- --------------------
                                 **20 g**             **100 g**            **1000 g**

  **Short Grass**                **[91.02]{.mark}**   **[40.77]{.mark}**   **[12.92]{.mark}**

  **Tall Grass**                 **[41.72]{.mark}**   **[18.69]{.mark}**   **[5.92]{.mark}**

  **Broadleaf plants/sm          **[51.20]{.mark}**   **[22.93]{.mark}**   **[7.27]{.mark}**
  insects**                                                                

  **Fruits/pods/seeds/lg         **[5.69]{.mark}**    **[2.55]{.mark}**    **[0.81]{.mark}**
  insects**                                                                
  ------------------------------ -------------------- -------------------- --------------------

**[Exceeds acute risk LOC (0.5)]{.mark}**

***Exceeds restricted use LOC (0.2)***

**Exceeds listed spp LOC (0.1)**

[]{.mark}

Terrestrial Risk-Mammalian

At the 0.8 lbs ai/A rate, the acute LOC is exceeded for mammals in the
15g and 35g size classes foraging on short grass and broadleaf
plants/small insects (Table 4.9). The acute risk to endangered species
LOC is exceeded for all mammal size classes foraging on short grass,
tall grass and broadleaf plant/small insects. The chronic risk LOC is
exceeded for all mammal size classes on the short grass, tall grass and
broadleaf plant/small insect forage items.

Table 4.9. Acute and chronic dose-based RQs for mammalian wildlife
resulting from use of ADBAC on turf/golf courses at the maximum rate of
0.8 lb ai/A, applied 26 times at 10 day intervals.

  ------------------- ------------------- ------------- ------------------- ------------- ------------ -------------
                      **15 g mammal**                   **35 g mammal**                   **1000 g     
                                                                                          mammal**     

                                                                                                       

                      **Acute**           **Chronic**   **Acute**           **Chronic**   **Acute**    **Chronic**

  **Short Grass**     **[1.07]{.mark}**   **10.47**     **[0.92]{.mark}**   **8.95**      ***0.49***   **4.80**

  **Tall Grass**      ***0.49***          **4.80**      ***0.42***          **4.10**      ***0.22***   **2.20**

  **Broadleaf         **[0.60]{.mark}**   **5.89**      **[0.52]{.mark}**   **5.03**      ***0.28***   **2.70**
  plants/sm insects**                                                                                  

  **Fruits/pods/lg    0.07                0.65          0.06                0.56          0.03         0.30
  insects**                                                                                            

  **Seeds**           0.01                0.15          0.01                0.12          0.01         0.07
  ------------------- ------------------- ------------- ------------------- ------------- ------------ -------------

**[Exceeds acute risk LOC (0.5)]{.mark}**

***Exceeds restricted use LOC (0.2)***

**Exceeds listed spp LOC (0.1) or chronic risk LOC (1.0)**

At the 6.8 lbs ai/A rate, the acute risk LOC is exceeded for mammals in
all size classes foraging on short grass, tall grass and broadleaf
plants/small insects (Table 4.10). The acute risk to endangered species
LOC is exceeded for all mammal size classes foraging on short grass,
tall grass and broadleaf plant/small insects. The chronic risk LOC is
exceeded for all mammal size classes foraging on any of the food items
evaluated, except medium and large size classes foraging on seeds.

[]{.mark}

[]{.mark}

[]{.mark}

[]{.mark}

[]{.mark}

[]{.mark}

Table 4.10. Acute and chronic dose-based RQs for mammalian wildlife
resulting from use of ADBAC on nursery ornamentals at the maximum rate
of 6.8 lb ai/A, applied 10 times at 10 day intervals.

  ----------------------- ------------------- ------------- ------------------- ------------- ------------------- -------------
                          **15 g mammal**                   **35 g mammal**                   **1000 g mammal**   

                                                                                                                  

                          **Acute**           **Chronic**   **Acute**           **Chronic**   **Acute**           **Chronic**

  **Short Grass**         **[7.90]{.mark}**   **77.20**     **[6.75]{.mark}**   **65.94**     **[3.62]{.mark}**   **35.35**

  **Tall Grass**          **[3.62]{.mark}**   **35.38**     **[3.09]{.mark}**   **30.22**     **[1.66]{.mark}**   **16.20**

  **Broadleaf plants/sm   **[4.44]{.mark}**   **43.42**     **[3.80]{.mark}**   **37.09**     **[2.03]{.mark}**   **19.88**
  insects**                                                                                                       

  **Fruits/pods/lg        ***0.49***          **4.82**      ***0.42***          **4.12**      ***0.23***          **2.21**
  insects**                                                                                                       

  **Seeds**               **0.11**            **1.1**       0.09                0.92          0.05                0.49
  ----------------------- ------------------- ------------- ------------------- ------------- ------------------- -------------

**[Exceeds acute risk LOC (0.5)]{.mark}**

***Exceeds restricted use LOC (0.2)***

**Exceeds listed spp LOC (0.1) or chronic risk LOC (1.0)**

*Mosquito control*

For mosquito control uses, drinking water is presumed to be the most
likely route of exposure to wildlife. At the labeled rate of 200 ppm in
the target waterbody, RQs exceed the acute risk to endangered species
LOC for birds in the 20g and 100g size classes (Table 4.11.). The
restricted use LOC (0.2) is exceeded for 20g birds. Due to lack of data
on chronic toxicity of ADBAC to birds, chronic RQs cannot be calculated
and chronic effects are assumed. Neither acute nor chronic mammalian RQs
are exceeded. Equations are included in Appendix C.

Since it is possible that amphibians would use many of the potentially
treated waterbodies for at least their reproductive stage, RQs were
calculated using the most sensitive freshwater fish endpoint. Assuming a
concentration of 200 ppm, RQs were 0.71 for acute risk and 6.2 for
chronic risk, both of which exceed the LOCs. It is possible that, due to
additional applications indicated on the label, concentrations greater
than 200 ppm may be attained. In such instances, RQs would be higher.

Table 4.11. Wildlife drinking water RQs for ADBAC use in mosquito
control applications.

  ----------------- ----------------- ----------------- -----------------
  **Birds**         **20g**           **100g**          **1000g**

  DWIR^a^           0.004             0.013             0.059

  DPE^b^            42.91             25.23             11.80

  RQ^c^             *0.32*            *0.19*            0.09

                                                        

  **Mammals**       **15g**           **35g**           **1000g**

  DWIR^a^           0.002             0.005             0.099

  DPE^b^            30.13             27.69             19.80

  RQ^c^             0.07              0.06              0.05

                                                        
  ----------------- ----------------- ----------------- -----------------

^a^DWIR-drinking water ingestion rate (L/day)

^b^DPE-daily pesticide exposure (mg/kg-bw/day)

^c^RQ-risk quotient

*Puddles, Ornamental Ponds and Pools*

For the of ADBAC/DDAC in puddles, ornamental ponds and pools, drinking
water is presumed to be the most likely route of exposure to terrestrial
wildlife. At the labeled rate of 5 ppm in the target waterbody, acute
avian and mammalian RQs are all below 0.01, using toxicity endpoints
from ADBAC. The acute risk LOC for terrestrial animals is 0.5 and the
acute endangered LOC is 0.1. The RQs were calculated using the total
active ingredient. The formulations for these applications are 12% DDAC
and 8% ADBAC. Unless the wildlife endpoints for DDAC are more than 10
times more sensitive than for ADBAC, acute environmental risk from this
use appears to be unlikely. Mammalian chronic risk quotients are also
all below the LOC of 1.0; chronic risk to birds cannot be estimated due
to lack of data. Chronic risk to birds cannot be precluded.

Since it is possible that amphibians would use many of the potentially
treated waterbodies for at least their reproductive stage, RQs were
calculated using the most sensitive freshwater fish endpoint. Assuming a
concentration of 5 ppm, RQs were 0.02 for acute risk and 0.2 for chronic
risk, neither of which exceed the LOCs. It is possible that, due to
additional applications indicated on the label, concentrations greater
than 5 ppm may be attained. In such instances, RQs would be higher.

**4.2 Risk Description**

As presented in the previous section, LOCs are exceeded for several of
the outdoor uses of ADBAC. The one outdoor use of DDAC appears to result
in low exposure to wildlife. It is not possible to evaluate whether this
exposure results in risk to organisms due to the lack of toxicity data.
However, DDAC toxicity would need to be considerably greater than that
of ADBAC to pose a risk to wildlife based on this screening-level
assessment, and further discussion of DDAC is not warranted included in
this document. Risk from the various uses of ADBAC, as estimated in the
previous section, is highly dependant on the assumption of the model. In
the risk estimation section, conservative assumptions are used to
provide a protective assessment. Because the labels for these uses are
not explicitly directive, a variety of assumptions were explored to give
the risk manager a better sense of the range of possible exposure, and
therefore risk, to wildlife species under the current labels.

*Nursery Ornamentals*

This use has the highest application rates of any outdoor uses, and
subsequently results in the highest RQs. Because the labels have no
restrictions on the amount of product applied per unit area per year,
several assumptions are made. The RQs vary with differing assumptions.
For this document, it is assumed that large- and medium-sized
shrubs/trees represent the greatest use of the products, that the trees
are treated with 0.25 lbs ai each, for each application. Though the
concentration in ppm varies among tree/shrub, the volume needed for
adequate coverage is assumed to be less for smaller trees (higher
concentration), thus the 0.25 lbs ai/tree is used to calculate RQs. Many
of the applications are limited to three per year, i.e., the number used
in the modeling. It is possible that, in some instances, more
applications will be made. It is also assumed that the shrubs/trees were
evenly spaced at 6'x6'; however, changing the spacing would affect the
maximum application rate (lbs ai/A).

*Aquatic*

Aquatic RQs from nursery uses exceed the acute risk LOC for freshwater
fish by a factor of four to 10, and exceed the acute risk LOC for
estuarine marine fish by a similar magnitude. The acute risk LOC is
exceeded by up to 500-fold for freshwater invertebrates, and up to
54-fold for estuarine/marine invertebrates. Chronic risk LOCs for
freshwater organisms are exceeded factors ranging from 10 to over
200-fold. While data on chronic toxicity to estuarine/marine organisms
were not available for review, the lines of evidence strongly suggest
potential chronic risk to these animals. These RQs are based on EECs
derived from standard scenarios that assume 25 acres treated. It may not
be realistic to assume 25 acres of treated shrubs and trees in a given
nursery are treated at the same time, so RQs assuming 10, one and 0.5
acres are also calculated (Table 4.12). These adjustments assume a
linear relationship between EEC and area treated. If only one acre were
treated, following the stated assumptions, the acute risk to endangered
species LOC would still be exceeded for fish in both PRZM/EXAMS
scenarios and the restricted use LOC would still be exceeded in the GA
pecan scenario. The freshwater chronic risk LOC would still be exceeded
in the GA pecan scenario. If only a half acre were treated, the
restricted use LOC would still be exceeded for fish in the GA pecan
scenario. The freshwater invertebrate acute and chronic risk LOCs are
exceeded regardless of the size of the treated area. The
estuarine/marine invertebrate acute risk LOC is exceeded for treated
areas of all sizes in the GA pecan scenario, and the restricted use LOC
is exceeded for treated areas of all sizes in the OR Christmas tree
scenario.

Table 4.12. Aquatic RQs adjusted for area treated.

+--------+-------+--------+--------+--------+--------+--------+--------+
| *      | *     | *      | **c    | *      | **c    | *      | *      |
| *Scena | *Area | *acute | hronic | *acute | hronic | *acute | *acute |
| rios** | trea  | FW     | FW     | FW     | FW     | E      | E      |
|        | ted** | fish** | fish** | in     | in     | st/Mar | st/Mar |
|        |       |        |        | vert** | vert** | fish** | in     |
|        | *     |        |        |        |        |        | vert** |
|        | *(acr |        |        |        |        |        |        |
|        | es)** |        |        |        |        |        |        |
+--------+-------+--------+--------+--------+--------+--------+--------+
| GA     | 25    | **[5.  | **2    | *      | **22   | **[4.  | **[26. |
| pecan  |       | 26]{.m | 8.04** | *[249. | 1.69** | 75]{.m | 78]{.m |
|        |       | ark}** |        | 66]{.m |        | ark}** | ark}** |
|        |       |        |        | ark}** |        |        |        |
+--------+-------+--------+--------+--------+--------+--------+--------+
|        | 10    | **[2.  | **1    | **[99. | **8    | **[1.  | **[10. |
|        |       | 10]{.m | 1.21** | 83]{.m | 8.67** | 90]{.m | 71]{.m |
|        |       | ark}** |        | ark}** |        | ark}** | ark}** |
+--------+-------+--------+--------+--------+--------+--------+--------+
|        | 1     | ***0   | **     | **[9.  | **     | ***0   | **[1.  |
|        |       | .21*** | 1.12** | 98]{.m | 8.87** | .19*** | 07]{.m |
|        |       |        |        | ark}** |        |        | ark}** |
+--------+-------+--------+--------+--------+--------+--------+--------+
|        | 0.5   | ***0   | .0.56  | **[5.  | **     | ***0   | **[0.  |
|        |       | .11*** |        | 00]{.m | 4.43** | .10*** | 54]{.m |
|        |       |        |        | ark}** |        |        | ark}** |
+--------+-------+--------+--------+--------+--------+--------+--------+
| OR     | 25    | **[1.  | **1    | **[94. | **8    | **[1.  | **[10. |
| Chr    |       | 99]{.m | 0.53** | 41]{.m | 6.99** | 80]{.m | 13]{.m |
| istmas |       | ark}** |        | ark}** |        | ark}** | ark}** |
| tree   |       |        |        |        |        |        |        |
+--------+-------+--------+--------+--------+--------+--------+--------+
|        | 10    | **[0.  | **     | **[37. | **3    | **[0.  | **[4.  |
|        |       | 80]{.m | 4.22** | 80]{.m | 4.70** | 72]{.m | 05]{.m |
|        |       | ark}** |        | ark}** |        | ark}** | ark}** |
+--------+-------+--------+--------+--------+--------+--------+--------+
|        | 1     | **     | 0.42   | **[3.  | **     | **     | ***0   |
|        |       | 0.08** |        | 78]{.m | 3.47** | 0.07** | .41*** |
|        |       |        |        | ark}** |        |        |        |
+--------+-------+--------+--------+--------+--------+--------+--------+
|        | 0.5   | **     | 0.21   | **[1.  | **     | **     | ***0   |
|        |       | 0.04** |        | 90]{.m | 1.73** | 0.04** | .20*** |
|        |       |        |        | ark}** |        |        |        |
+--------+-------+--------+--------+--------+--------+--------+--------+

**[Exceeds acute risk LOC (0.5)]{.mark}**

***Exceeds restricted use LOC (0.1)***

**Exceeds listed spp LOC (0.05) or chronic risk LOC (1.0)**

*Terrestrial*

Acute avian RQs are exceeded from this use, by a minimum of 38-fold, and
both acute and chronic risk LOCs mammalian RQs are exceeded 10- to
1700-fold, and even a single application results in LOC exceedances
four- to 1400-fold. Chronic RQs for birds cannot be calculated due to
lack of data and is therefore presumed. The labels do make some effort
to minimize wildlife exposure, by limiting applications to before and
after fruit production, though the flowers and foliage would remain
potentially attractive forage. Even at an application rate of one half
of one percent of the modeled rate (0.5%; 1.5 lbs ai/A), an amount less
than is typically modeled for off-site drift, there are exceedances for
almost all size classes and forage items for birds and most mammal size
categories. It is presumed that nursery ornamentals are not intended to
present forage, and that efforts are made by operators to make the
plants unappealing to wildlife. However, non-target plants may receive
unintentional exposure and may be used by wildlife as forage. While the
areal extent of ADBAC application in nurseries is not known, these uses
may present a risk to wildlife in proximity to nurseries.

*Turf and Golf Courses*

These uses have two considerably different maximum application rates.
The type of sprayer used determines which maximum rate can be used. For
commercial power sprayers, presumably used on golf course fairways and
larger commercial lawns, the label allows a rate of 0.8 lbs ai/A. For
other sprayers, the labels allow a rate of 6.8 lbs ai/A. The distinction
between these types of sprayers is not further delineated, which
presumably leaves interpretation to the applicator.

Because the labels lack limits on the number of applications that can be
made per year, the scenarios presented in the Risk Estimation section of
this document represent high-end usage patterns, though not necessarily
the maximum allowable. For example, the 0.8 lbs ai/A rate is modeled
assuming 26 applications at 10 day intervals, the minimum allowable
interval for this use on the label. However, there could be situations
where 36 applications could occur, since there is no restriction on the
maximum number of applications. Since many of the target pathogens
thrive in warm humid weather, applicators in areas with such climatic
conditions year round could choose to apply ADBAC at the limit. In such
situations, the RQs for all wildlife would increase by about 25%. In
areas where growth conditions for the target pathogens are less ideal,
fewer applications may be necessary, with an associated decrease in the
RQs for wildlife.

*Aquatic*

As the number of applications decline, so do the aquatic RQs. At 26
applications at the 0.8 lbs ai/A rate, acute RQs meet or exceed the
acute risk to endangered species LOC for freshwater and estuarine/marine
fish. Applications of ten, five and one per year were also modeled
(Table 4.13) and the LOC is not exceeded. The same pattern of decreasing
RQs is found for invertebrates, but exceedances are not fully mitigated
by limiting the number of applications. Acute freshwater invertebrate
RQs remain above the acute risk LOC at five applications and the acute
risk to endangered species LOC is exceeded after a single application.
Acute estuarine/marine RQs remain above the restricted use LOC at after
10 applications, and above the acute risk to endangered species LOC
after five applications.

Table 4.13. Acute and chronic RQs from different numbers of applications
per year, assuming a rate of 0.8 lbs ai/A over 25 acres.

  -------------- ---------- ---------- ----------- ------------------- ----------- ---------- ------------
  **Scenario**   **Number   **acute FW **chronic   **acute FW invert** **chronic   **acute    **acute
                 of App.**  fish**     FW fish**                       FW invert** Est/Mar    Est/Mar
                                                                                   fish**     invert**

  FL turf        26         **0.06**   0.48        **[2.64]{.mark}**   **2.27**    **0.05**   ***0.28***

                 10         0.02       0.19        **[1.02]{.mark}**   0.87        0.02       ***0.11***

                 5          0.01       0.10        **[0.53]{.mark}**   0.43        0.01       **0.06**

                 1          0.00       0.02        ***0.11***          0.09        0.00       0.01

  PA turf        26         **0.07**   0.64        **[3.49]{.mark}**   **2.63**    **0.07**   ***0.37***

                 10         0.03       0.24        **[1.32]{.mark}**   **1.01**    0.03       ***0.14***

                 5          0.01       0.12        **[0.66]{.mark}**   0.51        0.01       **0.07**

                 1          0.00       0.02        ***0.14***          0.10        0.00       0.01
  -------------- ---------- ---------- ----------- ------------------- ----------- ---------- ------------

[Exceeds acute risk LOC (0.5)]{.mark}

*Exceeds restricted use LOC (0.1)*

**Exceeds listed spp LOC (0.05) or chronic risk LOC (1.0)**

At the 6.8 lbs ai/A rate, allowed by the label if the applicator is not
using 'commercial power sprayers', RQs exceed the restricted use and
chronic risk LOCs for fish and both the acute and chronic LOCs for
invertebrates. These RQs are calculated assuming 10 applications per
year, though the label doesn't limit the number of applications per
year. Therefore, if additional applications are made, the RQs would be
higher. However, there is uncertainty about how much area will actually
be treated at this rate. Several different application areas are modeled
to explore the effect area treated would have on the RQs, assuming a
linear relationship between area applied and EEC (Table 4.14). It is
conceivable that aggregate use in a community could approach 25 acres
treated in a given area, and a half acre treated is considered a
reasonable low-end assumption. Like the previous scenario, RQs are
greatest for aquatic invertebrates, where even at the smallest treatment
area, the restricted use LOC is exceeded.

Table 4.14. Acute and chronic RQs from different size areas treated,
assuming a rate of 6.8 lbs ai/A and 10 applications per year.

  -------------- ----------- ------------ ----------- -------------------- ----------- ------------ -------------------
  **Scenario**   **Acres     **acute FW   **chronic   **acute FW invert**  **chronic   **acute      **acute Est/Mar
                 treated**   fish**       FW fish**                        FW invert** Est/Mar      invert**
                                                                                       fish**       

  FL turf        25          ***0.18***   **1.53**    **[8.34]{.mark}**    **6.39**    ***0.16***   **[0.89]{.mark}**

                 10          **0.07**     0.61        **[3.34]{.mark}**    **2.55**    **0.06**     ***0.36***

                 1           0.01         0.06        ***0.33***           0.26        0.01         0.04

                 0.5         0.00         0.03        ***0.17***           0.13        0.00         0.02

  PA turf        25          ***0.22***   **1.94**    **[10.59]{.mark}**   **7.30**    ***0.20***   **[1.14]{.mark}**

                 10          **0.09**     0.78        **[4.24]{.mark}**    **2.92**    **0.08**     ***0.45***

                 1           0.01         0.08        ***0.42***           0.29        0.01         **0.05**

                 0.5         0.00         0.04        ***0.21***           0.15        0.00         0.02
  -------------- ----------- ------------ ----------- -------------------- ----------- ------------ -------------------

[Exceeds acute risk LOC (0.5)]{.mark}

*Exceeds restricted use LOC (0.1)*

**Exceeds listed spp LOC (0.05) or chronic risk LOC (1.0)**

*Terrestrial*

The avian and mammalian model, TREX assumes wildlife is present and
foraging on the treated area; therefore no area adjustment is necessary.
For these scenarios, drift is not considered for exposure; it would be
some fraction of the application rate but is not routinely considered in
screening-level assessments. The terrestrial RQ values are based on
upper bound exposure estimates. The mean exposure values are somewhat
lower; however, 50% of the time, exposure values would be expected to
exceed the means. Where multiple applications are considered, the
default foliar half-life of 35 days is used. If data were submitted to
show that the actual foliar half-life were shorter than the default
value, the RQs would be somewhat lower.

*Avian*

While ADBAC is classified as moderately toxic to birds on an acute
exposure basis, the avian acute LOC was exceed by two- to 24-fold for
most forage items at the 0.8 lbs ai/A rate, assuming 26 applications at
10 day intervals. The acute risk to endangered species LOC is exceeded
for all size birds foraging on all of the feed items evaluated. Several
alternate numbers of applications are explored to see the effect on the
RQs (Table 4.15). Reducing the number of applications to just one still
results in RQs exceeding the acute risk to endangered species LOC for
all categories except 100g and 1000g birds foraging on fruit/pods/large
insects. Avian reproduction studies were not submitted for ADBAC,
therefore chronic avian risk cannot be assessed. In the absence of data,
risk is presumed.

Table 4.15. Acute avian RQs resulting from different numbers of
applications pre year.

  --------- -------- ------------ ------------- -------------------- ------------------- -------------------
  ** **     **App    **Number**   **Forage**    **Dose-based RQs**                       
            rate**                                                                       

  **Use**   **lb     **apps**     **Item(s)**   **20g**              **100g**            **1000g**
            ai/A**                                                                       

  Turf      0.8      10           short grass   **[10.71]{.mark}**   **[4.80]{.mark}**   **[1.52]{.mark}**

                                  tall grass    **[4.91]{.mark}**    **[2.20]{.mark}**   **[0.70]{.mark}**

                                  bdlf/sm ins   **[6.02]{.mark}**    **[2.70]{.mark}**   **[0.86]{.mark}**

                                  Fr/pods/lg    **[0.67]{.mark}**    ***0.30***          **0.10**
                                  ins                                                    

                     5            short grass   **[7.81]{.mark}**    **[3.50]{.mark}**   **[1.11]{.mark}**

                                  tall grass    **[3.58]{.mark}**    **[1.60]{.mark}**   **[0.51]{.mark}**

                                  bdlf/sm ins   **[4.39]{.mark}**    **[1.97]{.mark}**   **[0.62]{.mark}**

                                  Fr/pods/lg    ***0.49***           ***0.22***          0.07
                                  ins                                                    

                     1            short grass   **[2.23]{.mark}**    **[1.00]{.mark}**   ***0.32***

                                  tall grass    **[1.02]{.mark}**    ***0.46***          **0.15**

                                  bdlf/sm ins   **[1.26]{.mark}**    **[0.56]{.mark}**   **0.18**

                                  Fr/pods/lg    **0.14**             0.06                0.02
                                  ins                                                    
  --------- -------- ------------ ------------- -------------------- ------------------- -------------------

[Exceeds acute risk LOC (0.5)]{.mark}

*Exceeds restricted use LOC (0.2)*

**Exceeds listed spp LOC (0.1)**

For the 6.8 lbs ai/A application rate, at the assumed 10 applications
per year at 10 day intervals, the acute risk LOC is exceeded for all
size birds for all forage items. Since the label does not limit the
number of applications, these RQs may not be indicative of actual risk,
as more applications would increase the RQ values. To establish a
base-line, one application is modeled at this rate (Table 4.16). One
application of ADBAC at the label rate of 6.8 lbs ai/A results in
exceedances of the acute risk LOC for all forage items and all size
birds, except 1000g birds foraging on fruits/pods/large insects. That
exception still exceeds the acute risk to endangered species LOC though.
While RQs cannot be calculated for chronic risk to birds, chronic risk
is presumed.

Table 4.16. Acute RQs for avian wildlife resulting from use of ADBAC on
lawns/turf at the maximum rate of 6.8 lb ai/A, applied once per year.

  ------------------------------ -------------------- ------------------- -------------------
                                 **20 g**             **100 g**           **1000 g**

  **Short Grass**                **[18.97]{.mark}**   **[8.50]{.mark}**   **[2.69]{.mark}**

  **Tall Grass**                 **[8.69]{.mark}**    **[3.89]{.mark}**   **[1.23]{.mark}**

  **Broadleaf plants/sm          **[10.67]{.mark}**   **[4.78]{.mark}**   **[1.51]{.mark}**
  insects**                                                               

  **Fruits/pods/seeds/lg         **[1.19]{.mark}**    **[0.53]{.mark}**   **0.17**
  insects**                                                               
  ------------------------------ -------------------- ------------------- -------------------

[Exceeds acute risk LOC (0.5)]{.mark}

*Exceeds restricted use LOC (0.2)*

**Exceeds listed spp LOC (0.1)**

[]{.mark}

*Mammals*

As seen in the Risk Estimation section of this document, there are acute
and chronic risk LOC exceedances for all size classes and most forage
items when the 0.8 lbs ai/A rate is modeled assuming 26 applications at
10 day intervals. Again, since it possible to have more than 26
applications in a given year, those RQs are not entirely conservative.
However, to provide a sense of perspective, RQs resulting from a single
application are modeled (Table 4.17). One application results in acute
risk to endangered species LOC exceedances for 15g and 35g mammals
foraging on short grass, 15g mammals foraging on broadleaf plants/small
insects; additionally, the chronic risk LOC is exceeded for those same
categories. Given the nature of the target pathogens, it does not seem
likely that one application would be sufficient to achieve control.
Therefore, five applications at 10 day intervals are also modeled
(Table. 4.18). Resulting RQs increase approximately three-fold and many
more LOCs are exceeded. The typical number of applications at this rate
is unknown for these products.

Table 4.17. Acute and chronic dose-based RQs for mammalian wildlife
resulting from use of ADBAC on turf/golf courses at the maximum rate of
0.8 lb ai/A, applied once (exceedances in bold).

  ------------------- ----------- ------------- ----------- ------------- ----------- -------------
                      **15 g                    **35 g                    **1000 g    
                      mammal**                  mammal**                  mammal**    

                                                                                      

                      **Acute**   **Chronic**   **Acute**   **Chronic**   **Acute**   **Chronic**

  **Short Grass**     **0.19**    **1.89**      **0.17**    **1.62**      0.09        0.87

  **Tall Grass**      0.09        0.87          0.08        0.74          0.04        0.40

  **Broadleaf         **0.11**    **1.06**      0.09        0.91          0.05        0.49
  plants/sm insects**                                                                 

  **Fruits/pods/lg    0.01        0.12          0.01        0.10          0.01        0.05
  insects**                                                                           
  ------------------- ----------- ------------- ----------- ------------- ----------- -------------

**[Exceeds acute risk LOC (0.5)]{.mark}**

*Exceeds restricted use LOC (0.2)*

**Exceeds listed spp LOC (0.1)**

Table 4.18. Acute and chronic dose-based RQs for mammalian wildlife
resulting from use of ADBAC on turf/golf courses at the maximum rate of
0.8 lb ai/A, applied five times with a 10 day interval.

  ------------------- ------------------- ------------- ------------------- ------------- ------------ -------------
                      **15 g mammal**                   **35 g mammal**                   **1000 g     
                                                                                          mammal**     

                                                                                                       

                      **Acute**           **Chronic**   **Acute**           **Chronic**   **Acute**    **Chronic**

  **Short Grass**     **[0.68]{.mark}**   **6.62**      **[0.58]{.mark}**   **5.66**      ***0.31***   **3.03**

  **Tall Grass**      ***0.31***          **3.04**      ***0.27***          **2.59**      ***0.14***   **1.39**

  **Broadleaf         ***0.38***          **3.72**      ***0.33***          **3.18**      ***0.17***   **1.71**
  plants/sm insects**                                                                                  

  **Fruits/pods/lg    0.04                0.41          0.04                0.35          0.02         0.19
  insects**                                                                                            
  ------------------- ------------------- ------------- ------------------- ------------- ------------ -------------

**[Exceeds acute risk LOC (0.5)]{.mark}**

*Exceeds restricted use LOC (0.2)*

**Exceeds listed spp LOC (0.1)**

[]{.mark}

At the higher application rate (6.8 lbs ai/A), the acute risk LOC is
exceeded four- to 16-fold for all size class mammals foraging on short
grass, tall grass and broadleaf plants/small insects. The restricted use
LOC is exceeded for all size classes foraging on fruits/pods/large
insects. The chronic risk LOC is exceeded for all size classes and
forage items. These exceedances result from 10 applications at 10 day
intervals. However, if only five applications are made, there would
still be exceedances of acute and chronic LOCs for all forage items and
all size classes. In fact, at the 6.8 lbs ai/A rate, there would still
be acute, restricted use and acute risk to endangered species LOC
exceedances for all categories except the 35g and 1000g size classes
foraging on fruits/pods/large insects. Chronic RQs would also exceed the
LOC in the same categories.

*Mosquito control*

Since ADBAC is applied directly to target waterbodies, disconnected from
the greater watershed, limited exposure to non-target aquatic wildlife
is expected; however, ephemeral pools and ornamental ponds often play an
important role in the lifecycle of amphibians. The label does not
preclude potential exposure to these organisms and therefore these uses
may pose a significant risk to amphibians. EFED uses freshwater fish as
surrogate for aquatic-phase amphibians. At the initial concentration of
200 ppm, the acute RQ would be 0.71, which exceeds LOC. The chronic RQ,
based on a concentration of 200 ppm would be 6.1, which also exceeds the
LOC.

As stated previously, drinking water is presumed to be the most likely
route of exposure to terrestrial wildlife from these uses. Terrestrial
wildlife exposure via forage items is also expected to be low, due to
the application method and the limited scale of the target waterbody.
Estimated exposure via drinking water is based on allometric equations,
specific to birds and mammals (Appendix C), that are used to calculate
daily pesticide exposure, assuming the animal gets 100% of its water
from the treated water. However, it is possible that to small (15-g)
mammals feeding on short grasses, an ephemeral pond could represent a
sizable area in which to forage. Grasses may preferentially grow along
or within these areas and attract these animals.

At the labeled rate of 200 ppm in the target waterbody, RQs exceed the
acute risk to endangered species LOC for birds in the 20g and 100 g size
classes. The restricted use LOC is exceeded for 20g birds. An increase
in concentration to 220 ppm in the drinking water source would elevate
the RQ for 1000g birds above the acute risk to endangered species LOC.
Due to lack of data on chronic toxicity of ADBAC to birds, chronic RQs
cannot be calculated and chronic risk is assumed.

Neither acute nor chronic mammalian RQs are exceeded at 200 ppm. The
acute RQ for 15g mammals would exceed the acute risk to endangered
species LOC at a concentration of 280 ppm. The acute RQs for mammals of
all size classes exceed the acute risk to endangered species LOC at a
concentration of 450 ppm, though at this concentration, restricted use
LOC is not exceeded. The chronic risk LOC for 15g mammals would be
exceeded at a concentration of 300 ppm and exceeded for mammals of all
size classes at a concentration of 450 ppm.

The fate of the initial concentrations of ADBAC is unknown, and
therefore subsequent weekly 'maintenance' applications of 100 ppm may
result in cumulative concentration greater than the initial 200 ppm. If
each application were wholly cumulative (i.e. no dissipation), the
concentration in any given treated waterbody after five weeks would be
600 ppm. The likelihood of reaching these concentrations from these
labeled uses is not known; it is clear that at such a concentration,
calculable RQs would exceed LOCs for wildlife many-fold.

The labels should state specific limitations, such as size of target
waterbodies and application timing, which could mitigate potential
exposure to non-target organisms. Due to the lack of explicit
limitations on the labels, risk to non-target organisms may be
under-estimated in this assessment.

*Puddles, Ornamental Ponds and Pools*

The risk to terrestrial wildlife from this use appears to be minimal,
based on the initial target concentration of 5 ppm. Calculable RQs all
fall below 0.01, and the most conservative LOC for terrestrial animals
is 0.1, for threatened and endangered species. Exposure to fish and
non-target populations of aquatic invertebrates is likely to be minimal,
based on label descriptions; specific limitations in number of
applications and size of target waterbody should be stated on the
labels. However, ephemeral waterbodies play an important role in the
lifecycle of amphibians. The label does not preclude potential exposure
to these organisms and therefore these uses may pose a risk to
amphibians. EFED uses freshwater fish as surrogate for aquatic-phase
amphibians. At the initial concentration of 5 ppm, both the acute and
chronic RQs are well below the LOCs. The acute listed species LOC is
exceeded at 15 ppm and the chronic LOC is exceeded at 35 ppm. Thus,
multiple applications, as allowed by the label, may result in acute
and/or chronic risk to listed amphibians.

Since this use is the only one identified as of concern to EFED
containing DDAC, it appears that ADBAC and DDAC are of low concern for
terrestrial wildlife exposure for these uses. DDAC would be of concern
if avian or mammalian endpoints were significantly more sensitive
(\>10X) than for ADBAC; however, since toxicity of DDAC is unavailable
for this assessment, potential risk due to DDAC remains an uncertainty.
This use would also be of concern if concentrations in target
waterbodies increase due to repeated applications.

The fate of the initial applications of ADBAC and DDAC is unknown. Since
the label allows weekly application of 2.5 ppm, after the initial 5 ppm
application, it is possible a cumulative concentration of greater than 5
ppm may occur. If each application were cumulative (i.e. no
dissipation), the concentration in any given treated waterbody after
five weeks would be 20 ppm. The LOC for listed mammals in the 15g size
class is exceeded at concentrations greater than 280 ppm and for listed
birds in the 20g size class at \>65 ppm. The likelihood of reaching
these concentrations from these labeled uses it uncertain; however,
given the chemical's persistence and immobility, it is likely that
concentrations would increase with repeatedly applications.

Additionally, the lack of data on the chronic toxicity of ADBAC and DDAC
on birds makes quantified chronic risk estimation impossible

**5 Threatened and Endangered Species Concerns**

**5.1 Action Area**

For listed species assessment purposes, the action area is considered to
be the area affected directly or indirectly by the Federal action and
not merely the immediate area involved in the action. At the initial
screening-level, the risk assessment considers broadly described
taxonomic groups and so conservatively assumes that listed species
within those broad groups are co-located with the pesticide treatment
area. This means that terrestrial plants and wildlife are assumed to be
located on or adjacent to the treated site and aquatic organisms are
assumed to be located in a surface water body adjacent to the treated
site. The assessment also assumes that the listed species are located
within an assumed area that has the relatively highest potential
exposure to the pesticide, and that exposures are likely to decrease
with distance from the treatment area.

If the assumptions associated with the screening-level action area
result in RQs that are below the listed species LOCs, a \"no effect\"
determination conclusion is made with respect to listed species in that
taxa, and no further refinement of the action area is necessary.
Furthermore, RQs below the listed species LOCs for a given taxonomic
group indicate no concern for indirect effects upon listed species that
depend upon the taxonomic group covered by the RQ as a resource.
However, in situations where the screening assumptions lead to RQs in
excess of the listed species LOCs for a given taxonomic group, a
potential for a \"may affect\" conclusion exists and may be associated
with direct effects on listed species belonging to that taxonomic group
or may extend to indirect effects upon listed species that depend upon
that taxonomic group as a resource. In such cases, additional
information on the biology of listed species, the locations of these
species, and the locations of use sites could be considered to determine
the extent to which screening assumptions regarding an action area apply
to a particular listed organism. These subsequent refinement steps could
consider how this information would impact the action area for a
particular listed organism and may potentially include areas of exposure
that are downwind and downstream of the pesticide use site.

**5.2 Taxonomic Groups Potentially at Risk**

Based on available screening level information, it is possible that
ADBAC may have acute and/or chronic toxic effects on endangered or
threatened aquatic or terrestrial organisms. Should estimated exposure
levels occur in proximity to listed resources, the available screening
level information suggests a potential concern for effects on some
listed species associated with the outdoor use of ADBAC. This screening
assessment is based on the initial assumption that listed species within
the taxonomic groups of concern are actually present in areas for which
the estimated exposure levels used for RQ calculation can be expected to
occur. A specific determination of "may affect" for any RQ in excess of
listed species LOCs cannot be made without further refinement of the
co-occurrence of listed species in ADBAC use areas.

The LOCATES database was used to identify those U.S. counties that have
nurseries and have Federally listed endangered or threatened species. A
count summary of listed taxa that have been known to occur in those
areas is presented in **Appendix D**, by State. Further refinements to
the risk assessment must be made for the Agency to be in compliance with
the Endangered Species Act and to determine the need for consultation
with the Services. There is no general scenario for determining the
co-occurrence of turf or golf courses with listed species.

# Appendix A. PRZM/EXAMS Input Files {#appendix-a.-przmexams-input-files .unnumbered}

**FL Turf (0.8 lbs ai/A; 26 applications/year)**

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: FLturf26

Metfile: w12834.dvf

PRZM scenario: FLturfC.txt

EXAMS environment file: pond298.exv

Chemical Name: ADBAC

Description Variable Name Value Units Comments

Molecular weight mwt 368.05 g/mol

Henry\'s Law Const. henry 7.76e-13 atm-m\^3/mol

Vapor Pressure vapr 3.53e-12 torr

Solubility sol 184.4 mg/L

Kd Kd mg/L

Koc Koc 2.7e6 mg/L

Photolysis half-life kdp 0 days Half-life

Aerobic Aquatic Metabolism kbacw 0 days Halfife

Anaerobic Aquatic Metabolism kbacs 5445 days Halfife

Aerobic Soil Metabolism asm 0 days Halfife

Hydrolysis: pH 7 183 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 0.9 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 2-1 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 10 days Set to 0 or delete line for single app.

Interval 2 interval 10 days Set to 0 or delete line for single app.

Interval 3 interval 10 days Set to 0 or delete line for single app.

Interval 4 interval 10 days Set to 0 or delete line for single app.

Interval 5 interval 10 days Set to 0 or delete line for single app.

Interval 6 interval 10 days Set to 0 or delete line for single app.

Interval 7 interval 10 days Set to 0 or delete line for single app.

Interval 8 interval 10 days Set to 0 or delete line for single app.

Interval 9 interval 10 days Set to 0 or delete line for single app.

Interval 10 interval 10 days Set to 0 or delete line for single app.

Interval 11 interval 10 days Set to 0 or delete line for single app.

Interval 12 interval 10 days Set to 0 or delete line for single app.

Interval 13 interval 10 days Set to 0 or delete line for single app.

Interval 14 interval 10 days Set to 0 or delete line for single app.

Interval 15 interval 10 days Set to 0 or delete line for single app.

Interval 16 interval 10 days Set to 0 or delete line for single app.

Interval 17 interval 10 days Set to 0 or delete line for single app.

Interval 18 interval 10 days Set to 0 or delete line for single app.

Interval 19 interval 10 days Set to 0 or delete line for single app.

Interval 20 interval 10 days Set to 0 or delete line for single app.

Interval 21 interval 10 days Set to 0 or delete line for single app.

Interval 22 interval 10 days Set to 0 or delete line for single app.

Interval 23 interval 10 days Set to 0 or delete line for single app.

Interval 24 interval 10 days Set to 0 or delete line for single app.

Interval 25 interval 10 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND 1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of
entire run)

**FL Turf (0.8 lbs ai/A; 10 applications/year)**

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: FLturf10

Metfile: w12834.dvf

PRZM scenario: FLturfC.txt

EXAMS environment file: pond298.exv

Chemical Name: ADBAC

Description Variable Name Value Units Comments

Molecular weight mwt 368.05 g/mol

Henry\'s Law Const. henry 7.76e-13 atm-m\^3/mol

Vapor Pressure vapr 3.53e-12 torr

Solubility sol 184.4 mg/L

Kd Kd mg/L

Koc Koc 2.7e6 mg/L

Photolysis half-life kdp 0 days Half-life

Aerobic Aquatic Metabolism kbacw 0 days Halfife

Anaerobic Aquatic Metabolism kbacs 5445 days Halfife

Aerobic Soil Metabolism asm 0 days Halfife

Hydrolysis: pH 7 183 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 0.9 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 1-4 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 10 days Set to 0 or delete line for single app.

Interval 2 interval 10 days Set to 0 or delete line for single app.

Interval 3 interval 10 days Set to 0 or delete line for single app.

Interval 4 interval 10 days Set to 0 or delete line for single app.

Interval 5 interval 10 days Set to 0 or delete line for single app.

Interval 6 interval 10 days Set to 0 or delete line for single app.

Interval 7 interval 10 days Set to 0 or delete line for single app.

Interval 8 interval 10 days Set to 0 or delete line for single app.

Interval 9 interval 10 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND 1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of
entire run)

**FL Turf (0.8 lbs ai/A; 5 applications/year)**

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: FLturf5

Metfile: w12834.dvf

PRZM scenario: FLturfC.txt

EXAMS environment file: pond298.exv

Chemical Name: ADBAC

Description Variable Name Value Units Comments

Molecular weight mwt 368.05 g/mol

Henry\'s Law Const. henry 7.76e-13 atm-m\^3/mol

Vapor Pressure vapr 3.53e-12 torr

Solubility sol 184.4 mg/L

Kd Kd mg/L

Koc Koc 2.7e6 mg/L

Photolysis half-life kdp 0 days Half-life

Aerobic Aquatic Metabolism kbacw 0 days Halfife

Anaerobic Aquatic Metabolism kbacs 5445 days Halfife

Aerobic Soil Metabolism asm 0 days Halfife

Hydrolysis: pH 7 183 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 0.9 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 1-4 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 10 days Set to 0 or delete line for single app.

Interval 2 interval 10 days Set to 0 or delete line for single app.

Interval 3 interval 10 days Set to 0 or delete line for single app.

Interval 4 interval 10 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND 1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of
entire run)

**FL Turf (0.8 lbs ai/A; 1 applications/year)**

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: FLturf1

Metfile: w12834.dvf

PRZM scenario: FLturfC.txt

EXAMS environment file: pond298.exv

Chemical Name: ADBAC

Description Variable Name Value Units Comments

Molecular weight mwt 368.05 g/mol

Henry\'s Law Const. henry 7.76e-13 atm-m\^3/mol

Vapor Pressure vapr 3.53e-12 torr

Solubility sol 184.4 mg/L

Kd Kd mg/L

Koc Koc 2.7e6 mg/L

Photolysis half-life kdp 0 days Half-life

Aerobic Aquatic Metabolism kbacw 0 days Halfife

Anaerobic Aquatic Metabolism kbacs 5445 days Halfife

Aerobic Soil Metabolism asm 0 days Halfife

Hydrolysis: pH 7 183 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 0.9 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 1-4 dd/mm or dd/mmm or dd-mm or dd-mmm

Record 17: FILTRA

IPSCND 1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of
entire run)

**FL Turf (6.8 lbs ai/A; 10 applications/year)**

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: FLturfRES

Metfile: w12834.dvf

PRZM scenario: FLturfC.txt

EXAMS environment file: pond298.exv

Chemical Name: ADBAC

Description Variable Name Value Units Comments

Molecular weight mwt 368.05 g/mol

Henry\'s Law Const. henry 7.76e-13 atm-m\^3/mol

Vapor Pressure vapr 3.53e-12 torr

Solubility sol 184.4 mg/L

Kd Kd mg/L

Koc Koc 2.7e6 mg/L

Photolysis half-life kdp 0 days Half-life

Aerobic Aquatic Metabolism kbacw 0 days Halfife

Anaerobic Aquatic Metabolism kbacs 5445 days Halfife

Aerobic Soil Metabolism asm 0 days Halfife

Hydrolysis: pH 7 183 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 7.62 kg/ha

Application Efficiency: APPEFF .99 fraction

Spray Drift DRFT .01 fraction of application rate applied to pond

Application Date Date 1-4 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 10 days Set to 0 or delete line for single app.

Interval 2 interval 10 days Set to 0 or delete line for single app.

Interval 3 interval 10 days Set to 0 or delete line for single app.

Interval 4 interval 10 days Set to 0 or delete line for single app.

Interval 5 interval 10 days Set to 0 or delete line for single app.

Interval 6 interval 10 days Set to 0 or delete line for single app.

Interval 7 interval 10 days Set to 0 or delete line for single app.

Interval 8 interval 10 days Set to 0 or delete line for single app.

Interval 9 interval 10 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND 1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of
entire run)

**PA Turf (0.8 lbs ai/A; 26 applications/year)**

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: PAturf26

Metfile: w14737.dvf

PRZM scenario: PAturfC.txt

EXAMS environment file: pond298.exv

Chemical Name: ADBAC

Description Variable Name Value Units Comments

Molecular weight mwt 368.05 g/mol

Henry\'s Law Const. henry 7.76e-13 atm-m\^3/mol

Vapor Pressure vapr 3.53e-12 torr

Solubility sol 184.4 mg/L

Kd Kd mg/L

Koc Koc 2.7e6 mg/L

Photolysis half-life kdp 0 days Half-life

Aerobic Aquatic Metabolism kbacw 0 days Halfife

Anaerobic Aquatic Metabolism kbacs 5445 days Halfife

Aerobic Soil Metabolism asm 0 days Halfife

Hydrolysis: pH 7 183 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 0.9 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 2-1 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 10 days Set to 0 or delete line for single app.

Interval 2 interval 10 days Set to 0 or delete line for single app.

Interval 3 interval 10 days Set to 0 or delete line for single app.

Interval 4 interval 10 days Set to 0 or delete line for single app.

Interval 5 interval 10 days Set to 0 or delete line for single app.

Interval 6 interval 10 days Set to 0 or delete line for single app.

Interval 7 interval 10 days Set to 0 or delete line for single app.

Interval 8 interval 10 days Set to 0 or delete line for single app.

Interval 9 interval 10 days Set to 0 or delete line for single app.

Interval 10 interval 10 days Set to 0 or delete line for single app.

Interval 11 interval 10 days Set to 0 or delete line for single app.

Interval 12 interval 10 days Set to 0 or delete line for single app.

Interval 13 interval 10 days Set to 0 or delete line for single app.

Interval 14 interval 10 days Set to 0 or delete line for single app.

Interval 15 interval 10 days Set to 0 or delete line for single app.

Interval 16 interval 10 days Set to 0 or delete line for single app.

Interval 17 interval 10 days Set to 0 or delete line for single app.

Interval 18 interval 10 days Set to 0 or delete line for single app.

Interval 19 interval 10 days Set to 0 or delete line for single app.

Interval 20 interval 10 days Set to 0 or delete line for single app.

Interval 21 interval 10 days Set to 0 or delete line for single app.

Interval 22 interval 10 days Set to 0 or delete line for single app.

Interval 23 interval 10 days Set to 0 or delete line for single app.

Interval 24 interval 10 days Set to 0 or delete line for single app.

Interval 25 interval 10 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND 1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of
entire run)

**PA Turf (0.8 lbs ai/A; 10 applications/year)**

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: PAturf10

Metfile: w14737.dvf

PRZM scenario: PAturfC.txt

EXAMS environment file: pond298.exv

Chemical Name: ADBAC

Description Variable Name Value Units Comments

Molecular weight mwt 368.05 g/mol

Henry\'s Law Const. henry 7.76e-13 atm-m\^3/mol

Vapor Pressure vapr 3.53e-12 torr

Solubility sol 184.4 mg/L

Kd Kd mg/L

Koc Koc 2.7e6 mg/L

Photolysis half-life kdp 0 days Half-life

Aerobic Aquatic Metabolism kbacw 0 days Halfife

Anaerobic Aquatic Metabolism kbacs 5445 days Halfife

Aerobic Soil Metabolism asm 0 days Halfife

Hydrolysis: pH 7 183 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 0.9 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 1-5 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 10 days Set to 0 or delete line for single app.

Interval 2 interval 10 days Set to 0 or delete line for single app.

Interval 3 interval 10 days Set to 0 or delete line for single app.

Interval 4 interval 10 days Set to 0 or delete line for single app.

Interval 5 interval 10 days Set to 0 or delete line for single app.

Interval 6 interval 10 days Set to 0 or delete line for single app.

Interval 7 interval 10 days Set to 0 or delete line for single app.

Interval 8 interval 10 days Set to 0 or delete line for single app.

Interval 9 interval 10 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND 1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of
entire run)

**PA Turf (0.8 lbs ai/A; 5 applications/year)**

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: PAturf5

Metfile: w14737.dvf

PRZM scenario: PAturfC.txt

EXAMS environment file: pond298.exv

Chemical Name: ADBAC

Description Variable Name Value Units Comments

Molecular weight mwt 368.05 g/mol

Henry\'s Law Const. henry 7.76e-13 atm-m\^3/mol

Vapor Pressure vapr 3.53e-12 torr

Solubility sol 184.4 mg/L

Kd Kd mg/L

Koc Koc 2.7e6 mg/L

Photolysis half-life kdp 0 days Half-life

Aerobic Aquatic Metabolism kbacw 0 days Halfife

Anaerobic Aquatic Metabolism kbacs 5445 days Halfife

Aerobic Soil Metabolism asm 0 days Halfife

Hydrolysis: pH 7 183 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 0.9 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 1-5 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 10 days Set to 0 or delete line for single app.

Interval 2 interval 10 days Set to 0 or delete line for single app.

Interval 3 interval 10 days Set to 0 or delete line for single app.

Interval 4 interval 10 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND 1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of
entire run)

**PA Turf (0.8 lbs ai/A; 1 applications/year)**

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: PAturf1

Metfile: w14737.dvf

PRZM scenario: PAturfC.txt

EXAMS environment file: pond298.exv

Chemical Name: ADBAC

Description Variable Name Value Units Comments

Molecular weight mwt 368.05 g/mol

Henry\'s Law Const. henry 7.76e-13 atm-m\^3/mol

Vapor Pressure vapr 3.53e-12 torr

Solubility sol 184.4 mg/L

Kd Kd mg/L

Koc Koc 2.7e6 mg/L

Photolysis half-life kdp 0 days Half-life

Aerobic Aquatic Metabolism kbacw 0 days Halfife

Anaerobic Aquatic Metabolism kbacs 5445 days Halfife

Aerobic Soil Metabolism asm 0 days Halfife

Hydrolysis: pH 7 183 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 0.9 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 1-5 dd/mm or dd/mmm or dd-mm or dd-mmm

Record 17: FILTRA

IPSCND 1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of
entire run)

**PA Turf (6.8 lbs ai/A; 10 applications/year)**

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: PAturfRES

Metfile: w14737.dvf

PRZM scenario: PAturfC.txt

EXAMS environment file: pond298.exv

Chemical Name: ADBAC

Description Variable Name Value Units Comments

Molecular weight mwt 368.05 g/mol

Henry\'s Law Const. henry 7.76e-13 atm-m\^3/mol

Vapor Pressure vapr 3.53e-12 torr

Solubility sol 184.4 mg/L

Kd Kd mg/L

Koc Koc 2.7e6 mg/L

Photolysis half-life kdp 0 days Half-life

Aerobic Aquatic Metabolism kbacw 0 days Halfife

Anaerobic Aquatic Metabolism kbacs 5445 days Halfife

Aerobic Soil Metabolism asm 0 days Halfife

Hydrolysis: pH 7 183 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 7.62 kg/ha

Application Efficiency: APPEFF .99 fraction

Spray Drift DRFT .01 fraction of application rate applied to pond

Application Date Date 1-5 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 10 days Set to 0 or delete line for single app.

Interval 2 interval 10 days Set to 0 or delete line for single app.

Interval 3 interval 10 days Set to 0 or delete line for single app.

Interval 4 interval 10 days Set to 0 or delete line for single app.

Interval 5 interval 10 days Set to 0 or delete line for single app.

Interval 6 interval 10 days Set to 0 or delete line for single app.

Interval 7 interval 10 days Set to 0 or delete line for single app.

Interval 8 interval 10 days Set to 0 or delete line for single app.

Interval 9 interval 10 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND 1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of
entire run)

**GA Pecans**

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: GApecans

Metfile: w93805.dvf

PRZM scenario: GAPecansC.txt

EXAMS environment file: pond298.exv

Chemical Name: ADBAC

Description Variable Name Value Units Comments

Molecular weight mwt 368.05 g/mol

Henry\'s Law Const. henry 7.76e-13 atm-m\^3/mol

Vapor Pressure vapr 3.53e-12 torr

Solubility sol 184.4 mg/L

Kd Kd mg/L

Koc Koc 2.7e6 mg/L

Photolysis half-life kdp 0 days Half-life

Aerobic Aquatic Metabolism kbacw 0 days Halfife

Anaerobic Aquatic Metabolism kbacs 5445 days Halfife

Aerobic Soil Metabolism asm 0 days Halfife

Hydrolysis: pH 7 183 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 339 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 10-5 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 7 days Set to 0 or delete line for single app.

Interval 2 interval 7 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND 1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of
entire run)

**OR Christmas Tree**

Inputs generated by pe4.pl - 8-August-2003

Data used for this run:

Output File: ORXmasstree

Metfile: w24232.dvf

PRZM scenario: ORXmasTreeC.txt

EXAMS environment file: pond298.exv

Chemical Name: ADBAC

Description Variable Name Value Units Comments

Molecular weight mwt 368.05 g/mol

Henry\'s Law Const. henry 7.76e-13 atm-m\^3/mol

Vapor Pressure vapr 3.53e-12 torr

Solubility sol 184.4 mg/L

Kd Kd mg/L

Koc Koc 2.7e6 mg/L

Photolysis half-life kdp 0 days Half-life

Aerobic Aquatic Metabolism kbacw 0 days Halfife

Anaerobic Aquatic Metabolism kbacs 5445 days Halfife

Aerobic Soil Metabolism asm 0 days Halfife

Hydrolysis: pH 7 183 days Half-life

Method: CAM 2 integer See PRZM manual

Incorporation Depth: DEPI cm

Application Rate: TAPP 339 kg/ha

Application Efficiency: APPEFF .95 fraction

Spray Drift DRFT .05 fraction of application rate applied to pond

Application Date Date 10-5 dd/mm or dd/mmm or dd-mm or dd-mmm

Interval 1 interval 7 days Set to 0 or delete line for single app.

Interval 2 interval 7 days Set to 0 or delete line for single app.

Record 17: FILTRA

IPSCND 1

UPTKF

Record 18: PLVKRT

PLDKRT

FEXTRC 0.5

Flag for Index Res. Run IR Pond

Flag for runoff calc. RUNOFF none none, monthly or total(average of
entire run)

Appendix B. Ecotoxicity

The ecotoxicologic endpoints used in this assessment are those used by
AD in their assessments. Refer to the RED details of the studies. The
endpoints are summarized and briefly described here. Only ADBAC is
considered in this section, as DDAC endpoints were not provided. As
described in other parts of this document, wildlife exposure to DDAC is
expected to be limited.

> **A. Toxicity to Terrestrial Animals**
>
> **(1) Avian, Acute and Chronic**

In order to establish the toxicity of ADBAC to avian species for indoor,
aquatic industrial, and wood preservative uses, the Agency requires an
acute oral toxicity study using the technical grade active ingredient
(TGAI). The preferred-test species is either mallard duck (a waterfowl)
or bobwhite quail (an upland game bird). The results of one acute oral
toxicity study, submitted for ADBAC, are provided in the following table
(Table 1). The results from the acceptable study indicate that ADBAC is
moderately toxic to avian species on an acute oral basis. The study
fulfills guideline requirements.

**Table 1. Acute Oral Toxicity of ADBAC to Birds**

+-----------+----------+----------+---------+---------------+--------+
| **        | **Che    | **En     | **T     | **Satisfies   | *      |
| Species** | mical,** | dpoint** | oxicity | Guidelines/** | *Refer |
|           |          |          | Cat     |               | ence** |
|           | **%      | **(      | egory** | **Comments**  |        |
|           | Active   | mg/kg)** |         |               | *      |
|           | Ingr     |          |         |               | *(MRID |
|           | edient** |          |         |               | No.)** |
|           |          |          |         |               |        |
|           | **       |          |         |               |        |
|           | (a.i.)** |          |         |               |        |
+-----------+----------+----------+---------+---------------+--------+
| Bobwhite  | ADBAC    | LD~50~ = | Mod     | Yes           | 428    |
| quail     | 80%      | 136      | erately |               | 859-01 |
|           |          |          | toxic   |               |        |
| (*Colinus |          | NOEC =   |         |               |        |
| vir       |          | 62.5     |         |               |        |
| ginianus* |          |          |         |               |        |
|           |          | (a.i.)   |         |               |        |
+-----------+----------+----------+---------+---------------+--------+

No data are available regarding the chronic toxicity of ADBAC to birds.
Chronic risk to avian species cannot be precluded in the absence of
data.

(2) **Mammals, Acute and Chronic Toxicity**

The endpoints used in this risk assessment were chosen by AD and used
without details of the studies available. The acute LD~50~ for rats
exposed to ADBAC is 430 mg/kg-bw (MRID 232269). The NOAEL, from a
chronic toxicity study with rats (MRID 41947501), is 44 mg/kg/day (1000
ppm).

> **B. Toxicity to Aquatic Animals**

The Agency requested that aquatic toxicity studies be conducted with
ADBAC since, under typical use conditions, it may be introduced into the
aquatic environment.

> **(1) Freshwater Fish, Acute**

In order to establish the acute toxicity of ADBAC to freshwater fish,
the Agency requires freshwater fish toxicity studies using the TGAI. The
preferred test species are rainbow trout (a coldwater fish) and bluegill
sunfish (a warmwater fish). Results of freshwater fish acute studies,
submitted for ADBAC and obtained from the open literature, are presented
in Table 3. The results indicate that ADBAC is highly toxic to on an
acute basis. The core studies fulfill guideline requirements.

**Table 3. Acute Toxicity of ADBAC to Freshwater Fish**

+-----------+--------+-----------+----------+---------------+--------+
| **        | *      | **E       | **       | **Satisfies   | *      |
| Species** | *Chemi | ndpoint** | Toxicity | Guidelines/** | *Refer |
|           | cal,** |           | Ca       |               | ence** |
|           |        | **(ppm)** | tegory** | **Comments**  |        |
|           | **%    |           |          |               | *      |
|           | Active |           |          |               | *(MRID |
|           | Ingred |           |          |               | No.)** |
|           | ient** |           |          |               |        |
|           |        |           |          |               |        |
|           | **(a   |           |          |               |        |
|           | .i.)** |           |          |               |        |
+===========+========+===========+==========+===============+========+
| Bluegill  | ADBAC  | LC~50~ =  | Highly   | Yes           | 419    |
| sunfish   | 30%\*  | 0.515     | toxic    |               | 472-01 |
| (*Lepomis |        |           |          | core study    |        |
| macr      |        | NOEC =    |          |               |        |
| ochirus)* |        | 0.456     |          |               |        |
|           |        |           |          |               |        |
|           |        | (a.i.)    |          |               |        |
+-----------+--------+-----------+----------+---------------+--------+
| Fathead   | ADBAC  | LC~50~ =  | Highly   | Yes           | 437    |
| minnow    |        | 0.28      | toxic    |               | 401-03 |
| (*P       | 80%    |           |          | core study    |        |
| imephales |        | NOEC = ND |          |               |        |
| p         |        |           |          |               |        |
| romelas)* |        | (a.i.)    |          |               |        |
+-----------+--------+-----------+----------+---------------+--------+
| Rainbow   | ADBAC  | LC~50~ =  | Highly   | Yes           | 419    |
| Trout     | 30%    | 0.923     | toxic    |               | 472-02 |
| (*Onc     |        |           |          | core study    |        |
| orhynchus |        | NOEC =    |          |               |        |
| mykiss)*  |        | 0.619     |          |               |        |
|           |        |           |          |               |        |
|           |        | (a.i.)    |          |               |        |
+-----------+--------+-----------+----------+---------------+--------+
| Rainbow   | ADBAC  | LC~50~ =  | Highly/  | No            | Dobbs, |
| Trout     |        | 1.01      | mo       |               | M.G.   |
| (O*nc     | 50%    |           | derately | open          | et al. |
| orhynchus |        | (a.i.)    | toxic    | literature    |        |
| mykiss*)  |        |           |          |               |        |
+-----------+--------+-----------+----------+---------------+--------+

**(2)** **Freshwater Invertebrates, Acute**

The Agency requires a freshwater aquatic invertebrate study using the
TGAI to establish the acute toxicity to freshwater invertebrates. The
preferred test species is *Daphnia magna*. Results of two studies,
submitted for ADBAC and obtained from the open literature, are provided
in the following table (Table 4). Results of the studies indicate that
ADBAC is very highly toxic to freshwater invertebrates. The guideline
requirement has been fulfilled.

**Table 4. Acute Toxicity of ADBAC to Freshwater Invertebrates**

+------------+----------+----------+--------+--------------+--------+
| *          | **Che    | **En     | **To   | **Satisfies  | *      |
| *Species** | mical,** | dpoint** | xicity | G            | *Refer |
|            |          |          | Cate   | uidelines/** | ence** |
|            | **%      | *        | gory** |              |        |
|            | Active   | *(ppm)** |        | **Comments** | *      |
|            | Ingr     |          |        |              | *(MRID |
|            | edient** |          |        |              | No.)** |
|            |          |          |        |              |        |
|            | **       |          |        |              |        |
|            | (a.i.)** |          |        |              |        |
+============+==========+==========+========+==============+========+
| Waterflea  | ADBAC    | EC~50~ = | Very   | Yes          | 419    |
| (*Daphnia  |          | 0.0059   | highly |              | 472-03 |
| magna)*    | 30%[^1]  |          | toxic  | core study   |        |
|            |          | NOEC =   |        |              |        |
|            |          | ND       |        |              |        |
|            |          | (a.i.)   |        |              |        |
+------------+----------+----------+--------+--------------+--------+
| Waterflea  | ADBAC    | LC~50~ = | Very   | No           | Dobbs, |
| (*Daphnia  |          | 0.02     | highly |              | M.G.,  |
| magna)*    | 50%      | (a.i.)   | toxic  | open         | et al. |
|            |          |          |        | literature   |        |
+------------+----------+----------+--------+--------------+--------+

> **(3) Estuarine and Marine Organisms, Acute**

Acute toxicity testing with estuarine and marine organisms using the
TGAI is required when the end-use product is intended for direct
application to the marine/estuarine environment or effluent containing
the active ingredient is expected to reach this environment. The
preferred fish test species is sheepshead minnow. The preferred
invertebrate test species are mysid shrimp and eastern oysters. This
testing is required for ADBAC based on the chemical's use in aquatic
sites such as pulp and paper mills, once-through cooling towers, oil
field recovery systems and as a wood preservative. Results of toxicity
studies, submitted for ADBAC and obtained from the open literature, are
presented in Table 5.

**Table 5. Acute Toxicity of ADBAC to Estuarine and Marine Organisms**

+-----------+--------+------------+--------+----------------+---------+
| **        | *      | **         | **To   | **Satisfies    | **Refe  |
| Species** | *Chemi | Endpoint** | xicity | Guidelines/**  | rence** |
|           | cal,** |            | Cate   |                |         |
|           |        | **(ppm     | gory** | **Comments**   | **(MRID |
|           | **%    | ai)**      |        |                | No.)**  |
|           | Active |            |        |                |         |
|           | Ingred |            |        |                |         |
|           | ient** |            |        |                |         |
|           |        |            |        |                |         |
|           | **(a   |            |        |                |         |
|           | .i.)** |            |        |                |         |
+===========+========+============+========+================+=========+
| S         | ADBAC  | LC~50~ =   | Highly | Yes            | 42      |
| heepshead | 80%    | 0.86       | toxic  |                | 4795-02 |
| minnow    |        |            |        | core study     |         |
| (*C       |        | NOEC =     |        |                |         |
| yprinodon |        | 0.68       |        |                |         |
| var       |        |            |        |                |         |
| iegatus*) |        |            |        |                |         |
+-----------+--------+------------+--------+----------------+---------+
| Inland    | ADBAC  | LC~50~ =   | Highly | No             | Dobbs,  |
| s         | 50%    | 0.31       | toxic  |                | M.G. et |
| ilverside |        |            |        | open           | al.     |
| (*Menidia |        |            |        | literature     |         |
| be        |        |            |        |                |         |
| ryllina)* |        |            |        |                |         |
+-----------+--------+------------+--------+----------------+---------+
| Mysid     | ADBAC  | LC~50~ =   | Very   | Yes            | 42      |
| shrimp    | 80%    | 0.092      | highly |                | 4795-01 |
| (*M       |        |            | toxic  | core study     |         |
| ysidopsis |        | NOEC =     |        |                |         |
| bahia)*   |        | 0.047      |        |                |         |
+-----------+--------+------------+--------+----------------+---------+
| Mysid     | ADBAC  | LC~50~ =   | Very   | No             | Dobbs,  |
| shrimp    | 50%    | 0.08       | highly |                | M.G. et |
| (*M       |        |            | toxic  | supplemental   | al.     |
| ysidopsis |        |            |        | study          |         |
| bahia*)   |        |            |        |                |         |
+-----------+--------+------------+--------+----------------+---------+
| Eastern   | ADBAC  | LC~50~ =   | Very   | No             | 42      |
| oyster    |        | 0.055      | highly |                | 4795-03 |
| (*Cr      | 80%    |            | toxic  | supplemental   |         |
| assostrea |        |            |        | study          |         |
| vi        |        |            |        |                |         |
| rginica*) |        |            |        |                |         |
+-----------+--------+------------+--------+----------------+---------+

The results of the studies indicate that ADBAC is highly toxic to
estuarine/marine fish and very highly toxic to estuarine/marine
invertebrates on an acute basis. The two core studies (MRID 424795-01
and MRID 424795-02) fulfill guideline requirements for acute toxicity
tests using estuarine/marine fish and shrimp. However, the one study
using an estuarine/marine mollusk (MRID 424795-03) was classified as
supplemental and does not fulfill guideline requirements.

> **(4) Aquatic Organisms, Chronic**

Chronic toxicity testing (fish early life stage, 72-4a/OPPTS 850.1400
and aquatic invertebrate life cycle, 72-4b/OPPTS 850.1300) is required
for pesticides when certain conditions of use and environmental fate
apply. The preferred freshwater fish test species is fathead minnow
(*Pimephales promelas*), but other species may be used. The preferred
freshwater invertebrate is *Daphnia magna*. This testing is required for
ADBAC. Results of these toxicity studies, submitted for ADBAC, are
presented in Table 6. The results indicate that exposure to ADBAC on a
chronic basis results in measurable effects on warmwater fish at a
concentration of 75.9 µg a.i./L. This study fulfills guideline
requirements for a fish early life stage chronic test (72-4(a)/OPPTS
850.1400). No measurable effects on freshwater invertebrates were noted
at a concentration of 4.15 µg/L. However, an MATC could not be
determined in this study. Therefore, the study was classified as
supplemental and does not fulfill guideline requirements for an aquatic
invertebrate life cycle test (72-4b/OPPTS 850.1300).

**Table 6. Chronic Toxicity of ADBAC to Freshwater Organisms**

+----------------+-----------+------------+---------------+-----------+
| **Species**    | **Ch      | **         | **Satisfies   | **Re      |
|                | emical,** | Endpoint** | Guidelines/** | ference** |
|                |           |            |               |           |
|                | **%       | **(µg/L    | **Comments**  | **(MRID   |
|                | Active    | ai)**      |               | No.)**    |
|                | Ing       |            |               |           |
|                | redient** |            |               |           |
|                |           |            |               |           |
|                | *         |            |               |           |
|                | *(a.i.)** |            |               |           |
+================+===========+============+===============+===========+
| Fathead Minnow | ADBAC     | LOEC =     | Yes           | 423021-02 |
| (*Pimephales   |           | 75.9 NOEC  |               |           |
| promelas*)     | 30%       | = 32.2     | acceptable    |           |
|                |           | MATC =     | study         |           |
|                |           | 49.4       |               |           |
+----------------+-----------+------------+---------------+-----------+
| Waterflea      | ADBAC     | LOEC = ND  | No            | 423021-01 |
| (*Daphnia      |           | NOEC =     |               |           |
| magna*)        | 30%       | 4.15 MATC  | supplemental  |           |
|                |           | = ND       | study         |           |
+----------------+-----------+------------+---------------+-----------+

**Appendix C. Wildlife Drinking Water Exposure**

Problem: ADBAC is a antimicrobial pesticide used to control algae in
outdoor fountains, bird baths, puddles and decorative pools. No running
water uses.

Issue is wildlife exposure via drinking water.

Assumption wildlife is using puddles and bird baths as a source of
drinking water.

Method will be based on daily oral exposure. Daily dose is expressed as
mass of pesticide/kg-bw.

Inputs needed:

Concentration of pesticide in water source: labeled rate is 5 and 200
mg/L

Body weight of target species: Avian 20g, 100g, 1000 g

Mammalian 15, 35, 1000 g

Calculations:

Drinking water intake rate (IRw): EPA (1994) intake L/day = 0.059(bw
kg)\^0.67 (birds)

intake L/day = 0.099(bw kg)\^0.90 (mammals)

Daily pesticide exposure (Water dose mg/kg-bw) = \[(Cwater mg/L)(IRw
L)\]/bw kg

Caveats :

1\. Does not consider additional exposure from dermal contact nor from
preening after bathing events

2\. Chronic exposures are likely over estimated as concentration is
based on target concentration at time of application.

Acute RQ = (Water dose mg/kg-bw)/(LD50 mg/kg-bw)

Source: Wildlife Exposure Factors Handbook, USEPA, 1994.

**Appendix D. Endangered Species**

*Species Taxa Count Report for Crops*

*foliage plants*

No species were excluded

Minimum of 1 Acre.

AL, AK, AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, IN, IA, KS, KY,
LA, ME, MD,

MA, MI, MN, MS, MO, MT, NE, NV, NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA,
PR,

RI, SC, SD, TN, TX, UT, VT, VA, WA, WV, WI, WY

***Alabama***

The taxa Amphibian has 1 species affected by indicated crops.

The taxa Bird has 4 species affected by indicated crops.

The taxa Bivalve has 20 species affected by indicated crops.

The taxa Dicot has 6 species affected by indicated crops.

The taxa Fish has 8 species affected by indicated crops.

The taxa Gastropod has 9 species affected by indicated crops.

The taxa Mammal has 4 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

The taxa other has 2 species affected by indicated crops.

The taxa Reptile has 5 species affected by indicated crops.

***Arizona***

The taxa Amphibian has 1 species affected by indicated crops.

The taxa Bird has 7 species affected by indicated crops.

The taxa Bivalve has 1 species affected by indicated crops.

The taxa Dicot has 9 species affected by indicated crops.

The taxa Fish has 9 species affected by indicated crops.

The taxa Gastropod has 1 species affected by indicated crops.

The taxa Mammal has 6 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

The taxa Reptile has 1 species affected by indicated crops.

***Arkansas***

The taxa Bird has 3 species affected by indicated crops.

The taxa Bivalve has 4 species affected by indicated crops.

The taxa Crustacean has 1 species affected by indicated crops.

The taxa Dicot has 1 species affected by indicated crops.

The taxa Insect has 1 species affected by indicated crops.

The taxa Mammal has 3 species affected by indicated crops.

***California***

The taxa Amphibian has 6 species affected by indicated crops.

The taxa Bird has 15 species affected by indicated crops.

The taxa Crustacean has 7 species affected by indicated crops.

The taxa Dicot has 135 species affected by indicated crops.

The taxa Fish has 24 species affected by indicated crops.

The taxa Gastropod has 1 species affected by indicated crops.

The taxa Insect has 19 species affected by indicated crops.

The taxa Mammal has 21 species affected by indicated crops.

The taxa Monocot has 14 species affected by indicated crops.

The taxa other has 2 species affected by indicated crops.

The taxa Reptile has 8 species affected by indicated crops.

***Colorado***

The taxa Bird has 2 species affected by indicated crops.

The taxa Dicot has 1 species affected by indicated crops.

The taxa Mammal has 1 species affected by indicated crops.

***Connecticut***

The taxa Bird has 1 species affected by indicated crops.

The taxa Bivalve has 1 species affected by indicated crops.

The taxa Fish has 1 species affected by indicated crops.

***Florida***

The taxa Bird has 10 species affected by indicated crops.

The taxa Bivalve has 1 species affected by indicated crops.

The taxa Crustacean has 1 species affected by indicated crops.

The taxa Dicot has 41 species affected by indicated crops.

The taxa Fish has 3 species affected by indicated crops.

The taxa Gastropod has 1 species affected by indicated crops.

The taxa Insect has 1 species affected by indicated crops.

The taxa Mammal has 11 species affected by indicated crops.

The taxa Monocot has 2 species affected by indicated crops.

The taxa other has 1 species affected by indicated crops.

The taxa Reptile has 10 species affected by indicated crops.

***Georgia***

The taxa Bird has 5 species affected by indicated crops.

The taxa Bivalve has 13 species affected by indicated crops.

The taxa Dicot has 5 species affected by indicated crops.

The taxa Fish has 7 species affected by indicated crops.

The taxa Mammal has 3 species affected by indicated crops.

The taxa Monocot has 3 species affected by indicated crops.

The taxa other has 3 species affected by indicated crops.

The taxa Reptile has 2 species affected by indicated crops.

***Hawaii***

The taxa Arachnid has 1 species affected by indicated crops.

The taxa Bird has 32 species affected by indicated crops.

The taxa Crustacean has 1 species affected by indicated crops.

The taxa Dicot has 233 species affected by indicated crops.

The taxa Gastropod has 39 species affected by indicated crops.

The taxa Insect has 1 species affected by indicated crops.

The taxa Mammal has 2 species affected by indicated crops.

The taxa Monocot has 22 species affected by indicated crops.

The taxa other has 12 species affected by indicated crops.

The taxa Reptile has 2 species affected by indicated crops.

***Idaho***

The taxa Bird has 1 species affected by indicated crops.

The taxa Fish has 3 species affected by indicated crops.

***Illinois***

The taxa Bird has 3 species affected by indicated crops.

The taxa Dicot has 3 species affected by indicated crops.

The taxa Fish has 1 species affected by indicated crops.

The taxa Insect has 2 species affected by indicated crops.

The taxa Mammal has 2 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

***Indiana***

The taxa Bird has 1 species affected by indicated crops.

The taxa Dicot has 2 species affected by indicated crops.

The taxa Insect has 2 species affected by indicated crops.

The taxa Mammal has 1 species affected by indicated crops.

The taxa Reptile has 1 species affected by indicated crops.

***Iowa***

The taxa Bird has 3 species affected by indicated crops.

The taxa Dicot has 2 species affected by indicated crops.

The taxa Fish has 1 species affected by indicated crops.

The taxa Mammal has 1 species affected by indicated crops.

The taxa Monocot has 2 species affected by indicated crops.

***Kentucky***

The taxa Bird has 3 species affected by indicated crops.

The taxa Bivalve has 9 species affected by indicated crops.

The taxa Mammal has 2 species affected by indicated crops.

***Louisiana***

The taxa Bird has 4 species affected by indicated crops.

The taxa Bivalve has 2 species affected by indicated crops.

The taxa Fish has 2 species affected by indicated crops.

The taxa Mammal has 2 species affected by indicated crops.

The taxa other has 1 species affected by indicated crops.

The taxa Reptile has 7 species affected by indicated crops.

***Maine***

The taxa Bird has 3 species affected by indicated crops.

The taxa Fish has 2 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

***Maryland***

The taxa Bird has 2 species affected by indicated crops.

The taxa Bivalve has 1 species affected by indicated crops.

The taxa Dicot has 1 species affected by indicated crops.

The taxa Fish has 1 species affected by indicated crops.

The taxa Insect has 1 species affected by indicated crops.

The taxa Mammal has 2 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

The taxa Reptile has 1 species affected by indicated crops.

***Massachusetts***

The taxa Bird has 4 species affected by indicated crops.

The taxa Dicot has 1 species affected by indicated crops.

The taxa Fish has 1 species affected by indicated crops.

The taxa Mammal has 1 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

The taxa Reptile has 1 species affected by indicated crops.

***Michigan***

The taxa Bird has 3 species affected by indicated crops.

The taxa Bivalve has 1 species affected by indicated crops.

The taxa Dicot has 1 species affected by indicated crops.

The taxa Insect has 2 species affected by indicated crops.

The taxa Mammal has 1 species affected by indicated crops.

The taxa Monocot has 2 species affected by indicated crops.

The taxa Reptile has 1 species affected by indicated crops.

***Minnesota***

The taxa Bird has 2 species affected by indicated crops.

The taxa Bivalve has 2 species affected by indicated crops.

The taxa Dicot has 1 species affected by indicated crops.

The taxa Insect has 1 species affected by indicated crops.

The taxa Mammal has 2 species affected by indicated crops.

***Mississippi***

The taxa Amphibian has 1 species affected by indicated crops.

The taxa Bird has 5 species affected by indicated crops.

The taxa Bivalve has 6 species affected by indicated crops.

The taxa Fish has 1 species affected by indicated crops.

The taxa Mammal has 1 species affected by indicated crops.

The taxa other has 1 species affected by indicated crops.

The taxa Reptile has 7 species affected by indicated crops.

***Missouri***

The taxa Bird has 3 species affected by indicated crops.

The taxa Bivalve has 2 species affected by indicated crops.

The taxa Dicot has 4 species affected by indicated crops.

The taxa Fish has 3 species affected by indicated crops.

The taxa Insect has 2 species affected by indicated crops.

The taxa Mammal has 2 species affected by indicated crops.

***Montana***

The taxa Bird has 1 species affected by indicated crops.

The taxa Dicot has 1 species affected by indicated crops.

The taxa Fish has 3 species affected by indicated crops.

The taxa Mammal has 2 species affected by indicated crops.

***Nebraska***

The taxa Bird has 4 species affected by indicated crops.

The taxa Fish has 1 species affected by indicated crops.

The taxa Insect has 1 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

***Nevada***

The taxa Bird has 1 species affected by indicated crops.

The taxa Dicot has 8 species affected by indicated crops.

The taxa Fish has 7 species affected by indicated crops.

The taxa Insect has 1 species affected by indicated crops.

The taxa Reptile has 1 species affected by indicated crops.

***New Hampshire***

The taxa Bird has 1 species affected by indicated crops.

The taxa Insect has 1 species affected by indicated crops.

The taxa Mammal has 1 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

***New Jersey***

The taxa Bird has 2 species affected by indicated crops.

The taxa Dicot has 2 species affected by indicated crops.

The taxa Fish has 1 species affected by indicated crops.

The taxa Mammal has 1 species affected by indicated crops.

The taxa Monocot has 2 species affected by indicated crops.

The taxa Reptile has 1 species affected by indicated crops.

***New Mexico***

The taxa Amphibian has 1 species affected by indicated crops.

The taxa Bird has 7 species affected by indicated crops.

The taxa Crustacean has 1 species affected by indicated crops.

The taxa Dicot has 1 species affected by indicated crops.

The taxa Fish has 1 species affected by indicated crops.

The taxa Gastropod has 2 species affected by indicated crops.

The taxa Mammal has 1 species affected by indicated crops.

***New York***

The taxa Bird has 3 species affected by indicated crops.

The taxa Dicot has 4 species affected by indicated crops.

The taxa Fish has 1 species affected by indicated crops.

The taxa Mammal has 1 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

The taxa other has 1 species affected by indicated crops.

The taxa Reptile has 1 species affected by indicated crops.

***North Carolina***

The taxa Arachnid has 1 species affected by indicated crops.

The taxa Bird has 4 species affected by indicated crops.

The taxa Bivalve has 8 species affected by indicated crops.

The taxa Dicot has 15 species affected by indicated crops.

The taxa Fish has 3 species affected by indicated crops.

The taxa Mammal has 5 species affected by indicated crops.

The taxa Monocot has 4 species affected by indicated crops.

The taxa other has 1 species affected by indicated crops.

The taxa Reptile has 5 species affected by indicated crops.

***Ohio***

The taxa Bird has 2 species affected by indicated crops.

The taxa Bivalve has 1 species affected by indicated crops.

The taxa Dicot has 2 species affected by indicated crops.

The taxa Insect has 1 species affected by indicated crops.

The taxa Mammal has 1 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

***Oklahoma***

The taxa Bird has 4 species affected by indicated crops.

The taxa Fish has 1 species affected by indicated crops.

The taxa Insect has 1 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

***Oregon***

The taxa Bird has 5 species affected by indicated crops.

The taxa Dicot has 6 species affected by indicated crops.

The taxa Fish has 18 species affected by indicated crops.

The taxa Insect has 2 species affected by indicated crops.

The taxa Mammal has 1 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

***Pennsylvania***

The taxa Bird has 2 species affected by indicated crops.

The taxa Bivalve has 2 species affected by indicated crops.

The taxa Mammal has 1 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

The taxa Reptile has 1 species affected by indicated crops.

***Rhode Island***

The taxa Bird has 1 species affected by indicated crops.

The taxa Dicot has 1 species affected by indicated crops.

The taxa Fish has 1 species affected by indicated crops.

The taxa Insect has 1 species affected by indicated crops.

***South Carolina***

The taxa Amphibian has 1 species affected by indicated crops.

The taxa Bird has 5 species affected by indicated crops.

The taxa Bivalve has 1 species affected by indicated crops.

The taxa Dicot has 9 species affected by indicated crops.

The taxa Fish has 1 species affected by indicated crops.

The taxa Mammal has 7 species affected by indicated crops.

The taxa Monocot has 3 species affected by indicated crops.

The taxa Reptile has 4 species affected by indicated crops.

***Tennessee***

The taxa Bird has 2 species affected by indicated crops.

The taxa Bivalve has 22 species affected by indicated crops.

The taxa Crustacean has 1 species affected by indicated crops.

The taxa Dicot has 9 species affected by indicated crops.

The taxa Fish has 10 species affected by indicated crops.

The taxa Gastropod has 1 species affected by indicated crops.

The taxa Mammal has 2 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

***Texas***

The taxa Amphibian has 4 species affected by indicated crops.

The taxa Arachnid has 4 species affected by indicated crops.

The taxa Bird has 12 species affected by indicated crops.

The taxa Crustacean has 1 species affected by indicated crops.

The taxa Dicot has 16 species affected by indicated crops.

The taxa Fish has 3 species affected by indicated crops.

The taxa Insect has 5 species affected by indicated crops.

The taxa Mammal has 5 species affected by indicated crops.

The taxa Monocot has 2 species affected by indicated crops.

The taxa Reptile has 5 species affected by indicated crops.

***Utah***

The taxa Bird has 1 species affected by indicated crops.

The taxa Dicot has 2 species affected by indicated crops.

The taxa Fish has 1 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

***Virginia***

The taxa Bird has 2 species affected by indicated crops.

The taxa Bivalve has 2 species affected by indicated crops.

The taxa Dicot has 5 species affected by indicated crops.

The taxa Fish has 2 species affected by indicated crops.

The taxa Insect has 2 species affected by indicated crops.

The taxa Mammal has 2 species affected by indicated crops.

The taxa Monocot has 2 species affected by indicated crops.

The taxa Reptile has 1 species affected by indicated crops.

***Washington***

The taxa Bird has 3 species affected by indicated crops.

The taxa Dicot has 3 species affected by indicated crops.

The taxa Fish has 17 species affected by indicated crops.

The taxa Mammal has 4 species affected by indicated crops.

***West Virginia***

The taxa Amphibian has 1 species affected by indicated crops.

The taxa Bivalve has 4 species affected by indicated crops.

The taxa Dicot has 2 species affected by indicated crops.

The taxa Gastropod has 1 species affected by indicated crops.

The taxa Mammal has 3 species affected by indicated crops.

***Wisconsin***

The taxa Bird has 2 species affected by indicated crops.

The taxa Bivalve has 1 species affected by indicated crops.

The taxa Dicot has 2 species affected by indicated crops.

The taxa Insect has 1 species affected by indicated crops.

The taxa Mammal has 2 species affected by indicated crops.

The taxa Monocot has 1 species affected by indicated crops.

[^1]:
    > \* Comparable to typical ADBAC Manufacturing Use Product (MUP) 80%
    > with regard to actual

    composition of ADBAC and its impurities