### 1 OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460



### MEMORANDUM

DATE: Octo ber 6 , 2015

SUBJECT: Tier I Estimated Drinking Waters Concentrations of Fluazinam and its Transformation Products for Use in the Human Health Risk Assessment for the Registration of the New Uses on Mayhaw, Cabbage and Chinese cabbage, Cucurbit Vegetables, Squash/Cucumber Subgr oup 9B, and Root and Tuber Vegetables, Tuberous and Corm Subgroup 1C 

## (PC Code 129098; DP Barcode 426144 )

FROM: José Meléndez, Chemist Environmental Risk Branch 5 Environmental Fate and Effects Division (7507P)

THROUGH: Mah T. Shamim, Ph.D., Branch Chief
Environmental Risk Branch 5
E nvironmental Fate and Effects Division (7507P)

TO: Erik Kraft , Risk Manager Reviewer Heather Garvie , Review Manager #2 4
Rachel Holloman , Branch Chief Fungicide

- Herbicide Branch

A. Willis Ertman, Risk Manager Reviewer Barbara Madden, Minor Use Team Leader
Marion Johnson , Branch Chief Risk Integration, Minor Use and Emergency Response Branch Registration Division (7505P)

AND: Christina Swartz, Branch Chief Registration Action Branch 2 Health Effects Division (7509P)

This memorandum presents the Estimated Drinking Water Concentrations (EDWCs) for the pyridine fungicide fluazinam , and for its major transformation products DCPA, HYPA, CAPA,
DAPA and AMPA , for use in the human health risk assessment ( Table 1 )

. A r equest for

### 2 registration of various new crops was submitted to the Agency . These included Mayhaw, Cabbage
and Chinese cabbage (foliar applications)

, Cucurbit Vegetables

– Squash/Cucumber Subgroup 9B,
and Root and Tuber Vegetables

– Tuberous and Corm Subgroup 1C

. Based on a review of the use information, it was found that the proposed new crops have lower seasonal application rates than the previously evaluated uses on turf. The maximum seasonal rates for the newly proposed crops
is for Cucurbit Vegetables

– Squash/Cucumber Subgroup 9B at 3.91 lb a.i./A/season , compared to
8.4 lb a.i./A/season for turf . The use on turf was previously evaluated under DP Barcode D391184

, dated 08/03/2011 ( Table 2 ). EDWCs for the new uses should be smaller than those already calculated for turf; therefore, new surface drinking water values are not required. The values reported in the previous assessment can be used to cover the new crops . However, f or groundwater, new EDWCs were calculated in this assessment using the new model PRZM

- GW (refer to Appendix A ).

The previous DWA dated August 3, 2011 (assessment of the use on turf ; DP Barcode D391184

, dated 08/03/2011 )

, has appended to it a copy of a DWA for the uses on lettuce, apple s, carrots an d bulb vegetables, Crop Subgroup 3

- 07A

, DP Barcodes D360713, D365942 & D365948

, dated February 24, 2010

. Th e DWA and its attachment provide specific information about the chemicals modeled ( i.e.

, fluazinam, DCPA, HYPA, CAPA, DAPA and AMPA ), structures, problem formulation and approach taken in modeling the crops, a summary of physicochemical and environmental fate properties of the chemicals , previous agricultural and turf uses, mode of action, analysis, uncertainties, characterization

, etc

.

EDWCs were c alculated for t otal f luazinam r esidues because the environmental fate studies indicated that the parent compound undergoes transformation to compounds w ith a similar

s tructure to the parent under most conditions [ refer to the Metabolism Assessment Review
C ommittee ( MARC ) decision under DP Barcode D272624 ( W. Cutchin, 0 4/23/2001 ) ]

.

The EDWCs summarized in Table 1 represent upper

- bound estimates of the parent and degradates’ concentrations that might be found in surface water and groundwater due to the use of
fluazinam on turf, as reported previously in DP Barcode D391184 and Appendix A of this DWA

. It is noted t hat this is still a screening

- level analysis and refinements are possible

. Should the registrant wish to include new crops, such like 

## watercress to the label, this use will need to be assessed in a separate DWA. Should any qu estions arise, please contact the Environmental Fate and Effects Division (E FED ) as soon as possible

.

Table 1. Maximum Tier 1 Estimated Drinking Water Concentrations (EDWCs) for drinking water assessment based on ground application of fluazinam on turf at a seasonal rate of 8.4 lb a .i./A

Source/Model Fluazinam Total Residues of Fluazinam 1 

### Acute/ppb Chronic/ppb Acute/ppb Chronic/ppb
Surface Waters/FIRST 217 2 

### 1.47 226 2 

### 37.8
Groundwater/PRZM

- GW 0.538 0.319 137 2 

### 119 2

1. Including the following transformation products: DCPA, HYPA, CAPA, DAPA and AMPA.

2

. Exceeds the solubility of fluazinam at pH 7 (71 ppb), but not the solubility at pH 11 (350 ppm).

3. For groundwater results, refer to Appendix A

.

### 3 

## Background and New Use Information

As indica ted above, new use s f or fluazinam ha ve been requested by the IR

- 4 Project and the registrant

, ISK Biosciences Corporation , under Section 3

, on m ayhaw, c abbage and Chinese cabbage (foliar applications)

, c ucurbit vegetables

- s quash/ c ucumber Subgroup 9B, and r oot and
tuber v egetables

– tuberous and c orm Subgroup 1C ( Table 2 )

. It was found that the maximum seasonal application rate for the previously assessed use on turf (8.4 lb a.i./A/season) is much higher than for the new uses . T he highest new rate is for c ucurbit v egetab les

– s quash/ c ucumber Subgroup 9B at 3.91 lb a.i./A/season

.

A summary table of the newly proposed use pattern s is provided in Table 2 . This information is based on the proposed Supplemental L abel s for the product OMEGA ® 

### 500F ( EPA Reg. No.
71512

- 1 ), which contains 40.0% a.i. or 4.17 lb a.i./gal of product. The product label claims that it is a broad spectrum fungicide for use to control diseases such as hawthorn leaf blight on mayhaw,
d owny m ildew on cabbage and Chinese cabbage, and c ucurbit vegetables

– squash/cucumber (m elon Subgroup 9B), and late blight on root and t uber v egetables ( t uberous and c orm Subgroup 1C).

Table 2

. Use information for fluazinam (based on the current and proposed label for Omega 500F, EPA Reg. No. 71512

- 1, and existing label for Fluazinam Turf Fungicide, EPA Reg. No. 71512

- 20). The proposed uses are shaded yellow

. Certain previously approved crops are shaded blue

.

USE MAXIMUM SINGLE APP. RATE

(lb. a.i./A) NUMBER OF APPS.
AT MAX

RATE MAXIMUM SEASONAL APP. RATE

(lb. a.i./A) INTERVAL
BETWEEN APPS. (days) APP. METHOD PHI (days)

Apples , Mayhaw 0.33

- 0.45 10 4.50 7

- 10 Broadcast

spray A 28

Brassica (Cole) Leafy Vegetables Crop Group 5, plus Turnip Greens in Crop Group 2 ; such as, but not limited to: broccoli; broccoli raab (rapini); cabbage, Chinese cabbage (napa); cauliflower; collards, kale; mizuna; mustard spinach; Chinese broccoli; Brussels sprouts; Chinese cabbage (bok choy); Chinese mustard cabbage; cavalo broccoli; kohlrabi; mustard

greens; rape greens, plus turnip greens from Crop Group 2 [Transplant
0. 21 lb]

[Soil incorporation

1.36 lb] B Not specified 2.01 for
soil applications N/A Soil drench
after transplant or
soil incorporated

(6

- 8 inch

depth, transplant the seedlings into

the treated

band) 20 for leafy

greens such as
mustard

greens; 50 for heading vegetable
s such as cabbage

and
broccoli Cabbage, Chinese cabbage (tight heading varieties only ; see also same

crops are mentioned in the previous row for soil apps ) 0.5 00 6 3.0 0 7 Foliar 7

### 4 USE MAXIMUM SINGLE APP. RATE

(lb. a.i./A) NUMBER OF APPS.
AT MAX

RATE MAXIMUM SEASONAL APP. RATE

(lb. a.i./A) INTERVAL
BETWEEN APPS. (days) APP. METHOD PHI (days)

Bushberry Crop Subgroup 13

- 07B ; such as, but not limited to: Aronia berry, blueberry (highbush and lowbush), Chilean guava, currant (Buffalo, black, red, and Native), elderberry, European barberry, gooseberry, highbush cranberry, honeysuckle, huckleberry, jostaberry, juneberry, lingonberry, salal,
and sea buckthorn 0.652 6 (at the max rate) 3.91 7

- 10 Ground C 30

Carrots 0.521 4 2.09 1 st app interval 14 days; subsequent

apps at 7

days Ground D 7

Ginseng 0.521

- 0.782 4 3.13 7

- 14 Ground D 30

Lettuce (head and leaf) 0.521

- 0.782 1 0.782 N/A Ground D : foliar band,
broadcast spray or soil
drench 30

Edible

- Podded Legume Vegetables Crop Subgroup 6A, except

peas ; such as, but not limited

to: Phaseolus spp. Such as: runner bean, snap bean, wax bean; Vigna spp. Such as: asparagus bean, Chinese longbean, moth bean, yardlong bean; jackbean, and sword bean

0.261

- 0.443 2 0.912 7

- 10 Ground, Sprinkler irrigation 14

Succulent Bean Crop Subgroup 6B ; such as, but

not limited to lima bean and
broad bean 14

Dry Bean Crop Subgroup 6C, except Peas and Soybeans ; such as, but not limited to dried cultivars of bean: Lupinus spp.; Phaseolus spp, such as kidney beans, dry lima bean, navy bean, pinto bean; Vigna spp., such as adzuki bean; and broad bean, such as lablab bean 30

Bulb Vegetables Crop Subgroup 3

- 07A ; Includes bulb daylily, bulb fritillaria, bulb garlic, bulb great headed garlic, bulb serpent garlic, bulb lily, bulb onion, bulb Chinese onion, pearl onion, bulb potato onion, bulb shallot, and cultivars, varieties, and/or hybrids of these 0.521 6 3.13 7

- 10 Ground (minimum 5

gal/A), or sprinkler irrigation 7

### 5 USE MAXIMUM SINGLE APP. RATE

(lb. a.i./A) NUMBER OF APPS.
AT MAX

RATE MAXIMUM SEASONAL APP. RATE

(lb. a.i./A) INTERVAL
BETWEEN APPS. (days) APP. METHOD PHI (days)

Cucurbit Vegetables, Melon Subgroup 9A ; Includes Citron melon; Muskmelon, including hybrids and/or varieties of Cucumis melo (including true cantaloupe, cantaloupe, casaba, Santa Claus melon, Crenshaw melon, honeydew melon, honey balls, Persian melon, golden pershaw melon, mango melon, pineapple melon, snake melon); and watermelon, including hybrids and/or varieties of Citrullus spp

. 0.391

- 0.782 6 4.69 7

- 10 Foliar E 30

Cucurbit Vegetables, Squash/ Cucumber Subgroup 9B ; Includes Chayote (fruit); Chinese waxgourd (Chinese preserving melon) Benincasa hispida ; cucumber; gherkin; edible gourd (Lagenaria spp. i.e. spaghetti squash, hyotan, cucuzza), ( Luffa acutangula, L. cylindrical i.e. hechima, Chinese okra); Momordica spp.(bitter melon, balsam pear, balsam apple, Chinese cucumber); pumpkin; squash, summer (Cucurbita

pepo i.e. crookneck squash, straightneck squash, scallop squash, vegetable marrow, zucchini); winter squash, ( Cucurbita m axima; C. moschata i.e. butternut squash, Calabaza, hubbard squash), ( C. mixta; C. pepo i.e. acorn squash); including hybrids
and/or varieties of these 0.391

- 0.782 1 (soil) 4 (foliar) 5 (total) 3.91 7 At plant or transplant

banded soil

drench F ;

or Foliar 7

Fruiting Vegetable, Pepper/ Eggplant Subgroup 8

- 10B ; Includes African eggplant; bell pepper; eggplant; martynia; nonbell pepper; okra; pea; eggplant; pepino; roselle; scarlet eggplant; cultivars, varieties, and/ or hybrids of these 0.521

- 0.782 6 4.69 7

- 14 Foliar E, F 30

Peanut 0.521

- 0.782 2 at max
rate or 3
at 0.70
lb a.i./A 2.09 21

- 28 Ground, Sprinkler irrigation G Do not apply
w/in 30 d
of threshing
for
harvest

### 6 USE MAXIMUM SINGLE APP. RATE

(lb. a.i./A) NUMBER OF APPS.
AT MAX

RATE MAXIMUM SEASONAL APP. RATE

(lb. a.i./A) INTERVAL
BETWEEN APPS. (days) APP. METHOD PHI (days)

Root and Tuber Vegetables, Tuberous and Corm Subgroup 1C ; Arracacha; arrowroot; artichoke, Chinese; artichoke, Jerusalem; canna, edible; cassava, bitter and sweet; chayote (root); chufa; dasheen (taro); ginger; leren; potato ; sweet potato; tanier; turmeric; yam bean; yam, true; cultivars, varieties, and/or hybrid s of these 0.179

- 0.261 7 1.82 7

- 10 Ground or Aerial, Sprinkler irrigation 14

Soybeans 0.391

- 0.521 2 1.04 10

- 14 Ground or
Aerial H NS

Turf grasses only on golf courses (tees, greens, fairways and roughs) 0.700 12 8.41 14 Ground I N/A

N/A=not applicable.

A. Applications based on a tree size requir ing a dilute spray of 200 gal/A

B. For transplants, assume maximum rate; the recommended application rate is 6.45 oz/100 gal, but the spray volume is not specified. When soil incorporated, apply in a minimum spra y volume of 50 gal/A.

C. Do not use an adjuvant in the spray mixture. Applications should correspond roughly with apps at green tip, pink tip, early bloom, full bloom, blossom drop, and small green fruit to some blue fruit.

D. Carrots: Apply in 30

- 50 gal water/A as a directed band spray over the crop. Ginseng: Apply in a minimum of 100 gal water/A. Lettuce: Apply in a minimum of 50 gal water/A

E. Use sufficient water to provide coverage of foliage. May be applied through sprinkler system irrigation equipment.

F. The initial application may be made as a soil drench at transplanting.

G. Apply at 45

- 70 days after planting.

H. Ground or aerial. The first application should be applied at R1 (early bloom) to R2 (full bloom) sta ge of development and if needed at stage R3 (early pod formation). Do not apply after growth stage R3.

I. Apply Fluazinam Turf in sufficient water to obtain adequate uniform coverage of the turf.



## Data Gaps

In the Preliminary Risk Assessment for Registr ation Review, a number of the environmental fate studies were listed as supplemental. Additionally, t he following data gaps still exist :

8 50 .6100: Environmental Chemistry Methods (ECMs) and Independent Laboratory Validations (ILVs) for Soil, Water and Sediment

. The registrant submitted various method s and validation studies of which a number of them were found to be unacceptable or supplemental / upgradable. These studies or upgrades should be submitted to the Agency.

Note that the ECM/ILV results are not used as an input parameter value in the aquatic models
used in this DWA.

### 7 

# Appendix A. Tier 1 EDWCs for Groundwater Using PRZM

- GW

PRZM

- GW v.1.07

Conceptual Model

Figure A

- 1 depicts the general groundwater scenario concept for estimating pesticide concentrations in drinking water as implemented in PRZM

- GW. This conceptual model is based on a rural drinking water well beneath an agricultural field (a high pesticide use area) drawing from an unconfined, high water

- table aquifer.

Figure A

- 1. General Groundwater Scenario Concept for Estimating Pesticide Concentrations in Drinking Water as Implemented in PRZM

- GW; The black line through the soil profile represents the decline in degradation with respect to the depth.

The depth of the well is site specific ( i.e. , scenario specific). The well extends into a shallow unconfined aquifer and has a well

- screen 1 

### that starts at the top and extends down into the aquifer. The length of the well

- screen represents the region of the aquifer where drinking water is collected.
The well

- screen length is well

- specific and can be adjusted. Processes included in the conceptual model that influence pesticide transport through the soil profile incl ude water flow, chemical specific dissipation and transportation parameters ( i.e. , degradation and sorption), and crop specific factors, including transpiration, pesticide interception and management practices.

The following is a brief description of the PRZM

- GW model. More information is available

at http://www.epa.gov/oppefed1/models/water/ (accessed 06/25/2015).

Tier 1 groundwater estimated drinking water concentrations (EDWCs) for a chemical, resulting from its use on a crop are derived with PRZM

- GW (Pesticide

1 A well screen is a filtering device that allows groundwater from unconsolidated and semi

- consolidated aquifers to enter the well while at the same time keeping the majority of sand and gravel out of the well.

### 8 Root Zone Model for Groundwater, version 1.07, March 6, 2014), using the
GW

- GUI (Graphical User Interface, version 1.07, March 6, 2014 ). PRZM

- GW
is a one

- dimensional, finite

- difference m odel that estimates the concentrations of pesticides in groundwater. It accounts for pesticide fate in the crop root zone by simulating pesticide transport and degradation through the soil profile after a pesticide is applied to an agricultural field. PRZ M

- GW permits the assessment of multiple years of pesticide application (up to 100 years) on a single site. Six standard scenarios, each representing a different region known to be vulnerable to groundwater contaminations, are available for use with
PRZM

- G W for risk assessment purposes. In PRZM

- GW simulations, each of
these standard scenarios is used. PRZM

- GW output values represent pesticide concentrations in a vulnerable groundwater supply that is located directly beneath a rural agricultural field.



### Input Parameters for PRZM

- GW and Results

For input parameters used in this model, refer to Table A

- 1

.

Table A

- 1. PRZM

- GW Input Parameters for modeling ground applications of fluazinam on turf

PARAMETER (units) VALUE 1 SOURCE COMMENT

Application date (day/month) 10

- 04

Turf is usually a permanent crop. First application

was set to occur at crop

emergence. Delmarva emergence 10

- 04, crop maturation 30

- 05, harvest 15

- 06

01

- 0 1 FL citrus crop emergence 01

- 01, crop maturation
01

- 02, harvest 31

- 12

15

- 02 FL potatoes emergence 15

- 02, crop maturation
01

- 05, harvest 01

- 06

01

- 05 GA coast emergence 01

- 05, crop maturation 01

- 08, harvest 01

- 10

15

- 05 NC coast emergence 15

- 05, crop maturation 01

- 08, harvest 01

- 11

01

- 05 WI sand emergence 01

- 05, crop maturation 21

- 07, harvest 20

- 10 Maximum Application Rate (kg a.i./ha) 1.884

Label Maximum rate allowed is 0.700 lb a.i./A x 1 2

a pplications at 14 day interval. Due to limitations
in the PRZM

- GW model, only 5 applications could be modeled; therefore, the application rate was adjusted accordingly. Number of Applications per Year 5

Retreatment Intervals (days) 14

Chemical Application Method (CAM) 2 Label Foliar

Incorporation Depth (cm) 0 Label Apply Fluazinam Turf in sufficient water to obtain adequate uniform coverage of the turf.
Air diffusion coefficient (cm 2 /day) 0 N/A Assuming no volatilization.

Vaporization enthalpy (kcal/mol) 0 N/A Assuming no volatilization.

Henry’s Law Constant ( atm

- m 3 /mol) 0 N/A Assuming no volatilization.

### 9 PARAMETER (units) VALUE 1 SOURCE COMMENT

Partition Coefficient (K OC ; mL/g OC ) 1958 42248628,
42974913 Sorption is correlated with OC Represents the average K OC value among four values ranging
from 1705 to 2316 ml/g OC

.

Aerobic Soil Metabolism Half

- life (days) 293 (Parent only 2 ) 42208413,
42208414 Represents the 90% upper confidence bound on the mean of two half

- life values ( 1 52 DFOP , 221
SFO days; Mean 186.5 days ; Std. Dev. 48.79 days ; n=2, t 90, n

- 1 = 3.078).

2 47 (TTRs 2 ) Represents the 90% upper confidence bound on
the mean of two half

- life values ( 247

- DFOP

, 2 47

- SFO days; Mean 2 47 days ; Std. Dev. 0 days ; n=2, t 90, n

- 1 = 3.078).

Hydrolysis Half

- life (days) 42 (Parent only) 42208412 The transformation product CAPA reaches a maximum at the end of the study at pH 7. 0 (TTR)

1 Parameters are selected as per “Guidance for Selecting Input Parameters for Modeling Pesticide Concentrations in Groundwater Using the Pesticide Root Zone Model” v.1.0, dated October 15, 2012.

2 T he representative half

- lives for the TTRs were higher than for the parent alone , since for the TTRs both half

- lives were the same value, which results in a slightly smaller half

- life for modeling the TTRs, compared to the half

- life for modeling the parent alone.



### Results are provided in Table A

- 2 for the parent alone and Table A

- 3 for the TTRs. Given that in all cases the run was incomplete, extended weather files were used to estimate groundwater
EDWCs. Since the maximum number of a pplications in PRZM

- GW is 500 per run, the application rate for the 12 applications was divided by 5 applications (times 100 years = 500 applications). This approach was taken to obtain upper bound values of groundwater EDWCs; however, should it be requir ed, additional refinements could be explored.

Table A

- 2

. Estimated Drinking Water Concentrations (EDWCs) resulting from the use of fluazinam
on turf , runs for the parent alone , with extended weather files

Crop/Scenario Highest Daily
Value (μg/L) Post Breakthrough Average

(μg/L) Average Simulation Breakthrough Time (days)

Turf /Tier I Delmarva 0.0863 0.0695 24,612
Turf /Tier I FL citrus 0.538 0.319 20,346
Turf /Tier I FL potatoes 5.53 x 10

- 5 Incomplete Incomplete
Turf /Tier I GA coast 1.48 x 10

- 4 1.11 x 10

- 4 33,583
Turf /Tier I NC coast 9.9 x 10

- 4 3.6 x 10

- 4 20,383
Turf /Tier I WI sand 9.34 x 10

- 3 6.91x10

- 3 28,579



### Table A

- 3

. Estimated Drinking Water Concentrations (EDWCs) resulting from the use of fluazinam on turf, runs for the TTRs , with extended weather files

Crop/Scenario Highest Daily
Value (μg/L) Post Breakthrough Average

(μg/L) Average Simulation Breakthrough Time (days)

Turf /Tier I Delmarva 26.5 22.8 24,612
Turf /Tier I FL citrus 103 101 20,346
Turf /Tier I FL potatoes 0.00173 Incomplete Incomplete
Turf /Tier I GA coast 5.17 4.82 33,583
Turf /Tier I NC coast 11.7 11.1 20,383 t t t s

n input n

= + − 1 2 90 1

/ , ( )

### 10 Crop/Scenario Highest Daily
Value (μg/L) Post Breakthrough Average

(μg/L) Average Simulation Breakthrough Time (days)
Turf /Tier I WI sand 137 119 28,579



# Example Output File from PRZM

- GW

For the FL citrus scenario, for the TTRs, the following output file was obtained.



# Groundwater Analysis for Fluazinam and the Florida Citrus

- FL Central Ridge, Polk County

- (Tampa) Met File (12842.Dvf)

- Astatula Sand, Hrgb A Scenario
Estimated groundwater concentrations and breakthrough times for Fluazinam are presented in
Table 1 for the Florida Citrus

- FL Central Ridge, Polk County

- (Tampa) Met File (12842.dvf)

- Astatula sand, hrgb A groundwater scenario. A graphical presentation of the daily concentrations in the aquifer is presented in Figure 1. These values were generated with the

P RZM

- GW (Version 1.07). Critical input values for the model are summarized in Tables 2 and 3.

Table 1. Groundwater Results for Fluazinam and the Florida Citrus

- FL Central Ridge, Polk County

- (Tampa) Met File (12842.dvf)

- Astatula sand, hrgb A Scenario.

Peak Concentration (ppb) 103

Post

- Breakthrough Mean Concentration (ppb) 101

Entire Simulation Mean Concentration (ppb) 66.5

Average Breakthrough Time (days) 20346.26

Throughputs 1.777329

Table 2. Chemical Properties for Groundwater Modeling of Fluazinam.

Koc (ml/g) 1958

Surface Soil Half Life (days) 247

Hydrolysis Half Life (days) 0

Diffusion Coefficint Air (cm2/day) 0.0

Henry's Constant 0.0

Enthalpy (kcal/mol) 0.0

### 11 Table 3. Pesticide application scheme used for Fluazinam. This application scheme was applied every year of the simulation.

Application Days
Relative to Emergence Date (01/01) Application Method Application Rate
(kg/ha)

0 Above canopy application 1.884

14 Above canopy application 1.884

28 Above canopy applicat ion 1.884

42 Above canopy application 1.884

56 Above canopy application 1.884

Figure 1. Aquifer Breakthrough Curve for Fluazinam and the Florida Citrus

- FL Central Ridge, Polk County

- (Tampa) Met File (12842.Dvf)

- Astatula Sand, Hrgb A Scenario