1 UNITED ST AT ES ENVIRONMENT AL PROTECTION A GENCY

WASHINGTON, D.C. 20460 OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES PC Code 12909 8 DP Barcode D360713, D365942 & D365948 MEMORANDUM D ATE: February

24, 2010 SUBJECT: Tier I Estimated Drinking Waters Concentrations (EDWCs) of Fluazinam

and its Transformation Products for the Use in the Human Health Risk Assessment for the Registration o f the Following New F ood Uses : Lettuce, Apples, Carrots and Bulb Vegetables ( Crop Subgroup 3 - 07A) FROM: José L . Meléndez, Chemist

Environmental Risk Branch V Environmental Fate and Effects Division (7507P) THROUGH : Mah T. Shamim, Branch Chief

Environmental Risk Branch V E nvironmental Fate and Ef fects Division (7507P) TO: Laura Nollen, Risk Manager Reviewer

Barbara Madden, Review Manager #05 Daniel Rosenblatt , Branch Chief Risk Integration, Minor Use and Emergency Response Branch Registration Division (7505P) AND: Douglas Dotson , Ph. D., Chemist

Christina Swartz, Branch Chief Registration Action Branch II Health Effects Division (7509P) This memo presents the Tier I Estimated Surface Drinking Water Concentrations and Estimated Ground Water Concentrations (EDWCs) for Fluazinam and Fluazinam Total Residues (parent plus its major transformation products), calculated using the Tier I aquatic models FIRST and SCI - GROW, respectively , for use in the human health risk assessment. The registrant is seeking registration of the use of fluazinam on lettuce, apples, carrots and bulb vegetables ( Crop Subgroup 3 - 07A) .2

The Estimated Drinking Water Concentrations (EDWCs) for Fluazinam and Fluazinam Total Residues were calculated based on a maximum application rate of 4.50 lb a.i./A/ season of fluazi nam on apples . For the parent f luazinam , the surface water acute value is 110 ppb, and the chronic value is 0. 744 ppb. The groundwater screening concentration is 0. 216 ppb of f

luazinam. For the t otal f

luazinam residues (including the parent compound) , the surface water acute value is 117 ppb and the chronic value is 19.8 ppb. The groundwater screening concentration is 0.216 ppb. These values represent upper bound estimates of the concentrations of the chemical s that might be found in surface water and groundwater due to the use of f luazinam on apples . EDWC s were calculated for t otal f luazinam residues because the environmental fate studies indicated that the parent compound forms transformation compounds which have similar s tructure to the parent under most conditions ( as per MARC request, DP Barcode D272624, W. Cutchin, 4/23/2001) . Should the results of this assessment indicate a need for further refinement, please, contact EFED as soon as possible so that the Division may schedule a Tier 2 assessment . Data Gaps: The environmental fate database is substantiall y complete. The following have been identified as data gaps: 835.6100: Terrestrial Field Dissipation . The registrant submitted two terrestrial field dissipation studies (MRID#s 45584207 and 455 84208). These studies are currentl y in review. And: 835.6100, 835.6200: Environmental Chemistry Methods (ECMs) and Independent Laboratory Validations (ILVs) for Soil, Water and Sediment . ECMs, along with successful confirmatory

method trials (validatio n) by an independent laboratory ( i.e. ILVs), are required. These ECMs should have limits of quantitation for the residues of concern that are lower than the relevant toxicological levels of concern. The latter risk assessments indicated concerns for organisms living in freshwater & estuarine/ marine bodies of water , and for estuarine/ marine organisms living in the benthos. Therefore, ECMs for water and sediment are required in addition to the ECM for soil. The registrant is encouraged to submit state - o f - the - art ECMs ; further, multi - residue methods (MRMs) for soil, water and sediment are preferred. EXECUTIVE SUMMARY Fluazinam ’s CAS Name is 3 - chloro -N - [3 - chloro - 2,6 - dinitro - 4 - (trifluoromethyl)phen yl ] - 5 - (trifluorometh yl ) - 2 - py

ridinamine, its IUPAC Name is 3 - chloro -N - (3 - chloro - 5 - trifluoromethyl - 2 - py

ridyl ) - α,α,α - trifluoro - 2,6 - dinitro - p - toluidine, its CAS Number is 79622 - 59 - 61 , and its PC Code is 129098 . Fluazinam is a p rotectant and contact fungicide . It is an uncoupler of oxidative phosphorilation in the respiration chain involving protonation/ deprotonation (it inhibits fungal respiration, and the production of energy within the fungus). Fluazinam is a phen ylpy ridinamine (dinitroaniline). The structure consists of one phenyl ring with two nitro groups, and a p yridine ring. Both rings have a trifluoromethyl group and are monochlorinated . The rings are attached b y an amine group .3 Fig. 1. Structure of Fluazinam The product containing fluazinam is Omega 500F Agricultural Fungicide (EPA Reg. No. 7151 2 - 1). It contains 40.0% fluazinam. It is currently used on potatoes , peanuts , edible podded legume vegetables (except peas), bushberry (crop subgroup 13B), brassica (cole) leafy vegetables, ginseng, and dry , and succulent bean crop Subgroup 6B (except pe as) . It is being proposed in a Section 3 (IR - 4) petition, for use on lettuce, apples, carrots and bulb vegetables ( Crop Subgroup 3 - 07A) . The application methods vary with the crops. For example, aerial applications are allowed onl y on potatoes , but the material may be applied by

sprinkler irrigation, or, for brassica leafy vegetables, it may

be applied by

soil incorporation prior to transplanting. This is a Tier I screening - level assessment using Tier 1 aquatic models SCI - GROW and FIRST for groundwate r and surface water, respectively . It was found that the worse case scenario was apples , with the highest seasonal application rate, and the highest PCA. In addition to the EDWC’s for f luazinam, EDWC’s were calculated for t otal f luazinam residues because the environmental fate studies indicated that the parent compound forms transformation compounds which are similar in structure to the parent under most conditions (for structures, refer to Table A - 1 of the Appendix ) . EFED observed that fluazinam does no t undergo degradation. Instead, it undergo es transformation into a series of products, all of which resemble the parent by way of their chemical structure. For the modeling, the EFED assumed that the ph ysicochemical characteristics were similar for both the parent and its products ( i.e. the total toxic residue approach). As indicated above, i t was assumed that for the total residues of fluazinam, the properties of fluazinam were applicable, and were similar for all the metabolites. For example, the solubility of fluazinam was assumed to appl y to the total residues as well. It was found that the solubility

of fluazinam depends on the pH. The solubility of the pH 11 solution was used in this assessment since it is the highest available value. Using this value resulted in an acute concentration that is higher than the solubility of fluazinam at pH 7. ( Mo st environmental conditions are close to neutral pH. ) This fact constitutes the source of highest uncertainty to the assessment, it appears that the inp ut value could have a large impact on the acute concentration . It was also assumed that the mobility of fluazinam was the same to the total residues ; this is supported by mobility data for two of the metabolites of fluazinam.4

This assessment was based on the maximum application rate for the crop (apples, 0.45 lb a.i./A) , the maximum seasonal rate (4.5 lb a.i./A/season) , the minimum interval between applications (7 day s), and the highest PCA ( 87%). T his is the most conservative assumption. The total resi dues approach is also conservative, with uncertainties due to unavailability

of detailed degradate information. At this time, the persistence of fluazinam transformation products is uncertain because the information about these compounds from terrestrial field dissipation studies has been deemed invalid. The aquatic metabolism studies signal high persistence of such degradates and i n the soil metabolism studies, generally the degradates were present in relativel y small amounts. To address this issue, two new terrestrial field dissipation studies have been submitted and are currently

in review. No readil y available monitoring data are available for fluazinam. It is likely that primary treatment may

reduce the levels of fluazinam due to its high level of binding and its tendency to hydrol yz e at higher pHs, but the level of reduction is unknown. Table 1 provides a summary of the Tier 1 modeled drinking water concentrations. S hould there be a need for additional refinements a more definitive assessment, us ing the Tier 2 aquatic models may be performed at the expenditure of additional resources . Table 1. Maximum Tier 1 Estimated Drinking Water Concentrations (EDWCs) for drinking water assessment based on ground application of fluazinam. DRINKING WATER SOU RCE (MODEL USED) USE (rate modeled) MAXIMUM ESTIMATED DRINKING WATER CONCENTRATION (EDWC) ( ppb) Groundwater (SCI - GROW) Fluazinam and Total Residues of Fluazinam (Including the Parent Compound) Apples (4.50 lb a.i./A /season ) Acute and Chronic 0. 216

S urface Water (FIRST) Fluazinam Apples (4.50 lb a.i./A /season ) Acute 110 1

Chronic 0.744 Surface Water (FIRST) T otal Residues of Fluazinam (Including the Parent Compound) Apples (4.50 lb a.i./A /season ) Acute 117 1

Chronic 19.8 1. This valu e exceeds the solubility of fluazinam at pH 7 (71 ppb), but is lower than the solubility at pH 11. PROBLEM FORMULATION This is a Tier I drinking water assessment that uses modeling and monitoring data, if available, to estimate the ground water and surface water concentrations of pesticides and transformation products in drinking water source water (pre - treatment) resulting from pesticide use on sites that are highl y vulnerable. This initial tier screens out chemicals with low potential risk and provides estimated exposure concentrations for the human health dietary

risk assessment.5

The last Tier 1 drinking water assessment was issued on 2/7/07 , using the FIRST and SCI - GROW models, with bushberries being the worst case scenario. T he current most conse rvative scenario was now found to be app les (seasonal application rate 4.50 lb a.i./A, divided into t en applications, and broadcast spray application method ). The present action triggers the need for a new drinking waters assessment because the uses have a higher seasonal rate of application. For fluazinam , the following drinking water hy pothesis is being employed for this assessment: Fluazinam use in accordance with the label, results in potential contamination of both, surface and ground water resources, with fluazinam and its relevant transformation products. The conceptual site model is a generic graphic depiction of the risk hy pothesis. Through a preliminary

iterative process of examining available data, the conceptual model ( i.e. , the drinking wate r h ypothesis) has been refined to reflect the likely exposure pathways that are most relevant and applicable to this assessment (refer to Fig. 2 ).

Fig. 2. Conceptual Model for Drinking W ater Assessment for Fluazinam Fluazinam is applied to the field via ground methods (for apples and other crops ) and ground and aerial methods (for potatoes onl y). Crop absorption may be important because fluazinam has a relativel y high tendency to bind , but crop uptake is not expected to be important ( for its relative ly high Kd and KOC values). In addition, spray drift is an important factor in the contamination of nearb y surface waters because fluazinam is applied via ground or aerial spray . As the field may be kept irrigated and the soils are wet, large runoff events , accompanied with erosion, may be a factor in horizontal6

movement due to the tendency of the chemical to remain bound to the soils (high tendency to partition with the soils). F luazinam shows low persistence in laboratory studies in aquatic media , but it s persistence is higher in soils. It may be available for moderate periods of time (on the order of several weeks to several months ) in soils ; fluazinam total residues are persistent in aquatic environments . Vertical movement to subsurfaces is not expecte d to be very important in the dissipation of fluazinam d espite its moderate persistence in aerobic environments due to its level of binding . Volatilization is expected to be a relatively minor route of dissipation for the active ingredient ( fluazinam has a relatively

small vapor pressure and Henry ’s Law Constant). The degradates observed in the laboratory studies included CAPA, G - 504, HYPA AMPA, MAPA, DAPA and DCPA , but not all of them are expected to be present in the aquatic environment . The major tran sformation products observed in the aquatic metabolism studies include DCPA, HYPA, CAPA, DAPA and AMPA . For structures of the various transformation products of fluazinam, refer to Table A - 1 of the Appendix . ANALYSIS Use Characterization A summary

tabl e of all use patterns, new uses and modeled uses, is provided in Table 2 . The crop groups shaded gray are the proposed ones; the bolded & underlined use is the modeled one (apples) . This information is based on the current and proposed label of Omega 500 F, EPA Reg. No. 71512 - 1. Table 2. U se information for fluazinam (based on Omega 500F label, EPA Reg. No. 71512 - 1).

USE SINGLE APP. RATE (lb. a.i./A) NUMBER

OF APPS. SEASONAL

APP. RATE (lb. a.i./A) INTERVAL

BETWEEN APP S . (days) APP . METHOD PHI (days) Lettuce (head and leaf) 1.00 1 1.00 N/A Ground: foliar band , broadcast spray or soil drench For h ead

lettuce 50; for leaf lettuce 30 Crop Subgroup 3 - 07A Bulb Vegetables ( includes bulb daylily, bulb fritillaria, bulb garlic, bulb great headed garlic, bulb serpent garlic, bulb lily, bulb o nion , bulb Chinese onion, pearl onion, bulb potato onion, bulb shallot, and cultivars, varieties, and/or hybrids of these) 0.52 6 3.13 7 - 10 Ground, through sprinkler irrigation 7

Carrots 0.52 4 2.09 7 Ground 7 Apples 0. 45 10 4.50 7 - 10 Broadcast spray 287

Table 2. U se information for fluazinam (based on Omega 500F label, EPA Reg. No. 71512 - 1).

USE SINGLE APP. RATE (lb. a.i./A) NUMBER

OF APPS. SEASONAL

APP. RATE (lb. a.i./A) INTERVAL

BETWEEN APP S . (days) APP . METHOD PHI (days) Peanut 0.52 - 1.04 2 2.09 21 Ground, Sprinkler irrigation Do not

apply w/in 30 d of threshing for harvest Potato 0.18 - 0.26 7 1.82 7 Aerial, Ground, Sprinkler irrigation 14 Succulent Bean Crop Subgroup 6B (such as, but not limited to lima bean and broad bean ) 0.26 - 0.44 2 0.91 7 Ground, Sprinkler irrigation 14 Ginseng 0.52 - 0.78 4 3.1 3 7 Ground 30 Crop Subgroup 6A, Edible - Podded Legume Vegetables except peas, such as, but not limited to: Phaseolus s

pp. Such as: runner bean, snap bean, wax bean; Vigna spp. Such as: asparagus bean, Chinese longbean, moth bean, yardlong bean; jackbean, and sword bean 0.26 - 0.44 2 0.91 7 Ground, Sprinkler irrigation 14

Dry Bean Crop Subgroup 6 C , except Peas and Soy beans (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 ) 0.26 - 0.44 2 0.91 7 Ground, Sprinkler irrigation 30

Crop Subgroup 13 - 07 B, Bushberry, 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, huc kleberry, jostaberry, juneberry, lingonberry, salal, and sea buckthorn 0.65 6 3.90 7 Ground 308

Table 2. U se information for fluazinam (based on Omega 500F label, EPA Reg. No. 71512 - 1).

USE SINGLE APP. RATE (lb. a.i./A) NUMBER

OF APPS. SEASONAL

APP. RATE (lb. a.i./A) INTERVAL

BETWEEN APP S . (days) APP . METHOD PHI (days) Crop Group 5, Brassica (Cole) Leafy Vegetables, such as, but not limited to: broccoli; broccoli raab (rapini); Chinese cabbage (napa); cauliflower; collards, ka le; mizuna; mustard spinach; turnip greens; Chinese broccoli; Brussels sprouts; Chinese cabbage (bok choy); Chinese mustard cabbage; cavalo broccoli; kohlrabi; mustard greens; rape greens [Transplant 6.45 fl oz/100 gal or presumably 0.64 lb a.i./A] Soil in corpo ration 1.36 at a soil depth of 6 - 8 in 1 2.00 N/A Soil drench after transplanting or soil incorporation (transplant the seedlings into the treated band 20;

50 for heading vegetables such as cabbage and broccoli

F luazinam may

be applied through sprinkler irrigation (through center pivot, motorized lateral move, traveling gun, solid set or portable 1 irrigation systems) ; however, it can also be soil incorporated before transplant, for Crop Group 5, b rassica ( c ole) l eafy v egetables, in soils with low infi ltration rates. The label requires a buffer zone of 25 ft within permanent bodies of water (lakes, reservoirs, rivers, permanent streams, marshes or natural ponds, and estuaries) so as to allow growth of a vegetative filter strip. The product should not be applied by aerial equipment within 150 ft of estuarine/ marine areas (aerial applications are currentl y allowed only for potatoes). The product does not require a similar buffer zone for aerial applications on freshwater bodies of water (for freshwater bodies of water, the 25 - ft buffer zone applies). The four newl y proposed uses are lettuce, bulb vegetables (Crop Subgroup 3 - 07A) , carrots and apples. Ground application methods are proposed for all those crops. The use pattern selected for modeling was apples . It is noted that the highest seasonal application rate is 4.50 lb a.i./A applies to apples; meanwhile, the individual single application rate is not the highest of all crops . The intervals between applications are 7 day s. Itis applied by broad cast spray , which may cause drift towards the index reservoir , it also has the highest PCA (default, 87%). With ten applications, at seven - day interval, it is likely that this scenario will provide the highest acute and chronic exposure. Fate and Transp ort Characterization A detailed summary

of phy sic oc hemical and environmental fate/transport properties of fluazinam , including measured parameters, values, data sources, and comments, is provided in Table 3 .

1 Wheel move, side roll, end tow, or hand move portable irrigation systems.9

Table 3 . Summary of Various Physicochemical and Environmental Fate Properties of Fluazinam

Parameter Value Reference/Comments * Selected Physicochemical Parameters Water Solubility (25 o C) 0.025 ppm at pH 5.5 ; 0.071 ppm at pH 7.0; and 350 ppm at pH 11.0 MRID 42208403 Vapor pressure 8.25x10 - 6 mm Hg MRID 42248403 Molecular Formula C 13 H 4 Cl 2 F 6N 4 O 4 Molecular Weight 465.1 g/mol CAS No. 79622 - 59 - 6 CAS name 3 - chloro -N - [3 - chloro - 2,6 - dinitro - 4 - (trifluoromethyl)phenyl] - 5 - (trifluoromethyl) - 2 - pyridinamine IUPAC name 3 - chloro -N - (3 - chloro - 5 - trifluoromethyl - 2 - py ridyl) - α,α,α - trifluoro - 2,6 - dinitro - p toluidine Henry’s Law Constant 6.73 x 10 - 7 atm- m3 /mol at pH 7 PMRA Reg. Note REG2003 - 12 Octanol/Water Partition & l og KOW 3620 & 3.56 (at 20°C ) MRID 42248403 Persistence: Fluazinam Fluaz.+Degradates Hydrolysis t 1/2 pH 5

pH 7 pH 9 stable

42 days 6 days stable

stable stable MRID 42208412 (a) Photolysis t 1/2 in water 2.5 days, dark control ≈stable one degradate (G 504) MRID 44807312, 43521009, 45584204

( a) on soil 35.0 days, value

corrected for dark control degradates at

≤10% of the applied MRID 44807313, 45584204 (a) Soil metabolism Aerobic t 1/2 114 - 132 days for samples treated at 1 kg/ha (5.56 ppm) degradates at

≤10% of the app.; HYPA was 11.4% at 30 days (for soil treated at 5 kg/ha) MRID 42208413, 42208414 (a)

Soil metabolism Anaerobic t 1/2 SL flooded at time 0 days

– half

- life 4 days; SL flooded at 30 days

– half

- life 32 days HYPA was 11.0%

at 60 days for the spl. flooded at 30 days. MAPA was up to 29.8% for the sample flooded at time 0. MRID 42208413, 42208414 (s)

Aquatic metabolism Aerobic DT 50 4.0 - 7.4 hours 51 - 71 days MRID 44807314 (a) Aquatic metabolism Anaerobic t 1/2 ≈ 1⁄3 day (or approximately 8 hours) stable MRID 43521010 (a)10

Table 3 . Summary of Various Physicochemical and Environmental Fate Properties of Fluazinam

Parameter Value Reference/Comments * Mobility/Adsorption -

Desorption Batch Equilibrium - Unaged Aged Soil Column Leaching 4 soils KF =11 - 44 KFOC =1700 - 2300 KF, des =34 - 507 KFOC, des =7000 - 19900

- - - - - - 0.66% in leachate MRID 42248628, 4297491 3 (a) MRID 42208415 (a) Batch Equilibrium HYPA Batch Equilibrium CAPA 6 soils Kd=6.6 - 51 KOC =640 - 3200 KF =4.3 - 26 KFOC =450 - 1700 Increasing adsorption w. increasing pH

- - - - - - - 4 soils KF =4.9 - 67 KFOC =1289 - 3784 Studies on HYPA and CAPA were conducted w. sterile soils. MRID 43528201 (a) MRID 44807315 (s) Field Dissipation Terrestrial Dissipation

t 1/2 in soil surface layer Range from 9 to 49 days: Ephrata, WA: DT50~9 days loamy sand, pinto beans; Kempton, ND: half - life=49 days, sandy loam, beans; Porterville, CA: half - life=20 days, loamy sand, beans; Montezuma, GA The degradation was biphasic. MRID 44807318, 44807320, 44807316 (s)

Bioaccumulation Accumulation in Fish, max. BCF 273 - 348 X for fillet portion 960 - 1220 X for whole fish 1410 - 1850 X for non - edible

~ 67% of the residues eliminated from the fillet during the 21 - day depuration phase MRID 43521012 (a)

(a) = acceptable or core study that fulfills guideline requirement; (s) = supplemental study; (u) = unacceptable st udy . Where two values are stated, they may correspond to two radiolabel positions. Fluazinam appears to degrade at moderate rates in aerobic soils (132 day s), but it is more rapidly transformed into other compounds of similar backbone structure in high p H solutions (6 day s at pH 9) or in aerobic ( ≤7.4 hr) or anaerobic aquatic (~8 hr) media. The transformation products of fluazinam appear to be relativel y persistent under most condit ions. Fluazinam may photol ys e relativel y rapidly in water (2.5 day s) to form a tricyclic compound (G - 504). The total fluazinam residues (fluazinam and its transformation products) are persistent in most environments (stable to hydroly sis at all pHs, aerobic aquatic metabolism 51 - 71 day s, relatively stable in anaerobic aquatic environment) and are likely to reach aquatic media as a totality through runoff. Since fluazinam does not alter substantially its backbone structure in the environment, but instead, goes through slight transformations of functional groups, EFED considers parent and transformation products together when making assessments. Based on the properties of the chemical, applications of fluazinam are likely to reach the target (the crop), but drift is also possible. The total residues of fluazinam may reach adja cent bodies of water via runoff events and may be persistent. The chemical has a low vapor pressure ( 8.25x10 - 6 mm Hg) , and a relativel y low Henry ’s Law constant ( 6.73 x 10 - 7 atm - m 3 /mol) .11

Due to the fact that it appears to show short half lives in aquatic media, and it binds to soils, EFED believes that the chemical would not volatilize substantially . While the parent and two transformation products, HYPA and CAPA, have relativel y low mobility , indicating low potential for ground water contamination, there is uncertainty about the other transformation products and further information on them was required in a new t errestrial f

ield dissipation study . Two such studies (MRID#’s 45584207 & 45584208) are currentl y in review. Hydrolysis The hydroly sis of fluazinam is pH dependent. It was relativel y stable at pH 5, and hydrol yz ed with half

- lives of 42 and 6 day s at pH s of 7 and 9, respectivel y. The major degradate was CAPA. Photolysis Fluazinam photoly ses in aqueous solutions , mainly to G - 504, a tricyclic compound , and possibly one or more other unidentified products ) . The half - life obtained in the study was 2.5 day s. The soil photoly sis, on the other hand, the half - life was 22 day s (compared to 69 day s for the dark control). The dark control corrected half - life is 35 day s. Metabolism The metabolism of fluazinam appears to be moderate in a sandy loam soil treated at 1 kg/ha (5.56 ppm) (DT 50 ≤ 30 day s). The calculated half - li fe (linear regression, assuming first order kinetics) was about 114 - 132 days, which is in agreement with the fact that after 361 day s, 6.8 and 9.5% of the applied fluazinam remained intact for the 14 C - p yridyland 14 C - p henyl labels, respectively . N o major metabolites were observed. The sandy loam treated at 5 kg/ha yi elded a half - life of 227 day s . For the samples treated at the high rate, Compound XII (HYPA) was observed at up to 11.4% at 30 day s posttreatment. A loamy sand treated at 1 kg/ha yi elded a h alf - life of 165 day s with no major metabolites. No major degradation products were observed in the samples treated at 1 kg/ha, but a major fraction (~41%) was bound material at the end of the study (day 361). Sediment/Water Systems The aerobic aquatic and the anaerobic aquatic metabolism studies resulted in very short half - lives ( 4

– 8 hours). In such studies, various metabolites were formed. All the major transformation products observed have structures that resemble the structure of the parent. The sum of the concentration of the parent , plus the concentrations of the transformation products (total fluazinam residues) , decrease d very slowl y under both aerobic (half

- lives 51 - 71 day s) and anaerobic (relatively sta ble) aquatic conditions. The major transformation products observed in these studies include DAPA, SDS - 67200, AMPA, DCPA, and CAPA. Mobility In batch equilibrium studies, fluazinam is slightly mobile in four soils tested. KFOC v alues ranged from 1705 - 2316. Similarly , an available soil column leaching study of aged fluazinam indicated low mobility of the residues of fluazinam. Less than 1% of the applied radiocarbon was found in the leachates and >>80% remained at the top of the soil12

columns. There is mobility information for two of the transformation products of fluazinam: HYPA and CAPA. Of them, HYPA appeared to be moderatel y to slightly mobile (K

FOC =450 - 1700, 6 soils), and CAPA appeared to be slightly mobile, but generall y l ess mobile than the parent (KFOC =1289 - 3784, 4 soils). The latter two batch/equilibrium studies were conducted on sterile soils. Field Dissipation Four terrestrial field dissipation studies were submitted by the registrant. Such studies were found to provide only limited supplemental information. In particular, the data about the degradates is very questionable due to poor recoveries in a storage stability study . In general, it appeared that parent fluazinam degraded mo deratel y rapidly in studies conducted in Ephrata, WA , Kempton, ND , Porterville, C A , and Monctezuma, GA . The dissipation half - lives ranged from 9 to 49 day s. These half - lives are in agreement with the aerobic soil metabolism half - lives. At this time, the EFED has two newly submitted terrestrial field dissipation studies, which are in review. Bioaccumulation Fluazinam demonstrated some potential to bioaccumulate in fish. The maximum BCF’s were 348X for fillet, 1220 for whole fish, and 1850 for viscera, all of which were obtained with the phenyllabel ed material. Fish residues identified included the parent compound, AMPA, MAPA and DAPA. Depuration was moderately slow. More than 67% of the residues were eliminated from the fillet during the 21 - day depuration phase. The fate and transport characterization also includes the various degradation and transformation products formed by each process in the studies reviewed. This is of particular importance for fluazinam, which forms metabolites of similar structure than the parent compound. Table 4 provides a summary of these transformation products. Table 4. Summary of degradate formation from degradation of fluazinam.

STUDY TYPE DEGRADATE and MAXIMUM CONCENTRATION SOURCE CAPA, G - 504, HYPA AMPA, MAPA, DAPA, DCPA (% applied) Hydrolysis CAPA 34% at 28 days pH 7; 84 - 85% at 20 days at pH 9 – – MRID: 4 2208412 . Aqueous Photolysis G - 504 was 14.0 - 17.1% by 7 - 10 days _ – MRID: 4 44807312, 43521009, 45584204 . Soil Photolysis HYPA, detected > dark control AMPA detected >

dark control – MRID: 4 4807313, 45584204 . Aerobic Soil Metabolism HYPA, MAPA and DAPA detected (in the SL s oils, applied at 1 kg/ha) MRID: 4 2208413, 42208414 . Anaerobic Soil Metabolism HYPA was 11.0% at 60 days for the SL flooded at 30 days MAPA was 29.8% at

14 days for the SL flooded at zero time – MRID: 4 2208413, 42208414 . Aerobic Aquatic Metabolism CAPA 12.6 % at 72 hr DAPA: 19.0% by 240 hr DCPA: 11.3% at 24 hr MRID: 4 4807314 .13

Table 4. Summary of degradate formation from degradation of fluazinam.

STUDY TYPE DEGRADATE and MAXIMUM CONCENTRATION SOURCE CAPA, G - 504, HYPA AMPA, MAPA, DAPA, DCPA (% applied) Anaerobic Aquatic Metabo lism AMPA 24.2% at 0.2 day DAPA: 32.7% at day 30 SDS - 67200 39.6% by

day 14 MRID: 4 3521010 . Terrestrial Field Dissipation MAPA, CAPA, and HYPA were monitored; however, there were problems with the storage stability data for the degradates. MRID: 44807318, 44807320, 44807316, 44807319, 44807317 . Drinking Water Exposure Modeling Models A b rief description of the models used follows. SCI - GROW (v 2.3, 8/5/03) (Screening Concentration in Ground Water) is a regression model used as a sc reening tool to estimate pesticide concentrations found in ground water used as drinking water. SCI - GROW was developed by fitting a linear model to groundwater concentrations with the Relative Index of L eaching Potential (RILP) as the independent variable . Groundwater concentrations were taken from 90 - day average high concentrations from Prospective Ground Water studies; the RILP is a function of aerobic soil metabolism and the soil - water partition coefficient. The output of SCI - GROW represents the conce ntrations that might be expected in shallow unconfined aquifers under sandy soils, which is representative of the ground water most vulnerable to pesticide contamination likely to serve as a drinking water source. ( Ref. 1 & 2 ) FIRST (v 1.1 .1, 3/26 /08) (F QPA Index Reservoir Screening Tool) is a metamodel of PRZM and EXAMS used as a screening tool to estimate pesticide concentrations found in surface water used as drinking water. FIRST was developed b y making multiple runs of PRZM using varying sorption co efficients and determining the concentration in the EXAMS index reservoir scenario after a two - inch single storm event. (The Index Reservoir is a standard water body used b y the Office of Pesticide Programs to assess drinking water exposure (Office of Pes ticide Programs, 2002). It is based on a real reservoir (albeit not currently in active use as a drinking water suppl y), Shipman City Lake in Illinois, that is known to be vulnerable to pesticide contamination.) The single runoff event moves a maximum of 8% of the applied pesticide into the reservoir. This amount can be reduced by degradation or effects of binding to soil in the field. Additionally , FIRST can account for spray drift and adjusts for the area within a watershed that is planted with the mo deled crop (Percent Cropped Area). Spray drift (modeled as direct deposition of the pesticide into the reservoir) is assumed to be 16% of the applied active ingredient for aerial application, 6.3% for orchard air blast application, and 6.4% for other gro und spray application. Despite being a single event model, FIRST can account for spray

drift from multiple applications. The default agricultural Percent Cropped Area (PCA) is 87%. The PRZM scenario used for FIRST development was among the most vulnerabl e, and thus resulting surface water concentrations represent the14

upper bound values on the concentrations that might be found in drinking water from the use of a pesticide. (

Ref. 1, 3 & 4) For volatile and semi - volatile compounds, Tier I modeling will ten d to over - estimate surface water EDWCs because there are no parameters in FIRST that explicitly take into account volatility

(ie., no vapor pressure or Henry’s Law constant inputs). Therefore, in reality , more of the compound will be volatilizing than Tie r I can account for. If drinking water levels of concern are exceeded for over - estimated Tier I surface water EDWCs, Tier II modeling will be able to refine these EDWCs by including volatility, Henry ’s Law, diffusion in air, and enthalpy considerations. Since SCI - GROW is a regression model developed from actual pesticide data with a range of volatilities, systematic conclusions cannot be drawn about over or underestimation of groundwater EDWCs at Tier I. Modeling Approach and Input Parameters Tables of modeling parameter input values for SCI - GROW and FIRST ( Tables 5 & 6 , respectivel y) are based on the current input parameter guidance ( Ref. 5 ) . In addition to the EDWC’s for f luazinam, EDWC’s were estimated for the total fluazinam residues , because the environmental fate studies indicated that the parent compound forms transformation compounds which are similar in structure to the parent under most conditions. The input parameters were selected according to the similarity observed in the mobility

characte ristics of fluazinam, HYPA, and CAPA. It was observed that the KOC model was better to describe the mobility of fluazinam. For SCI - GROW, the median value was used, while, for FIRST, the lowest non - sand value was selected. Onl y one value of aerobic soi l metabolism was available (it was used in SCI - GROW, and three times the value was used in FIRST. Two values of aerobic aquatic metabolism were available. For FIRST, the 90 th percentile of the upper confidence bound on the mean was calculated. It is not ed that the input value for the aerobic aquatic metabolism of the parent is onl y 0.454 day s ( 10.9 hours ) , while for the total residues, it is 91.8 day s . A ground application method was selected (with 6.4% drift). The m aximum available solubility value, at 20 - 25oC was used in modeling, as per current guidelines. This solubility applies to a pH 11. It is noted that the solubility of fluazinam is pH dependent. For the total residues, the half - life was calculated taking into consideration the transform ation products plus fluazinam. This applied to the aerobic aquatic metabolism ( as indicated earlier, 91.8 day s for total residues vs. 0.454 day s for fluazinam), and the hydrol ys is (relativel y stable for total residues vs. 42 day s for the parent). For the hydrol ys is study , the transformation product that is formed is CAPA. In the aerobic aquatic metabolism study, the transformation products formed are DCPA, CAPA, and DAPA, plus various minor transformation products. For other parameters, in the absence of a suitable value, it was assumed that the value for fluazinam was similar to that for the total residues because they had similar structures ( e.g. for the solubility) .15

Table 5. SCI - GROW (v 2.3) input parameter values for fluazinam and total residues of f luazinam, use on apples 1 . PARAMETER (units) FLUAZINAM TOTAL RESIDUES SOURCES AND COMMENTS Maximum Application Rate (lb a.i./A) 0.4 5 Proposed label. Number of Applications per Year 10 Proposed label. Represents most - conservative scenario in which the total maximum rate is applied in six applications. Organic Carbon Partition Coefficient (Koc ; mL /g) 1904.5 Represents the median value of four values ranging from 1705 to 2316 mL/g for the parent

compound. Aerobic Soil Metabolism Half - life (days) 132 Represents one value for the aerobic soil metabolism of the parent compound. 1 Parameters are selected as per Guidance for Selecting Input Parameters in Modeling the Environmental Fate and Transport of Pesticides; Version II, February 28, 2002. Table 6. FI RST (v 1.1. 1 ) input parameter values for fluazinam and total residues of fluazinam, use on apples 1 . PARAMETER (units) FLUAZINAM TOTAL RESIDUES SOURCES AND COMMENTS Application Rate (lb a.i./A) 0.4 5 0.4 5 Proposed label. Number of Applications 10 10 Propo sed label. Interval between Applications (days) 7 7 Proposed label. Percent Cropped Area (decimal) 0.87 0.87 National default. Soil Partition Coefficient (K d ; (mL/g) or K OC (mL /g OC )) 1894 1894 Represents the lowest non - sand K OC value among four values ranging from 1705 to 2316 mL/g. The K OC model is better for this chemical. Aerobic Soil Metabolism Half - life (days) 396 396 Determined by multiplying the calculated half - life (132 days) by 3 to account for the uncertainty associated with using a single v alue. Wetted in? No No Proposed label. Depth of I

ncorporation (inches) 0 .0 0 .0 Proposed label. Method of Application Gr ound application Gr ound

application Proposed label. Solubility in Water at pH 11 (mg/L or ppm) 350 350 Maximum available value, at 20 - 25oC . Aerobic Aquatic Metabolism Half - life (days) 0.454 91.8 Represents the 90 th percentile of the upper confidence bound on the mean of two half - life values (4.0 hr and 7.4 hr: mean 5.7 hr, std. dev. 2.40 hr, the value is 10.9 hr or 0.454 days). For t otal residues two half

- lives (51 and 71 days: mean 61 days, std. dev. 14.14 days)16

Table 6. FI RST (v 1.1. 1 ) input parameter values for fluazinam and total residues of fluazinam, use on apples 1 . PARAMETER (units) FLUAZINAM TOTAL RESIDUES SOURCES AND COMMENTS Hydrolysis Half

- life @ pH 7 (days) 42 Stable The transformation product CAPA reaches a maximum at the end of the study at pH 7. Aquatic Photolysis Half

- life @ pH 7 (days) 2.5 2.5 From aqueous photolysis study 1 Parameters are selected as per Guidance for Selecting Input Parameters in Modeling the Environmental Fate and Transport of Pesticides; Version II, February 28, 2002 . The Percent Cropped Area (PCA) used was the National Default of 0.87 ; it is intended for use on crops for which no PCA has been developed. Options for Tier I on a national scale are cotton, wheat, corn, soy beans, or default . R egional PCAs are a Tier II tool intended for refined assessment. ( Ref. 6 ) Modeling Results Table 7 summarizes the modeling results for all model runs. Table 7. Maximum Tier I Estimated Drinking Water Concentrations (EDWCs) for drinking water risk assessment based on ground application of fluazinam. DRINKING WATER SOURCE (MOD EL USED) USE (rate modeled) MAXIMUM ESTIMATED DRINKING WATER CONCENTRATION (EDWC) ( ppb) Groundwater (SCI - GROW) Fluazinam and/or Total Residues of Fluazinam Apples (4.50 lb a.i./A /season ) Acute and Chronic 0.216

Surface Water (FIRST) Fluazinam Apples (4.50 lb a.i./A /season ) Acute 110

Chronic 0.744 Surface Water (FIRST) Total Residues of Fluazinam Apples (4.50 lb a.i./A /season ) Acute 117

Chronic 19.8 The SCI - GROW concentration (ppb) represents the groundwater concentration that might be expected in shallow unconfined aquifers under sandy soils. The o utput is used for both acute and chronic endpoints. The FIRST concentrations (ppb) represent untreated surface water concentrations. The one - in - 10 - ye ar peak day

concentration is used f

or acute endpoints and the one - in - 10 - ye ar annual average concentration is used for chronic endpoints.17

The estimated concentrations provided in this assessment are conservative estimates of concentrations in drinking water. If dietary risks require refin ement, higher tiered crop specific and location - specific models and modeling scenarios can be used. Monitoring Data No readil y available monitoring data are available for fluazinam. In general, monitoring data provide different kinds of information than modeling estimates. For example, monitoring data consist of actual information from the field, reflecting current use pattern and usually

underestimating frequency of occurrence. Monitoring data does not alway s include peak values, and inputs for monitoring cannot be adjusted as modeled ones can. In addition, monitoring is often conducted for purposes other than characterizing exposure from a particular pesticide, and as a consequence is used to complement modeling rather than to refine it. In general, a useful interpretation of monitoring values requires in - depth assessment of the data, which is beyond the scope of a Tier I assessment. Drinking Water Treatment It is likel y that primary treatment may reduce the levels of fluazinam due to its tendency to bind. However, there is no information available at this time to determine the levels of reduction. F luazinam is very short lived in aquatic environments, forming various other transformation products , which are more persistent . S oftening of drinking w ater will generall y result in an increase in pH. Fluazinam is more susceptible to h ydrol ys is under alkaline conditions; therefore, softening may result in increased dissipation from hydrol ys is. (

Ref. 9 ) CONCLUSIONS This is a Tier I level drinking water s analy sis, refinements may be available should they be needed. In addition to the EDWCs for fluazinam, EDWCs were estimated for total f luazinam residues because the environmental fate studies indicated that the parent compound forms transformation compounds which are structurall y very similar to the parent under most conditions (for structures, refer to Table A - 1 of the Appendix ). EFED observed that fluazinam was not undergoing degradation. Instead, it was undergoing transformation into a series of prod ucts, all of which resemble d the parent in their chemical structure and were more persistent (this is particularl y true for the aquatic metabolism studies) . For the modeling, the EFED assumed that the ph ys icochemical characteristics were similar for both the products and the parent. This is named total toxic residue approach , which was taken as opposed to the approach that follows the formation/ decline of the residues or the approach that assumes an equivalent application rate for each metabolite. The two latter approaches require more data than are currentl y available. Exposure to fluazinam and its residues are possible due to spray drift or runoff. Both the aerobic and anaerobic aquatic metabolism studies show half - lives of ≤8 hours for fluazinam, wi th the formation of various metabolites which are much more persistent in such media . In soils, fluazinam is more persistent than in aquatic s ys tems (132 day s) . Therefore, exposure to the parent is more likel y in soils. In aquatic environments, it18

appears that the major exposure will be to the metabolites. The acute levels of fluazinam in surface drinking waters was 110 ppb, while the chronic level was 0.7 44 ppb. The groundwater concentration of fluazinam, suitable for acute and chronic exposure is 0. 2 16 p pb. For the total toxic residues, the acute levels of surface drinking waters was 117 ppb, the chronic level was 1 9.8 ppb ( of total residues ) . The groundwater concentration of total toxic residues of fluazinam, suitable for acute and chronic exposure is 0. 216 pp b. It was assumed that for the total residues, the properties of fluazinam were applicable , and were similar for all the metabolites . F or example, the solubility of fluazinam was assumed to apply

to the total residues as well . Itwas found that the solubility of fluazinam depends on the pH. It is higher when the pH is higher ( 0.0 25 pp m at pH 5.5, 0.0 71 pp m at pH 7.0, and 350 pp m at pH 11.0 ) . The solubility of the pH 11 solution was used in this assessment since it is the highest available v alue at 20 - 25oC, as per current guidelines. Us e of this value resulted in an acute concentration that is higher than the solubility of fluazinam at pH 7. It is noted that most environmental conditions are close to neutral pH . This fact brings uncertainty to the assessment and, since the acute value was greater than the solubility of the compound, it appears that the input value could have a high impact on the results (particularl y on the acute value) . Another example of the assumption that the propertie s of fluazinam apply to the total residues is the mobility . The mobility may be slightly

different for each transformation product . It was found that the KOC model was more suitable to describe the mobility of fluazinam than the Kd model. The batch equi librium studies performed on the degradates HYPA and CAPA show that the mobility of such metabolites is similar to that of the parent (for the parent, KFOC =1700 - 2300 ; for HYPA, KFOC =450 - 1700 ; and for CAPA, KFOC =1289 - 3784 , refer to Table 3 ). Nonetheless , the studies conducted on HYPA and CAPA were conducted on sterile soils. The aerobic soil metabolism input value for the FIRST model was determined by multiplying the available half - life (132 day s) b y 3 to account for the uncertainty associated with using a single value. This is considered a conservative assumption for the model. This assessment was based on the maximum application rate for the crop (apples, 0.45 lb a.i./A) , with the maximum seasonal rate (4.5 lb a.i./A/season) , with the minimum interval b etween applications (7 day s) , and the highest PCA (0.87 or 87%) . For apples, the maximum application rate of 0.45 lb a.i./A is recommended for certain species ( Bitter rot, Black rot, Brooks spot, Cedar apple rust, A lternaria blotch, White rot, Quince rust , Two spotted spider mite, European red mite and Apple rust mite ) . Meanwhile, f or Apple Scab, Fl ys peck and Sooty blotch, the recommended application rate range is 0.33 to 0.45 lb a.i./A and the interval between applications is 7 to 10 day s. The proposed label indicates that “the high rate and shortest intervals should be used for more susceptible varieties and heav y disease pressure.” T he maximum application rate and the crop19

scenario (apples) may

not be representative for all the crops registered or pro posed on a national scale basis . It is uncertain whether apples will represent a major use for fluazinam. However, this use is the most conservative assumption. The total residues approach is conservative , with uncertainties due to unavailability of det ailed degradate information. A more definitive assessment, using the Tier 2 aquatic models may

be performed at the expenditure of additional resources, and given the availability

of additional data . The assessment could involve input from additional studies (not available at this time , e.g. the detailed formation and decline data for the metabolites ) and refine the PCAs ( e.g. , by using regional PCAs ) . Also, typical application rates may

be used , when and if available . No readil y available monitoring dat a are available for fluazinam. It is likely that primary treatment may

reduce the levels of fluazinam due to its tendency to bind and its highest susceptibility

to hydrol ys is under alkaline conditions . However, there is no information available at this time to determine the levels of reduction. F urthermore, f luazinam is very short lived in aquatic environments, but it forms various other transformation products, which are more persistent in the media . *************************************************** ************** References: 1. Policy Establishing Current Versions of Exposure Models and Responsibility for Model Maintenance (11/06/2002) 2. SCI GROW: Users Manual (11/01/2001, revised 08/23/2002) 3. FIRST Users Manual (08/01/2001) 4. FIRST: A Screening Model to Esti mate Pesticide Concentrations in Drinking Water (05/01/2001) 5. Guidance for Selecting Input Parameters in Modeling the Environmental Fate and Transport of Pesticides, Version II (02/28/2002) 6. Use of the Index Reservoir and Percent Crop Area in EFED Drinking Water Assessments (12/01/1999) 7. Golf Course Adjustment Factors for Simulated Aquatic Exposure Concentrations (06/01/2005) 8. Policy for Estimating Aqueous Concentrations from Pesticides L abeled for Use on Rice (10/29 /2002) 9. The Incorporation of Water Treatment Effects on Pesticide Removal and Transformations in Food Quality Protection Act (FQPA) Drinking Water Assessments (10/25/2001) *****************************************************************20

APPENDIX Table A - 1. Fluazinam and Various Transformation Products Common Name Chemical Name Structure Fluazinam CAS Name: 3 - chloro -N - [3 - chloro 2,6 - dinitro - 4 - (trifluoromethyl) phenyl] - 5 - (trifluo - romethyl) - 2 - pyridinamine; IUPAC Name: 3 - chloro -N - (3 - chloro - 5 - trifluoromethyl - 2 - pyridyl) - α,α,α - trifluoro - 2,6 - dinitro p - toluidine CAPA 3 - chloro - 6 - (3 - chloro - 2,6 - dinitro - 4 -

trifluoromethyl anilino)nicotinic acid; 5 - chloro - 6 - (3 - chloro - α,α,α trifluoro - 2,6 - dinitro - p toluidino)nicotinic acid N H N

O 2 N O 2 N

Cl CF 3 Cl

HOOC DAPA 3 - chloro -N 4

- (3 - chloro - 5 -

trifluoromethyl - 2 - py

ridyl) - α,α,α trifluorotoluene - 3,5,5 - triamine; 3 - chloro - 2(2,6 - diamino - 3 - chloro α,α,α - trifluoro - p - toluidino) - 5 - (trifluoromethyl) pyridine N H N H 2 N

CF 3 Cl H 2 N Cl

F 3 C

DAPA AMPA 2 - (6 - amino - 3 - chloro - α,α,α - trifluoro 2 - nitro - p - toluidino) - 3 - chloro - 5 - (trifluoromethyl)pyridine N H N

O 2 N H 2 N

Cl CF 3 Cl

F 3 C DCPA 6 - (4 - carboxy - 3 - chloro - 2,6 -

dinitroanilino) - 5 - chloronicotinic acid N H N O 2 N

COOH Cl O 2 N Cl

HOOC

DCPA21

Table A - 1. Fluazinam and Various Transformation Products Common Name Chemical Name Structure MAPA 3 - chloro -N 4

- (3 - chloro - 5 -

trifluoromethyl - 2 - py

ridyl) - 5 - nitro α,α,α - trifluoro - toluene - 3,4 - diamine N H N

H 2 N O 2 N

Cl CF 3 Cl

F 3 C HYPA, Compound XII 5 - [[3 - chloro - 5 - (trifluoromethyl - 2 -

pyridyl]amino] - α,α,α - trifluoro - 4 ,6 - dinitro - o - cresol N H N O 2 N

CF 3 HO O 2 N Cl

F 3 C G- 504 4,9 - dichloro - 6 - nitro - 8 -

(trifluoromethyl)pyrido - [1,2 - α] - benzimidazole - 2 - carboxylic acid N N O 2 N

CF 3 Cl Cl

HOOC22

SCIGROW and FIRST model output files : SCIGROW VERSION 2.3 ENVIRONMEN TAL FATE AND EFFECTS DIVISION OFFICE OF PESTICIDE PROGRAMS U.S. ENVIRONMENTAL PROTECTION AGENCY

SCREENING MODEL FOR AQUATIC PESTICIDE EXPOSURE SciGrow version 2.3 chemical:Fluazinam time is 11/ 4/2009 12:10:11

------------------------------------------------------------------------ Application Number of Total Use Koc Soil Aerobic rate (lb/acre) applications (lb/acre/yr) (ml/g) metabolism (days)

------- ----------------------------------------------------------------- 0.450 10.0 4.500 1.90E+03 132.0

------------------------------------------------------------------------ groundwater screening cond (ppb) = 2.16E - 01 ************************************************************************

RUN No. 1 FOR Fluazinam ON Apples * INPUT VALUES *

-------------------------------------------------------------------- RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE %CROPPED INCORP ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) AREA (IN)

-------------------------------------------------------------------- 0.450( 4.261) 10 7 1894.0 350.0 GROUND( 6.4) 87.0 0.0 FIELD AND RESERVOIR HAL FLIFE VALUES (DAYS)

-------------------------------------------------------------------- METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAIN/RUNOFF (RESERVOIR) (RES. - EFF) (RESER.) (RESER.)

------------------------------ -------------------------------------- 396.00 2 0.00 2.50 - 310.00 0.45 0.45 UNTREATED WATER CONC (MICROGRAMS/LITER (PPB)) Ver 1.1.1 MAR 26, 2008

-------------------------------------------------------------------- PEAK DAY (ACUTE) ANNUAL AVERAGE (CHRONIC) CONCENTRATION CONCENTRATION

-------------------------------------------------------------------- 110.468 0.74423

RUN No. 2 FOR Total Res ON Apples * INPUT VALUES *

-------------------------------------------------------------------- RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE %CROPPED INCORP ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) AREA (IN)

----------------------------------------------------- --------------- 0.450( 4.261) 10 7 1894.0 350.0 GROUND( 6.4) 87.0 0.0 FIELD AND RESERVOIR HALFLIFE VALUES (DAYS)

-------------------------------------------------------------------- METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAIN/RUNOFF (RESERVOIR) (RES. - EFF) (RESER.) (RESER.)

-------------------------------------------------------------------- 396.00 2 N/A 2.50 - 310.00 91.80 70.83 UNTREATED WATER CONC (MICROGRAMS/LITER ( PPB)) Ver 1.1.1 MAR 26, 2008

-------------------------------------------------------------------- PEAK DAY (ACUTE) ANNUAL AVERAGE (CHRONIC) CONCENTRATION CONCENTRATION

-------------------------------------------------------------------- 116.750 19.777