2 the buffer zone to create an offsite exposure. Further, most fields have at least a 15-20 foot-wide access road on all edges; and all bu t one soil use pattern will utilize tarps. Farm roads surrounding fields make a de facto barrier to vegetation along the perimeter of the

treated fields. It is not realistic to assume that methyl bromide will travel in the soil >5 feet away from the injection site, let alone the 15-20 feet of hard-packed soil found under

farm roads.

Furthermore, essentially all soil applications used today require tarp s to limit the amount of methyl bromide that can escape the soil. Only one, very limited, use site does not require tarps: orchard replant. However, these applications are deep injected, either using deep-shank or deep-probe, which limit the ability of methyl bromide to volatize from the field and move laterally within the soil. More over, the amount of methyl bromide used in this singular non-tarped use pattern has dwi ndled. Methyl bromide was used via the nontarped deep-shank method on less than 100 acres of orchard replant land in California in the last two years (2012- 2013) combined.

EFED Response:

Based on evaluation of comments regarding th e deep injection requirements for orchard use, EFED agrees the danger to potential adjacent crops may be minimal from lateral transport through soils. EFED recently c onfirmed with the Biological Economics Assessment Division that the untarped methyl bromide use is small, and that exposure scenarios with methyl bromide translocati on via runoff would be limited. In addition, EFED agrees that exposure due to diffusion alone will not likely occur over large enough distances from the treated field to impact non-target plant seeds off the treated field. Though road beds may often be located around a pplication sites, this may not always be the case, but this factor does not effect our assessment. The required buffer zone of 25 ft or more is related to worker and bystander en try restrictions and w ould also not factor

into our assessment.

EFED will not conduct an assessment includi ng exposure to plant seeds off of the

treated field. Consequently, EFED will recommend removal of the seedling emergence data requirement from the Data Call-In Notice for registration review.

(2) MBIP Comment: Regarding Vegetative Vigor Study Requirement

Our initial review suggests th at the most likely protocol would mirror the non-guideline protocol developed and appr oved by EPA for the Vegetative Vigor study required in the prior Data Call In to meet Guideline 850.4150. (MRID No. 49171601). Therefore, it is unclear what new data, if any, a second replicat ion of essentially the same protocol would provide.

EFED Response:

EFED acknowledges the receipt of the st udy (MRID No. 49171601). We have included it in the DCI since it was received recently. The study is currently under review. Given3 the late submittal of the study, EFED will r ecommend it remains on the DCI. However, this study may be used to fulfill the vegeta tive vigor data requirement contingent upon the determination of its acceptabil ity for use in risk assessment.

(3) MBIP Comment: Regarding Environmental Chemistry Methods/Independent Laboratory Validation Study Requirement

An Environmental Chemistry Methods (ECM) was submitted to EPA as part of

MRID No. 48006001.

EFED Response:

The ECM report cited by MBIP is included in Appendix H of the field volatility guideline study report, “Monitori ng of Methyl Bromide and Ch loropicrin Field Emissions From Shank Applications at Shallow a nd Deep Injection Depths”, (MRID No. 48006001). The citation provided by MBIP appear s to be an abbreviated report of the laboratory analytical method used in th e field volatility study air concentration measurements for methyl bromide. In order to fulfill this study requirement, a complete study report of this method as specified unde r the Standard Evaluation Procedure (SEP) in Guideline No. 850.6100 is needed. Furthermore, an independent laboratory validation of this method performed by a separate study di rector is required to fulfill this study. Please refer to the, “Group F – Field Test Data Reporting Guidelines”, section of the website provided below which specifies the reporting requirements to support this study requirement:

http://www.epa.gov/ocspp/pubs/frs/public ations/Test_Guide lines/series850.htm