OFFICE OF CHEMICAL SAFETY

AND POLLUTION PREVENTION 

### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

June 24 , 2015

PC Code: 050410

MEMORANDUM DP Barcode: 424167

SUBJECT: Fluensulfone: Ecological Risk Assessment for Proposed Section 3 New Uses on Golf

Courses, Sports Fields, Commercial Turfgrass Areas, Sod Farms and Residential

Turfgrass Lawns.

FROM: Donna Reed Judkins, Ph.D., Biolog ist

James Lin, Ph.D., Environmental Engineer

ERB2/EFED (7507P)

REVIEWERS: Elyssa Arnold, Risk Assessment Process Leader



### R. David Jones, Ph.D., Senior Agronomist

ERB2/EFED (7507P)

THROUGH: Brian Anderson, Branch Chief

ERB2/EFED (7507P)

TO: 

### R ita Kumar

, Risk Manager Reviewer

Mark Suarez, T eam Leader, PM Team 7

Insecticide

- Vertebrate Branch 3

Registration Division (7505P)

Office of Pesticide Programs

Th e Environmental Fate and Effects Division (EFED ) conducted an ecological risk

assessment for the proposed label amendment s to add Section 3 new uses f or n ematode c ontrol

in Bermudagrass ( Cynodon dactylon ) , St. Augustine grass ( Stenotaphrum secundatum )



### , z oysia

( Zoysia japonica x 

### Z. tenuifolia )

, c entipede grass ( Eremochloa ophiuroides )

, s eashore p aspalum

( Paspalum vaginatum ) , Kentucky t all f escue ( Festuca arundinacanea , and c reeping b entgrass

( Agrostis stonolifera ) on g olf c ourses, s ports f ields, c ommercial t urfgrass a reas, s od f arms and

r esidential t urfgrass l awns. The following submission appl ies :

 Proposed Label: “ MCW

- 2 1.5G [Alternate brand name Quali

- Pro® Nimitz® 1.5 G Nematicide] For

nematode control in Bermudagrass, St. Augustinegrass, Zoysiagrass, Centipedegrass, Seashore Paspalum,

Kentucky Tall Fescue, and Creeping Bentgr ass on Golf Courses, Sports Fields, Commercial Turfgrass

Areas, Sod Farms and Residential Turfgrass Lawns (applied by State Certified/License Pesticide

Applicator). ”2



### 1. EXECUTIVE SUMMARY

The proposed new uses for fluensulfone were evaluated for potential ecological risks. A

recent (2014) new chemical assessment 1 

### that assessed higher maximum single application rates

and a similar maximum annual application rate was relied upon for this assessment

. The

proposed label was not mi ssing use directions and n o new fate or effects data have been

submitted for inclusion in a new assessment that would alter the list of taxa at risk.

The abbreviated assessment that follows cover s the following modifications to the

previous ecological r isk assessment :

 Aquatic Invertebrate and Non

- Vascular Aquatic Plant Assessment : S ince mollusks

and algae were close to LOCs (levels of concern) and a small difference in EEC

(estimated environmental concentration) might change the risk conclusions, an

abbreviated aquatic assessment was conducte d.

 Avian and Mammalian Foraging Area Assessment : S ince previous uses were either

drip irrigated or incorporated immediately, the mammalian and avian assessment s were

limited to wildlife that eat arthropods or seeds. This new proposed product is granular

and so the exposure route differs from that of liquid spray

. Exposur es to granules are

based on direct consumption and amount of granules in a given area adjusted for toxicity.

 Terrestrial Insect Partial Assessment : S ince the previous assessment showed that a

single application exceeded the acute listed species LOC and tha t earthworm exposure

could exceed toxicity endpoints, risk was reconsidered for the proposed new uses

.

 Terrestrial Plant Assessment : S ince the single application rate was lower for th e

proposed new uses than the one previously assessed, and the terrestrial plant risk

assessment is based on maximum single, rather than maximum annual

, application rates,

terrestrial plant risk was reassessed

. In this case, only the runoff calculations applied

since spray drift is not calculated for granular applica tions.

As i llustrated in Figure 1 and Table 1 , risks from the proposed new uses on turf are similar to

those previously assessed.

Figure 1. Quadrant G raph s S howing O verview of T axanomic G roups at R isk from P reviously

A ssessed Uses of F l uensulfone on Crop Groups 8 and 9 and from P roposed N ew Uses on T urf

.

1 D. Judkins and J. Lin. “ United States Environmental Protection Agency Environmental Assessment for the New

Chemical Fluensulfone ,” internal communication to the Registration Division. DP Barcode 4 02512

, January 8

, 20143



### Table 1 . Evidence of Risk to Taxonomic Groups from Fluensulfone Proposed New Uses on Turf. 1



### Predominant Evidence of Negligible Risk Predominant Evidence of Risk

Not Assessed in this Abbreviated Assessment

–

Information from 2014 Assessment and assumed

to Apply to Proposed New Uses on Turf: fish,

freshwater invertebrates and vascular aquatic plants

do not have LOC exceedances; however, since this is

a relatively n ew chemical, the ability to comment on

unexpected long

- term effects is limited and so even

though the predominant evidence indicates negligible

risk, there is some uncertainty.

For mollusks and aquatic non

- vascular plants, no RQs

were exceeded based on runoff only since this is a

granular product. Previous assessment on a spray

able product at the same application rate, exceeded

risk concern levels ; however, with the reduced

exposure from e liminating spray drift, all aquatic

invertebrates and aquatic plants are placed in the

green quadrant. Terrestrial i nvertebrates, especially those below

- ground,

are clearly at risk similar to the target nematodes for

which the product was designed. Risk t o those exposed

on foliage and other above

- ground sites is uncertain.



### Limited Evidence of Negligible Risk Limited Evidence of Risk

One sq. ft. of treated area would contain enough

chemical to be acutely toxic to small birds; an important

uncertainty is whether birds would consume the

granules and/or whether dissolve granules would taint

food items at levels sufficient to cause effects to birds

. Less than two sq. ft. of treated area would contain

enough active ingredient to be acutely toxic to small

mammals . A small area ( 0.7 to 6 sq ft. depending on

feeding efficiency) would be large enough to cause

chronic risk to mammals. An important uncertainty is

whether mammals would consume the granules and/or

whether dissolve g ranules would taint food items at

levels sufficient to cause effects to mammals.

. Semi

- aquatic d icots had a listed

- species RQ of 6. 4

, exceed ing the LOC (1.0); all other t errestrial p lant

groups and all non

- listed species RQs did not exceed the

LOC.

1 A key to the categories defined by each quadrant ( e.g.

, Predominant Evidence of Risk ) is found in Appendix A

.



### The list of taxa that exceed risk levels of concern is reduced from the previous

assessment at the same annual application rate maximum, since granules are not subject to spray

drift ( Figure 1, Table 1 ) . Terrestrial invertebrates , especially those below

- ground, are clearly at

risk given that fluensulfone is used to control some terrestrial invertebrates ; risk is less certain to

those on foliage and/or other above

- ground sites. Birds and mammals foraging in the immediate

treatment area are at risk above concern levels , though the evidence of risk is limited because the

opportunity or likelihood regarding the potential to consume granules either d irectly or dissolved

onto food items is unknown . Similarly, terrestrial plants are at risk above concern levels , though

only semi

- aquatic dicots exceeded the listed

- species LOC, and other plant groups did not.

M ollusks and aquatic non

- vascular plants were not found to be at risk above concern levels from

th ese proposed new use s since only runoff applied . T he same application rate previously

assessed with a spray

- drift component did exceed LOCs ; however with the reduced exposure

from eliminating spray drift , all aquatic invertebrates and aquatic plants are placed in the green4



### quadrant. Fish and aquatic vascular plants are not likely at risk s of concern , though there is some

uncertaintly since this is a relatively new chemical and limited information ex ists on any

unexpected long

- term effects that are sometimes seen over time through incident reports or new

data that may be generated over time

.

2. USE CHARACTERIZATION FOR PROPOSED NEW USES ON TURF

Quali

- Pro Nimitz1.5G Nematicide is a granul ar formulation containing 1.5% of

fluensulfone active ingredient by weight. The label specifies that applications should be

uniformly broadcasted over turfgrass area suspected to have nematodes or with a history of

nematodes. The use rate range is 60

– 120 pounds product per acre with a maximum seasonal

amount of 240 po unds product per year (3.6 lb a.i./acre ). Depending on nematode populations

and damage, applications can be made monthly, bi

- monthly or sequentially. It is recommended

to irrigate following application with an adequate amount of water (generally 0.5 inches). The

proposed label specifies three application scenarios:

Table 2 . Proposed N ew S ingle A pplication R ates, N umber of A pplications and I ntervals for

Proposed N ew Uses on T urf

-- A ll H ave Maximum Annual A pplication R ate of 3.6 lb a.i./acre.



### Single Application Rate Number of Applications and Application Intervals

(1) 60 lb/acre (0.9 lb a.i./acre) can be applied at 1 month intervals for 4 consecutive months

(2) 80 lb/acre (1.2 lb a.i./a cre) can be applied at 1 month interval for 3 consecutive months

(3) 120 lb/acre (1.8 lb a.i./acre) can be made in spring or early summer with a second application at

the same rate 2

- 6 months following the initial broadcast



### PREVIOUS EECS FOR SECTION 3 USES

The only ecological risk assessment previously completed by EFED was the 2014 new

chemical assessment. T he maximum application rate assessed wa s a single application of 3.5 lb

a.i./acre with only one application allowed ; the aquatic exposure EECs are shown below in

Table 3

. These EECs are for fluensulfone plus its major degradate, methyl sulfone (MS) which

are considered here to be the total toxic residues (TTR). The total annual rate for the proposed

new uses on turf (3.6 lb a.i./acre) is 0.1 lb a.i./acre higher than that previously assessed but this is

likely an artifact of rounding, since this rate is an annual maximum from multiple applications

and not likely to make a difference in any of the risk conclusions

. Ther efore, the previous risk

conclusions that apply to the annual maximum application rate are assumed to apply to the

proposed new uses on turf

.

Table 3

. Aquatic EECs from P revious A ssessment in 2014 for F luensulfone plus M ethyl S ulfone at

Maximum Annual Application Rate of 3.5 lb a.i./A

.

Use Scenario Peak (μg/L) 21

- day Mean

(μg/L) 60

- day Mean

(μg/L)

Fruiting vegetables STX vegetable 15.23 12.20 8.69

Cucurbits FL cucumber 17.60 14.80 10.745



### UPDATED AQUATIC EXPOSURE AND RISK ASSESSMENT FOR THE

PROPOSED NEW TURF USES

Since RQs (risk quotients) for mollusks and algae only exceeded the LOCs for listed

species and a small difference in EEC might change the risk conclusions, an abbreviated aquatic

assessment was conducte d on these taxa only.

The re are three standard scenarios for turf uses : CA, FL, and PA. Each scenario is

modeled with 3 application schemes: (1) 2 applications @ 1.8 lb a.i./acre ; (2) 3 applications @

1.2 lb a.i./acre ; and (3) 4 applications @ 0.9 lb a.i./acre . The result ing EEC s for fluensulfone

plus methyl sulfone are list in Table 4 (also see Appendix B )

.

Table 4

. SWCC Results for Fluensulfone plus Methyl Sulfone EECs for Proposed New Uses on

Turf at Maximum Annual Rate of 3.5 lb a.i./A

.

PRZM Scenario Type of

Application 1

- in

- 10

- year

Peak

Exposure (μg/L) 1

- in

- 10

- year

21

- day Average

Exposure (μg/L) 1

- in

- 10

- year

60

- day Average

Exposure (μg/L)

CA Turf 2 app.

Ground 8.80 7.47 5.54

CA Turf 3 app. 8.47 7.16 6.10

CA Turf 4 app. 7.16 6.06 5.40

FL Turf 2 app. 10.2 8.56 6.60

FL Turf 3 app. 10.4 8.36 7.17

FL Turf 4 app. 7.92 6.28 5.42

PA Turf 2 app. 9.96 8.16 5.89

PA Turf 3 app. 10.2 8.31 7.32

PA Turf 4 app. 9.00 7.53 6.30



### These aquatic EECs are all less than the previous S ection 3 uses , so aquatic impact will

not exceed the previous assessment. The only risks to be re

- assessed are those that exceeded

LOCs (mollusks and algae) to determine whether they still exceed or drop below LOCs. Please

note that the mollusk data are used in estua rine/marine invertebrate risk calculations, but the

greater sensitivity may be more a function of taxonomic order than ecosystem, so any

estuarine/marine invertebrate LOC exceedances may suggest mollusc risk in general.

Table 5 lists RQs calculated for a quatic animals exposed to fluensulfone, based on the

highest SWCC

- calculated EECs for turf uses listed in Table 4 . These EECs are based on TTR

exposure ( fluensulfone and MS )

.6



### Table 5 . Aquatic RQs for Exposure to Fluensulfone plus MS Resulting from Ru noff from Proposed

New Uses on Turf at Maximum Annual Application Rate of 3.6 lb a.i./A

.

Taxa Surface Water EEC

μg/L Endpoint Used

μg a.i./L 1 

### RQ

Acute Exposure

Estuarine/Marine Invertebrates Peak/10.4 EC 50 = 7800 2 <0.01

Aquatic non

- vascular plants Peak/10.4 Non

- Listed: IC 50 = 22 3 0.47

Listed: IC 05 = 11 3 0.95

Chronic Exposure

Estuarine/Marine Invertebrates 21

- d/ 8.4 NOAEC = 370 4 0.02

Bolded and shaded values indicate RQs that exceed the Agency’s risk LOC s. For invertebrates, the acute LOC was

0.05 for listed species or 0.5 for non

- listed species ; the chronic risk LOC was 1.0. The LOC was 1.0 for listed

and/or non

- listed aquatic plants . Asterisk (*) indicates that only the listed species LOC was exceeded.

1 Endpoints were b ased on fluensulfone TGAI (technical

- grade active ingredient) since the parent compound was

more toxic than the MS degradate (see the 2014 new chemical assessment for a breakdown)

.

2 Based on oyster shell

- growth inhibition (MRID 48574865 ) from exposure to fluensul fone TGAI, technical

- grade

active ingredient

.

3 Based on P. subcapitata cell density (MRID 48574858).

4 Based on mysid NOAEC = 370 (MRID 48574857).



### The acute and chronic RQs were below the Agency’s acute and chronic risk LOCs based

on the highest TTR EECs (parent + MS degradate) for the proposed new uses on turf compared

with TGAI (technical

- grade active ingredient) toxicity

.

TERRESTRIAL WILDLIFE EXPOSURE AND RISK ASSESSMENT FOR THE

PROPOSED NEW TURF USES

In the previous assessment all uses were either drip irrigated or immediately

incorporated ; therefore

, the only exposures to birds and mammals that were assessed were from

food items that could leave the furrows either by wind or crawling ( i.e. , seeds and arthropods)

. T h e proposed new uses on turf do not differentiate food items given the assessment methods

used for granules, which is ba sed on consumption of granules as calculated using the T

- REX

model ( v. 1.5, March 22, 2012) for mammals and birds. Input values for deriving EECs in T

REX are shown in Table 6

.

Table 6 . T

- REX Input Parameters for Deriving Maximum Terrestrial EECs for Fluensulfone

Proposed New Uses on Turf. 1



### Proposed Use

(Application Method) Application Rate

(lbs a.i./A) Number of Applications

(Interval between applications)

Turf

(broadcast) 1.8 2

(60 days)

1 Half

- life used was the default 35 days.7



### Table 7 summarizes the dietary

- and dose

- based EECs, based on the maximum single

application rate of fluensulfone for the proposed uses (also see Appendix C ). The amount per

square foot (both by a.i. weight and portion of the LD 50 

### for each size class) was estimated. An

analysis based on how many granules of product would need to be consumed to cause mortality

was not run because information was not available on the weight of single granule s

. This

information could allow for some additional characterization regarding the opportunity for

wildlife to consume sufficient numbers of granules to result in toxic effects.

Table 7 . T

- REX Calculated EECs of Fluensulfone P roposed New Uses on Turf at Maximum

Annual Application Rate of 2 Applications of 1.8 lbs a.i./A with 60

- D ay I nterval

.

Proposed

Application

Methods Type of Exposure Dietary

Based

(ppm)

(mammals

and birds) Dose Based

(mg/kg

- bw)

(birds) Dose Based

(mg/kg

- bw)

(mammals)

All Size

Classes Small

(20 g) Medium

(100 g) Large

(1000 g) Small

(15 g) Medium

(35 g) Large

(1000 g)

T

- REX Estimates of Risk per Square Foot from Broadcast Application.

Turf

Broadcast of 2

apps @ 1.8 lb

a.i./A (60d

interval) mg per sq. ft. 18.7

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

LD 50 /sq ft

-- 7.11 1.12 0.08 0.85 0.45 0.04



### F or avian (also surrogate for reptiles and terrestrial

- phase amphibians) and mammalian

exposure to fluensulfone based on granular exposure as estimated using T

- REX

, Table 7 above

shows that the amount of potential exposure is 18.7 mg a.i./sq. ft. It also provides an estimate

that for small birds, one sq. ft. of treated area would contain 7x the LD 50 

### , for medium birds 1.12x

and for large birds, 0.08x the LD 50 

### . Though RQs are not c alculable from this, conclusions may

be drawn that small to medium sized birds c ould have more than adequate opportunity for

sufficient exposure to cause toxic effects.

For mammals, Table 7 shows that for small mammals, one sq. ft. of treated area would

contain 0.85x the LD 50 

### , for medium mammals 0.45x and for large mammals, 0.04x the LD 50



### . Though RQs are not calculable from this, conclusions may be drawn that small mammals c ould

have adequate opportunity for exposure at toxic levels, although it is less certain if larger birds

could be impacted.

T

- REX calculations were also available to break down the foraging area needed for

mammals to consume enough fluensulfone to exceed the chronic LOC based on feeding

efficiency, since chronic dose

- based toxicity data were available. Table 8 show s that the

foraging area needed in general for all size classes is 0.7 sq. ft. when 100% feeding efficiency is

assumed and ranges to 6 sq. ft. when only 10% fe eding efficiency is assumed.8



### Table 8 . Characterization of Minimum Foraging Area Needed to Allow for Ingestion of Sufficient

Mass of A.I. to Achieve LOC Exceedance at Proposed M aximum Annual A pplication R ate of 2

A pplications of 1.8 lb a.i./A with 60

- D ay I nterval.



### Mammalian Assessment 1

Foraging area (square feet) needed to achieve LOC exceedance assuming

100% feeding efficiency 0.66

Foraging area (square feet) needed to achieve LOC exceedance assuming 50%

feeding efficiency 1.33

Foraging area (square feet) needed to achieve LOC exceedance assuming 10%

feeding efficiency 6.64

1 Avian assessment was unavailable due to lack of chronic dose

- based data.



### TERRESTRIAL PLANT EXPOSURE AND RISK ASSESSMENT FOR THE

PROPOSED NEW TURF USES

T errestrial plant risk was re

- calculated since calculations are based on the maximum

single application rate and that rate is lower for the proposed new uses on turf than the one

previously assessed for broadcast application

. Fluensulfone exposure estimates from TerrPlant

for terrestrial plants inhabiting dry and wetland treated areas were derived from exposure

estimates of runoff only ( Table 9 , also see Appendix D ).

Table 9

. EECs Calculated using Terr P lant for Terrestrial Plant Exposure from Runoff to

Fluensulfone from Proposed New Uses on Turf at Maximum Single Application Rate of 1.8 lb

a.i./A

.

Description EEC, lb a.i./A

Runoff to dry areas 0.09

Runoff to semi

- aquatic areas 0.90

Spray drift 0

Total for dry areas 0. 09

Total for semi

- aquatic areas 0.9 0



### The EEC estimates for dry and semi

- aquatic areas were 0. 09 and 0. 9 0 lb a.i./A,

respectively ( Table 8 )

.

Since the single application rate was lower for th ese uses than the one previously

assessed for broadcast application, and the terrestrial plant risk assessment is based on maximum

single, rather than maximum annual application rates, TerrPlant was re

- run to see if the risk

conclusions changed for the proposed ne w uses on turf, using only runoff calculations ( Table

1 0 ).9



### Table 1 0 . Terrestrial Plant RQs for Exposure from Runoff to Fluensulfone from Proposed New

Uses on Turf at Maximum Single Application Rate of 1.8 lb a.i./A.

Taxa EEC a



### lb a.i. / A Endpoint Used

Seedling Emergence

lb a.i./ A RQ values *

Dry Semi

Aquatic Dry Semi

Aquatic

Fluensulfone Alone



### Monocots Non

- Listed

0.0 9 0. 90 EC 25 = 2.50 1 <0.1 0. 36

Listed NOAEC = 1.21 1 <0.1 0. 74



### Dicots Non

- Listed EC 25 = > 3. 77 2 <0.1 0.24

Listed NOAEC = 0.141 2 0.64 6.38

* RQs that exceed the LOC (1.0) for listed or non

- listed terrestrial plants are bolded and shaded

.

1 Based on onion height (MRID 48574 945 ).

2 Based on soybean emergence and survival (MRID 485749 45 ).



### RQ values for listed semi

- aquatic dicots exceed the Agency’s LOC of 1.0 based on

fluensulfone exposure from the proposed uses (RQ of 6.4). No other LOCs were exceeded for

terrestrial plants ( Table 1 0 ).

TERRESTRIAL INVERTEB RATE RISK ASSESSMENT FOR THE PR OPOSED

NEW TURF USES (QUALITATIVE)

Since a single application estimate showed listed

- species LOC exceedances for non

target terrestrial invertebrates in the previous assessment, and also that earthworm exposure

could exceed toxicity endpoints, terrestri al invertebrate risk was reconsidered

. However, this

was qualitative since the previous assessment was based on liquid applications calculated in T

REX. EFED does not routinely quantitatively model exposure to terrestrial invertebrates from

runoff alone ; however, exposure to above

- and below

- ground invertebrates is likely to occur

, especially as the granules are dissolved and seep into the ground. This is the same as its

application to reach target species and

, therefore, it would reason that terrestrial invertebrates in

the treatment area would be at risk similar to target species. This would apply to contact with

runoff and not foliage, i.e. would not apply to pollinators or other species present only on foliage.

3. CONCLUSIONS

Conclusions from the four areas of this abbreviated assessment are as follows:

 Aquatic Invertebrate and Non

- Vascular Aquatic Plant Assessment :

Even though annual application rates were approximately the same, removing the spray

drift component reduced RQs to below LOCs for a quatic invertebrates and aquatic non

vascular plants.

 Avian and Mammalian Assessment :

Since the proposed product is granular the assessment based on dietary exposure to10



### various food items did not apply. All exposure here is based on consumption of th e

granules and the amount falling on food items to be consumed or consumed separately is

unknown. The amount available in a given forage area was calculated and the following

conclusions were reached:

 one square foot of treated area would contain 7x the amount acutely toxic to

small birds;

 less than two square feet of treated area would contain an amount acutely toxic to

small mammals: and

 o nly a small foraging area would be needed (0.7 to 6 sq. ft., depending on feeding

efficiency) for a mammal to consum e enough fluensulfone to exceed the chronic

LOC in the immediate treatment area.

 Terrestrial Insect Partial Assessment :

Since the product is granular and EFED does not have an approved method to assess

exposure to terrestrial invertebrates from granules or their runoff, this assessment was

qualitative. Foliar exposure was not considered. However, since the product was

designed to kill nematodes, exposure, especially to below

- ground invertebrates, is clearly

sufficient to cause risk to other invertebrate s ; above ground exposure is uncertain.

 Terrestrial Plant Assessment :

The listed

- species LOC was exceeded only for semi

- aquatic dicots (RQ of 6. 4 ) based on

runoff . No other LOCs were exceeded for terrestrial plants

.

The overall conclusions, including some carried forward from the previous assessment in

2014 are summarized in Table 1 (a key to Table 1 is found in Appendix A )

.

.

### Appendix A: Key to Categories for Table 1.

Predominant Evidence of Negligible Risk Predominant Evidence of Environmental

Impact

• No LOC e xceedance with relatively complete data

set or risks have been mitigated;

• High confidence in data

• Fate and ecotox profiles clearly support low risk • More than one line of evidence predicts effects will

occur

• LOC exceedances, fate, and ecotox profile should be

considered

• Exposure is expected to occur based on fate profile

and uses

• Probable cause of incident(s).

• Examples: High toxicity, high persistence,

incident(s), little exposure needed to cause effects



### Limited Evidence of Negligible Risk Limited Evidence of Risk

• No LOCs exceeded but other non

- compelling

circumstances suggest that there may be issues

• Missing endpoints, poorly spaced test

concentrations, low confidence in data showing low

toxicity

• Low risk calls based on extrapolation and

additional information is being re quested to

corroborate low risk

• Examples: high persistence and bioa ccumulation,

but low risk calls • Chronic risk called for non

- persistent chemical

• Risk to taxonomic group called based on complete

lack of submitted data

• Risk calls based on lack of data wit hout other lines

of evidence available

• Risk calls based on uncertain extrapolation methods

or conflicting data

• Missing endpoints, poorly spaced test

concentrations, low confidence in data showing high

toxicity

• Examples: Risk calls based on total residues, but not

parent only (sometimes)2



### Appendix B : One Example SWCC Output

– Florida with 3 applications scenario



# Summary of Water Modeling of fluensulfone + methyl Sulfone and

the USEPA Standard Pond

Estimated Environmental Concentrations for fluensulfone + methyl Sulfone are presented in Table

1 for the USEPA standard pond with the FLturfSTD field scenario. A graphical presentation of the

year

- to

- year peaks is presented in Figure 1. These values were generated with the Surface Water

Concentration Calculat or (SWCC Version 1.106). Critical input values for the model are

summarized in Tables 2 and 3.

This model estimates that about 0.67% of fluensulfone + methyl s ulfone applied to the field

eventually reaches the water body. The main mechanism of transport f rom the field to the water

body is by spray drift (92.2% of the total transport) followed by runoff (7.77%).

In the water body, pesticide dissipates with an effective water column half

- life of 32.1 days. (This

value does not include dissipation by transpor t to the benthic region; it includes only processes

that result in removal of pesticide from the complete system.) The main source of dissipation in

the water column is metabolism (effective average half

- life = 53.3 days) followed by photolysis

(85.5 days) and volatilization (1461.9 days).

In the benthic region, pesticide dissipates (52.6 days). The main source of dissipation in the benthic

region is metabolism (effective average half

- life = 52.6 days). Most of the pesticide in the benthic

region (84%) is sorbed to sediment rather than in the pore water.

Table 1. Estimated Environmental Concentrations (ppb) for fluensulfone + methyl s ulfone.

Peak (1

- in

- 10 yr) 10.4

4

- day Avg (1

- in

- 10 yr) 9.98

21

- day Avg (1

- in

- 10 yr) 8.36

60

- day Avg (1

- in

- 10 yr) 7.17

365

- day Avg (1

- in

- 10 yr) 2.11

Entire Simulation Mean 1.62

Table 2. Summary of m odel i nputs for fluensulfone + methyl s ulfone.

Scenario FLturfSTD

Cropped Area Fraction 1

Koc (ml/g) 47.08

Water Half

- Life (days) @ 20 °C 60.38

Benthic Half

- Life (days) @ 20 °C 59.61

Photolysis Half

- Life (days) @ 20

°Lat 0.7843



### Hydrolysis Half

- Life (days) 0

Soil Half

- Life (days) @ 20 °C 24.01

Foliar Half

- Life (days) 0

Molecular Wt 291.7

Vapor Pressure (torr) 2.3e

- 4

Solubility (mg/l) 545.3

Table 3. Application s chedule for fluensulfone + methyl s ulfone.

Date (Mon/Day) Type Amount (kg/ha) Eff. Drift

3/15 Ground 1.344 0.99 0.062

4/15 Ground 1.344 0.99 0.062

5/15 Ground 1.344 0.99 0.062

Figure 1. Yearly Peak Concentrations4



### Appendix C : T

- REX Output.

T

- REX MODEL INPUTS

These values will be used in the calculation of exposure estimates for foliar, granular, liquid and/or

seed applications of pesticides.

Chemical Identity and Application Information

Chemical Name: Fluensulfone

Seed Treatment? (Check if yes) FALSE

Use: Turf

Product name and form: Quali

- Pro Nimitz 1.5G (1.5% but all calcs in a.i.)

% A.I. (leading zero must be entered for

formulations <1% a.i.): 100.00%

Application Rate (lb ai/acre) 1.8

Half

- life (days): 35

Application Interval (days): 60

Number of Applications: 2

Are you assessing applications with

variable rates or intervals? no

Assessed Species Inputs (optional, use defaults for RQs for national level assessments)

What body weight range is assessed

(grams)? Birds Mammals

Small 20 15

Medium 100 35

Large 1000 1000

Endpoints

Avian

Endpoint Toxicity value Indicate test species below

LD50 (mg/kg

- bw) 254.00

2

LC50 (mg/kg

- diet) 5760.00 2

NOAEL (mg/kg

- bw)

2

NOAEC (mg/kg

- diet)

255.00 2

Enter the Mineau et al. Scaling Factor 1.15

Mammalian

Acute Study

Size (g) of mammal used in toxicity study

Default rat body weight is 350 grams 350

Endpoint Toxicity value

LD50 (mg/kg

- bw) 671.00

LC50 (mg/kg

- diet)

Reported Chronic Endpoint 18.30 1

Is dietary concentration (mg/kg

- diet) reported

from the available chronic mammal study?

(yes or no) yes

Enter dietary concentration (mg/kg

- diet) 250.005

LD50 ft

- 2

Application Type: 1 Make sure to enter an

1 application rate

above

Do not use this input yes

Do not use this input 1.80

Do not use this input

Do not use this input

Do not use this input

% incorporated 0.00%

Chemical : Fluensulfone

LD50 ft

- 2

INPUTS Do not overwrite these numbers.

Application Rate: 1.8 lbs / acre

% A.I.: 100.00%

Avian LD50 (20g): 131.88 mg/kg bw

(100g) 167.89

(1000g) 237.16

Mammalian LD50 (15g): 1474.74 mg/kg bw

(35g) 1193.23

(1000g) 516.11

Row Spacing: 0 inches

Bandwidth: 0 inches

Unincorporation: 100%

Row/Band/In

- furrow applications

Granular N/A

Intermediate Calculations Intermediate Calculations

# rows acre

- 1: N/A mg a.i./1000 ft row: N/A

row length (ft): N/A bandwidth: N/A

lb ai/1000 ft row: N/A mg a.i./ft2: N/A

bandwidth (ft): N/A exposed mg a.i./ft2: N/A

mg ai/ft2: N/A

exposed mg ai/ft2: N/A

LD50 ft

- 2 N/A

wgt class (grams) wgt class (grams)

Avian 20 N/A Avian 20 N/A

100 N/A 100 N/A

1000 N/A 1000 N/A

Mammal 15 N/A Mammal 15 N/A

35 N/A 35 N/A

1000 N/A 1000 N/A6

Broadcast applications

Granular

Intermediate Calculations

mg ai/ft2: 18.74

LD50 ft

- 2

wgt class (grams)

Avian 20 7.11

100 1.12

1000 0.08

Mammal 15 0.85

35 0.45

1000 0.04

Formulas used in the calculations are in the User's Guide7



### Appendix D : TerrPlant Output.

TerrPlant v. 1.2.2

Green values signify user inputs (Tables 1, 2 and 4).

Input and output guidance is in popups indicated by red arrows.

Table 1. Chemical Identity.

Chemical Name Fluensulfone

PC code 50410

Use Turf

Application Method Broadcast

Application Form Spray

Solubility in Water

(ppm) 545

Table 2. Input parameters used to derive EECs.

Input Parameter Symbol Value Units

Application Rate A 1.8 y

Incorporation I 1 none

Runoff Fraction R 0.05 none

Drift Fraction D 0 none

Table 3. EECs for Fluensulfone. Units in y.

Description Equation EEC

Runoff to dry areas (A/I)*R 0.09

Runoff to semi

- aquatic areas (A/I)*R*10 0.9

Spray drift A*D 0

Total for dry areas ((A/I)*R)+(A*D) 0.09

Total for semi

- aquatic areas ((A/I)*R*10)+(A*D) 0.9

Table 4. Plant survival and growth data used for RQ derivation. Units are in y.

Seedling Emergence Vegetative Vigor

Plant type EC 25 NOAEC EC 25 NOAEC

Monocot 2.5 1.21 3.49 0.0415

Dicot 3.77 0.141 1.31 0.419

Table 5. RQ values for plants in dry and semi

- aquatic areas exposed to Fluensulfone through runoff

and/or spray drift.*

Plant Type Listed Status Dry Semi

- Aquatic Spray Drift

Monocot non

- listed <0.1 0.36 <0.1

Monocot listed <0.1 0.74 <0.1

Dicot non

- listed <0.1 0.24 <0.1

Dicot listed 0.64 6.38 <0.1

*If RQ > 1.0, the LOC is exceeded, resulting in potential for risk to that plant group.