### 2 Data Gaps

The available environmental fate and transport data set is considered incomplete and inadequate for the purposes of risk assessment. The data gaps are l isted below. For each data gap, in absence of additional data, an assumption can be made for the purposes of risk assessment. These assumptions are identified in each bullet for fate studies, and consistent with other assessments, risk is presumed in the absence of ecological effects data

.

**•** Aqueous Photodegradation (835.2240):

**•** Although there are no acceptable studies, the Agency does not anticipate recommending a new study be conducted as a new study would not be expected to yield significantly different results. Aerobic Soil Metabolism (835.4100)

**•** . The Agency currently has data for only one soil in the submitted study. In absence of additional data, the Agency will multipl y the single degradation half

- life by three for the purposes of risk assessment to account for the potential variability in degradation rates between different soil types. The submission of studies on additional soil types would reduce the uncertainty in th e degradation of bromacil in aerobic systems. The acceptable study is in a clay loam soil, thus the submission of an a study in a soil with higher organic matter may result in less conservative metabolism input for risk assessment. Anaerobic Soil metabolis m (835.4200)

**•** . Currently, there are no available data. In lieu of acceptable data , bromacil is assumed to be stable to metabolism in soil in oxygen

- limit ed environments. Aerobic Aquatic Metabolism (835.4300)

**•** . Data requirement was previously waived due to

mo difications to the label for bromacil that intended to avoid use sites with high potential to result in aquatic exposure (DP 182792). 40 CFR part 158 Subpart N §158.1300 (July, 2010) requires the submission of aquatic metabolism data for all pesticides with use patterns for terrestrial food and nonfood applications. In lieu of this data, modeling for risk assessment will assume 2x aerobic soil metabolism input (resulting in a 6x factor). Additional data would reduce the considerable uncertainty with using the assumed modeling input. Additionally, the submission of acceptable soil metabolism data would reduce the uncertainty factor by 3x (in lieu of additional aerobic aquatic metabolism data, modeling assumes 2x the aerob ic soil metabolism input). Anaerobic Aquatic Metabolism (835.4400).

**•** Currently there are no acceptable data for anaerobic aquatic metabolism. This study is necessary to understand the degradation of bromacil in oxygen

- limit ed environments. In lieu of additi onal acceptable data, stability is assumed. Adsorption/Desorption, Batch Equilibrium (835.1230).

**•** S ubmitted studies only include soil column leaching data. Batch equilibrium data are needed to determine the sorption coefficients for bromacil, the bromacil acid should be used for this study as the salt dissociates to the acid under environmental conditions

. In absence of these data experimental organi c carbon partitioning coefficients will be used from open literature sources (e.g., Gersch, 1984 and Corwin a nd Farmer, 198 4 )

. Additional data is unlikely to increase the conservatism of the assumed sorption coefficient for bromacil. Terrestrial Field Dissipation (835.6100)

. The original study conducted at two bare

- ground sites was classified acceptable. It was n oted in the review that to fulfill the guideline

### 3 additional studies are required on different soils that capture the use areas for bromacil (e.g., highly permeable citrus production areas of Florida). Based on open literature data and monitoring data that confirms that bromacil leaches through the soil profile and contaminates groundwater , the Agency does not anticipate needing additional data on the field dissipation of bromacil.

The available effects dataset is considered incomplete for the purposes of risk assessment. The following data gaps exist:

**•** 850.1350. No data have been received to characterize the chronic toxicity of bromacil to the estuarine invertebrate Americamysis bahia. In acute testing, e stuarine invertebrates (i.e., A. bahia ) were found to be more sensitive to bromacil than freshwater invertebrates ( Daphnia sp.). Alternatively, a NO A EC will be e stimated using acute

- to

- chronic ratio for Daphnia magna of 14.8 (acute = 121 ; chronic= 8.2 ; 121 / 8.2 = 1 4.8) . This would result in a mysid NOAEC of 7 .7 ppm.

**•** 850.2100

. A definitive acute oral L D 50



### • 850.2200 . A sub

- acute (dietary) study technical bromacil to birds has not been received. Alternatively , data from a study involving dietary exposures of birds to a formulated product containing bromacil will be used to assess avian dietary risk

. has not been established for an avian species

. In order to gain a better understanding of how the EECs for the maximum bromacil application rate relate to the toxicity data currently available for birds

, the T

- REX model is used to calculate a ratio of the EEC and toxicity endpoint using the conservative assumption that the highest value tested represents the toxicity endpoint. In this exercise, some of the acute ratios calculated are > 1. Because the highest dose tested is below the highest predicted exposure level, the specific risk to birds from the use of bromacil is unknown. Therefore, in order to complete the risk assessment, additional data are needed. In the absence of such data, risks to both listed and non

- listed bird species will be assumed in the risk assessment conducted for Registration Review.

**•** 850. 4100 and 850.41 50. Tier II terrestrial plant studies (seedling emergence and vegetative vigor) conducted using a typical end

- use product (TEP) are necessary for risk

assessment.

Additional detail on the current data gaps for environmental fate and effects for bromacil is provided in Section 8.

### 4 

# Problem Formulation for the Ecological Risk , Endangered Species, and Drinking Water Exposure Assessment s in Support of the Registration Review of Bromacil and Bromacil Lithium Salt

CAS Registry Number s : 314

- 40

- 9 and 53404

- 19

- 6 PC Code s : 012301 and 012302

Prepared by: Nathan Miller , Biologist U.S. Environmental Protection Agency Reuben Baris, Environmental Scientist Office of Pesticide Programs Environmental Fate and Effects Division Reviewed by : Environmental Risk Branch 6 William Eckel

, Acting Branch Chief 1200 Pennsylvania Ave., NW Mail Code 7507P Washington, DC 20460

May 22 , 2012

### 5 Table of Contents

1. PURPOSE

................................ ................................ ................................ ................................ ............................... 7

2. PROBLEM FORMULAT ION

................................ ................................ ................................ .............................. 7

2.1. N ATURE OF R EGULATORY A CTION

................................ ................................ ................................ ................. 7 2.2. P REVIOUS A SSESSMENTS

................................ ................................ ................................ ................................ .. 7 2.2.1. Ecological Risk Assessments

................................ ................................ ................................ ....... 7 2.2.2. Drinking Water Exposure Assessment

................................ ................................ ........................ 8

3. STRESSOR SOURCE AND DISTRIBUTION

................................ ................................ ................................ .... 8

3.1. M ECHANISM OF A CTION

................................ ................................ ................................ ................................ .. 9 3.2. O VERVIEW OF P ESTICIDE U SE AND U SAGE

................................ ................................ ................................ ..... 9 3.3. E NVIRONMENTAL F ATE AND T RANSPORT

................................ ................................ ................................ ..... 14 3.3.1 Environmental Fate Assessment

................................ ................................ ............................ 14 3.3.2 Environmental Transport Assessment

................................ ................................ ................... 18

4. RECEPTORS

................................ ................................ ................................ ................................ ........................ 20

4.1. E FFECTS TO A QUATIC O RGANISMS

................................ ................................ ................................ ............... 20 4.1.1. Toxicity to freshwater fish

................................ ................................ ................................ .......... 21 4.1.2. Toxicity to freshwater invertebrates

................................ ................................ .......................... 21 4.1.3. Toxicity to aquatic plants

................................ ................................ ................................ ........... 22 4.2. E FFECTS TO T ERRESTRIAL O RGANISMS

................................ ................................ ................................ ....... 23 4.2.1. Toxicity to birds

................................ ................................ ................................ ......................... 24 4.2.2. Toxicity to mammals

................................ ................................ ................................ .................. 24 4.2.3. Toxicity to terrestrial insects

................................ ................................ ................................ ..... 25 4.2.4. Toxicity to terrestrial plants

................................ ................................ ................................ ...... 25 4.3. I NCIDENT D ATABASE R EVIEW

................................ ................................ ................................ ....................... 27 4.4. E COSYSTEMS P OTENTIALLY AT R ISK

................................ ................................ ................................ ............ 27

5. ASSESSMENT ENDPO INTS

................................ ................................ ................................ .............................. 28

6. CONCE PTUAL MODEL

................................ ................................ ................................ ................................ 28

6.1. R ISK H YPOTHESIS

................................ ................................ ................................ ................................ .......... 28 6.2. C ONCEP TUAL D IAGRAM

................................ ................................ ................................ ................................ . 29

7. ANALYSIS PLAN

................................ ................................ ................................ ................................ ................ 31

7.1. S TRESSORS OF C ONCERN

................................ ................................ ................................ ............................... 32 7.2. M EASURES OF E XPOSURE

................................ ................................ ................................ .............................. 32 7.3. M EASURES OF E FFECT

................................ ................................ ................................ ................................ ... 34 7.4. I NTEGRATION OF E XP OSURE AND E FFECTS

................................ ................................ ................................ .. 35 7.5. D ETERMINISTIC AND P ROBABILISTIC A SSESSMENT M ETHODS

................................ ................................ .... 35 7.6. E NDOCRINE D ISRUPTOR S CREENING P ROGRAM

................................ ................................ ........................... 35 7.7. E NDANGERED S PECIES A SSESSMENT

................................ ................................ ................................ ............. 36 7.8. D RINKING W ATER A SSESSMENT

................................ ................................ ................................ .................... 37 7.9. E NVIRONMENTAL M ONITORING D ATA

................................ ................................ ................................ ......... 37 7.10. C LEAN W ATER A CT

................................ ................................ ................................ ................................ ..... 40

8. DATA G APS AND UNCERTAINTIE S

................................ ................................ ................................ ......... 41

8.1. E NVIRONMENTAL F ATE

................................ ................................ ................................ ................................ . 41 8.2. E C OLOGICAL E FFECTS

................................ ................................ ................................ ................................ ... 43 8.3. U SAGE S PECIFIC U NCERTAINTIES

................................ ................................ ................................ .................. 47

9. REFERENCES

................................ ................................ ................................ ................................ ...................... 48

APPENDIX A. ECOLOGI CAL EFFECTS DATA SUM MARIES

................................ ................................ ...... 50

### 6 APPENDIX B. FATE AN D ECOLOGICAL EFFECTS BIBLIOGRAPHIES

................................ ................... 57

APPENDIX C. BROMACI L ECOLOGICAL INCIDEN T SU MMARIES REPORTED IN THE EIIS DATABASE

................................ ................................ ................................ ................................ ............................... 66

### 7 1. Purpose

The main purpose of this problem formulation is to provide the status of the environmental fate and ecological effects of bromacil and its lithium salt , considering its currently registered uses. Bromacil is a non

- selective, broad spectrum herbicide of th e uracil class

. Registered nationally,

a gricultural uses of bromacil are limited to weed control in citrus orchards and pineapple fields

, while n on

- agricultural uses of bromacil and its lithium salt are less geographically restricted

, approved for weed an d brush control for right

- of

- ways, railroads, and industrial yards among other sites

. Bromacil can be applied as a soil band, soil broadcast, basal spray, or directed spray all of which will be considered during risk assessment. This document will provide a plan for analyzing data relevant to bromacil and for conducting ecological risk, federally

- listed threatened and endangered species (hereafter referred to as “listed”), and drinking water exposure assessments for its register ed uses. Additionally, this problem formulation is intended to identify data gaps, uncertainties, and potential assumptions used to address those uncertainties relative to characterizing the ecological risk associated with the registered uses of bromacil

.

2. Problem Formulation

2.1. Nature of Regulatory Action

Under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), all pesticides distributed or sold in the United States generally must be registered by the Environmental Protection Agency (EPA). In determining whether a pesticide can be registered in the United States, EPA evaluates its safety to non

- target species based on a wide range of environmental and health effects studies. In 1996, FIFRA was amended by the Food Quality Protection Act, and the Agency was mandated to implement a new program for the periodic review of pesticides, i

. e ., Registration R eview ( http://www.epa.gov/oppsrrd1/registration_review/ ). The Registrati on Review program is intended to ensure that, as the ability to assess risk evolves and as policies and practices change, all registered pesticides continue to meet the statutory standard of no unreasonable adverse effects to human health and the environme nt. Changes in science, public policy, and pesticide use practices will occur over time. Through the new Registration Review program, the Agency periodically reevaluates pesticides to make sure that as change occurs, products in the marketplace can be us ed safely.

As part of the implementation of the Registration Review program pursuant to Section 3(g) of the Federal Insecticide, Fungicide and Rodenticide Act (FIFRA), the Agency is beginning its evaluation of bromacil to determine whether it continues to meet the FIFRA standard for registration. This problem formulation for the ecological risk, listed species, and drinking water assessment chapter in support of Registration R eview will be posted in the initial docket that will open the public phase of the review process.

2.2. Previous Assessments

2.2.1. Ecological Risk Assessments

Bromacil was first regi stered in the United States in 1961. EPA issued a Registration Standard for bromacil in September 1982 (PB87

- 110276). In 1996, the Agency completed a Reregistration

### 8 Eligibility Decision (RED) for bromacil and its lithium salt (USEPA 1996)

. At the time of the RED, application rates were considerably higher than are presently registered, and registered uses included direct application to water. As a result, t he RED identified potential acute toxicity risks to mammals, listed birds , listed freshwater fish and invertebrates

, and terres trial and aquatic plants, with potential chronic risk to mammals

. The chronic toxicity dataset was largely deficient at the time of the RED, but because of the compound’s persistence in soil and water and the likelihood of repeat applications, the potenti al for chronic exposure was presumed to be high

. M itigation measures were required in the RED ; specifically application rate reductions and restrictions on aq uatic use that would reduce risk to freshwater fish and invertebrates

. Consistent with what was done for the environmental fate and ecological risk assessment in support of the RED, only parent bromacil and its lithium salt are included in this assessment.

In 2007, a litigation

- related California red

- legged frog (CRLF) effects determination was completed for b romacil. The CRLF assessment, which considered a maximum application rate of approximately half of the rate assessed in the RED, identified risk to aquatic nonvascular plants and small terrestrial mammals. The assessment resulted in a determination that the use of pesticide products containing bromacil and its lithium salt may affect, and is l ikely to adversely affect (LAA) the CRLF

.
2.2.2. Drinking Water Exposure Assessment

No formal drinking water assessment has been completed for bromacil. However, i n the RED drinking water exposure was assumed to be equal to the concentration of bromacil reported in submitted monitoring data ( i.e., 100 ppb)

. This approach was used because e xtensive data exists as evidence that bromacil leaches to groundwater as a result of normal agricultural use . A calculation of exposure to bromacil in drinking wa ter sources was completed. T he Agency determined that an adult drinking 2 liters of water per day over a lifetime containing 100 ppb of bromacil reaches < 4% of the reference dose ( RfD ) , and a 10 kg child drinking 1 liter of water containing 100 ppb of bromacil reaches 10% of the RfD. Furthermore, as the infant's/child's body weight increases with age, the percent of the RfD for consumption of bromacil

contaminated water decreases.

3. Stressor Source and Distribution

Bromacil is applied as a soil broadcast

, soil band ed

, basal spray

, or directed spray to control weeds in citrus orchards and pineapple fields. Bromacil and bromacil lithium are also registered for use on non

- cropland areas, including ( but not limited to) airports, parkin g lots, industrial areas, right

- of

- way s (for railroads, highways, pipeline and utilities), storage areas, lum beryards, tank farms, under asphalt and concrete pavement and fence rows. These chemicals can also be used in uncultivated portions of agricultural areas, including farmyards, fuel storage areas, fence rows and barrier strips. Aerial applications of brom acil are also registered on a national label

.
This assessment considers registrations of bromacil, as well as its salt, bromacil lithium, which in the environment rapidly dissociates to the anion bromacil acid in water (pKa = 9.1) . Bromacil and bromacil lithium are currently registered for use as herbicides , however since the salt rapidly dissociates to the acid in the environment this assessment is based on the acid bromacil.

### 9 3.1. Mechanism of Action

Bromacil is a uracil herbicide that interferes with plant photosynthesis by inhibiting the Hill reaction

. The herbicidal activity of the compound results from its ability to block O 2 

### release during the photosynthetic sequence, causing a build

- up of phytotoxic free radical molecules (Hoffman 1971).

3.2. Overview of Pesticide Use and Usage

Bromacil, a non

- selective broad spectrum herbicide

, along with its lit h ium salt

, are used for control of annual and perennial broadleaf and grass weeds in agricultural and non

- agricultural lands . In agri culture, bromacil (not bromacil lithium) is applied as a soil treatment on citrus and

as a post

- harvest application on pineapples. There are also labeled pre

- emergence and post

- plant uses on pineapple fields.

Bromacil is formulated as a wettable powder (WP), water dispersible gra nules (WDG), pressurized liqui d, pressurized gas, as pellets and ta blets, and in soluble and emulsifiable concentrates (SC and EC). The lithium salt of bromacil is exclusively formulated as a liquid. According to the Biological and Economic Analysis Division’s (BEAD) Usage Analysis Memo (USEPA 2011), roughly 370,000 lbs of bromacil is applied annually for the agricultural uses

. Oranges maintain the highest percent of total bromacil use at 86%, followe d by grapefruit (10%)

, and lemons (4%). N ote that BEAD does not have data on pesticide use on pineapple.

M ost agricultural usage ( in terms of pounds a.i. ) occurs in Florida (74%) and California (21%) (USEPA 2011)

. Based on information provided by BEAD, non

- agricultural uses collectively comprise a small share of the total usage of bromacil, but total non

- agricultural usage could not be quantified

.

There are a total of 45 current and active labels and one pending product for bromacil at this time , and e ight current and active labels for the bromacil lithium salt

. A ny new uses registered prior to completion of the ecological risk assessment in support of Registration Review will be assessed.

Tables 3.1 and 3 .2 present the uses and corresponding application rates (single and maximum), and the methods of application that will be considered in the Registration R eview assessment. Where seasonal /annual application rates or reapplication intervals are not stated, conservati ve assumptions will be made for risk assessment , unless modifications to the label are made that would restrict the number of applications and the interval between applications . For example, EFED may assume a 3 day retreatment interval for foliar applicati ons at the max labeled rate (the interval may be longer or shorter based on the activity of the compound)

.

### 10 Table 3

. 1

. Summary of use Sites and Application R ates for B romacil

.

Site Use Group AI%Formulation Max imum App lication Rate (lbs a.i./A) Seasonal Max Rate /Year (lbs a.i./A/yr) Application Method Application Timing

PINEAPPLE TERRESTRIAL FOOD 80 WP 4.8 8 Broadcast. Postplant
PINEAPPLE TERRESTRIAL FOOD + FEED 80 WP 3.2 3.2 Soil broadcast Postharvest
PINEAPPLE TERRESTRIAL FOOD + FEED 80 WP 4.8 8 Soil broadcast Preemergence CITRUS TERRESTRIAL FOOD + FEED 40 DF 3.2 6.4 Soil band When needed

80 WP 6.4 6.4 Soil broadcast Early summer, Winter COMMERCIAL/INSTI

TUTIONAL/INDUSTRIAL PREMISES/EQUIPMENT (OUTDOOR) TERRESTRIAL NON

- FOOD 0.61 RTU 8.9 8.9 Spray When needed FENCEROWS/ HEDGEROWS TERRESTRIAL NON

- FOOD 1 P/T 10 NS Spot

treatment. When needed INDUSTRIAL / CONSTRUCTION AREAS (OUTDOOR) TERRESTRIAL NON

- FOOD 1.52 EC 12 NS Spray When needed

80 WP .003125 lb / in of stem dia 12 Basal spray

treatment. Spring, Summer NONAGRICULTURAL OUTDOOR BUILDINGS/STRUCTURES TERRESTRIAL NON

- FOOD 0.61 RTU 9 9 Spray When needed NONAGRICULTURAL RIGHTS

- OF

WAY/FENCEROWS/HEDGE ROWS TERRESTRIAL NON

- FOOD 40 DF 12 12 Soil band/ broadcast

treatment When needed

80 WP .003125 lb / in of stem dia 12 Basal spray

treatment. Spring, Summer NONAGRICULTURAL UNCULTIVATED AREAS/SOILS TERRESTRIAL NON

- FOOD 1.52 EC 12 12 Spray When needed

80 WP .003125 lb / in of stem dia 12 Basal spray

treatment. Spring, Summer PAVED AREAS (ROADS/SIDEWALKS) TERRESTRIAL NON

- FOOD 80 WP 12 12 Soil

treatment. Preconstruction AGRICULTURAL UNCULTIVATED AREAS TERRESTRIAL NON

- FOOD 80 WP 12 12 Soil

treatment When needed

80 WP .003125 lb / in of stem dia 12 Basal spray treatment. Spring, Summer AIRPORTS/LANDING FIELDS TERRESTRIAL NON

- FOOD 2 G 8 12 Broadcast When needed 

### Form ulation abbreviations: WP= wettable powder; G= granular; RTU=ready to use, DF= dry flowable ; EC= emulsifiable concentrate; P/T= pelleted/ tableted

### 11 Table 3. 2

. Summary of Terrestrial Non

- f ood use Sites and Application Rates for B romacil Lithium S alt

.

Site AI%Formulation A.I. Max App Rate (lbs a.i./A) A.I. Conv Seasonal

Max Dose/Year (lbs a.i./A) Application Method Application Timing

AGRICULTURAL RIGHTS

- OF

WAY/FENCEROWS/HEDGEROWS 21.9 L .003 lb / in stem

dia 12. 4 Basal spray

treatment Summer, Late winter.

21.9 L 12.4 12. 4 Spray, Broadcast Summer, Late winter. AGRICULTURAL UNCULTIVATED AREAS 21.9 L .003 lb / in stem

dia 12. 4 Basal spray

treatment Summer, Late winter.

21.9 L 12. 4 12. 4 Broadcast, Spray Summer, Late winter. INDUSTRIAL / CONSTRUCTION AREAS (OUTDOOR) 7.5 L 12 12 Broadcast When needed.

2.5 RTU .00657031 lb / in trunk 12 Basal spray

treatment When needed.

2.5 RTU 12 12 Broadcast When needed.

21.9 L .00268902 lb / in stem dia 12. 4 Basal spray

treatment Summer, Late winter.

21.9 L 12. 4 12. 4 Spray Summer, Late winter. NONAGRICULTURAL RIGHTS

OF

WAY/FENCEROWS/HEDGEROWS 2.5 RTU .00657031 lb / in trunk 12 Basal spray

treatment When needed.

2.5 RTU 12 12 Broadcast When needed.

21.9 L .00272778 lb / in stem dia 12. 4 Basal spray

treatment When needed.

21.9 L 24.78204 lb / a NS Pre

- paving

treatment When needed.

21.9 L 12.4 12. 4 Broadcast Summer, Late winter. NONAGRICULTURAL UNCULTIVATED AREAS/SOILS 2.5 RTU .00657031 lb / in trunk 12 Basal spray

treatment When needed.

2.5 RTU 12 12 Broadcast When needed.

21.9 L .00272778 lb / in of stem dia 12. 4 Basal spray

treatment When needed.

21.9 L 12. 4 12. 4 Broadcast Summer, Late winter SEWAGE DISPOSAL AREAS 21.9 L 12. 4 12. 4 Broadcast, Spray When needed 

### Formulation abbreviations: L= liquid; RTU= ready to use

### 12 Table 3. 3 contains estimates for the annual average pounds of bromacil applied on a given crop based on data obtained from the USDA’s National Agric ultural Statistics Service (2003

- 2009 ) 1

, 2



### , and pr ivate market research data (2003

- 2010 ) 3



### . Additional registered uses may exist but are not included because the available surveys do not report usage ( e.g., small acreage crops). Lack of reported usage data for the pesticide on a crop does not imply zero usage. In instances where usage on a site was noted but not quantified, the site would not be reported. Table 3.1 does not inclu de non

- agricultural use sites ( e.g ., airports

, right

- of

- ways , stockyards

, etc .). Some sites show some use, even though they are not on the label. This usage could be due to various factors, including, but not limited to Special Local Need (SLN) Exemptions, existing stocks of the chemical, and data collection errors.

Table 3.3

. Screening

- Level Estimates of Agricultural Uses of Bromacil , Sorted Alphabetically Percent Crop Treated Crop Amount Active Ingredient (lb) Average Maximum

1 Fallow 1,000 <1 <2.5

2 Grapefruit 55,000 25 35

3 Lemons 1 0 ,000 10 15

4 Oranges 1 0 ,000 15 2 5 All numbers rounded. <500 Less than 500 pounds of active ingredient <2.5 Less than 2.5 percent of crop treated

<1 Less than 1 percent of crop treated N/C Only Lbs. A.I. available

SLUA (screening

- level usage analysis) data sources include: USDA

- NASS (United States Department of Agriculture's National Agricultural Statistics Service) Private Pesticide Market Research California DPR (Department of Pesticide Regulation)

1 USDA, 2006

- 2010. NASS Crop Reporting Districts. Online: http://www.ers.usda.gov/briefing/arms/resourceregions/resourceregions.htm#nass

2 USDA, 2007. Census of Agriculture. Online: http://www.agcensus.usda.gov/Publications/2007/index.asp

3 Proprietary Data. 2006

- 2010

### 13 Table 3.4 includes data for bromacil applications in the state of California between 2007 and 2010

. Total b romacil use on oranges and tangerines has increased since 2007

.
Table 3.4. Bromacil (012301) CA DPR Usage Data

– Amount of Bromacil Used in California from 2007 to 2010

Commodity 2007 Pounds Applied 2008 Pounds Applied 2009 Pounds Applied 2010 Pounds Applied

ALMOND 153
CITRUS FRUITS (ALL OR UNSPEC) 271 324 37 39 COMMERCIAL, INSTITUTIONAL OR INDUSTRIAL AREAS 69 4

GRAPEFRUIT 1940 1326 2612 1005

LANDSCAPE MAINTENANCE 2536 1898 2458 3948

LEMON 3108 2298 1855 2055
LETTUCE, LEAF (ALL OR UNSPEC) 27

LIME 43

N

- OUTDR CONTAINER/FLD GRWN PLANTS 8 10

ORANGE 18039 17597 19286 22091 POMELO (SHADDOCK) (CITRUS GRANDIS) 16 106

RANGELAND (ALL OR UNSPEC) 6 8

RIGHTS OF WAY 56842 40933 20311 33779

SUGARBEET, GENERAL 2
SOIL APPLICATION, PREPLANT

OUTDOOR 12

TANGELO 1013 961 1303 1029

TANGERINE 344 2462 3166 3524

UNCULTIVATED NON

- AG AREAS 455 232 448 131

WALNUT 72



### Grand Total 84772 68070 51580 67770 

### Date Prepared: 2/9/12 Cal DPR Data: http://www.cdpr.ca.gov/docs/pur/purmain.htm Empty cells indicate no available usage.

Figure 1 shows agricultural pesticide usage at the Crop Reporting District (CRD) level (map generated by the Biological and Economic Analysis Division of the Office of Pesticide Programs) . CRDs are boundaries created by USDA NASS which a re aggregates of counties (USDA 2010). Pesticide usage is displayed as average pounds (for the years 2006

- 2010) per 1,000 acres of farmland in a CRD to normalize for the variation in farmland between CRDs. Farmland acreage was obtained from USDA ( USDA 2007). Usage is based on private market surveys of pesticide use in agriculture that are proprietary data covering the years 2006

- 2010 (USEPA 2012 ). The survey data are limited to the states that represent the top 80

- 90% of

### 14 acreage for the individua l crops; therefore, use may be occurring in regions outside the scope of the survey. It is important to note that data for usage on pineapple are not included in Figure 1, which is a major use for bromacil.

Figure 1

. Estimated Annual National Agricultural Bromacil Usage.

3.3

. Environmental Fate and Transport

The environmental fate database for b romacil is incomplete; there are some gaps in the database

. All of the data in the environmental fate and transport database is based on bromacil versus the salt, bromacil lithium

, since under environment al conditions the salt rapidly dissociates to the anion bromacil. Therefore the fate and transport information presented in this section is based on the anion bromacil.

3.3.1 Envi ronmental Fate Assessment

Bromacil is a persistent and mobile herbicide. The primary routes of dissipation appear to be photolysis in water under alkaline conditions (pH 9) and microbial degradation under anaerobic

### 15 conditions. However, the photodegradat es under alkaline conditions have not been defined, and the rate of degradation under anaerobic conditions has not been accurately determined.

Degradation

- Abiotic

In laboratory studies, b romacil was stable to hydrolysis, photodegradation in water at pH 5 and 7, and photodegradation on soil. At pH 9

, where an absorption spectrum shift occurs, bromacil photodegrade d fairly rapidly with a half

- life of 4

- 7 days . However, t he radio labeled residues in the pH 9 test solution were not further c haracterized , so degradates were not identified or quantified

. Although this study is supplemental the Agency does not anticipate the need for a new study.

Degradation

– Biotic

Microbial degradation of bromacil in aerobic soil is slow , with a half

- life of 275 days in a silty clay loam soil. Carbon dioxide was the major degradate, totaling 40.3% of the applied at 12 months posttreatment. Data for only one soil have been submitted to the Agency ; therefore there is considerable uncertainty about the varia bility in degradation in different soil types. OPPTS guideline number 835.4100 requires a single soil for metabolic pathway identification, and three additional soils for determination of degradation kinetics. When there is only one acceptable soil, it i s Agency policy to multiply the single soil half

- life by three in risk assessment to account for the potential variability that exists in the degradation rate for different soils.

Aerobic soil m etabolites were a maximum of 1.6% of applied radioactivity. Five nonvolatile degradates were identified: 1) 5

- bromo

- 6

- methyluracil ( Metabolite G ) was a maximum of 3.4% of applied radioactivity at 304 days post

- treatment; 2) 5

- bromo

- 3

- (alpha

- hydroxymethylpropyl)

- 6

- methyluracil ( Metabolite C ) was a maximum of 1.5% of applied radioactivity at 154 and 184 days; 3) 5

- bromo

- 3

- sec

- butyl

- 6

- hydroxymethyluracil ( Metabolite A ) was a maximum of 0.6% of applied radioactivity at 184 days post

- treatment; 4) 5

- bromo

- 3

- (2

- hydroxy

- 1

- methylpropyl)

- 6

- methyluracil ( Metabolite D ) was a m aximum of 0.8% of applied radioactivity at 304 days; and, 5) 3

- sec

- butyl

- 6

- methyluracil ( Metabolite F ) was a maximum of 0.7% of applied radioactivity at 304 days.

The anaerobic aquatic metabolism study submitted to the Agency is unacceptable and cannot be upgraded. The study did not adequately characterize the degradation of bromacil under anaerobic conditions, which may be a major route of dissipation in subsoil . The sampling intervals were inadequate to accurately establish the half

- life of the test substance (>50% degraded between two samplings). Between day 28 and day 93, the percent applied radioactivity identified as bromacil decreased from 78.1% to 1.3%. This study does provide information on the formation of a major degradate, Metaboli te F , also detected in the aerobic soil metabolism study. Metabolite F was a maximum of 80.7% of the applied at day 304 post

- treatment. This product is likely formed through reductive dehalogenation, a reaction favored under anaerobic conditions. A new

ana erobic aquatic study with adequate sampling intervals to determine a half

- life was

re commended in the RED , but was not issued in the Generic Data Call

- in (GDCI)

.

### 16 Bromacil may be expected to degrade more rapidly under anaerobic than aerobic conditions. In

an open

- literature laboratory study, bromacil had an observed half

- life of 144 to 198 days in Greenfield sandy loam soil under saturated (anaerobic) soil conditions (Wolf, 1974). However, there is no acceptable guideline study for aquatic metabolism (aer obic or anaerobic), nor anaerobic soil. Therefore in absence of these data, for risk assessment purposes , the following conservative assumption s will be made:

Aerobic aquatic metabolism: 2x the aerobic soil metabolism input (275 d x 3 x 2 = 1

, 650 days) Anaerobic aquatic metabolism: “stable to microbial degradation” Anaerobic soil metabolism: “stable to microbial degradation”

Accumulation

Bromacil accumulates only slightly in fish and depurates rapidly. Maximum bioconcentration factors (BCF) were 4.6X for muscle, 6.8

- 8.3X for viscera, 2.1

- 2.2X for carcass, and 2.5

- 2.8X for whole fish. Depuration was rapid, with >96% of the accumulated [ 14 

### C] residues eliminated from the fish tissues by day 3 of the depuration period.

Table 3.5 presents the chemica l identities of bromacil and bromacil lithium. Table 3.6 presents the general physical and chemical properties, as well as the available environmental fate properties of bromacil.

Table 1

. 5

. Chemical identities of bromacil and brom acil lithium.

PARAMETER Bromacil Bromacil lithium

PC code 012301 012302

CAS No. 314

- 40

- 9 53404

- 19

- 6

Chemical name 5

- bromo

- 3

- sec

- butyl

- 6

- methyluracil 5

- bromo

- 3

- sec

- butyl

- 6

- methyluracil, lithium salt

Chemical formula C 9 H 13 BrN 2 O C 2 9 H 1 2 BrN 2 O 2 Li +

Molecular weight 261.1 g/mol 267.1 g/mol



### Table 3.6

. General Chemical Properties and Environmental Fate Properties of Bromacil.

Parameter Value Reference (MRID #) /Comment
Physical/Chemical Parameters

Molecular mass 261.12 g/mol USEPA, 1996

Vapor pressure (20°C) 3.1 x 10 - 7 USEPA, 1996 torr

Henry’s Law Constant 1.1 X 10 - 9 atm*m 3 USEPA, 1996 /mol

Water solubility (25°C) 815 mg/L in water USEPA, 1996

Octanol

- water partition coefficient (LogK OW 2.11 ) Hansch & Leo, 1995
Dissociation Constant (pKa) 9.1 bromacil ionizes at pH 9.1; USEPA, 1996

### 17 Parameter Value Reference (MRID #) /Comment
Mobility Freundlich adsorption partition coefficient

, K oc , L/kg oc Baldwin Lake (1/n) Big Bear Lake Castle Lake Clear Lake Delta Lake Jenks Lake Mockingbird Canyon

San Joaquin Marsh Average 289.1 (0.984) 49.7 (0.860) 43.8 (0.930) 39.5 (0.917) 61.7 (0.905) 39.9 (0.891) 26.5 (0.951) 26.3 (0.900) 41.1 (0.917) Corwin and Farmer (1987)

Column Leaching Soil Texture % of applied bromacil found in leachate of the four columns MRID 40951512 ( only column leaching data were available from submitted studies )

Sand total residues in leachate = 91.2

- 99.6% of the applied;
bromacil in leachate = 89.0

- 94.1% of the applied Sandy loam

Clay loam

Silt loam

Persistence in Water Hydrolysis half

- life (25°C, pH 5, 7, & 9) Stable MRID 40951505
Aqueous photolysis half

- life (25°C) (t 1⁄2 days) pH 5: 356 pH 7: 102 pH 9: 7, 4.3 MRIDs 40951507, 40951508 Absorption spectrum shift occurs in alkaline conditions (at pk
a of 9.1).

Aerobic aquatic metabolism half

- life No data No studies submitted.
Anaerobic aquatic metabolism half

- life No data for degradation of bromacil in anaerobic conditions. Submitted study unacceptable half

- lives are unreliable

. Persistence in Soil Soil Photolysis (t 1⁄2 days) 166 MRID 40951509

Aerobic soil metabolism half

- life (25°C) (days) 275 MRID 409515 10 Single soil (silty clay loam, Stine Farm Soil)

Anaerobic soil metabolism No data No acceptable studies submitted.

Field Dissipation

Terrestrial field dissipation half

- life (DT 50 ) 155 (silty clay loam soil in DE) † 124 (loam soil in CA) MRID 41677101 ; dissipation from soil surface of bare ground plots
Aquatic Bioconcentration

### 18 Parameter Value Reference (MRID #) /Comment
Bioconcentration Factor (BCF) in fish 2.5

- 2.8X MRID 40951513



### 3.3.2 Environmental Transport Assessment

Laboratory mobility data, in addition to groundwater monitoring information, have clearly demonstrated that bromacil is mobile in soil. However, bromacil’s tendency to leach was not overwhelmingly apparent from the two field dissipation studies. The timing and amount of rainfall/irrigation in these studi es is a possible explanation. The following section provides an overview of the environmental transport of bromacil.

Mobility

In column leaching studies, bromacil was mobile in columns of sand, sandy loam, clay loam, and silt loam soils. [ 14 

### C]Residues in the leachates of all four soils totaled 91.2

- 99.6% of the applied (b romacil comprised 89.0

- 94.1% of the applied ).

Aged (30 days) bromacil residues were also mobile in a column of silt loam soil. [ 14



### Batch equilibrium data were not submitted for bromacil. Additional data to determine the mobility of bromacil in the environment are needed to support an exposure assessment for bromacil. The added value of this data will provide the Agency with guideline compliant sorption coefficients in multi ple soils confirming the findings in open literature (Corwin and Farmer, 1984 and Gerstl, 1984) and QSAR estimates that bromacil is a leacher. In the CRLF effects determination assessment a K C]Residues in the leachate totaled 87. 3% of the applied radioactivity

. Bromacil was the only compound identified in the leachate, comprising 82. 8% of the applied radioactivity

.

oc 

### value of 32 L/kg oc 

### was used to model aquatic exposures

, which was obtained from the Soil Conservation Service Agricultural Research Station (SCS/ARS) database (USEPA, 2007) . EPISuite v 4.1 provides an estimated Koc value of 66 L/kg oc 

### . The EPISuite value is twice the SCS value, but is still classified as mobile based on FAO Soil Mobility Classifications. This value is similar in magnitude to values reported in the open literature. Gerstl (1984) found a n average Koc value of 23 L/kg oc 

### from experimental values deter mined in 8 soils and 4 sediments. Corwin and Farmer ( 198 4 ) reported adsorption in eight freshwater sediments, with K oc 

### ’s ranging from 26.3 to 289.1 L/kg oc 

### (an average of 41.1 L/kg oc 

### ). These values indicate that bromacil is mobile in soil, a conclusion which is consistent with the results observed in the column leaching studies. In absence of additional submitted data , the values reported in Corwin and Farmer (1984) and Gerstl (1984) wil l be formally reviewed and if found acceptable for use in risk assessment, the reported sorption values will be used for modeling purposes

.
Field Dissipation

In the field, b romacil was persistent, but did not demonstrate the degree of mobility that was predicted based on the laboratory studies and the available groundwater monitoring data. One possible explanation for the limited mobility in the two sites could be the amount and timing of

### 19 rainfall and irrigation. However, t he average rainfall for the t est period was about or above the 30

- year annual average of 43.36 inches for Wilmington, Delaware, so minimal irrigation was needed. The average rainfall at the second field site was below the 30

- year annual average of 9.84 inches for Fresno, California, so substantial irrigation was needed. Irrigation was based on common agricultural practice for the area. Bromacil (Hyvar ® 

### X Herbicide, 80% WP), applied at 12 lb ai/A, dissipated with half

- lives of 155 days from the upper 10 cm of a bare ground plot of si lty clay loam soil located in Delaware, and 124 days from the upper 10 cm of a bare ground plot of loam soil located in California. Bromacil was detected at the Delaware and California sites in the upper 10 cm of the plots through 538 and 415 days post tr eatment, respectively.

Transport

P otential transport mechanisms for bromacil include surface water runoff, spray drift

, and secondary drift of volatilized or soil

- bound residues leading to deposition on to nearby or more distant ecosystems. T he magnitude of pesticide transport via secondary drift depends on the pesticide’s ability to be mobilized into air and its eventual removal through w et and dry deposition of gases/ particles and photochemical reactions in the atmosphere. Based on the vapor

p ressure and Henry’s Law constant of bromacil, volatilization from treated areas resulting in atmospheric transport and deposition represent unlikely transport pathways.

Extensive data exists as evidence that bromacil leaches to groundwater as a result of normal agricultural use. Less data are available to determine the impact of bromacil applications from use on rights

- of

- way or other non

- agricultural uses. Data currently available to the EPA in a retrospective groundwater study , conducted prior to the RED

, indicate that bromacil has been detected in groundwater in 5 states, with concentrations in many Florida wells exceeding 100 ppb (DP 191409, 191677)

. Bromacil has been shown conclusively from groundwater monitoring data to leach to groundwater, diminishi ng the quality of the resource. In areas of the Central Ridge of Florida, such as DeSoto City, groundwater contaminated with bromacil had remained contaminated for several years. Based on this information, and the environmental fate and transport profile f or bromacil, there is the potential for bromacil to contaminate groundwater

resources.

DuPont conducted a retrospective groundwater monitoring study in three ci trus growing regions of Florida between 1987 and 1990. Bromacil was detected in groundwater a t all three study sites (described in greater detail in Section 7.9). DuPont also conducted a prospective groundwater monitoring study in response to the Generic Data Call

- in (GDCI) issued as part of the RED. It

was designed to evaluate the potential for bromacil to leach to groundwater in Florida’s Central Ridge region required by both the USEPA and Florida Dept. of Agriculture and Consumer Services as part of a proposed bromacil management strategy. This study is currently under review by the Agency , ho wever preliminary review of the results show that the concentrations detected in groundwater are lower than those reported prior to the implementation of the label mitigations

. Additional groundwater monitoring data from state

- level studies in Florida, Texas, and California detail bromacil c ontaminat ion of groundwater resources. These data are discussed in greater detail in the RED and below in section 7.9.

### 20 4. Receptors

Consistent with the process described in the Overview Document (USEPA, 2 004), the risk assessment for bromacil will rely on a surrogate species approach. Toxicological data generated from surrogate test species, which are intended to be representative of broad taxonomic groups, are used to extrapolate the potential effects on a variety of species (receptors) included under these taxonomic groupings.

A cute and chronic toxicity data from studies submitted by pesticide registrants along with the available open literature are used to evaluate the potential direct and indirect eff ects of bromacil to aquatic and terrestrial receptors. This includes toxicity on the technical grade active ingredient, degradates, and when available, formulated products ( e.g. , “Six

- Pack” studies). The open literature studies are identified through EPA ’s ECOTOXicology (ECOTOX) database 4



### , which employs a literature search engine for locating chemical toxicity data for aquatic life, terrestrial plants, and wildlife. The evaluation of both sources of data may also provide insight into the direct and indir ect effects of bromacil on biotic communities from loss of species that are sensitive to the chemical and from changes in structure and functional characteristics of the affected communities. A review of o pen literature data from ECOTOX on bromacil will b e conducted prior to initiation of the risk assessment phase for possible quantitative and/or qualitative inclusion in this risk assessment. The Agency seeks comments from the public on more sensitive endpoints that may be used in risk assessment.

A summary of the most sensitive submitted data representing non

- target organisms exposed to bromacil in aquatic and terrestrial habitats is provided in Sections 4.1 and 4.2 , respectively.

4.1. Effects to Aquatic Organisms

A summary of the aquatic toxicity data for bromacil (and the lithium salt of bromacil, where applicable) from registrant

- submitted studies is provided in Table 4.1 . The bibliography of all submitted ecotoxicity data for bromacil is provided in Appendix B

, and study summaries are provided in Appendix A . Bromacil is classified as slightly toxic to freshwater fish and practically nontoxic to estuarine/marine fish on an acute exposure basis. The most sensitive acute toxicity endpoints (96

- hr LC 50 

### values) for freshwater and estuarine/marine fish are 36,000 (rainbow trout; Oncorhynchus mykiss ) and 162,000 μg/L (sheepshead minnow; Cyprinodon variegatus ), respectively. Among freshwater and estuarine/marine invertebrates

, the most sensitive acute toxicity endpoin ts (EC 50 

### values) were 121,000 μg/L (water flea; D. Magna ) and 1 12,900 μg/L (mysid shrimp; Americamysis bahia ), respectively.

On a chronic exposure basis, the most sensitive endpoints for freshwater fish and freshwater invertebrates are for rainbow trout ( O

. mykiss ); NOAEC= 3,000 μg/L and water flea ( Daphnia

magna ); NOAEC= 8,200 μg/L. No chronic data is available for estuarine/marine fish. Since there is no indication that estuarine/marine organisms are more sensitive than freshwater organisms, in the absence of additional data EFED will use the chronic freshwate r fish data when

4 USEPA. 2011. ECOTOX Database http://cfpub.epa.gov/ecotox/

### 21 evaluating chronic risk to saltwater fish. No data are available to assess chronic toxicity to estuarine/marine invertebrate s.

Aquatic vascular and non vascular plants are extremely sensitive to bromacil. The 14

- day EC 50 

### for the vascula r aquatic plant duckweed ( Lemna gibba) is 45 μg/L, and the most sensitive non

vascular species is freshwater green algae Pseudokirchneriella subcapitata , with a 120

- hr EC 50 

### of 6.8 μg/L.

4.1.1. Toxicity to freshwater fish

Acute exposures

The available re gistrant

- submitted study involving rainbow trout ( O

. mykiss ) was a static, 96

- h exposure, resulting in a LC 50 

### of 36 mg/L (95% confidence interval: 30

- 40 mg/L). This LC 50 

### value represents the most sensitive endpoint available for acute exposures of fish to bromacil. Sublethal effects observed in surviving fish exposed to 22.5 mg/L bromacil and higher included loss of equilibrium, swollen appearance and sinking to the bottom of test vessels. No effects were described at 16.9 mg/L (MRID 40951503).

The registrant

- submitted study involving bluegill sunfish ( Lepomis macrochirus ) was a static, 96

- h exposure, resulting in a LC 50 

### of 127 mg a.i. /L

. Sublethal effects observed in surviving fish exposed to 95 mg / L bromacil and higher included loss of equilibrium

. No effects were described at 71 mg/L (MRID 409515 02).

Chronic exposures

Data are available from a registrant

- submitted study where rainbow trout ( O

. mykiss ) were exposed to bromacil for 90 days in a flow

- though study . The NOAEC and LOAEC values for this study were 3.0 and 7.2 mg a.i. /L , respectively, based on treatment

- related effects to mean wet weight , which was the only measured endpoint that was affected

. At the highest test concentration (7.2 mg a.i./L), measur ed wet weights of juvenile fish were 32.4% lower than controls. No treatment related effects on survival were observed in any of the treatment groups (maximum of 7.2 mg a.i./L). This study is scientifically sound, but is classified supplemental

, due to excessive variation in measured concentrations of bromacil in the treatment levels (MRID 44566101).

4.1.2. Toxicity to freshwater invertebrates

Acute exposures

The available registrant

- submitted study involving waterflea ( D

. magna ) was a static, 48

- h exposure, resulting in an EC 50 

### of 121 mg/L (95% confidence interval: 111

- 148 mg/L), based on immobility. Effects were observed at 111 and 148 mg /L (20% and 100% immobility, respectively, with no effects de scribed at 83 mg/L (MRID 409515 04). This EC 50 

### value is used in this risk assessment for quantifying RQ values for acute exposures of aquatic invertebrates to bromacil.

### 22 Chronic exposures

Data are available from a registrant

- submitted study where waterfleas ( D. magna ) were exposed to b romacil for 21 days. The NOAEC and LOAEC values for this study were 8.2 and 21 mg

a .i./L, respectively, based on treatment

- related effects to reproduction and growth . In the 21 mg a.i./L treatment level, adults did not produce offspring. Also, at that t reatment level, adults had significantly reduced body lengths and dry weights in comparison to organisms in the negative control (13% and 45% decreases, respectively; MRID 44566401).

4.1.3. Toxicity to aquatic plants

Bromacil is highly toxic to aquatic plants, with an EC 50 

### for Selenastrum capricornatum of 6.8 ppb. This is of particular concern in Florida, where because of high water tables, groundwater discharges into drainage canals, which ultimately drain into surface water bodi es. In addition, bromacil has been found in groundwater at concentrations that exceed levels

- of

- concern for non

target terrestrial plants, as determined by seedling

- emergence studies. This could be a concern in areas where contaminated ground water is used for irrigation.

Unicellular plants

Registrant

- submitted studies for algae and diatoms (unicellular plants) include EC 50 

### values ranging from 6.8

- 69.9 μg a.i./L, based on decreased cell density. Reductions in biomass (determined from cell counts recorded via Coulter Counter) for Selenastrum capricornutum were observed at exposures to the lowest bromacil concentrations tested, i.e ., 1.1 μg a.i./L.

Vascular plants

Data are available from a registrant

- submitted study where duckweed ( L

. gibba ) was exposed to bromacil for 14 days. The NOAEC and EC 50 

### values based on decrease in frond number were 17 and 45 μ g a.i./L, respectively. Effects to dry weight were also observed during this study (MRID 46095401) albeit at higher concentrations

.

### 23 Table 4.1

. Summary of the Endpoints from Submitted Aquatic Toxicity Studies for Bromacil

Study Type Species Toxicity Value Toxicity Classification MRID & Status

Acute

– Freshwater Fish 850.1075 Rainbow trout (Oncorhynchus mykiss ) 96

- hr LC 50 Slightly toxic : 36 ppm 409515 03 Acceptable

Acute

– Estuarine/Marine Fish 850.1075 Sheepshead minnow (Cyprinodon variegatus ) 96

- hr LC 50 : 162.8 ppm Practically nontoxic 415887 02 Acceptable

Chronic

– Freshwater Fish 850.1400 Rainbow trout (Oncorhynchus mykiss ) NOAEC: 3.0 ppm LOAEC: 7.2 ppm N/A 445661 01 Supplemental

Chronic

-- Saltwater Fish 850.1400 N/A N/A N/A Data Gap

Acute

– Estuarine/Marine Invertebrate

850.1035 Mysid shrimp ( Americamysis bahia ) 96

- hr LC 50 Practically nontoxic : 112.9 ppm 415887 01 Acceptable

Acute

– Freshwater Invertebrate

850.1010 Water flea ( Daphnia

magna ) 48

- Hr EC 50 Practically

non toxic 121 ppm 409515 04 Acceptable

Chronic

– Freshwater Invertebrate

850.1300 Water flea ( Daphnia

magna ) NOAEC: 8.2 ppm LOAEC: 21 ppm (reproduction and growth) N/A 445664 01 Acceptable

Chronic

– Estuarine/Marine Invertebrate

850.1350 N/A N/A N/A Data Gap

Aquatic

– Non

vascular Plants 850.5400 Green algae ( Pseudokirchneriella subcapitata ) [Tier 2] 120

- hour EC 50 N/A : 0.0068

ppm 425164 01 Supplemental

Aquatic

– Vascular Plants 850.4400 Duckweed ( Lemna gibba ) [Tier 2] EC 50 NOAEC: 0.017 ppm : 0.045 ppm

(frond number and dryweight) N/A 460954 01 Acceptable



### 4.2. Effects to Terrestrial Organisms

Table 4.2 summarizes the terrestrial toxicity data for bromacil based on an evaluation of submitted studies. In general, bromacil is characterized as practically nontoxic toxic to birds on an acute oral exposure basis and practically nontoxic on a subacute dietary exposure basis . The acute oral endpoint for the northern bobwhite quail ( Colinus virginianus ) was > 2250 mg/kg, and subacute dietary LC 50 

### s for C. virginianus and mallard duck ( Anas platyrhynchos ) were > 10,000 mg/kg

- diet/day

. C

. virginianus and A

. platyrhynchos were equally sensitive under the study design for chronic exposure (NOAEC= 1550 mg/kg diet).

### 24 4 .2.1. Toxicity to birds

Acute

Data are available from a registrant

- submitted study, where bobwhite quail ( Colinus virginianus ) were given acute, oral doses of bromacil. No mortalities were observed during the 14

- day study period, which resulted in a LD 50 

### >2250 mg/kg (highest dose tested). Between days 0 and 3, reduced body weight gains in relation to the control were observed at the two highest t est doses, resulting in a NOAEL of 810 mg/kg. At 1350 mg/kg, body weight gains in female birds were 5.1% lower than controls. At 2250 mg/kg, body weight gains in female and male birds were decreased 4.7 and 5.4%, respectively, when compared to controls. By the end of the study, body weight gains of females and males were similar in all treatment groups, including controls (MRID 40951501).

No data are available for sub

- acute dietary exposures of birds to technical bromacil. I n lieu of toxicity data for technical grade bromacil, available data from a study involving dietary

- based exposures of birds to a formulated product (Hyvar ® 

### X Bromacil Weed Killer, 80% a.i.) of bromacil are used in this assessment. In this study, mallard ducks ( Anas platyrhynchos ) and bobwhite quail were exposed to a formulated product of bromacil (83.4% a.i.) through dietary exposures. The resulting 8

- d LC 50 

### values for both species exceeded the highest concentration tested, i.e. , >10,000 mg/kg

- diet/day (of bro macil). No mortalities were observed in exposures involving mallard ducks. Bobwhite quail mortalities were observed in exposures involving several different treatment levels; however, the mortalities were less than 50% of individuals in each treatment gr oup. In the test, 6.8% mortality was observed in controls, 10% mortality was observed in the 464 and 4,640 mg/kg

- diet/day treatment levels and 20% mortality was observed in the 2,150 and 10,000 mg/kg

- diet/day treatment levels (MRID 00013295). This study is classified acceptable for a formulated product , but supplemental for use in risk assessment, since the test material was not technical bromacil as required by 40 CFR §158.630

.

Chronic

Data are available from two registrant

- submitted studies, where bob white quail and mallard ducks were given chronic (21

- week) dietary exposures to bromacil. In the study involving Northern bobwhite quail, effects to hatchability, embryo viability, embryo survival and hatching survival were observed at 3100 mg/kg

- diet/day , resulting in a NOAEC of 1550 mg a.i./kg

diet/day (MRID 44844801). In the study involving mallard ducks, significant effects were observed in egg shell thickness at the 3100 mg a.i./kg

- diet/day treatment level. Significant effects to hatchability of mal lards were observed at the 6200 mg a.i./kg

- diet/day treatment level. The NOAEC for this study was also 1550 mg a.i./kg

- diet/day (MRID 44844601).

4.2.2. Toxicity to mammals

Acute

### 25 Data are available from a registrant

- submitted study, where laboratory rats ( Rattus norvegicus ) were given acute oral doses of technical grade bromacil. Mortalities were observed in animals dosed with 1000 and 2000 mg/kg, which resulted in an acute oral LD 50 

### of 812 mg/kg for females and 1682 mg/kg for males. Sub lethal effects that were observed included: hunched posture, ataxia, lethargy, decreased respiration, hemorrhagic lungs, and dark liver and kidneys (MRID 44196209).

Chronic

Data are available from a 2

- generation dietary exposure reproduction study in rat s. The reported NOAEL was 250 mg/kg

- diet/day, with a LOAEC of 2500 mg/kg

- diet/day. Observed effects included decreased growth ( body weight reductions ) in parent and first and second generation offspring (MRID 41804601).

4.2.3. Toxicity to terrestrial insects

Data are available on the acute toxicity of bromacil to honey bees ( Apis mellifera ). In an acute contact toxicity study, the LD 50 

### was higher than the highest dose tested, i.e., >11 μg a.i./bee (MRID 00251374). In another study involving 96

- h acute contact exposures of honeybees to a formulated product containing bromacil (Hyvar ® 

### X Bromacil Weed Killer, 80% a.i.), the LC 50



### was > 193.38 μg/bee (MRID 00018842). At this level, 1.2% mortality was observed. Adjustment of this value for the % a.i. of the test substance results in an LD 50 

### >155 μg a.i./bee. This toxicity value is converted to units of μg a.i./g (of bee) by multiplying by 1 bee/0.128 g thereby resul ting in an LD 50 

### >1209 μg a.i./g.

4.2.4. Toxicity to terrestrial plants

Toxicity data were submitted from seedling emergence and vegetative vigor studies involving separate exposures of wheat (monocot) and rape (dicot) to technical bromacil and technical bromacil lithium. This study was intended to create suitable data for comparison of the effects of bromacil and bromacil lithium on seedling emergence and vegetative vigor, using the most sensitive monocot and dicot species as determined by MRID 42491101

.
In the seedling emergence tests involving bromacil and bromacil lithium, percent survival, dry weight and plant height were significantly affecte d in both wheat and rape. The percent inhibition in seedling emergence in the treated species as compared t o the control ranged from

- 11 to 5% for bromacil and from

- 5 to 13% for bromacil lithium. The most sensitive endpoint for wheat and rape in the seedling emergence tests was dry weight. The following abnormalities were noted for bromacil: slight growth ret ardation, malformations, chlorosis and necrosis. The following abnormalities were noted for bromacil lithium: slight to moderate chlorosis, slight to severe growth retardation, slight unusual pigmentation and slight to severe burn or necrosis. NOAEC, EC 25 

### and EC 50 

### values for bromacil a nd bromacil lithium exposures indicate that the two chemicals are of similar toxicities to wheat and to rape (MRID 444883

- 07).

In the vegetative vigor tests, the plant dry weight and plant height were affected by exposures to bromacil and bromacil lithium. The most sensitive endpoint for wheat and rape in the vegetative

### 26 vigor tests was dry weight. The following abnormalities were noted in tests where plants were exposed to bromacil or bromacil lithium: chlorosis, necrosis and growth retardation. NOAEC, EC 25 

### and EC 50 

### values for bromacil a nd bromacil lithium exposures indicate that the two chemicals are of similar toxicities to wheat and to rape (MRID 444883 07).

Table 4.2. Summary of the Endpoints from Submitted Terrestrial Toxi city Studies for Bromacil Study Type Species Toxicity Value Toxicity Classification MRID & Status Acute

– Avian Oral 850.2100 Bobwhite Quail (Colinus virginianus ) LD 50 Practically nontoxic : > 2250 mg/kg

- bw 409515 01 Acceptable

Acute

– Avian Dietary 850.2200 Mallard Duck ( Anas platyrhynchos )

,

Bobwhite Quail (Colinus virginianus ) 8

- day LC 50 Practically non toxic : >10,000 ppm 00013295, 00013296 Acceptable

Chronic

– Avian

Reproduction

850.2300 Mallard Duck ( Anas platyrhynchos )

,

Bobwhite Quail (Colinus virginianus ) NOAEC: 1550 ppm LOAEC: 3100 ppm (eggs set , embryo viability,

hatchability, hatchling survival) N/A 448446 01

, 448448 01 Acceptable

Acute

– Mammalian Oral 870.1100 Rattus norvegicus (laboratory rat) LD 50 Slightly toxic = 812 mg/kg 44196209 Acceptable

Two

- generation

Mammalian Reproduction

870.4100 Rat ( Rattus norvegicus ) NOAEC = 250 mg/kg

diet/day (bodyweight reductions)

L OAEC = 2500 mg/kg

diet/day N/A 418046 01 Acceptable

Chronic Mammalian Reproduction (developmental) 870.4100 Rabbit (Sylvilagus sp.) NOAEL /LOAEL = 100/300 mg/kg (development) N/A 409848 01

Acute

– Contact Toxicity 850.3020 Honey Bee ( Apis mellifera ) LD 50 Practically nontoxic : 193 μg ai/bee 000 09181 Supplemental
Terrestrial plant Seedling

emergence

- Tier

I I 850.4225 Monocot: Wheat EC 25 NOAEC= 0.020 lbs ai/A = 0.030 lbs ai/A N/A 444883 07 Supplemental
Lithium salt: EC 25 NOAEC= 0.020 lbs ai/A = 0.034 lbs ai/A N/A 444883 07 Supplemental

Dicot: Oilseed rape EC 25 NOAEC= 0 .0011 lbs ai/A * = 0.0047 lbs ai/A N/A 444883 07 Supplemental
Lithium salt: EC 25 NOAEC= 0.006 lbs ai/A = 0.010 lbs ai/A N/A 444883 07 Supplemental
Terrestrial plant Vegetative vigor

- Tier II

850.4250 Monocot: Wheat EC 25 NOAEC= 0.020 lbs ai/A = 0.042 lbs ai/A N/A 444883 07 Supplemental
Lithium salt: EC 25 NOAEC= 0.001 lbs ai/A = 0.028 lbs ai/A N/A 444883 07 Supplemental

Dicot: Oilseed rape EC 25 NOAEC= 0.006 lbs ai/A = 0.0055 lbs ai/A N/A 444883 07 Supplemental

### 27 Study Type Species Toxicity Value Toxicity Classification MRID & Status
Lithium salt: EC 25 NOAEC= 0.003 lbs ai/A = 0.0060 lbs ai/A N/A 444883 07 Supplemental

*The EC 05 is used in lieu of the NOAEC



### 4.3. Incident Database Review

A review of the Ecological Incident Information System (EIIS) database for incidents involving bromacil was conducted on February 27

, 2012

. Forty

- two incidents are reported in the database (Appendix C ) encompassing reports from 1992 through 2009

. Of these, 37 are plant incidents that occurred from use on agricultural areas (including citrus, peanut, corn , and pasture/fencerows ), and uses on home and r ights of way sites; the incidents ranged in certainty from ‘possible’ to ‘highly probable’. The magnitude of the inciden ts varied from three to 1 00

acres . In addition to the plant incidents, there is one aquatic incident with a certainty of ‘highly proba ble’, three with a certainty of ‘p robable

, ’ and one classified as ‘possible.’ One of the three ‘probable’ reports indicates a fish kill of hundreds of white sucker, notropis minnow, American eel, and blacknose dace in a stream in Delaware ; the next ‘proba ble’ report indicated a fish kill of 600 unidentified fish in a Louisiana stream (the sole ‘highly probable’ report indicated a kill of hundreds of unidentified species in a Louisiana stream following intentional misuse) ; and the third ‘probable’ report was not explicit regarding species or number of individuals dead in an Iowa stream

. The incident classified as ‘possible’ reported the death of some catfish in a pond adjacent to a use site in Mississippi

.
Similarly, a search of the Avian Incident Monito ring System (AIMS; http://www.abcbirds.org/abcprograms/policy/toxins/aims/aims/index.cfm ) was conducted. AIMS is a database administered by the American Bird Conservancy t hat contains publicly available data on reported avian incidents involving pesticides. No incidents with bromacil were reported via AIMS.

Pesticide registrants report certain types of incidents to the Agency as aggregate counts of incidents occurring per product per quarter. Thirteen aggregated plant incidents have been reported to the Agency associated with bromacil since 1998. Unless further information regarding these aggregate incidents is discovered, it will be assumed that they resulted from regis tered uses.

4.4. Ecosystems Potentially at Risk

The ecosystems at risk are often extensive in scope; therefore, it may not be possible to identify specific ecosystems during the development of a nation

- wide ecological risk assessment. However, in general terms, terrestrial ecosystems potentially at ris k could include the treated field and immediately adjacent areas that may receive drift or runoff. Areas adjacent to the treated site could include cultivated fields, fencerows and hedgerows, meadows, fallow fields or grasslands, woodlands, riparian habit ats and other uncultivated areas.

Aquatic ecosystems potentially at risk include water bodies adjacent to, or downstream from, the treated field and could include impounded bodies such as ponds, lakes and reservoirs, or flowing

### 28 waterways such as streams or rivers. For uses in coastal areas, aquatic habitat also includes marine ecosystems, including estuaries.

5. Assessment Endpoints

Assessment endpoints represent the actual environmental value that is to be protected, defined by an ecological entity (species, community, or other entity) and its attribute or characteristics (USEPA 1998). For bromacil, the ecological entities may include the following: birds, mammals, terrestrial

- phase amphibians, reptiles, freshwater fish and invertebrates, aq uatic

- phase amphibians, estuarine/marine fish and invertebrates, terrestrial plants, terrestrial invertebrates, and aquatic plants. The attributes for each of these entities include growth, reproduction, and survival.

6. Conceptual Model

For a pesticide to pose an ecological risk, it must reach ecological receptors in biologically significant concentrations. An exposure pathway is the means by which a pesticide moves in the environment from a source to an ecological receptor. For an ecological pathway to be complete, it must have a source, a release mechanism, an environmental transport medium, a point of exposure for ecological receptors, and a feasible route of exposure.

The conceptual model for bromacil provides a written description (risk hypothesi s) and visual representation (conceptual diagram) of the predicted relationships between bromacil, potential routes of exposure, and the predicted effects for the assessment endpoint. A conceptual model consists of two major components: risk hypothesis an d a conceptual diagram (USEPA 1998 ).

Based on the available data, bromacil is water soluble

. It is stable in neutral to acidic water, but is increasingly unstable in alkaline conditions. Bromacil is persistent in soil under aerobic conditions, but assume d to be stable in soil and sediment under anaerobic conditions until data are available. It is mobile in soil and is semi

- volatile. Bromacil appears to have the potential to leach into ground water , which is supported by monitoring data, or move offsite i nto surface water. Given its relatively low Log K ow 

### and BCF

, bromacil is not expected to bioaccumulate in aquatic or terrestrial food chains.

6.1. Risk Hypothesis

Risk hypotheses are specific assumptions about potential adverse effects (i.e., changes in assessment endpoints) and may be based on theory and logic, empirical data, mathematical models, or probability models (U.S. EPA, 1998). For this assessment, the ri sk is stressor

- linked, where the stressor is the release of bromacil and bromacil lithium to the environment. The following risk hypotheses are presumed for this national

- level ecological risk assessment:

Given the uses of bromacil and its environmental fate properties, there is a likelihood of exposure to non

- target terrestrial and aquatic organisms. When used in accordance with the label, bromacil may result in potential adverse effects upon the survival, growth, and reproduction of non

- target terrestr ial and aquatic organisms.

### 29 Additionally, bromacil is a uracil herbicide that is known to leach through the soil profile, and has been shown to contaminate ground water resources

. Therefore, bromacil has the potential to result in risk to terrestrial non

- target plants irrigated with contaminated ground water.

6.2. Conceptual Diagram

The conceptual model used to depict the potential ecological risk associated with the use of bromacil assumes that as a pesticide, bromacil can adversely affect terrestri al and aquatic organisms (the receptors) if environmental concentrations exceed toxic thresholds as a result of application according to the label directions ( Figures 2 and 3 ). Ecological receptors that may potentially be exposed to bromacil include terrestrial and semi

- aquatic wildlife ( e.g. , mammals, birds, terrestrial

- phase amphibians and reptiles), terrestrial and semi

- aquatic plants, and terrestrial invertebrates ( e.g. , honey bees). Additionally, aquatic organisms ( i.e. , freshwater and estuarine/marine fish and invertebrates, aquatic

- phase amphibians, and aquatic plants) are potential receptors in adjacent water bodies through off

- site transport of bromacil from the application site through runoff, erosion, and spray drift.

### 30 Figure 2 . Conceptual model for b romacil exposure to aquatic organisms. Dashed lines indicate low

- likelihood routes of exposure

. 

## Stressor

Source

Receptors

Attribute Change Bromacil and Bromacil Lithium Salt

Spray drift

Fish/aquatic

- phase amphibians Eggs Larvae Juveniles / Adults

Individual organisms Reduced survival Reduced growth Reduced reproduction Food chain Reduction in algae Reduction in prey Habitat integrity Reduction in primary productivity Reduced cover Community change Surface water Runoff

Aquatic Animals Invertebrates Vertebrates 

## Exposure Media

Uptake/gills

or integument

Ingestion Ingestion A tmospheric transport

Wet/dry deposition Soil Ground water

Uptake/gills or integument

Aquatic Plants Non

- vascular Vascular Uptake/cell, roots, leaves Riparian plant terrestrial

exposure pathways see

Figure 2

### 31 Figure 3 . Conceptual model for bromacil exposure to terrestrial organisms. Dashed lines indicate low

- likelihood routes of exposure

.


### 7. Analysis Plan

In order to address the risk hypothesis, the potential for adverse effects on the environment will be estimated. The use, environmental fate, and ecological effects of bromacil will be characterized and integrated to assess the risks. This will be accomp lished using a risk quotient (ratio of exposure concentration to effects concentration) approach. Although risk is often defined as the likelihood and magnitude of adverse ecological effects, the risk quotient

- based approach does not provide a quantitativ e estimate of likelihood and/or magnitude of an adverse effect. However, as outlined in the Overview Document (USEPA 2004), the likelihood of effects to individual organisms from particular uses of bromacil may be estimated using the probit dose

- response slope and either the level of concern (discussed below) or the actual calculated risk quotient value.

This analysis plan will be revisited and may be revised depending upon the information submitted by the public in response to the opening of the Regist ration Review docket for bromacil

. 

## Stressor

Source

Receptors

Attribute Change Bromacil and Bromacil Lithium Salt

Direct application Spray drift

Birds / Terrestrial

phase amphibians / reptiles / mammals/ Insects Terrestrial

i nver ts

Individual organisms Reduced survival Reduced growth Reduced reproduction Food chain Reduction in prey Habitat integrity Reduction in primary productivity Reduced cover Community change Terrestrial/riparian plants grasses/forbs, fruit, seeds (trees, shrubs) Runoff

Mammals 

## Exposure Media Soil

Ingestion Ingestion

Ingestion Ingestion Dermal uptake/Ingestion A tmospheric transport

Root uptake Wet/dry

Birds / Amphibians

Ingestio

### 32 7.1. Stressors of Concern

Bromacil has registered products that contain multiple active ingredients, including diuron; 2,4

- dichlorophenoxyacetic acid; sodium chlorate; sodium meta borate; and 2,4

- dichlorophenoxy acetic acid, isooctyl ester . Analysis of the available acute oral mammalian LD 50 

### data ( and available open literature for b romacil ) for multiple active ingredient products relative to the single active ingredient were provided in Appendix A of the 2007 California Red

- legged Frog assessment (USEPA 2007) . The results of that analysis show ed that an assessment based on the toxicity of the single active ingredient of bromacil or bromacil lithium would be appropriately conservative since the technical grade active ing redient is more toxic than the formulated end product. However, the assessed species and their environments may be exposed to multip le pesticides simultaneously, and the i nteractions of other toxic agents (not captured in the available mixture toxicity da ta) with bromacil could potentially result in additive effects, synergistic

, or antagonistic effects.

The Agency does not routinely include, in its risk assessments, an evaluation of mixtures of active ingredients, either those mixtures of multiple active ingredients in product formulations or those in the applicator’s tank. In the case of the product formulations of active ingredients (that is, a registered product containing more than one active ingredient), each active ingredient is subject to an individual risk assessment for regulatory decision regarding the active ingredient on a particular use site. If effects data are available for a formulated product containing more than one active ingredient, the data may be used qualitatively or quantita tively in accordance with the Agency’s Overview Document and the Services’ Evaluation Memorandum (U.S., EPA 2004; USFWS/NMFS 2004).

Although bromacil photodegrades rapidly in alkaline conditions, information on photodegradates is not available. In neut ral pH soil (pH 6.6) , bromacil degrades slowly (half

- life of 275 days), and CO 2 

### is the only major degradate. Five aerobic soil minor degradates were identified, but were present at only 0.6

- 3.4% of total residues. The major and persistent anaerobic aquat ic degradate, 3

- sec

- butyl

- 6

- methyluracil (Metabolite F), which represented a maximum of 80.7% of the applied (day 304), was not determined to be of toxicological concern for the human health risk assessment (Linda Taylor, HED/OPP) in the bromacil RED ; this determination of residues of concern also applies to the ecological risk assessment (i.e., only the parent bromacil is included for assessment of risk for ecological systems).

7.2. Measures of Exposure

Measures of exposure are based on aquatic and terrestrial models that predict estimated environmental concentrations (EECs) of bromacil using maximum labeled application rates and methods cited in Section 3.2 . The models used to predict aquatic EECs are the Pesticide Root Zone Model coupled with the Exposure Analysis Model System (PRZM/EXAMS). The model used to predict terrestrial EECs on food items is T

- REX. The model used to derive EECs relevant to terres trial and wetland plants was TerrPlant . These models are parameterized using relevant reviewed registrant

- submitted environmental fate data. Model input values will be consistent with the most recent version of the input parameter guidance (Version 2.1; USEPA 2009).

### 33 PRZM (v 3.12.2; 5/15/05 ) and EXAMS ( v2.98.04.06; 4/25/05 ) are simulation models coupled with the linkage program shell: PE5 ( P RZM E XAMS Model Shell; v 5 .0; 11/15/06), which incorporates the standard scenarios developed by EFED. The models gene rate daily exposures and calculated 1

- in

- 10 year EECs of bromacil

. PRZM simulates pesticide fate and transport as a result of leaching, direct spray drift, runoff and erosion from an agricultural field, and EXAMS estimates environmental fate and transport of pesticides in a surface water body for a 30

- year period. The combined model is designed to estimate pesticide concentrations found in water (standard pond) at the edge of the treated field. As such, it provides high

- end values of the pesticide concen trations that might be found in ecologically sensitive environments following pesticide application. The location of the field is specific to the crop being simulated using site

specific information on the soils, weather, cropping, and management factors associated with the scenario. The crop/location scenario is intended to represent a high

- end exposure site on which the crop is normally grown. Based on historical rainfall patterns, the receiving water body receives multiple runoff events during the yea rs simulated. Weather and agricultural practices are simulated for 30 years so that the 10

- year exceedance probability at the site can be estimated. The simulation is generated using 30 years of meteorological data, encompassing the years from 1961 to 19 90. Additional information on these models can be found at: http://www.epa.gov/oppefed1/models/water/index.htm

.
The standard scenarios used for ecological pesticide assessments assume appl ication to a 10

- hectare agricultural field that drains into an adjacent 1

- hectare water body that is 2 meters deep (20,000 m 3 

### volume) with no outlet. PRZM/EXAMS is used to estimate screening

- level exposure of aquatic organisms to bromacil. The measure of exposure for aquatic species is the 1

- in

- 10 year return peak or rolling mean concentration. The 1

- in

- 10 year peak is used for estimating acute exposures of direct effects to aquatic organisms. The 1

- in

- 10

- year 60

- day mean is used for assessing chronic ex posure to fish and aquatic

- phase amphibians. The 1

- in

- 10

- year 21

- day mean is used for assessing chronic exposure to aquatic invertebrates.

Exposure estimates for terrestrial organisms assumed to be in the target area or in an area exposed to off

- site depo sition are derived using the T

- REX model (version 1.4.1, 10/09/2008). This model incorporates the Kenaga nomograph, as modified by Fletcher et al. (1994), which is based on a large set of field residue data. The upper limit values from the nomograph repr esent the upper bound 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 informati on on 118 species of plants, 121 pesticides, and 17 chemical classes. Based on these data, T

- REX assumes a 35

- day foliar dissipation half

- life in the absence of other data.

In order to determine if more data are necessary, the S creening T ool for I nhalation R isk (STIR v.1.0) was used to calculate an upper bound estimate of exposure using bromacil’s vapor pressure and molecular weight for vapor phase exposure as well as the maximum application rate and method of application for spray drift. STIR inc orporates results from several toxicity studies including acute oral and inhalation rat toxicity endpoints obtained from the “six

- pack” of core studies, which are a series of six guideline studies that are submitted to the Registration Division of the Offi ce of Pesticide Programs for technical and formulated products of a pesticide as well

### 34 as the most sensitive acute oral avian toxicity endpoint. Based on the results of the STIR model, inhalation exposure alone was not determined to be a potential pathway of concern for avian or mammalian species on an acute exposure basis.

Inhalation exposure via spray drift and/or vapor

- phase of the pesticide alone does not appear to be of concern. The analysis of the inhalation route of exposure in STIR does not cons ider that aggregation with other exposure pathways such as dietary, dermal, or drinking water may contribute to a total exposure that has a potential for effects to non

- target animals. However, the Agency does consider the relative importance of other rou tes of exposure in situations where data indicate that pesticide exposures through other routes may be potentially significant contributors to wildlife risk (USEPA, 2004). The risk assessment will discuss the impact of consideration of other routes of exp osure that have been identified as potentially important and the degree of certainty associated with screening

- level risk assessment conclusions. Detailed information about STIR v.1.0, as well as the tool, can be found on the EPA’s website at: http://www.epa.gov/pesticides/science/models_pg.htm#terrestrial

.

The S creening I mbibition P rogram (SIP v.1.0) was used to calculate an upper bound estimate of exposure using bromacil’ s solubility, the most sensitive acute and chronic avian and mammalian toxicity endpoints. Drinking water exposure alone was determined to be a potential pathway of concern for both avian (and surrogates) and mammalian species on an acute and chronic

expo sure basis. This route of exposure will be considered further in the risk assessment.

This pathway will be explored further with the development of SIP v.2.0 in the risk assessment for bromacil . Detailed information about the SIP v.1.0, as well as the tool, can be found on the EPA’s website at http://www.epa.gov/pesticides/science/models_pg.htm#terrestrial

.
EECs for terrestrial plants are derived using TerrPlant (v.1.2. 2). This model uses estimates of pesticides in runoff and in spray drift to calculate EECs. EECs are based upon solubility, application rate and minimum incorporation depth.

The AgDRIFT (v2.01; May 2001) or AgDISP (v. 8.15) spray drift model may be us ed to assess exposures of organisms to bromacil deposited on terrestrial habitats by spray drift.

7.3. Measures of Effect

Ecological effects data are used as measures of direct and indirect effects to biological receptors. Effects data are obtained from registrant

- submitted studies or from literature studies identified by the ECOTOX database.

The acute measures of effect u sed for animals in this assessment are the LD 50 

### , LC 50 

### and EC 50



### . LD stands for "Lethal Dose", and LD 50 

### is the amount of a material, given all at once, that is estimated to cause the death of 50% of the test organisms. LC stands for “Lethal Concentration” and LC 50 

### is the concentration of a chemical that is estimated to kill 50% of the test organisms. EC stands for “Effective Concentration” and the EC 50 

### is the concentration of a chemical that is estimated to produce a specific effect in 50% of the test orga nisms. Endpoints for chronic measures of exposure for listed and non

- listed animals are the NOAEL/NOAEC and NOEC.

### 35 NOAEL stands for “No Observed

- Adverse

- Effect

- Level” and refers to the highest tested dose of a substance that has been reported to have no h armful ( adverse) effects on test organisms. The NOAEC ( i.e. , “No

- Observed

- Adverse

- Effect

- Concentration”) is the highest test concentration at which none of the observed effects were statistically different from the control. For non

- listed plants, only ac ute exposures are assessed ( i.e. , EC 25 

### for terrestrial plants and EC 50 

### for aquatic plants); for listed plants the NOAEC ( or , when a NOAEC is not available, the EC 05 

### ) is used.

Where available, sublethal effects observed in both registrant

- submitted and o pen literature studies will be evaluated qualitatively. Such effects may include behavioral changes ( e.g. , lethargy and changes in coloration). Quantitative assessments of risks, though, are limited to those endpoints that can be directly linked to the A gency’s assessment endpoints of impaired survival, growth and reproduction.

In the absence of taxon

- specific data, t he assessment of risk for direct effects to non

- target organisms makes the assumption that toxicity of bromacil to birds is similar to terr estrial

- phase amphibians and reptiles. Likewise, the toxicity of bromacil to fish is assumed to be similar to aquatic

- phase amphibians. In the absence of data for either acute or chronic effects, the conservative assumption will be to presume that bromac il is toxic.

7.4. Integration of Exposure and Effects

Risk characterization is the integration of exposure and ecological effects characterization to determine the potential ecological risk from the registered uses of bromacil and the likelihood of direct and indirect effects to non

- target organisms in aquati c and terrestrial habitats. The exposure and toxicity effects data are integrated in order to evaluate the risks of adverse ecological effects on non

- target species. For the assessment of bromacil risks, the risk quotient (RQ) method is used to compare e xposure and measured toxicity values. EECs are divided by acute and chronic toxicity values. The resulting RQs are then compared to the Agency’s Levels of Concern (LOCs) (USEPA 2004). These criteria are used to indicate when bromacil use, as directed on the labels, has the potential to cause adverse direct or indirect effects to non

- target organisms. In addition, incident data from the EIIS will be considered as part of the risk characterization.

7.5. Deterministic and Probabilistic Assessment M ethods

The quantitative assessment of risk will primarily depend on the deterministic point

- estimate (RQ) based approach described in the risk assessment. An effort will be made to further qualitatively describe risk using probabilistic tools that the Ag ency has developed. These tools have been reviewed by F IFRA Scientific Advisory Panels ( http://www.epa.gov/scipoly/sap/index.htm ) and have been deemed as appropriate means of refining assessments wher e deterministic approaches have identified risks. Newer tools may be available to assess the routes of exposure ( e.g. TIM and SWAMP models) and will be applied as appropriate in Registration Review.

7.6. Endocrine Disruptor Screening Program

### 36 As required under FFDCA section 408(p), EPA has developed the Endocrine Disruptor Screening Program (EDSP) to determine whether certain substances (including pesticide active and other ingredients) may have an effect in humans or wildlife similar to an eff ect produced by a “naturally occurring estrogen, or other such endocrine effects as the Administrator may designate.” The EDSP employs a two

- tiered approach to making the statutorily required determinations. Tier 1 consists of a battery of 11 screening as says to identify the potential of a chemical substance to interact with the estrogen, androgen, or thyroid (E, A, or T) hormonal systems. Chemicals that go through Tier 1 screening and are found to have the potential to interact with E, A, or T hormonal s ystems will proceed to the next stage of the EDSP where EPA will determine which, if any, of the Tier 2 tests are necessary based on the available data. Tier 2 testing is designed to identify any adverse endocrine related effects caused by the substance, a nd establish a dose

- response relationship between the dose and the E, A, or T effect.

Between October 2009 and February 2010, EPA issued test orders/data call

- ins for the first group of 67 chemicals, which contains 58 pesticide active ingredients and 9 in ert ingredients. This list of chemicals was selected based on the potential for human exposure through pathways such as food and water, residential activity, and certain post

- application agricultural scenarios. This list should not be construed as a list of known or likely endocrine disruptors.

Bromacil is not among the group of 58 pesticide active ingredients on the initial list to be screened under the EDSP. Under FFDCA sec. 408(p) the Agency must screen all pesticide chemicals. Accordingly, EPA anti cipates issuing future EDSP test orders/data call

- ins for all pesticide active ingredients

.
For further information on the status of the EDSP, the policies and procedures, the list of 67 chemicals, the test guidelines and the Tier 1 screening battery, please visit our website: http://www.epa.gov/endo/

.

7. 7. Endangered Species Assessment

Consistent with the Agency’s responsibility under the Endangered Species Act (ESA), the Agency will evaluate risks to Federally

- listed threatened and/or endangered (listed) species from registered uses of bromacil . This assessment will be conducted i n accordance with the Overview Document (USEPA 2004), provisions of the ESA, and the Services’ Endangered Species Consultation Handbook (USFWS/NMFS, 1998).

The assessment of effects associated with the registration of bromacil is based on an action area. The action area is considered to be the area directly or indirectly affected by the federal action, as indicated by the exceedance of Agency Levels of Concern (LOCs) used to evaluate direct or indirect effects. The Ag ency’s approach to defining the action area under the provisions of the Overview Document (USEPA 2004) considers the results of the risk assessment process to establish boundaries for that action area with the understanding that exposures below the Agency’ s defined LOCs constitute a no

- effect threshold. For the purposes of this assessment, attention will be focused on the footprint of the action ( i.e ., the area where bromacil application occurs), plus all areas where offsite transport ( i.e ., spray drift, r unoff, etc .) may result in potential exposure that exceeds the Agency’s LOCs. Specific measure s of ecological effect that define the

### 37 action area for listed species include any direct and indirect effects and/or potential modification of its critical habit at, including reduction in survival, growth, and reproduction as well as the full suite of sublethal effects available in the effects literature. Therefore, the action area extends to a point where environmental exposures are below any measured lethal or sublethal effect threshold for any biological entity at the whole organism, organ, tissue, and cellular level of organization. In situations where it is not possible to determine the threshold for an observed effect, the action area will initially be assu med to include all counties where bromacil is used in the United States.

7.8. Drinking Water Assessment

A new drinking water assessment will be conducted with current data, models and simulation model guidance to support future human health dietary ris k assessments of bromacil . The drinking water exposure assessment will be conducted for the maximum labeled use in support of the human health dietary risk assessment. The drinking water assessment will incorporate model estimates of bromacil in surface water and groundwater including any residues that are determined to be of toxicological concern. Concentrations of bromacil in surface waters will be estimated using PRZM/EXAMS (see description above) using the Index Reservoir scenario to estimate environmental concentrations in drinking water rather than the standard pond used with aquatic exposure assessment.

An EDWC of bro macil in groundwater may be estimated using EFED’s Tier I aquatic model SCIGROW (Screening Concentration in Ground Water, version 2.3; 8/8/2003) , or other approved groundwater models at the time of risk assessment

. SCIGROW is a regression model used as a screening tool to estimate pesticide concentrations found in groundwater used as drinking water. The output of SCIGROW represents the concentrations that might be expected in shallow unconfined aquifers under sandy soils, which is representative of the gr oundwater most vulnerable to pesticide contamination likely to serve as a drinking water source.

The drinking water assessment will also include available surface and groundwater monitoring data with consideration of changes in use patterns that may have occurred. States are encouraged to submit monitoring data for review.

7.9. Environmental Monitoring Data

All monitoring data may be considered to characterize the modeling results and risk estimations for bromacil in the environment. States, Tribal O rganizations, and other government and non

government organizations are encouraged to submit additional surface water and groundwater monitoring data for bromacil. Below is a summary of currently available monitoring data from publicly available databases (e.g., NAWQA), submitted studies ( retro

- and prospective groundwater monitoring studies), as well as state

- level monitoring studies.

USGS NAWQA

A query of the United States Geological Survey’s (USGS) National Water Quality Assessment Program (NAWQA) 5

5 USGS NAWQA Program: 

### for detections of bromacil in surface water and groundwater, returned 355

http://infotrek.er.usgs.gov/apex/f?p=NAWQA:HOME:0 . Accessed February 24, 2012.

### 38 detections in surface water out of 8,262 samples analyzed from 1,026 sites (concentrations ranging from 0.00 1 to 5.0 ug/L; detection frequency of 4.3 % ; MDL ranged from 0.001 to 8.64 ug/L ). Of the 355 detections , 14 exceeded the lowest concentration know to cause effects (1.1 ppb) to non

- vascular plants

. For groundwater

, 155 detections were reported out of 6,476 samples analyzed for bromacil (detected concentrations ranging from 0.003 to 21.74 ug/L; a detection frequency of <3 %; MDL ranged from 0.003 to 1.33). Of the 155 detections

, 18 were greater than the lowest concentration know to cause effects (1.1 ppb) to non

- vascular plants

. Although the detection frequencies are low f or surface water and groundwater, these detections illustrate that bromacil may contaminate both surface water and groundwater resulting from use of the compound

.
USGS/USEPA Pilot Reservoir Monitoring Study

In 1999, a pilot monitoring program was init iated by the USG S and the U.S. Environmental Protection Agency to provide information on pesticide concentrations in drinking water and to assist in the implementation of the Food Quality Protection Act of 1996. Twelve water

- supply reservoirs were sampled, ranging in size from 120 to 92,600 acre

- feet normal capacity, with contributing watersheds ranging from 3.3 to 784 square miles. The sites are in California, Indiana, Ohio, Oklahoma, Louisiana, Missouri, South Carolina, South Dakota, New York, No rth Carolina, Pennsylvania, and Texas. Analyses for pesticides in water samples were performed at the USGS National Water Quality Laboratory in Denver, Colorado, using three analytical methods. Overall, these methods included 178 different pesticides and degradation products. Bromacil was included as one of the analytes in this study. Bromacil was detected in both source water and finished water. In source water bromacil was detected at a maximum concentration of 0.481 ug/L (detection frequency of 15.7 %; 49 detections

– 47 confirmed

– out of 312 samples of raw water; MRL = 0.081 ug/L). In the 225 samples of finished water

, bromacil was detected two times at a maximum concentration of 0.481 ug/L (detection frequency of 0.9%; MRL = 0.081 ug/L).

Retros pective G roundwater M onitoring S tudy

DuPont conducted retrospective groundwater monitoring studies in three citrus

- growing regions (Central Ridge, Flatwoods and Coastal) of Florida between 1987 and 1990 ( USEPA, 1993 ; D P 191409, 191677)

. Bromacil was detec ted in groundwater at all three study sites. A brief summary of the results for each site is provided below.

Central Ridge: Bromacil was detected in all 10 wells at this site, with well depths ranging from 14 to 54 feet. Five of these wells had at least one detection above the 90 ppb Health Advisory Level (HAL), with a maximum concentration of 156 ppb. Concentrations of bromacil at this site did not decrease with time in these monitoring wells, although the application rate of bromacil was decreased thr oughout the study.

Flatwoods: Bromacil was detected in all three of the monitoring wells installed at this site, with a maximum detection of 21.8 ppb.

### 39 Coastal: Bromacil was detected in three of the four monitoring wells at this site, with a maximum conce ntration of 147 ppb. The three wells with detections were screened from 5 to 10 feet. The single well without detections was screened from 50 to 60 feet.

Prospective Groundwater Monitoring Study

DuPont conducted a prospective groundwater monitoring stu dy (MRID 44480701) in response to the GDCI issued following the RED. It was designed to evaluate the potential for bromacil to leach to groundwater in Florida’s Central Ridge region required by both the USEPA and Florida Dept. of Agriculture and Consumer S ervices as part of a proposed bromacil management strategy. This study is currently under review by the Agency. A preliminary review of the data showed that the maximum detected concentration in shallow, intermediate, and deep wells, respectively were 55 .2, 43.2 and 38 ppb. It is important to note that bromacil concentrations as high as 27 ppb were detected in the control well. However these detected concentrations were less than the detections

– except for the Florida Flatwoods site

– reported in the p revious retrospective groundwater monitoring stud y conducted prior to the implementation of label mitigations.

State Groundwater Monitoring Studies

The data and discussion below for monitoring studies in Florida, Texas and California was discussed in the 1996 RED (USEPA, 1996)

. For Registration Review , the Agency will update the current database for bromacil. It should be noted that the data included below were provided to the Agency prior to the implementation of mitigation measures of bromacil application rates.

1) Florida: Although bromacil is used in many states, the greatest use has been on citrus crops in Florida. In addi tion, the most extensive ground water monitoring for bromacil has been in Florida. As a result of this monitoring, it has become clear that contamination of groundwater with bromacil has occurred to varying degrees throughout the citrus growing regions of the state.

Br omacil was one of the pesticides tracked in Florida's Pesticide Contamination Monitoring System. This system kept a running total of ground water samples analyzed for bromacil, and the number of samples with concentrations above and below the 90 ppb healt h advisory level. This system is no longer in place, however, a s of May 1995, 2

, 837 wells were sampled for bromacil; 899 had detections below the HAL (90 pbb) , and 57 had detections above the HAL. Of this number, 679 of the wells with detections below th e HAL, and 55 with detections above the HAL were from Highlands County, in the Central Ridge. Polk County recorded 121 wells with detections below the HAL, and 1 above the HAL. Lake County followed with 70 wells with detections below the HAL, then Hardee County with 16 wells with detections below and one with detections above the HAL.

A separate study performed in Collier County, in the Flatwoods region of southern Florida, had detections well above the HAL in shallow ground water. In a report on this s tudy, detections of bromacil in ground water are listed at concentrations as high as 1

, 422 ppb. These samples were collected at the very top of the water table, from wells with one

- foot screens. The State of Florida does not consider bromacil to be a gro und water concern in the Flatwoods region, as

### 40 there is generally a low

- permeability spodic layer near the surface, perching this uppermost saturated zone. However, as a result, the contaminated shallow ground water is available for transport into surface water through drainage ditches.

2) Texas: While bromacil use is greatest in Florida, significant amounts are also applied in California and Texas for both citrus and right

- of

- way uses. The Agency’s "Pesticides in Ground Water Data base" reports that brom acil was detected in 6 of 230 wells sampled in Texas between 1983 and 1989.

3) California: In 1994, the Department of Pesticide Regulation of the California Environmental Protection Agency (CalEPA) reported that bromacil was one of 5 pesticides for which detections were "verified" in California groundwater as a result of non

- point agricultural use within the past

year. CalEPA defines a detection as "verified" when (a) the pesticide (or breakdown product) is detected in two discrete samples taken from a si ngle well during a 30

- day period AND (b) the second sample is analyzed either by the same laboratory using different analytical methods or by two laboratories using the same method (analytical methods must have been approved by the department of pesticide regulators )

. Bromacil was detected in two other wells but these detections could not be verified because bromacil was not detected in the second discrete samples from these wells. Bromacil detection was verified in 4 wells in 2 counties in 1994 where it had not been previously detected and found but not verified in two new wells in two other counties. For the risk assessment, an attempt will be made to update the database for bromacil in groundwater resources in California.

In California, the quality of groundwater is managed by the use of Pesticide Management Zones (PMZs). A PMZ is an approximately square

- mile area designated as sensitive to ground water contamination. PMZs are created based on verified detections in groundwater of a particular pestic ide residue. PMZs are chemical specific; there are bromacil PMZs, simazine PMZs, diuron PMZs, etc. CalEPA monitors compliance within PMZs to ensure pesticides are not reapplied in these areas, and to determine if previously detected residues are still pr esent in the soil. Previous data included in the RED reported r esidues of bromacil in three of five PMZs at levels ranging from 50 to 240 ppb. These residues were considered to have resulted from normal agricultural use before the PMZ was established. F or the risk assessment, an attempt with me made to update these data sources with current data , and analyze the impact of the establishment of PMZs on bromacil detections in groundwater

. States are encouraged to submit monitoring data to support its use i n risk assessment.

7.10 . Clean Water Act

Bromacil is not identified as a cause of impairment for any water bodies listed as impaired under section 303(d) of the Clean Water Act 6 

### . In addition, no Total Maximum Daily Loads (TMDL) have been developed for the herbicide 7



### . The Impaired Waters and Total Maximum Daily Loads website can be consulted for more information 8

6 http://iaspub.epa. gov/tmdl_waters10/attains_nation_cy.cause_detail_303d?p_cause_group_id=885 

### . The Agency invites submission of water quality

7 h ttp://iaspub.epa.gov/tmdl_waters10/attains_nation.tmdl_pollutant_detail?p_pollutant_group_id=885&p_pollutant_ group_name=PESTICIDES

8 http://www.epa.gov/owow/tmdl/

### 41 data for this pesticide. To the extent possible, data should conform to the quality standard s in Appendix A of the OPP Standard Operating Procedure: Inclusion of Impaired Water Body and Other Water Quality Data in OPP’s Registration Review Risk Assessment and Management
Process 9 

### , in order to ensure they can be used quantitatively or qualitatively in pesticide risk

assessments.

8

. Data Gaps and Uncertainties

8 .1 . Environmental Fate

The studies submitted to fulfill environmental fate data requirements for bromacil are not sufficient to conduct an exposure assessment ; seven data requirements have not been met as stipulated in 40 CFR part 158 Subpart N §158.1300 for all pesticides with u se patterns for terrestrial food and nonfood applications. Table 8.1 catalogues the classifications for submitted studies on the envi ronmental fate and transport of bromacil. Listed below are the identified data gaps and what would be assumed in the absence of these data.

**•** Aqueous Photodegradation (835.2240):

**•** Although there are no acceptable studies, the Agency does not anticipate reco mmending a new study be conducted as a new study would not yield significantly different results. Aerobic Soil Metabolism (835.4100)

**•** : The guideline stipulates that data from at least four relevant soils of different organic carbon content, pH, clay content, and microbial biomass must be submitted in order to characterize the variability in aerobic biodegradation of bromacil in the environment. The Agency currently has da ta from one soil in the submitted study. In absence of additiona l data, the Agency will multiply the single degradation half

- life by three for the purposes of estimating aquatic exposure to account for the potential variability in degradation rates betwee n different soil types. Anaerobic soil metabolism (835.4200)

**•** . Currently, there are no available data. In lieu of acceptable data, bromacil is assumed to be stable to metabolism in soil in oxygen limiting environments. Aerobic Aquatic Metabolism (835.4300)

**•** . Data requirement was previously waived due to modifications to the label for bromacil avoiding use sites with high potential to result in aquatic exposure ( USEPA, 1992; DP 182792). In lieu of this data , aquatic exposure modeling for risk assessment will assume a half

- life value equal to 2x the aerobic soil metabolism input (resulting in a 6x factor).
Anaerobic A quatic M etabolism (835.4400) :

**•** Currently there are no acceptable data for anaerobic aquatic metabolism. This study is necessary to understand the degradation of bromacil in oxygen

- limiting environments. In lieu of additional acceptable data, stability is assumed. Adsorption/desorption Batch Equilibrium ( 835.1230):

9 http://www.epa .gov/oppfead1/cb/ppdc/2006/november06/session1

- sop.pdf 

### Studies submitted only include soil column leaching data. Batch equilibrium data are needed to determine the sorption coefficient for bromacil. In absence of these data

, experimental organi c carbon partitioning coefficients will be used from open literature sources (e.g., Gersch, 1984 and Corwin and Farmer, 198 4 )

.

### 42 **•** T errestrial Field Dissipation (835.6 1 00) : The original study conducted at two bare

ground sites was classified acceptable. It was noted in the review that to fulfill the guideline additional studies are required on different soils that capture the use areas for bromacil (e.g., highly permeable citrus production areas of Florida). Based on open literature data for sorption coefficients and monitoring data, the Agency does not anticipate needing additional data on the field dissipation of bromacil.

Tab le 8.1 identifies studies by MRID that offer data for each guideline requirement, as well as study classifications and whether or not further data are needed in order to support risk assessment ( i.e. , whether there is a data gap).

Table 8.1. Summary of av ailable environmental fate data.

Guideline No. Data Requirement MRID / ACC No. Classification Are Additional Data Needed for Risk Assessment? Comments

835.2120 Hydrolysis 40951505 Acceptable No Stable at pH 5,7 and 9 @ 25oC.

40951506 Acceptable Classified acceptable.

835.2240 Photodegradation in Water 40951507 Supplemental No

, bromacil is photolytically stable at neutral and acidic pHs, and is photolabile in alkaline conditions The portion of study conducted at pHs 5 and 7 is acceptable. MRID 40951508 provided additional information for photodegradation at pH 9.

40951508 Supplemental Study was originally classified as upgradeable because data on degradates were not provided for alkaline pH (9).

00126338 Supplemental Orginial study was not reviewed, but results are similar to those in MRIDs 40951507 and 40951508

. 5018069 Supplemental

835.2410 Photodegradation on Soil 40951509 Acceptable No Stable to photodegradation on soil

.

835.4100 Aerobic Soil Metabolism 40951510 Acceptable Yes

, Additional soils

would reduce uncertainty with

using a single value. Only one soil was used in laboratory study. Data from 3 additional soils are needed to determine degradation kinetics. In lieu of these data the single value is multiplied by 3 to account for potential variability in the degradation rate in different soil types.

835.4200 Anaerobic Soil Metabolism No Data

-- Yes No data available. In lieu of these data stability is assumed.

835.4300 Aerobic Aquatic Metabolism No Data

-- Yes

, In lieu of this data

risk assessment will assume 2x

aerobic soil metabolism input (resulting in a 6x factor). Data requirement was previously waived due to modifications to the label for bromacil avoiding use sites with high potential to result in aquatic exposure

. Potential use sites include applications near surface water therefore this data is need for risk assessment.

### 43 Guideline No. Data Requirement MRID / ACC No. Classification Are Additional Data Needed for Risk Assessment? Comments

835.4400 Anaerobic Aquatic Metabolism 40951511 Unacceptable Yes , in lieu of additional acceptable data, stability is assumed. Study provides supplemental data and cannot be upgraded.

835.1240 Mobility

- Column Leaching 40951512 Supplemental Yes , in absence of additional data,

values from Corwin and Farmer, 198 4 and/or Gerstl, 1984 will be used. Studies submitted only include soil column leaching data. Batch equilibrium data are needed to determine sorption coefficients of bromacil.

835.6100 Terrestrial Field Dissipation 41677101 Acceptable No A dditional studies we re required on different soils that capt ure the use areas for bromacil. However, o pen literature data and groundwater studies provide adequate information about the dissipation path ways of bromacil in the environment, therefore the Agency does not anticipate requesting additional field studies at this time.

850.1730 Fish Accumulation 40951513 Acceptable No

835.7100 Groundwater, Smal

scalel Prospective 44480701 In Review No Currently under review by the Agency.

-- Groundwater Small

scale Retrospective No MRID Supplemental No No MRID in OPPIN. Review and discussion of use of data included in USEPA, 1993.



### 8 .2. Ecological Effects

For Registration R eview, the following studies are requested to resolve uncertainties in the risk

assessment :

**•** Mysid chronic toxicity test with bromacil TGAI (850 .1350 ) :

**•** No data have been received to characterize the chronic toxicity of bromacil to the estuarine invertebrate Americamysis bahia. Data are required on one estuarine/marine invertebrate species under the data requirements ( 40 CFR §158. 630 ) for conventional pesticides. In acute testing, e stuarine invertebrates (i.e., A. bahia ) were found to be more sensitive to br omacil than freshwater invertebrates ( Daphnia sp.) . In the absence of data, chronic toxicity to marine/estuarine taxa will be derived from available chronic freshwater invertebrate data. Avian acute oral to xicity test with bromacil TGAI ( 850.2100 ): Acute avian oral toxicity data are needed for either one waterfowl or one upland game species and one passerine species under the data requirements ( 40 CFR §158. 630 ) for conventional pesticides. Based on a preliminary screen using the highest agricultural appli cation scenario for bromacil (see Table 3.1 ), the highest peak dose

- based EEC is 3,280 mg/kg bw.

### 44 Available avian acute oral toxicity data to the bobwhite quail determined a no effects level at 2,250 mg/kg bw; well below the maximum field application rate (i.e., the environmentally r elevant concentration). I n order to properly characterize risk to birds, a new study dosing the bobwhite quail at the maximum label rate is nec essary for risk assessment. Testing with the bo bwhite quail is requested because of mortalities recorded in a previous dietary study with this species (MRID 00013295), and frank sublethal effects in an acute oral study with this species (MRID 40951501).

**•** Avian sub

- acute dietary toxicity test with bromac il TGAI ( 850.2200 ):

**•** No data are available to define the sub

- acute (dietary) exposure of technical bromacil to birds. In the absence of new data, endpoints from a study involving dietary exposures of birds to a formulated product containing bromacil will b e used in risk assessment

. Terrestrial plant seedling emergence and vegetative vigor toxicity tests, Tier II ( 850.4 100 and 850.41 50 ): Tier II terrestrial plant seedling emergence and vegetative vigor studies conducted with a typical end

- use product (TEP) test substance are requested. All currently available terrestrial plant studies were conducted with TGAI rather than TEP as specified in 40 CFR §158. 660

. An additional line of evidence supporting this data request comes from the 3 7 r eported incidents involving terrestrial plants (See Appendix C ).

### 45 Table 8.2 . Summary of available ecological effects data.

Guideline No. Data Requirement MRID / ACC No. Classification Are Additional Data Needed for Risk Assessment? Comments

850.1075 Acute

– Freshwater Fish 409515 03 Acceptable No

--

850.1075 Acute

– Saltwater Fish 415887 02 Acceptable No

--

850.1400 Chronic

– Freshwater Fish 44566101 Supplemental No The endpoints are useful for risk assessment. A

r etrospective groundwater stud y (conservative EEC scenario) indicate s that EECs

are below concentrations of chronic concern

.

850.1400 Chronic

– Saltwater Fish No Data

-- No Chronic toxicity data are available for freshwater fish,

which were more acutely sensitive than saltwater fish.

850.1035 Acute

– Estuarine/Marine

Invertebrate 41588701 Acceptable No

--

850.1010 Acute

– Freshwater Invertebrate 40951504 Acceptable No

--

850.1300 Chronic

– Freshwater Invertebrate 44566401 Acceptable No

--

850.1350 Chronic

– Estuarine/Marine

Invertebrate No Data

-- Yes Estuarine invertebrates tested more acutely sensitive to bromacil than freshwater invertebrates. In the absence

of data, chronic toxicity to marine/estuarine taxa will be derived from chronic freshwater inver tebrate data

. *

850.5400 Aquatic

– Non

- vascular Plants 42516401 Acceptable No

--

### 46 Guideline No. Data Requirement MRID / ACC No. Classification Are Additional Data Needed for Risk Assessment? Comments

850.4 400 Aquatic

– Vascular Plants 46095401 Acceptable No

--

850.4 100 Terrestrial plant Seedling emergence

- Tier II 42491101, 44488307 Supplemental Yes These studies were conducted with TGAI. 40 CFR §158. 660 specifies that TEP should be used.

850.4 150 Terrestrial plant Vegetative vigor

- Tier II 42491101, 44488307 Supplemental Yes These studies were conducted with TGAI. 40 CFR §158. 660 specifies that TEP should be

used. Reported incidents involving terrestrial plants

support the request for additional data.

850.2100 Acute

– Avian Oral (bobwhite quail ) 40951501 Acceptable Yes An avian acute oral study testing bobwhite quail at environmentally relevant

rates is requested.

850.2200 Acute

– Avian Dietary (bobwhite quail, mallard) 00013295, 00013296 Acceptable Yes No data is available to define the avian dietary toxicity of technical bromacil

. In the

absence of data, a study involving dietary exposures

of birds to a formulated product containing bromacil will be used to assess avian dietary risk

.

850.2300 Chronic

– Avian Reproduction 44844601, 44844801 Acceptable No

--

850.3020 Honey Bee Acute Contact Toxicity 00009181 Supplemental No The LD 50 was not determined in the limit test, which indicates that the compound

is practically nontoxic to honey bees.
* A NO A EC could be e stimated using acute

- to

- chronic ratio for Daphnia magna of 14.8 (acute = 121 ; chronic= 8.2 ; 121 / 8.2 = 1 4.8) . This would result in a mysid NOAEC of 7.7 ppm.

### 47 8.3. Usage Specific Uncertainties

Bromacil usage data for pineapple grown in Hawaii is not quantified by the currently available information , presenting considerable uncertainty since Hawaii has the highest number of listed plant and animal species of any state (USFWS, 2011 ). As of 13 April 2010, 343 Hawaiian Island plants were listed as Endangered, and 11 were listed as Threatened (USFWS, 2011 ). EFED seeks comments from the public that will refine analysis of areas planted in pineapple in the state of Hawaii.

### 48 9

. R eferences

Corwin D.L. and W.J Farmer. 1987. Nonsingle

- Valued Adsorption

- Desorption of Bromacil and Diquat by Freshwater Sediments. Environ. Sci. Technol., 18:7: 507

- 514.

Gerstl Z, Mingelgrin U. 1984. J Environ Sci Health B19: 297

- 312.

Hansch, C., Leo, A., D. Hoekman. Exploring QSAR

- Hydrophobic, Electronic, and Steric Constants. Washington, D

. C

. : Amer ican Chemical Society. pg 61. 1995.

Hoffman, C.E. 1971. The Mode of Action of Bromacil and Related Uracils. IUPAC Congress of Pesticide Chemistry. Tel Aviv

. Pesticide Chemistry Proceedings, 1972. Pp 65

- 85.

United States Department of Agriculture. 2010 ( 2006

- 2010 ) . NASS Crop Reporting Districts. Online: http://www.ers.usda.gov/briefing/arms/resourceregions/resourceregions.htm#nass

.

United States Department of Agriculture. 2007. Census of Agriculture. Online: http://www.agcensus.usda.gov/Publications/2007/index.asp

.

United States E nvironmental P rotection A gency

. 1992. Memor andum from Dana Spatz (EFGWB/EFED) to Linda Propst (SRRD). Oct. 5, 1992. DP 182792.

United States E nvironmental P rotection A gency

. 1993. Memorandum from David Wells (EFGWB/EFED) to Linda Propst (SRRD), July 21, 1993. DP 191409, 191677.

United States E nvironmental P rotection A gency . 1996. Reregistration Eligibility Decision on Bromacil. Office of Prevention, Pesticides, and Toxic Substances. Office of Pesticide Programs. Washington

, D

. C . August 1996.

United States E nvironmental P rotection A gency

. 1998. Guidelines for Ecological Risk Assessment. Risk Assessment Forum, Offi ce of Research and Development, Washington, D.C. EPA/630/R

- 95/002F. April 1998. http://cfpub.epa.gov/nce a/cfm/recordisplay.cfm?deid=30759

United States E nvironmental P rotection A gency . 2004. Overview of the Ecological Risk Assessment Process in the Office of Pesticide Programs. Office of Prevention, Pesticides, and Toxic Substances. Office of Pesticide Programs. Washington, D.C. January 23, 2004.

United States E nvironmental P rotection A gency . 2007. Risks of Bromacil and Bromacil Lithium use to the Federally Listed California Red

- legged Frog (Pesticide Effects Determination). Office of Prevention, Pes ticides, and Toxic Substances. Office of Pesticide Programs. Washington, D.C. October 19, 2007.

### 49 United States E nvironmental P rotection A gency . 2011. BEAD Chemical Profile for Registration Review: Bromacil (012301). Office of Chemical Safety and Pollution Prevention . Office of Pesticide Programs, Biological and Economical Analysis Division. Washington, D.C. December 5, 2011

.

United States E nvironmental P rotection A gency. 2012. BEAD Bromacil Usage Map by Crop Reporting District (012301). Office of Chemical Safety and Pollution Prevention . Office of Pesticide Programs, Biological and Economical Analysis Division. Washington, D.C. February 15, 2012.

U nited S tates F ish and W ildlife S ervice . 2011. Endangered species; Pacific Islands Fish and Wil dlife Office. Webpage updated April 4, 2011; accessed on February 17, 2012. http://www.fws.gov/pacificislands/species.html

U nited S tates F ish and W ildlife S ervice /N ational M arine F isheries S er vice . 2004. 50 CFR Part 402. Joint Counterpart Endangered Species Act Section 7 Consultation Regulations; Final Rule. FR 47732

- 47762.

Wolf DC, Martin JP. 1974. Soil Sci Amer Proc 38: 921

- 5.

### 50 Appendix A. Ecological Effects Data Summaries

Aquatic plant toxicity testing

OPPTS 850.5400 Selenastrum capricornutum was exposed to technical bromacil (96.5% ai) for 120 hours ( MRID 425164 01; Supplemental ). Initial

- measured concentrations of bromacil were: <1.0 (control), 1.10, 2.17, 4.38, 8.55, and 17.4 μ g/L. Five

- day inhibition (based on cell count) ranged from 15.2 to 92.1%, yielding a five

- day EC 50 

### of 6.8 μg/L. A NOAEC was not established, and significant differences in cell count (as compared to the control) were determined at all concentrations using Will i ams test.

OPPTS 850.5400 Navicula pelliculosa was exposed to technical bromacil (97.0% ai) for 120 hours ( MRID 442185 01, Acceptable ). Measured concentrations of bromacil were 0.403, 0.905, 1.88, 3.39, 7.34, and 13.8 μg/L. Since no solvent was used , only a negative control was included in this test. The 120

- hour EC 50 

### was 6.91 μg ai/L, and the NOAEC was statistically established at 3.39 μg ai/L. T he study personnel placed the algal cells exposed to the highest test concentration in fresh media foll owing the five

- day exposure and observed growth similar to that of the controls, indicating algistatic and not algicidal properties of bromacil.

OPPTS 850.5400 Anabaena flos

- aquae was exposed to technical bromacil (97.0% ai) for 120 hours ( MRID 442185 02, Acceptable ). Measured concentrations of bromacil were 11.2 20.5, 42.7, 111, and 188 μg ai/L. Since no solvent was used, only a negative control was included in this test. The 120

- hour EC 50 

### was 69.9 μg ai/L, and the NOAEC was statistically established at 11.2 μg ai/L. Post

- study experimentation with bromacil

- exposed algae indicated compound algistatic, not algicidal, effects.

OPPTS 850.5400 Skeletonema costatum was exposed to technical bromacil (97.0% ai) for 120 hours ( MRID 442185 03, Acceptable ). Measured concentrations of bromacil were 5.51, 11.5, 23.5, 44.8, and 98.8 μg ai/L. Since no solvent was used, only a negative control was included in this test. The 120

- hour EC 50 

### was 12.1 μg ai/L, and the NOAEC was statistically established at 5.5 μg ai/ L. Seven days of post

- study experimentation with bromacil

- exposed algae indicated compound algistatic, not algicidal, effects.

OPPTS 850.4400 Lemna gibba was exposed to technical bromacil (97.0% ai) for 14 days ( MRID 460954 01, Acceptable ). Measured co ncentrations of bromacil were <1.13 (<LOQ; control), 17.0, 32.4, 74.4, 157, 333, and 656 μg ai/L. Frond number and dry weight were similarly sensitive to treatment with bromacil. The NOAEC and EC 50 

### /IC 50 

### values based on frond number were 17.0 and 45 μg ai/ L, respectively. The percent growth inhibition in the treated culture as compared to the control ranged from

- 1.6 to 98.4% based on frond number and from

- 7.7 to 98.8 based on dry weight. By test termination, chlorotic fronds were observed in the control and all treatment levels.

### 51 Freshwater f ish and invertebrate acute toxicity

Two studies of acute effects of bromacil formulated product to rainbow trout ( Oncorhynchus mykiss ) , and six studies of acute effects of bromacil formulated product to bluegill su nfish ( Lepomis machrochirus ) are characterized in Appendix A of the 2007 California Red

- legged Frog Assessment (USEPA 2007).

Additionally, one study conducted to determine the acute effects of bromacil formulated product (80% ai) to bluegill sunfish ( Le pomis machrochirus ) was not captured in Appendix A of the 2007 assessment ( MRID 00013297; Supplemental ). The study author reported 24

- and 48

- hr LC 50 

### values of 103 and 71 ppm, respectively.

OPPTS 850.1075 A cute effects of bromacil (96.6% ai) to rainbow trout ( Oncorhynchus mykiss ) were studied over a 96

- hour static exposure ( MRID 409515 03; Acceptable ). Rainbow trout were exposed to nominal concentrations of 0 (negative control), 16.9, 22.5, 30, 40, 53, 71, 95, 127, 169, and 225 mg/L. The 96

- hour L C 50 

### was 36 mg /L; the NOAEC was 16.9 mg /L.

OPPTS 850.1075 A cute effects of bromacil (95% ai) to bluegill sunfish ( Lepomis machrochirus ) were studied over

a 96

- hour static exposure ( MRID 409515 02; Acceptable ). Bluegill sunfish were exposed to nominal concentr ations of 0 (negative control ), 30 , 40, 53 , 71, 95, 127, 169, 225, and 300 mg/L. The 96

- hour LC 50 

### was 127 mg/L; the NOAEC was 71 mg/L.

OPPTS 850.1010 A cute effects of bromacil (96.6% ai) to Daphnia magna were studied over a 48

- hour static

exposure ( MRID 409515 04; Acceptable ). Two replicates of 10 individuals were exposed to nominal concentrations of 0 (negative control), 11.2, 14.5, 20, 27, 35.5, 62.5, 83, 111, and 148

m g /L. Total mortality was recorded for the highest dosage level of 148 mg/L; while th e 111 mg/L treatment only had 20% mortality in one replicate. The E C 50 

### was 121 mg /L; the NOAEC

was 83 mg /L.

Estuarine/Marine fish and invertebrates

OPPTS 850.1075 A cute effects of bromacil (95 .1 % ai) to Cyprinodon variegatus were studied over a 96

- hour semi

- static exposure ( MRID 415887 02; Acceptable ). C. variegatus were exposed to mean

measured concentrations of 37.6, 55.1, 95.6, 145.8, and 272 mg ai/L. A negative control was used, and no solvents were employed. The 96

- hour L C 50 

### was 162.8 mg ai /L; the NOAEC was 55.1 mg ai/L.

OPPTS 850.1035

### 52 A cute effects of bromacil (95 .1 % ai) to Americamysis bahia were studied over a 96

- hour static exposure ( MRID 415887 01; Acceptable ). A. bahia were exposed to mean

- measured concentrations of 25.7, 42, 67.0, 104.4, and 148 mg ai/L. A negative control was used, and no solvents were employed. The 96

- hour L C 50 

### was 112.9 ppm ; the NOAEC was 67 ppm.

OPPTS 850.1035 A cute effects of bromacil (95% ai) to Americamysis bahia were studied over a 96

- hour static

exposure ( MRID 00126346; Supplemental ). A. bahia were exposed to nominal concentrations of 62, 125, 250, 500, and 1,000 μg/L . The 96

- hour L C 50 

### was estimated to be >1,000 μg/L

.

OPPTS 850.1055 A cute effects of bromacil (95 .1 % ai) to Crassostrea virginica were studied over a 48

- hour static exposure ( MRID 415887 03; Supplemental ). C. virginica were exposed to measured concentrations of 26, 41, 62, 100, and 150 mg/L. A negative control was employed. The 48

- hour E C 50 

### , based on percentage reduction of normal oyste r larvae, was 130 mg ai /L; the NOAEC could not be established because of poor control performance.

Non

- guideline Juvenile individuals of the following species were tested by the EPA ORD Environmental Research Laboratory at Gulf Breeze, FL: brown shrimp ( P enaeus aztecus ), eastern oyster ( Crassostrea virginica ), and spot ( Leiostomus xanthurus ) ( MRID 40228401; Supplemental ). Technical Bromacil (95% ai) was diluted in exposure water at concentrations up to 1,000 μg/L. The 48

- hour EC 50 

### for brown shrimp and sp ot, and 96

- hour EC 50 

### for eastern oyster, were estimated to be >1.0 ppm.

Fish and invertebrate chronic toxicity

OPPTS 850.1400 The 90

- day chronic toxicity of DPX

- N976 Technical (bromacil, 98.07 % ai ) to the early life stage of rainbow trout ( Oncorhynchus mykiss ) was studied under flow

- through conditions ( MRID 445661 01; Supplemental ) . Fertilized eggs/embryos (80/level, 22 hours post

- fertilization) of rainbow trout were exposed to nominal concentrations of 0 (negative and solvent controls), 0.0 6, 0.12, 0.24, 0.48, 0.96, 2.4, and 6.0 mg/L. TWA concentrations (reviewer

- calculated) were <0.0004 (<LOD, controls), 0.070, 0.15, 0.29, 0.60, 1.2, 3.0, and 7.2 mg ai/L, respectively. The NOAEC and LOAEC values for this study were 3.0 and 7.2 mg ai/L, re spectively, based on

treatment

- related effects on mean wet weight (the only endpoint affected).

OPPTS 850. 130 0 The 21

- day

- chronic toxicity of DPX

- N976 Technical (bromacil, 98.07% ai ) to Daphnia magna was studied under static renewal conditions ( MRID 44566 4 01; Acceptable ) . Daphnids were exposed to DPX

- N976 Technical at m ean

- measured concentrations of <0.00040 (<LOD, control), 0.10, 0.21, 0.45, 0.88, 1.7, 3.4, 8.2, and 21 mg ai/L, respectively. The number of live neonates per adult, mean terminal length, a nd mean terminal dry weight were the most sensitive endpoints, with significant reductions at the 21 mg ai/L treatment level. Based on these effects, the 21

- day NOAEC and LOAEC were 8.2 and 21 mg ai/L, respectively. There were no

### 53 treatment

- related effect s on survival, reproduction, or growth of Daphnia magna exposed to
DPX

- N976 at concentrations up through 8.2 mg ai/L for 21 days. At test termination, all surviving adult daphnids exposed appeared normal without ephippia. Daphnids exposed to 21 mg ai/L d id not produce any neonates and had significantly reduced lengths (13% inhibition) and dry weights (45% inhibition) in comparison to the negative control.

Avian toxicity studies

OPPTS 850.2 1 00 Technical bromacil (96.6% ai) was ad ministered to 21

- week old bobwhite quail at nominal doses of 292, 486, 810, 1350, and 2250 mg/kg

- bw ( MRID 409515 01; Acceptable ). Corn oil was used

as the test diet vehicle and dosages were adjusted upward to correct to 100% active ingredient. The acute oral LD 50 

### was determined to be >2250 mg/kg

- bw and the NOAEC was 810 mg/kg

bw , based on reductions in female body weight gain at 1350 mg/kg

- bw

.

OPPTS 850.2100 The lithium salt of bromacil was administered to four

- to

- six day old bobwhite quail chicks over 7 days at nominal doses of 0 (control), 200, 300, 350, 400, 450, and 500 mL/kg. The LD 50 

### was determined to be 355 mL/kg. The NOAEC was established at 200 mL/kg, based on slight depression following dosing at 300 mL/kg.

OPPTS 850.2200 Bromacil (80% ai) was fed to one

- week old mallard ducks at nominal doses of 0, 464, 1000, 2150, 4640, and 10,000 ppm, and to one

- week old bobwhite quail at nominal doses of 0, 215, 464, 1000, 2150, 4640, and 10,000 ppm for five days ( MRID 00013295; Acceptable ). No mortalit ies were observed in exposures involving mallard ducks. Bobwhite quail mortalities were observed in exposures involving several different treatment levels; however, the mortalities were less than 50% of individuals in each treatment group. In the test, 6 .8% mortality was observed in controls, 10% mortality was observed in the 464 and 4,640 mg/kg

- diet/day treatment levels and 20% mortality was observed in the 2,150 and 10,000 mg/kg

- diet/day treatment levels. The eight

- day LC 50 

### was determined to be >10,000 ppm. This study is classified acceptable for a formulated product , but supplemental for use in risk assessment, since the test material was not technical bromacil as required by 40 CFR §158.630

.

OPPTS 850.2200 Bromacil (80% ai) was fed to mallard ducks and bobwhite quail at nominal doses up to 10,000 ppm ( MRID 00013296; Acceptable ). No toxic effects were recorded. The eight

- day LC 50 

### was determined to be >10,000 ppm.

OPPTS 850.2300 Technical bromacil (98.07% ai) was fed to 18

- week old mallard duck for 22 weeks at nominal concentrations of 775, 1550, 3100, and 6200 ppm ( MRID 448446 01; Acceptable ). There were statistically significant treatment

- related effects to hatchability at the 3100 ppm ai treatment level. The NOAEC and LOAEC were determined to be 1550 and 3100 ppm, respectively.

### 54 OPPTS 850.2300 Technical bromacil (98.07% ai) was fed to 18

- week old bobwhite quail for 21 weeks at nominal concentrations of 775, 1550, 3100, and 6200 ppm ( MRID 44844 8 01; Acceptable ). There were statistically significant treatment

- related effects to hatchability at the 3100 ppm ai treatment level. The NOAEC and LOAEC were determined to be 1550 and 3100 ppm, respectively.

Terrestrial invertebrate studies

OPPTS 850.3020 Acute laboratory comparative tests were performed with more than 50 chemicals, including bromacil (Hyvar ®



### - X, purity not reported) ( MRID 00009181; Supplemental ). The material was mixed with non

- toxic diluent dust and applied directly to bees in a vacuum dusting apparatus. Mortality was evaluated 48 hours after application. The LD 50 

### was reported to be 193.38 μg per bee, and bromacil is classified as practically nontoxic to honey bees.

OPPTS 850.3020 Acute laboratory comparative tests were performed with 197 chemicals, including bromacil (Hyvar ® 

### , purity not reported) ( MRID 00 132710 ; Supplemental ). The material was mixed with

non

- toxic diluent dust and applied directly to bees in a vacuum dusting apparatus at concentrations up to 11 μg per bee. Mortality was evaluated 48 hours after application. The
LD 5 0 

### level was not attained, and bromacil is classified as practically nontoxic to honey bees.

Non

- guideline toxicity to insect parasite The toxicity of bromacil (80% ai) to juvenile Aphytis melinus and virgin 3 rd 

### instar red scale, was studied four days afte r treatment, and to emerging adult A. melinus 14

- 27 days after treatment ( MRID 05004003; Supplemental ). Bromacil was applied at 4,000 ppm. 97.5% of juvenile A. melinus were alive at four days after treatment. Of the 41 adults that emerged, 7 were activ e at day 27, and toxicity was qualitatively rated as “moderate.”

Terrestrial Plant Studies

OPPTS 850.4225 A 14

- day terrestrial plant: seedling emergence ( MRID 424911 01; Supplemental 10 

### ) was conducted for bromacil (95.9% ai). Species tested; monocots: corn, onion, sorghum, and wheat; dicots: cucumber, pea, rape, soybean, sugarbeet 11



### , and tomato. N ominal application rates were: 0.00586 , 0.0117, 0.0234, 0.0469, and 0.0938 lb ai/A (onion, sugarbeet , tomato, rape, cucumber); 0.0938, 0.188, 0.375, 0.750, and 1.50 lbs ai/A (corn); 0.0234, 0.0469, 0.0938, 0.188, and 0.375 lb ai/A (wheat, sorghum, soybean); and 0.0234, 0.0938, 0.375, 1.50, and 6.00 lbs ai/A (pea) . The most sensitive dicot was rape with NOAEC and EC 25

10 Although data for nine plant species were acceptable, this study was classified as supplemental overall because data for sugarbeet were unacceptable. 

### values for shoot height of 0.0117 and 0.0136 lb ai/A, respectively. Statistical analysis to determine the most sensitive monocot was

11 The results of testing with sugarbeet were not considered scientifically sound and were classified as unacceptable because of seed treatment with unapproved chemicals (i.e., chlorneb, lindane, and dexon).

### 55 not performed; however, the study authors’ analysis indicates that wheat was the most sensitive, with shoot height NOAEC and EC 25 

### values of 0.0234 and 0.0731 lb ai/A.

OPPTS 850.42 50 A 21

- day terrestrial plant: vegetative vigor ( MRID 424911 01; Supplemental 10 

### ) was conducted for bromacil (95.9% ai). Species tested; monocots: corn, o nion, sorghum, and wheat; dicots: cucumber, pea, rape, soybean, sugarbeet 11



### , and tomato. Nominal rates of 0.00586, 0.0117, 0.0234, 0.0469, and 0.0938 lb ai/A were applied to onion, wheat, sugarbeet, soybean, tomato, rape, and cucumber; and nominal rates of 0.0234, 0.0469, 0.0938, 0.188, and 0.375 lb ai/A were applied to corn, sorghum, and pea . The results from rape were scientifically sound but did not meet the guideline requirement for a tier II vegetative vigor study because a NOAEC was not determined for the most sensitive endpoint: root weight. The most sensitive dicot was rape, with an EC 25 

### for root weight of 0.0023 lb ai/A. Statistical analysis to determine the most sensitive monocot was not performed; however, the stud y authors’ analysis indicates that wheat was the

most sensitive, with shoot weight NOAEC and EC 25 

### values of 0.0469 and 0.0684 lb ai/A.

OPPTS 850.4225 A 14

- day terrestrial plant: seedling emergence ( MRID 444883 07; Supplemental, non

guideline 12 

### ) was conducted for bromacil (98.07% ai). Nominal rates of 0 (negative and carrier controls), 0.003, 0.006, 0.01, 0.02, 0.04, 0.09, and 0.2 lb ai/A were applied to wheat, while nominal rates of 0 (negative and carrier controls), 0.001, 0.003, 0.006, 0.01, 0.02, 0.04, and 0.09 lb ai/A were applied to rape. The most sensitive endpoint for monocot wheat was dry weight with NOAEC and EC 25 

### values of 0.02 and 0.030 lb ai/A, respectively. The most sensitive endpoint for dicot rape was also dry weight, with NOAE C and EC 25 

### values of 0.0011 and 0.0047 lb ai/A. The following abnormalities were noted: slight growth retardation, malformations, chlorosis, and necrosis.

OPPTS 850.4225 A 1 4

- day terrestrial plant: seedling emergence ( MRID 444883 07; Supplemental, non

gu ideline 12 

### ) was conducted for the lithium salt of bromacil (86.07% ai). Nominal rates of 0 (negative and carrier controls), 0.003, 0.006, 0.01, 0.02, 0.04, 0.09, and 0.2 lb ai/A were applied to wheat, while nominal rates of 0 ( negative and carrier controls), 0.001, 0.003, 0.006, 0.01, 0.02, 0.04, and 0.09 lb ai/A were applied to rape. The most sensitive endpoint for monocot wheat was dry weight with NOAEC and EC 25 

### values of 0.02 and 0.034 lb ai/A, respectively. The most sensit ive endpoint for dicot rape was also dry weight, with NOAEC and EC 25 

### values of 0.006 and 0.010 lb ai/A. The following abnormalities were noted: slight to moderate chlorosis, slight to severe growth retardation, slight unusual pigmentation, and slight to s evere burns or necrosis.

OPPTS 850.42 50 The effect of bromacil (98.07% ai) on the vegetative vigor of monocot (wheat) and dicot (rape) were studied at nominal application rates of 0 (negative and carrier controls), 0.0007, 0.001, 0.003, 0.006, 0.01, 0.02 , 0.04, 0.09, 0.2, and 0.4 lb ai/A over 21

- days ( MRID 444883 07;

12 This study is classified as non

- guideline because it does not contain information for all 10 req uired test species of plants. Instead, this study was intended to create suitable data for comparison of the effects of bromacil and bromacil lithium on seedling emergence and vegetative vigor. This study is useful for comparing the toxicities of the two chemicals to terrestrial plants.

### 56 Supplemental, non

- guideline 12 

### ). The most sensitive endpoint for wheat was dry weight with NOAEC and EC 25 

### values of 0.02 and 0.042 lb ai/A, respectively. The most sensitive endpoint for rape was also dry weight, with NOAEC and EC 25 

### values of 0.003 and 0.0055 lb ai/A. The following abnormalities were noted: chlorosis, necrosis, and growth retardation.

OPPTS 850.42 50 The effect of the lithium salt of bromacil (86. 07% ai) on the vegetative vigor of monocot (wheat) and dicot (rape) were studied at nominal application rates of 0 (negative and carrier controls), 0.0007, 0.001, 0.003, 0.006, 0.01, 0.02, 0.04, 0.09, 0.2, and 0.4 lb ai/A over 21

- days ( MRID 44488307; Supplemental , non

- guideline 12 

### ). The most sensitive endpoint for wheat was dry weight with NOAEC and EC 25 

### values of 0.001 and 0.028 lb ai/A, respectively. The most sensitive endpoint for rape was also dry weight, with NOAEC an d EC 25 

### values of 0.006 and 0.0060 lb ai/A. The following abnormalities were noted: chlorosis, necrosis, and growth retardation.

Bromacil seedling emergence Species Endpoint NOAEC EC EC 25 50 Wheat Dry Weight 0.02 0.030 0.085 Wheat Height 0.04 0.080 0.22 Rape Dry Weight 0.0011 * 0.0047 0.013 Rape Height 0.01 0.018 0.17



### Bromacil lithium salt seedling emergence Species Endpoint NOAEC EC EC 25 50 Wheat Dry Weight 0.02 0.03 4 0.08 7 Wheat Height 0.04 ** 0.091 0.23 Rape Dry Weight 0.006 0.0 10 0.013 Rape Height 0.01 0.018 0.028



### Bromacil vegetative vigor Species Endpoint NOAEC EC EC 25 50 Wheat Dry Weight 0.02 0.042 0.068 Wheat Height 0.04 ** 0.23 0.55 Rape Dry Weight 0.003 0.0055 0.010 Rape Height 0.01 ** 0.025 0.063



### Bromacil lithium salt vegetative vigor Species Endpoint NOAEC EC EC 25 50 Wheat Dry Weight 0.001 0.028 0.065 Wheat Height 0.04 0.34 0.87 Rape Dry Weight 0.003 ** 0.0060 0.010 Rape Height 0.01 ** 0.024 0.034

*The EC 05 **NOAEC visually determined is used in lieu of the NOAEC

### 57 Appendix B. Fate and Ecological Effects Bibliographies

Environmental Fate and Transport Bibliography

MRID/PDF/Ecotox Citation Reference

40951505 Das, Y. (1988) Hydrolysis of ? 2

- ?carbon 14||Bromacil in Aqueous Solutions Buffered at pH 5,7, and 9: Project No. 86001

- 02; Du Pont Document No. AMR

- 522

- 86. Unpublished study prepared by Biospherics Inc. 33 p.

40951506 Dulka, J.; Ryan, T. (1988) Hydrolysis of ? 2

- ?carbon 14||Bromacil in Aqueous Solution Buffered at pH 9: Project ID: AMR

- 902

- 87. Un

- published study prepared by E.I. du Pont de Nemours and Co., Inc. 22 p.

161

- 2 Photodegradation

- water

MRID Citation Reference

40951507 Das, Y. (1986) Photodegradation of ?2

- ?carbon 14||Bromacil in Aqueous Solutions Buffered at pH 5, 7, and 9: Project No. 86001

- 01; Study No. AMR

- 523

- 86. Unpublished study prepared by Bio

- spherics Inc. 65 p.

40951508 Dulka, J.; Ryan, T. (1988) Photodegradation of ?2

- ?c arbon 14||Bro

- macil in Water at pH 9: Project ID: AMR

- 901

- 87. Unpublished study prepared by E.I. du Pont de Nemours and Co., Inc. 28 p.

00126338 Chrzanowski, R. (1981?) Photodegradation of Bromacil in Water: Doc

- ument No. AMR

- 78

- 82. (Unpublished study received Mar 10, 1983 under 352

- 325; submitted by E.I. du Pont de Nemours & Co., Inc., Wilmington, DE; CDL:249679

- C)

5018069 Archer, A.J. and E. Dunkelblum. 1979. Identification of sensitized photooxidation products of bromacil in water. J. Agric. Food Ch em. 27(6):1184

- 1187.

161

- 3 Photodegradation

- soil

MRID Citation Reference

40951509 Das, Y. (1988) Photodegradation of ?2

- ?carbon 14||Bromacil on Soil Under Artificial Sunlight: Project No. 86001

- 03; Du Pont Docu

- ment No. AMR

- 558

- 86. Unpublished study prepared by Biospheric Inc. 46 p.

162

- 1 Aerobic soil metabolism

MRID Citation Reference

40951510 Vigon, B.; Arthur, M. (1988) Aerobic Soil Metabolism of ?2

- ?carbon 14||Bromacil in Stine Farm, DE, Silty Clay Loam: Project ID: N0766

- 7300; Du Pont Report No. AMR

- 500

- 86. Unpublished study prepared by Battelle Columbus Div. 50 p.

### 58 162

- 3 Anaerobic aquatic metab.

MRID Citation Reference

40951511 Vigon , B.; Arthur, M. (1988) Anaerobic Aquatic Metabolism of ?2

- ?carbon 14||Bromacil in West Jefferson, OH Pond Sediment and Water: Project ID: N0766

- 7300. Unpublished study prepared by Battelle Columbus Div. 57 p.

163

- 1 Leach/adsorp/desorption

MRID Ci tation Reference

40951512 Voudrias, E. (1988) Soil

- Column Leaching of ?2

- ?carbon 14||Broma

- cil: Project ID: Battelle Project No. N0799

- 8700; Du Pont Report No. AMR

- 645

- 86. Unpublished study prepared by Battelle Columbus Div. 54 p.

164

- 1 Terrestrial field dissipation

MRID Citation Reference

41677101 Schneiders, G. (1990) Field Soil Dissipation of Hyvar X Herbicide: Lab Project Number: AMR/1146/88. Unpublished study prepared by E. I. du Pont de Nemours and Co. 64 p.

165

- 4 Bioaccumulation in fish

MRID Citation Reference

40951513 Hutton, D. (1986) ?2

- ?carbon 14|| Bromacil Bioconcentration in Bluegill Sunfish: Du Pont HLR 378

- 86; AMR

- 494

- 86. Unpublished study prepared by E.I. du Pont de Nemours and Co., Inc. 49

p.

166

- 1 Ground water

- small prospective

MRID Citation Reference

44480701 Peter, C.; Carver, L.; Johnson, L. et al. (1998) Small

- Scale Prospective Ground

- Water Monitoring Study for Bromacil (DPX

- N976): Final Report: Lab Project Number: AMR 2931

- 94: 387.10: AMR

- 633

- 86. Unpublished study prepared by Waterborne Environmental, Inc.; Florida Pesticide Research, Inc.; Murray Consultants, Inc. 692 p.



### Ecological Effects Bibliography

71

- 1 Avian Single Dose Oral Toxicity

### 59 MRID PDF # Citation Reference

13295 Dieterich, W.H. (1965) Acute Oral Toxicity

-- Mallard Ducks, Bobwhite Quail: Project No. 201

- 154. (Unpublished study received Nov 22, 1965 under 352

- 287; prepared by Hazleton Laboratories, Inc., submitted by E.I. du Pont de Nemours & Co., Wilmington, Del.; C DL:100405

- A)

40951501 2025321 Grimes, J. (1986) H

- 16287: An Acute Oral Toxicity Study with the Bobwhite: Final Report: Wildlife International Ltd., Project No. 112

- 173. Unpublished stud y prepared by Wildlife Interna tional Ltd. 18 p.

71

- 2 Avian Dietary

MRID PDF # Citation Reference

13295 or 13296 2025298 E.I. du Pont de Nemours & Company (1970) Toxicological Information: Hyvar X Bromacil Weed Killer

-- Fish and Wildlife. (Unpublished study received on unknown date under 352

- 287; CDL:100850

- A)

71

- 4 Avian Reproduction

MRID PDF # Citation Reference

44844601 2025332 Gallagher, S.; Beavers, J.; Jaber, M. (1999) DPX

- N976 Technical: A Reproduction Study with the Mallard (Anas platyrhynchos): Lab Project Number: AMR 4832

- 97: 112

- 477. Unpublished study prepared by Wildlife International Ltd. 186 p.

44844801 2025331 Galla gher, S.; Beavers, J.; Jaber, M. (1999) DPX

- N976 Technical: A Reproduction Study with the Northern Bobwhite (Colinus virginianus): Lab Project Number: AMR

4831

- 97: 112

- 476. Unpublished study prepared by Wildlife International Ltd. 187 p.

72

- 1 Acut e Toxicity to Freshwater Fish

MRID PDF# Citation Reference

13378 Rausina , G. (1976) Report to Nalco Chemical Company: Four

- Day Static Aquatic Toxicity Studies with BX

- 933 in Rainbow Trout, Bluegills and Daphnia: IBT No. 8560

- 08684. (Unpublished study including letter dated Nov 2, 1977 from C.H. Wolf to Environmental Protection Agency, received Nov 9, 1977 under 1706

- 107; prepared by Industrial Bio

- Test Laboratories, Inc., submitted by Nalco Chemical Co., Oak Brook, Ill.; CDL:232181

- A)

13297 2025300 E.I. du Pont de Nemours and Company (1964) Hyvar X Bromacil Weed Killer: Acute Toxicity

-- Fish. (Unpublished study received on unknown date under 352

- 287; CDL:100850

- B)

111458 Bond, C.; Wilson, D.; Malick, J. (1967) Progress Report on Aquatic Weed Research (Project 773). (Unpublished study received Jun 28, 1979 under 0F0863; prepar ed by Oregon State Univ., Agricul

- tural Experiment Station, Dept. of Fisheries and Wildlife, sub

- mitted by Dow Chemical Co., Indianapolis, IN; CDL:098349

- I)

126344 Call, D.; Kent, R.; Brooke, L. (1979) Estimates of No Effect Con

- centrations of Select ed Pesticides in Freshwater Organisms: U.S. EPA Grant No. R

- 806196

- 01. 3rd

### 60 quarterly progress rept. Jan 1

- Mar 31, 1979. (Unpublished study received Mar 10, 1983 under 352

- 325; prepared by Univ. of Wisconsin, submitted by E.I. du Pont de Nemours & Co., Inc. , Wilmington, DE; CDL:249679

- J)

126345 2025310 Yoshida, K.; Nishiuchi, Y. (1972) Toxicity of Pesticides to Some Water Organisms. (Unpublished study received Mar 10, 1983 under 352

- 325; submitted by E.I. du Pont de Nemours & Co., Inc., Wil

- mington, DE; C DL:249679

- K)

141633 2025227 Call, D.; Brooke, L.; Kent, R. (1983) Toxicity, bioconcentration, and metabolism of five herbicides in freshwater fish. Prepared by Univ. of Wisconsin , Center for Lake Superior Environmental Studies for the Environmental Protection Agency; available from the National Technical Information Service. 113 p.

141636 Call, D.; Brooke, L.; Kent, R. (1983) Toxicity, bioconcentration, and metabolism of five h erbicides in freshwater fish. Prepared by Univ. of Wisconsin, Center for Lake Superior Environmental studies for the Environmental Protection Agency; available from the National Technical Information Service. 113 p.

40951502 2025322 Hutton, D. (1988) Sta tic Acute 96

- Hour LC50a of Bromacil to the Bluegill Sunfish (Lepomis macrochirus): Haskell Laboratory Report No. 163

- 83; MR No. 7708

- 001. Unpublished study prepared by E.I. du Pont de Nemours and Co., Inc. 10 p.

40951503 2025323 Hutton, D. (1988) Static Acute 96

- Hour LC50a of Bromacil to Rainbow Trout (Salmo gairdneri): Haskell Laboratory Report No. 265

- 86; MR No. 4581

- 373. Unpublished study prepared by E.I. du Pont de Nemours and Co., Inc. 10 p.

24960 2025302 TN353 McCann, J.A . (1971) ?Hyvar X: Toxicity to Bluegill|: Test No. 353. (U.S. Agricultural Research Service, Pesticides Regulation Div., Animal Biology Laboratory, unpublished report.)

24961 2025303 TN610 Pitcher, F.G. (1973) ?Mister Zero: Toxicity to Bluegill|: Test N o. 610. (U.S. Environmental Protection Agency, Pesticides Reg

- ulation Div., Agricultural Research Center, Animal Biology Labo

- ratory, unpublished report.)

24962 2025304 TN626 Pitcher, F.G. (1973) ?Atlas 603 Ded

- Veg: Toxicity to Bluegill|: Test No. 626 . (U.S. Environmental Protection Agency, Pesticides Regulation Div., Agricultural Research Center, Animal Biology Laboratory, unpublished report.)

24964/ 2025305 TN 457 McCann, J.A. (1972) (Ureabor : Toxicity to Rainbow Trout): Test No. 457. (U.S. Agricultural Research Service, Pesticides Regu

- lation Div., Animal Biology Laboratory, unpublished report.)

24965 2025306 TN447 McCann, J.A. (1972) (Ureabor: Toxicity to Bluegill): Test No. 447. (U.S. A gricultural Research Service, Pesticides Regulation Div., Animal Biology Laboratory, unpublished report.) Mixture with Na Metaborate and Na chloate

24967 2025307 TN773 Pitcher, F.G. (1974) ?Weedgard G: Toxicity to Rainbow Trout|: Test No. 773. (U.S. Env ironmental Protection Agency, Chemical & Biological Investigations Branch, TSD, Animal Biology Laborato

- ry, unpublished report.)

24968 2025308 TN608 Pitcher, F.G. (1973) ?UL

- 85: Toxicity to Bluegill|: Test No. 608. (U.S. Environmental Protection Agency , Pesticides Regulation Div., Agricultural Research Center, Animal Biology Laboratory, unpublished report.)

24969 2025309 TN 643 Pitcher, F.G. (1973) ?Weedgard G: Toxicity to Bluegill|: Test No. 643. (U.S. Environmental Protection Agency, Pesticides Reg

- ulation Div., Agricultural Research Center, Animal Biology Labo

- ratory, unpublished report.)

### 61 72

- 2 Acute Toxicity to Freshwater Invertebrates

MRID Citation Reference

126345 2025318 2025315 Yoshida, K.; Nishiuchi, Y. (1972) Toxicity of Pesticides to Some Water Organisms. (Unpublished study received Mar 10, 1983 under 352

- 325; submitted by E.I. du Pont de Nemours & Co., Inc., Wil

- mington , DE; CDL:249679

- K)

40951504 2025324 Hutton, D. (1986) Daphnia magna Static Acute 48

- Hour EC50 of Bromo

- cil: Project ID: HLR 341

- 86. Unpublished study prepared by E.I. du Pont de Nemours and Co., Inc. 10 p.

13378 Rausina, G. (1976) Report to Nalco Ch emical Company: Four

- Day Static Aquatic Toxicity Studies with BX

- 933 in Rainbow Trout, Bluegills and Daphnia: IBT No. 8560

- 08684. (Unpublished study including letter dated Nov 2, 1977 from C.H. Wolf to Environmental Protection Agency, received Nov 9, 1977 under 1706

- 107; prepared by Industrial Bio

- Test Laboratories, Inc., submitted by Nalco Chemical Co., Oak Brook, Ill.; CDL:232181

- A)

72

- 3 Acute Toxicity to Estuarine/Marine Organisms

MRID Citation Reference

126346// 2025316 2025311 Hollister, T. (1980) Acute Toxicity of Fifteen Chemicals to Mysid Shrimp ...: Report No. BP

- 80

- 2

- 43. (Unpublished study received Mar 10, 1983 under 352

- 325; prepared by EG & G, Bionomics, sub

- mitted by E.I. du Pont de Nemours & Co., Inc., Wilmington, DE; CDL:249679

- L)

41588701 2025325 Boeri, R. (1989) Static Acute Toxicity of Bromacil to the Mysid, Mysidopsis bahia: Lab Project Number: DP2788. Unpublished study prepared by Enseco Inc. 21 p.

41588702 2025326 Boeri , R. (1989) Static Acute Toxicity of Bromacil to the Sheep

- shead Minnow, Cyprinodon variegatus: Lab Project Number: DP2888. Unpublished study prepared by Enseco Inc. 21 p.

41588703 2025327 Boeri, R. (1989) Static Acute Toxicity of Bromacil to Embryos an d Larvae of the Eastern Oyster Crassostrea virginica: Lab Project Number: DP2988. Unpublished study prepared by Enseco Inc., 21 p.

41896101 Wrong Chemical Ward, T.; Boeri, R. (1991) Static Acute Toxicity of Terbacil to the Sheepshead Minnow, Cyprinodon variegatus: Lab Project Number: 4581

- 806. Unpublished study prepared by Envirosystems/Resource Analysts Inc. 31 p.

ACC 249679 2025310 Yoshida, K. 1970. Toxicity of Pesticide to Killifish.

40228401 2025320 Mayer, F.L. 1986 EPA /600/x

- 86/231 Acute Toxicity Handbook of Chemicals to Estuarine Organisms

72

- 4 Fish Early Life Stage/Aquatic Invertebrate Life Cycle Study

MRID PDF # Citation Reference

44566101 2066664 Hoke, R. (1998) DPX

- N976 Technical: Early Life

- Stage Toxicity to Rainbow

### 62 Trout (Oncorhynchus mykiss): Lab Project Number: HL

- 1998

- 01349: 11691. Unpublished study prepared by E.I. du Pont de Nemours and Company. 148 p.

44566401 2066665 Drottar , K.; Krueger, H. (1998) DPX

- N976 Technical: A Semi

- Static Life

Cycle Toxicity Test with the Cladoceran (Daphnia magna): Final Report: Lab Project Number: 112A

- 172: 1998

- 01475. Unpublished study prepared by Wildlife International Ltd. 73 p.

72

- 5 L ife cycle fish (OPPIN incorrectly placed these under 72

- 5)

MRID Citation Reference

141633 or 141636 DER not located Call, D.; Brooke, L.; Kent , R. (1983) Toxicity, bioconcentration, and metabolism of five herbicides in freshwater fish. Prepared by Univ. of Wisconsin, Center for Lake Superior Environmental Studies for the Environmental Protection Agency; available from the National Technical Info rmation Service. 113 p.

122

- 1 Seed Germination/Seedline Emergence and Vegetative Vigor

MRID PDF/ Citation Reference

42491101 2025328 Carski , T. (1992) Influence of Bromacil on Seed Germination, Seedling Emergence, and Vegetative Vigor of Several Terrestrial Plants: Lab Project Number: AMR 2304

- 92. Unpublished study prepared by Dupont Haskell Labs. 237

p.

44036501 2025339 Heldreth, K. (1993) Impact of An Acetone Control on Seed Germination of Several Terrestrial Plant Species: Lab Project Number: AMR 2624

- 93. Unpublished study prepared by Stine

- Haskell Research Center, DuPont Agricultural Products. 22 p.

44036502 2025339 Heldreth , K. (1993) Impact of An Acetone Control on Seedling Emergence and Elongation of Several Terrestrial Plant Species: Lab Project Number: AMR 2688

- 93. Unpublished study prepared by Stine

- Haskell Research Center, DuPont Agricultural Products. 24 p.

44036503 2025339 Heldreth, K. (1993) Impact of An Acetone Control on Vegetative Vigor of Several Terrestrial Plant Species: Lab Project Number: AMR 2720

- 93. Unpublished study prepared by Stine

- Haskell Research Center, DuPont Agricultural Products. 28 p.

123

- 1 Seed germination/seedling emergence and vegetative vigor

MRID Citation Reference

42491101 2025328 Carski , T. (1992) Influence of Bromacil on Seed Germination, Seedling Emergence, and Vegetative Vigor of Several Terrestrial Plants: Lab Project Number: AMR 2304

- 92. Unpublished study prepared by Dupont Haskell Labs. 237 p.

44488307 2066670

- SE 20666671

– VVg 2066672= lithium salt 2066673 = Heldreth, K.; McKelvey, R. (1997) Influence of Bromacil on Seed Germination, Seedling Emergence, and Vegetative Vigor of Several Terrestrial Plants: Supplement No. 1: Lab Project Number: MR 11430: AMR 2304

- 92. Unpublished study prepared by DuPont Stine

- Haskell Research Center and Haskell Laboratory for Toxicology and Industrial Medicine. 209 p.

### 63 lithium salt

123

- 2 Aquatic plant growth

MRID Citation Reference

42516401 2025329 Hughes, J.; Williams, T. (1992) Bromacil: Toxicity to Selenastrum capriconutum: Lab Project Number: B382

- 156

- 1: AMR 2402

- 92. Unpublished study prepared by Malcolm Pinie Inc. 27 p.

44218501 2066666 Hughes, J.; Alexander, M.; Conder , L. (1997) Bromacil: Influence on Growth and Reproduction of Navicula pelliculosa: Lab Project Number: AMR 3799

- 96: 19

- 05

- 2. Unpublished study prepared by Carolina Ecotox, Inc. 84 p. Relates to L0000187.

44218502 2066667 Hughes, J.; Alexander, M.; Conder , L. (1997) Bromacil: Influence on Growth and Reproduction of Anabaena flos

- aquae: Lab Project Number: AMR 3800

- 96: 19

- 05

- 1. Unpublished study prepared by Carolina Ecotox, Inc. 83 p. Relates to L0000187.

44218503 2066668 Hughes, J.; Alexander, M.; Conder, L. (1997) Bromacil: Influence on Growth and Reproduction of Skeletonema costatum: Lab Project Number: 19

- 05

- 3: AMR 3801

- 96. Unpublished study prepared by Carolina Ecotox, Inc. 86 p. Relates to L0000187.

44300901 Hughes, J.; Alexander, M.; Conder, L. (1 997) Bromacil: Influence on Growth and Reproduction of Lemna gibba: (Revision 1): Lab Project Number: AMR 3990

- 96: 19

- 05

- 4. Unpublished study prepared by Carolina Ecotox, Inc. 74 p.

46095401 2066669 Hughes, J.; Alexander, M.; Conder, L. (1997) Bromacil: Influence on Growth and Reproduction of Lemna gibba. Project Number: 19/05/4, AMR/3990/96. Unpublished study prepared by Carolina Ecotox, Inc. 74 p.

5014904 2025263 Citation for this MRID not found in OPPIN

141

- 1 Honeybee toxicity

MRID PDF # Citation Reference

132710 ACC251374 2025319 Atkins, E.; Anderson, L.; Kellum, D.; et al. (1977) Protecting Hon

- ey Bees from Pesticides. Riverside, CA: Univ. of California . (Leaflet 2883; also In unpublished submission received Nov 2, 1983 under 239

- 2507; submitted by Chevron Chemical Co., Rich

- mond, CA; CDL:251760

- B)

9181 2025297 Atkins, E.L., Jr.; Anderson, L.D.; Greywood, E.A. (1969) Effect of Pesticides on Apiculture: Project No. 1499. (Unpublished study received Jul 29, 1976 under 352

- 342; prepared by Univ. of Cali

- fornia

-- Riverside, Dept. of Entomology, submitted by E.I. du Pont de Nemours & Co., Wilmington, Del.; CDL:224800

- C)

18842 2025301 Same as 9181

142

- 3 Simulated or Actual Field Testing

MRID Citation Reference

60632 No DER found Johansen, C.; Eves, J. (1967) Bee Research Investigations, 1967: Report No. 21866. (Unpublished study received Mar 27, 1974 un

- der 4F1485; prepared by Washington State Univ., submitted by Chemagro Corp., Kansas City, Mo.; CDL:092011

- M)

### 64 NON Guideline

5004003 2025312 Citation for this MRID not found in OPPIN

5019478 2025313 Citation for this MRID not found in OPPIN

5020972 2025314 Citation for this MRID not found in OPPIN

5014916 2025265 Citation for this MRID not found in OPPIN

41145 Bond, C.E.; Wilson, D.C.; Malick, J. (1967) Aquatic Weed Control Progress Report 1967: Project 773. (Unpublished study received on unknown date under 8F0660; prepared by Oregon State Univ., Agricultural Experiment Station, Dept. of Fisheries and Wild

- life, submitted by Dow Chemical U.S.A., Midland, Mich.; CDL: 094930

- G)

111458 Bond, C.; Wilson, D.; Malick, J. (1967) Progress Report on Aquatic Weed Research (Project 773). (Unpublished study received Jun 28, 1979 under 0F0863; prepared by Oregon State Univ., Agricul

- tural Experiment Station, Dept. of Fisheries and Wildlife, sub

- mitted by Dow Chemical Co., Indianapolis, IN; CDL:098349

- I)

For lithium salt of bromacil:

71

- 1 Avian Single Dose Oral Toxicity

MRID Citation Reference

13386 2025828 McGee, G.J.; Freeman, L. (1971) Acute Toxicity (LDI50^) in Bobwhite Quail. (Unpublished study received Dec 14, 1971 under 359

- 627; prepared by Biometric Testing, Inc. for Rhodia, Inc., submitted by Rhone

- Poulenc, Inc., Monmouth Junction, N.J.; CDL:003176

- B )

133170 Mixture of 3
actives

– not
found in
012302 Posner, S.; McGee, G.; Freeman, L. (1971) Acute Toxicity (LD50) in Bobwhite Quail: ? Weed Broom Weed Killer |: Experimental Reference No. A

- 433. (Unpublished study received Dec 14, 1971 under 359

- 627; su bmitted by
Rhone

- Poulenc, Inc., Monmouth Junction, NJ; CDL:023338

- C) Ingredients

72

- 1 Acute Toxicity to Freshwater Fish

MRID Citation Reference

133171 Mixture of 3
actives see
13387

- same citation Posner, S.; Grim, J. (1971) Acute TLm 96

- hour (Static) of Weed Broom to Bluegill Sunfish ... and Rainbow Trout ...: Experimen

- tal Reference No. F

- 393. (Unpublished study received Dec 14, 1971 under 359

- 627; prepared by Biometric Testing, Inc., submit

- ted by Rhone

- Poulenc, Inc., Monmouth
Jun ction, NJ; CDL:023338

- D)

### 65 ACC 130653 see
also 26183 2025827 McCann, J.A. EPA Animal Test Laboratory, Beltsville Md. Bluegill static tox with 80% Hyvar X weed killer

13387 2025829 Grim, J. (1971) Acute TLm 96

- Hour (Static) of Weed Broom to Blue

- gill Sunfish (?~Leponis machrochirus?~) and Rainbow Trout (?~Salmo gairdneri?~). (Unpublished study received Dec 14, 1971 under 359

- 627; prepared by Biometric Testing, Inc. for Rhodia, Inc., submitted by Rhone

Poule nc, Inc., Monmouth Junction, N.J.; CDL:003176

- C)

24963 2025826

2025830 McCann, J.A. (1970) ?Weed

- Free LB: Toxicity to Bluegill|: Test No. 328. (U.S. Agricultural Res earch Service, Pesticides Regu lation Div., Animal Biology Laboratory, unpublished report. ) Bluegill static test with Chapman
Weed

- free LB 27.75% ai

26183 2025831

2025832 McCann, J.A. (1971) ?Hyvar X

- 1 Weed Killer: Toxicity to Bluegill|: Test No. 367. (U.S. Agricultural Research Service, Pesticides Regulation Div., Animal Biology Laboratory, unpublished report.)

72

- 2 Acute Toxicity to Freshwater Invertebrates

MRID Citation Reference

137445 2025317 Surprenant , D. (1983) Acute Toxicity of Liquid VIII Concentrate to Daphnia magna: Report #BW

- 83

- 8

- 1447; Study #079

- 0783

- H55

- 110. (Unpublished study received Dec 9, 1983 under 2155

- 99; prepared by EG&G Bionomics, submitted by I. Schneid, Inc., Atlanta. GA; CDL:252042

- A)

### 66 Appendix C

. Bromacil Ecological Incident Summaries Reported in the EIIS Database

Table C

- 1. Bromacil Incident Report Summaries

Incident # Organism(s) Affected Certainty of Involvement Legality of Use Description

I003601

- 001 White sucker Notropis minnow

American eel Blacknose dace Probable Registered Use Improper spraying o f the herbicides 2,4

- D and Broma cil directly on the stream b ank caused a significant losses of fish life in a tributary of Little Mill Creek. Investigation revealed tha t a cemetery ca retaker assumed that there were no fish present in the stream to worry about when he sprayed t he stream banks on the cemetery property to control weeds. No analysis or any other data provided in this report.

I004668

- 001 / I004875

- 001 Unknown fish Probable/ Highly Probable Misuse (accidental) / Misuse intentional A fish kill occurred in Weiner Creek in Baton Rouge on March 10, 1996. A 55

- gallon drum of 2,4

- D and bromacil, and a 55

- gallon drum of degreaser, had leaked into Wiener Creek c ausing the kill that extended about 1.6 miles along the creek. Criminal action is being taken by State and Federal authorities. I005075

- 001 Alfalfa Oats Hay Probable Misuse (accidental) DuP ont filed this report wit h the EPA to comply with FIFRA Section 6(a)(2). A property o wner in Texas has alleged that use of herbicide Krovar (Bromacil+Diuron) by the neigh bor adjacent to his property has resulted in the death of alfalfa, oats and forage hay. Herbicide was allegedly applied to a tank farm property appro ximately 2 days before a heavy rainfall. The tank dikes were later opened and three acres of pasture including a pond were allegedly exposed thus damaging alfalfa, oats and forage hay. I005972

- 001 Live oak Probable Registered Use Allegedly, the pesticide compounds in

run

- off from an adjacent plant site did injury to an individual's three (3) live oaks approximately 10 to 30 years old, subsequent to treatment by his neighbors application which affected his (individuals) property.
I 006010

- 003 Grass Bull rush (cattail) Probable Misuse (accidental) DuP ont filed this report with the EPA to comply with FIFRA Section 6(a)(2). Run

- off of Sulfometuron methyl, Diuron plus Broma cil, and Glyphosate from a n adja cent u tility

### 67 Table C

- 1. Bromacil Incident Report Summaries

Incident # Organism(s) Affected Certainty of Involvement Legality of Use Description

sub

- s tation affecte d the non

- target
p lants including pasture grass and bull

r ush (aquatic vegetation). I007154

- 001 Catfish Possible Registered Use A fish kill was possibly generated by a utility company on an alleged off

target incident/ water detection movement into a nearby two (2) acre

po nd from an electric substation. However, on 13 April and 13 May, the Utility stated that copper sulfate had been applied to the p ond since the soil application of the pe sticide; considered to be relatively non

- toxic, based on data fro m fish studies. DuPont makes the point that in the time frame before copper sulfate application, no sick fish with 'sores' were reported in the pond by the pond owner. I008184

- 001 Plants Possible Undetermined To comply with 6(a) ( 2 ) regulations, NCH Cor p. reported the alleged damage to soil and trees upon exposure to bromacil. No information on the state, the county, or the types of plants damaged was included in the report. This was the single incident to be reported in the time frame of 8/19/98 to 11 /19/98. I008441

- 001 Trees Turf Possible Undetermined To comply with 6(a) ( 2 ) regulations, NCH Corp. reported a complaint alleging that Certifen III leached from a fence line, where it was applied, into adjoining property where it damaged trees and turf. This took place in Maysville, KY, sometime between November 6, 1998, and February 6, 1999. I008956

- 001 Fish Probable Misuse intentional To comp ly with 6(a) ( 2 ) regulations, NCH Corp. reported a number of incidents involving their products. This particular incident concerned bromacil which was dumped into a storm drain in Iowa and discharged into a local river. There was a report of some fish being killed. I010837

- 020 Corn Possible Undetermined To comply with 6(a) ( 2 ) requirements, Novartis reported a complaint from Ulster, PA, that Bicep II damaged all 60 acres of a corn crop. The inspector reported that the application was made within the guidelines on the label. "Stand reduction" was the problem,

### 68 Table C

- 1. Bromacil Incident Report Summaries

Incident # Organism(s) Affected Certainty of Involvement Legality of Use Description

and a factor coul d have been Prowl which was also allegedly involved. I010837

- 030 / I010837

- 031 Sunflower Possible/ Probable Undetermined To comply with 6(a) ( 2 ) requirements, Novartis reported a complaint from Armour, SD, that there was a carryover injury to sunflowers

res ulting from an earlier use of Northstar. The symptom of the injury was uneven height. Here is the response of the inspector for Novartis: "Northstar carryover to sunflowers. Some stunting in areas throughout field. Stacked nodes and some yellowing. S oil samples sent (to

- - - ) to run test on pH and test for Beacon. Sunflower hybrid s eed: Cargill SF 270. Prowl applied PPI in 2000." This incident, and that described in I010837

- 031, concerns the same neighborho od in Armour, SD, and the

same circ umstances. I010837

- 045 Corn Possible Undetermined To comply with 6(a) ( 2 ) requirements, Novartis reported a complaint from Castile, NY, that BICEP LITE II damaged 100% of a corn crop; the acreage affected was not given. I010837

- 048 Corn Possible Undetermined To comply with 6(a) ( 2 ) requirements, Novartis reported a complaint from Hornell, NY, that BICEP LITE II damaged all 12 acres of a corn crop. The company paid the complainant $1100 as a good will gesture and would send 20 gallons of BICEP
LITE II MAGNUM to Agway Bath, NY. PROWL was reportedly another product involved but there was no indication of the extent of its involvement. I010837

- 055 Soybeans Possible Undetermined To comply with 6(a) ( 2 ) requirements, Novartis reported a complaint from Mapleton, PA, that BICEP LITE II damaged 35 acres of soybeans out of 65 that were treated. On the front page of the report, the item marked Acres Treated states 325. Obviously there is a discrepancy of so me sort in the reporting. I012457

- 012 Peanut Possible Undetermined To comply with 6(a) ( 2 ) requirements, Valent reported a complaint from Smithfield, VA, that VALOR damaged two plots of peanuts, one of 47.5 acres and the other 5 acres. Also

### 69 Table C

- 1. Bromacil Incident Report Summaries

Incident # Organism(s) Affected Certainty of Involvement Legality of Use Description
applied were PROWL and DUAL MAG. The symptoms were described as: "Phytotoxicity. Stunted leaves." I012457

- 013 Peanut Possible Undetermined To comply with 6(a) ( 2 ) requirements, Valent reported a complaint from Baconton, GA, that VALOR damaged two sites of peanut cro ps, one of 46.2 acres and the other 56.5 acres. PROWL was also applied. The symptoms were described as: "Phytotoxicity. Stunted, stand reduction." I012457

- 017 Peanut Possible Undetermined To comply with 6(a) ( 2 ) requirements, Valent reported a complai nt from Sayre, OK, that VALOR damaged 30 acres of peanuts. PROWL was also applied. The damage symptoms were described as: "Phytotoxicity: Burnt & wilted plants." I012457

- 019 Peanut Possible Undetermined To comply with 6(a) ( 2 ) requirements, Valent reported a complaint from Whigham, GA, that VALOR damaged two peanut sites, one of 41 acres and the other 47.7 acres. PROWL and SONALAN had also been applied. The damage symptoms were described as: "Phytotoxicity: Stunting with sta nd reduction." I012684

- 012 Peanut Possible Registered Use To comply with 6(a) ( 2 ) requirements, Valent reported a complaint from Yale, VA, that VALOR damaged 40 acres of peanuts. DUAL MAGNUM and TOUCHDOWN were also applied but no information was given a bout their application rates. The damage symptoms were reported as: "Phytotoxicity: Burnt leaf & petioles, slow emergence." This is a PA severity incident. I012708

- 001 Oak Shrub Ornamental Probable Undetermined To comply with 6(a) ( 2 ) requirements, DuPont reported a complaint from the Lake Wales Ridge area of Florida that BROMACIL damaged 40 mature oak trees, and many shrubs and plants. Here is the description of the incident: "Dennis Howard, PhD, Chief, Bureau of Pesticides; Florida Dept. of Agri. and Consumer Services (DACS), sent

an e

- mail (3/7/2002) to a representative of DuPont Crop Protection regarding water monitoring detects of shallow ground water wells

### 70 Table C

- 1. Bromacil Incident Report Summaries

Incident # Organism(s) Affected Certainty of Involvement Legality of Use Description
in the Lake Ridge area of Florida and associated adverse effect allegatio ns surrounding one of the wells. Dr. Howard previously communicated water detection results (5/2/2001) pertaining to the Lake Wales Ridge area wells and specifically the well that now has the additional allegations of adverse effects. This information

wa s submitted (6/1/2001) see attached earlier submission. DuPont has submitted, over many years, ground water detection information regarding the Lake Wales Ridge area of Florida, as it has become known to us. The additional allegations of adverse effects c ame from the resident owner of a private well after they were told that their shallow well tested above the HAL (reported in 6/1/2001 submission attached). The resident's allegations include death of landscape shrubs, perennials, and trees because use of the well for irrigation. In addition, the resident alleged he recently had his thyroid gland removed after developing a benign uni

- nodular goiter possibly from drinking from this well. The resident used a reverse osmosis system that cleaned the water whi ch was used until a new deep water well could be installed for the resident. In addition, two of the wells tested in this area were alleged to be over the bromacil Health Advisory Level (HAL) of 90 ppb. Three other wells were over 10% of the HAL but belo w the HAL, each detection of these wells will be counted in DuPont's next Quarterly Aggregate Submission under bromacil." I013587

- 020 Evergreen Possible Registered Use In the 2000

- 2001 Annual Report of the Pesticide Incident Reporting and Tracking (PIRT) Review Panel of Washington State, an incident that took place on March 2, 1998 in Adams County is reported. A combination of Bromacil and Diuron was applied, presumably to a right

- of

way, but in 1999 a row of evergreens alongside the damaged party's home were dying. No residues were

### 71 Table C

- 1. Bromacil Incident Report Summaries

Incident # Organism(s) Affected Certainty of Involvement Legality of Use Description
detected in the foliage samples that were taken, but a trace of one pesticide was found in the right

- of

way. No pesticides were found outside of the right

- of

- way. The affected trees were located within 30 degrees of the righ t

- of

- way. This is listed as a Severity 1 type of incident but there is nothing in the report to indicate the meaning of that severity rating . No action was indicated. I013850

- 001 Grass Possible Registered Use An Ohio

- based applicator used a railroad vehicle with flood jet and boom buster nozzles for the application of three products to railroad tracks on May 24, 2002. The products were Krovar IDF Herbicide, Roundup Original and Weeder IV. A resident next to t he railroad reported that a third of the backyard was turning brown and dying. I013884

- 004 Grass Highly Probable Registered Use This is from the 1999 Annual Report from the Washington State Department of Health Pesticide Incident Reporting and Tracking Review Panel, November 2000, from the 1998 PIRT Data. Product applied last fall was carried by runoff, came across street and damaged three yard s within two weeks. I014177

- 001 Pepper, red bell Possible Registered Use This is a Superior Court of California case. The plaintiff allege d that KROVAR I DF herbicide (Bromacil + Diuron) damaged their red bell pepper crop. KROVAR was applied in January 1998 to Tangerine orchard. In the summer of 2000, the tangerines were harvested and the trees removed

. Early fall 2001, the field was irrigated and planted with 30 pounds of barley per acre. December 2001, the barley was discarded after reaching approx.... 6 inches in height with no visible problems. On January 14, 2002, the soil was prepared for plant ing and the red bell pepper crop was planted. This is four years after the application of KROVER to an orchard. In March 2002, it was noticed that a majority of the bell pepper seeds were not producing a plant, and plants that were growing, were stunted. After it was

### 72 Table C

- 1. Bromacil Incident Report Summaries

Incident # Organism(s) Affected Certainty of Involvement Legality of Use Description
noticed that the plants were not growing, the plaintiff had analysis of the soil performed. It showed 0.134 ppm of Bromacil. Other bioassays results were not given. At the present time, there are two other incidents which showed carryover of Bromacil from a different product effecting sunflowers. I014409

- 062 Tree Possible Undetermined This incident was reported in the Washington State Dept. of Health Annual Report 1993, Pesticide Incident Reporting Review Panel, April 1994, prepared by th e Washington State Department of Agriculture. A commercial applicator unknowingly mixed oryzalin and bromacil/diuron and made application. Damaged trees and shrubs. No analysis nor any State action. I0144700

- 001 Grass Possible Registered Use An alleged runoff from treated substations of OGE a ffected strips of sod downhill from the application. Treatment was bare ground at 12 pounds per acre. Weather records indicated that these areas received heavy rains in May, which may have caused the runoff. Ther e was a severe drought in the summer. I015360

- 001 Deciduous tree Pine tree Possible Misuse (accidental) To comply with 6(a) ( 2 ) requirements, DuPont reported a complaint from an applicator in John Day, OR, that 2 trees 10

- 15 years old, one pine and one deciduous, and an older deciduous tree were damaged by the application of Krovar I DF Herbicide to a bareground driveway. The dri v eway was treated in 2000, 2001, and 2002 at the rate of 8 lbs/acre, and the owner began complaining of tree damage in 2002. Near the edge of the driveway were a deciduous tree and a pine tree, both about 10

- 15 years old, and appeared to have yellowed lea ves/needles, and the pine tree had shed much of the needles on the upper half of the tree. The homeowner also felt that there was some damage to an older deciduous tree behind the house. Specif ic language on the label warns against this situation and use. I015382

- 001 Grass Trees Probable Undetermined To comply with 6(a) ( 2 ) requirements,
D uPont reported an incident in

### 73 Table C

- 1. Bromacil Incident Report Summaries

Incident # Organism(s) Affected Certainty of Involvement Legality of Use Description
Wyoming (location not mentioned) in which Krovar was applied to some weeds, after which a large rain came and washed the product down a 200 foot embankment. The result was stated as "Now grass in his yard has turned brown and trees in his neighbor's yard are starting to turn brown." Evidently it was an instance of large runoff. I016569

- 001 Glove willow trees Possible Undetermined To comply with 6(a) ( 2 ) requirements, DuPont reported an incident in Flora Vista, NM, in which DuPont's Krovar I DF Herbicide allegedly killed 45 glove willow trees. The complainant stated that there is an oil pipe line behind their house, and for the past fou r years the land was sprayed with Krovar plus another chemical. Approximately eleven months ago, a weed company sprayed the fence line with those products but this time the spraying included a ten

- foot width that was inside the complainant's land. The

resu lt was that 45 glove willow trees died. I016610

- 001 Cottonwood Pine Willow Probable Misuse (intentional) It was alleged that a neighbor maliciously "threw onto the land" approximately four pounds of DuPont Krovar herbicide in order to kill their neighbors trees. In 2004, the dead grass area doubled in size to 30 by 10 feet. There was one dying pine tree, one dying cottonwood tree and a dead willow tree. In October 2004, an Arborist tested some white power on top of the dirt and the results reported 7.4% b romacil. Later in November 2004, some affected foliage was tested and showed 4.3 ppm of bro macil. It was alleged that the County sprayed a right

- of

- way with Telar (active ingredient: chlorsulfuron) and Dimension (active ingredient: dithiopyr ) herbicides w hich drifted on to a field of peach trees. No analysis was reported. 75 to 100 peach trees were damaged. I018527

- 001 Willow Lilac Highly Probable Undetermined DuP ont Krover and Karmex Herbicides containing ingredients bromacil and diuron that were sprayed to control vegetation at an industrial

### 74 Table C

- 1. Bromacil Incident Report Summaries

Incident # Organism(s) Affected Certainty of Involvement Legality of Use Description
site (Key Energy) caused damage to trees belonging to a private home owner adjacent to the spray site. Soil and plant tissue analyse s were performed and detected the presence of bromacil and diuron in soil around

trees. I019519

- 045 Celery Possible Undetermined Grower reported crop loss happened 40

- 60 feet next to railroad track to the Ventura County Agricultural Commissioner office on April 9, 2008. Plant dam a ge was about 7 acres of 35 acres of celery. A pest control company located in Chino sprayed for weeds around the railroad track 2

- 3 weeks prior to the noticeable celery damage. The herbicides sprayed include product Karmex with active ingredient diuron, product Krovar with active ingredient bromacil and diuron, product Payload with active ingredient flumioxazin, and product Razor with active ingredient glyphosate. I020725

- 004 Celery Possible Undetermined A grower reported crop damage to Ventura County Agricultural Commissioner's Office and celery field about 40 to 60 feet next to railroad track showed root damage. A pest control company located in Chino, California sprayed for weeds around the railroad tra ck 2

- 3 weeks prior to the noticeable celery damage. Chemical analysis showed presence of Diuron and Bromacil in the celery samples collected from the suspected field. I020180

- 033 Brussel s sprouts Possible Undetermined Oust XP and Krovar herbicides had

cau sed damage to brussel s sprouts by rain runoff from the railroad right

- of

way that was located adjacent to the growing site. In January 2008, an application of the herbicides Krovar 1DF and Oust were made to the railroad by a pest control business. Brussel s sprout transplants were planted on the damaged site during the month of April. The grower noticed stunting and dying o ff of approximately 9 acres of B russel s sprouts around May 15, 2008. Diuron, one of the active ingredients of Krovar, was detected in so il samples

### 75 Table C

- 1. Bromacil Incident Report Summaries

Incident # Organism(s) Affected Certainty of Involvement Legality of Use Description

taken from the treatment site, but not from soil samples taken from the brussel s sprout field. I020459

- 001 Wheat Possible Undetermined The Washington State Department of Agriculture reported in the 2002 PIRT Report a case that involve alleged d rift and run off of herbicides from road ROW applications that damaged a wheat field. Diuron, bromacil, and imazapyr were applied along a freeway and a county road, and were also detected on the wheat. I020459

- 005 Ornamental Possible Undetermined Three ornamental trees at a residence were damaged by herbicide. The herbicides may have come from an off

- label application to a driveway, or possibly from drift from spraying of a roadside or an adjacent field. The applications were made by a commercial pest c ontrol company to a

non

- farm residence. The Washington State Department of Agriculture (WSDA) lab detected bromacil and diuron in leaves from the trees. Glyphosate, also applied by the company, was found in one of the trees damaged by the herbicide. I020459

- 035 Ornamentals (Juniper) Possible Misuse (accidental) The Washington State Department of Agriculture reported in the 2002 PIRT Report a case that involved damage to juniper trees that were caused by an application of of Krovar (active ingredients bromacil and diuron). Krovar was applied for weed control around the newly planted Juniper plants almost a year ago. The K r ovar label states "not to be used in or around houses" and "do not to sites which have roots of desirable plants growing in the tre atment zone as plant injury or death may occur. The trees likely died from root uptake of the product. I020627

- 005 Trees Shrubs Possible Misuse (accidental) The Office of Environmental Health and Safety, Washington State Department of Agriculture Annual report 2003 indicates a case that involve alleged drift or overspray from roadside application of the herbicides 2,4

- D, diuron, and bromacil resulted in injury to multiple trees and shrubs on private property. The application was a misuse because it

### 76 Table C

- 1. Bromacil Incident Report Summaries

Incident # Organism(s) Affected Certainty of Involvement Legality of Use Description

was made under conditions conducive to drift. I021074

- 001 Cottonwood Oak Pine Cedar Grass Highly Probable Undetermined DuP ont Hyvar Herbici de (active ingredient bromacil) was sprayed by a neighbor three times to kill weeds. There was 3 inches of rain which

c aused runoff of the herbicide, killing grass and assorted trees in his yard and his neighbor's yard. There was a clear swath of dead plants from the application site to the neighbor's house 200 ft away. Th e product caused damage to oak , cedar, pines, and cott onwoods trees as well as grasses. The arid area had li ttle rainfall before the 3

- inch rain event. The neighbor who applied the herbicide product works for the railroad and brought the herbicide home to spray on weeds. This was a misuse of the produ ct.