NH N + N H 2

- O O 

# Level I Screening Ecological Risk Assessment for the Reregistration of Dodine

Dodine (dodecylguanidine monoacetate) CAS No. 2439-10-3

Prepared by: Christopher J. Salice, Biologist Marietta Echeverria, Environmental Scientist U. S. Environmental Protection Agency Office of Pesticide Programs Environmental Fate and Effects Division Environmental Risk Branch IV

1200 Pennsylvania Ave., NW Mail Code 7507C Washington, DC 20460 Reviewed by: Elizabeth Behl, Branch Chief Ed Fite, Senior Biologist Kevin Costello, RAPLPage 2 of 219 1 EXECUTIVE SUMMARY
1.1 Nature of Chemical Stressor Dodine (n-dodecylguanidine monoacetate; CAS 2439- 10-3) is a fungicide of the guanidine group of chemicals. Dodine is classified as a general toxophore with several sites of action; it has been shown to disrupt the cytoplasmic membrane of some plant pathoge ns. Dodine is registered for control of a range of pathogenic fungi that affect a number of agricultura l and some ornamental crops. Current formulations for dodine include liquid flowable concentrate and we ttable powder. Based on current label information, dodine is applied via ground spray, airblast or aeria l application to apples, cherries, peaches, pears, pecans, strawberries, and black walnut; crab apple and ornamental shade trees (SLN OR). There are no expected major environmental degradates (other than CO 2 ) of dodine.
This assessment utilizes environmental fate and toxic ity data for both dodine and DGH (dodecylguanidine hydrochloride) because these compounds behave the same under environmental conditions. Dodine and DGH are water soluble salts of a strong base, dodecyl guanidine, and are expected to dissociate to the same degree under any normal environmental cond itions. As strong bases, these compounds will be completely dissociated in aqueous solutions at normal environmental pHs. At the low concentrations present in the environment, and in the presence of moisture, both compounds would be present as the dodecylguanidinium ion and either the acetate or chlori de ion. DGH is an antimicrobial pesticide that is used as a sanitizer, bacteriostat, microbiocide, microbistat, fungicide, algicide, and molluscicide. Currently, a quantitative evaluation of the likeli hood of the ecological exposures resulting from the industrial uses of DGH overlapping spatially and te mporally with the exposures resulting from the agricultural uses of dodine is not possible. Therefor e, the ecological risks are not aggregated in this assessment. 1.2 Potential Risks to Non-target Organisms This is a national screening-level ecological risk assessment for all labeled uses of dodine. The aquatic assessment involved Tier II modeling (PRZM/EXAMS) for scenarios representing all proposed dodine uses. Monitoring data were not considered because national-scale monitoring studies were not identified. Tables 1.1 and 1.2 summarize the major conclusions and uncer tainties of this assessment for aquatic and terrestrial receptors, respectively. The results of this screening-level risk assessment suggest the potential for direct adverse acute effects to non-target aquatic freshwater invertebrates, non-vascular aquatic plants, saltwater invertebrates and mollusc based on modeled national aerial application rates (7.8 to 13.0 lb ai/A/yr) of dodine except strawberries and in some cases p ears, and walnuts. The results also suggest the potential for direct adverse acute effects to non-target terrestrial birds and mammals and chronic effects to birds and mammals, based on modeled aerial application rates of dodine (2.0 to 13.0 lb ai/A/yr). Simulations indicate that to reduce risk below the ch ronic risk levels of concern for birds and mammals, the application rate for a single application would have to be 0.825 lbs a.i./A and 0.29 lbs a.i./A for birds and mammals, respectively. Also, based on modeled aerial applications to apples (Pennsylvania; 11.7 lbs. a.i./A/yr) there is the potential for direct adverse acu te effects to endangered and/or threatened (listed) freshwater fish and chronic effects on freshwater inve rtebrates. Functionally, the estimated risks may translate to reduced survival and reproduction of imp acted species with subsequent effects at higher levels of biological organization. Dodine is not likely to po se an acute risk to saltwater/estuarine fish nor is it likely to pose a chronic risk to freshwater fish. There were no identified incidents or field studies to either support or refute the estimated risks.Page 3 of 219 Chronic endpoints for saltwater fish and invertebra tes could not be determined because no data were available and the possibility of risk from chronic e xposure to these receptors can not be precluded. The low estimated acute risk to saltwater fish may indi cate low risk to this receptor resulting from chronic exposure as well. However, the high sensitivity of freshwater invertebrates and estimated risks to saltwater invertebrates and molluscs indicate that conclu sive determinations of chronic risk to saltwater invertebrates cannot be made without more data. Complete evaluation of the risk to aquatic plants could not be conducted sincePage 4 of 219Table 1.1. Summary of Environmental RiskConclusions for Aquatic Organisms and PlantsRisk Category Use: Application RateaSummarized Risk Characterization and Important UncertaintiesAcute Risk toFreshwater FishApples: 11.7 lbs ai/A/yr aerial* The acute RQ, based on aerial application to apples (in Pennsylvania), exceeds theendangered species LOC. Exposure concentrations based on application to applesat other sites did not result in exceedances. The Pennsylvania apple scenario ischaracterized by relatively high average annual erosion, which results in theexceedance for this use despite not having the highest application rate of all uses.Chronic Risk toFreshwater FishNone The available data suggest that dodine is not likely to pose risk above LOCs tofreshwater fish based on modeled chronic exposure estimates for all uses.Acute Risk toFreshwaterInvertebratesApples: 11.7 lbs ai/A/yr aerial***Cherries: 7.8 lbs ai/A/yr aerial***Peaches: 13.0 lbs ai/A/yr aerial***Pears: 11.7 lbs ai/A/yr aerial**Pecans: 13.0 lbs ai/A/yr aerial***Walnuts: 13.0 lbs ai/A/yr aerial**The acute RQs, based on aerial applications of all national uses exceptstrawberries, exceed endangered species, acuterestricted use and/or acute LOCs.Chronic Risk toFreshwaterInvertebratesApples: 11.7 lbs ai /A/yr aerial The chronic RQ, based onaerial application to apples (in Pennsylvania), exceedsthe LOC. Exposure concentrations based onapplication to apples at other sites didnot result in exceedances. The Pennsylvania apple scenario is characterized byrelatively high average annual erosion, which results in the exceedance for this usedespite not having the highest application rate of all uses.Acute Risk toEstuarine/Marine FishNone The available data suggest that dodine is not likely to pose risk above LOCs toestuarine/marine fish based on modeledexposure estimates from all labeled uses.Chronic Risk toEstuarine/Marine FishUnknown Chronic endpoints for esturaine/marine fish can not be derived because toxicitydata was not available. Risk to esturaine/marine fish from chronic exposure ofdodine can not be precluded. This is a source of uncertainty in this assessment.Acute Risk toEstuarine/MarineInvertebratesApples: 11.7 lbs ai/A/yr aerial**Cherries: 7.8 lbs ai/A/yr aerial**Peaches: 13.0 lbs ai/A/yr aerial*Pecans: 13.0 lbs ai/A/yr aerial**The acute RQs, based on aerial applications of all national uses except pears,strawberries, and walnuts exceed acute restricted use and/or listed species LOCs.Table 1.1. Summary of Environmental RiskConclusions for Aquatic Organisms and PlantsRisk Category Use: Application RateaSummarized Risk Characterization and Important UncertaintiesPage 5 of 219Chronic Risk toEstuarine/MarineInvertebratesUnknown Chronic endpoints for estuarine/marine invertebrates can not be derived becausetoxicity data are not available. Risk toestuarine/marine invertebrates from chronicexposure of dodine can not be precluded.This is a source of uncertainty in thisassessment.Acute Risk toEstuarine/MarineMolluscApples: 11.7 lbs ai/A/yr aerial**Cherries: 7.8 lbs ai/A/yr aerial**Peaches: 13.0 lbs ai/A/yr aerial**Pecans: 13.0 lbs ai/A/yr aerial**Walnuts: 13.0 lbs ai/A/yr aerial*The acute RQs, based on aerial applications of all national uses except pears andstrawberries, exceed acute restricted use and/or listed species LOCs.Risk to AquaticVascular PlantsUnknown There are no available aquatic vascular plant toxicity data; this is a major data gapand source of uncertainty in this assessment. Risk to aquatic vascular plants cannot be precluded.Risk to Aquatic Nonvascular PlantsApples: 11.7 lbs ai/A/yr aerial***Cherries: 7.8 lbs ai/A/yr aerial***Peaches: 13.0 lbs ai/A/yr aerial***Pears: 11.7 lbs ai/A/yr aerial***Pecans: 13.0 lbs ai/A/yr aerial***Walnuts: 13.0 lbs ai/A/yr aerial***The acute RQs, based on aerial applications for all national uses exceptstrawberries, exceed LOCs.aAerial applications assume 5% spray drift.* Exceeds acute listed species LOC for aquatics.** Exceeds acute listed species and acute restricted use LOC for aquatics.*** Exceeds acute listed species, acute restricted use and acute LOC for aquatics.Page 6 of 219Table 1.2. Summary of Environmental RiskConclusions for Terrestrial Organisms and PlantsRisk Category Use: Application Rate Summarized RiskCharacterization and Important UncertaintiesAcute Risk to Birds Apples: 11.7 lbs ai/A/yr aerial***Cherries: 7.8 lbs ai/A/yr aerial***Crab apples (OR): 2.04 lbs ai/A/yr aerial***Ornamentals (OR): 5.1 lbs ai/A/yr aerial***Peaches: 13.0 lbs ai/A/yr aerial***Pears: 11.7 lbs ai/A/yr aerial***Pecans: 13.0 lbs ai/A/yr aerial***Strawberries: 6.5 lbs ai/A/yr aerial***Walnuts: 13.0 lbs ai/A/yr aerial***Acute, acute restricted use and/or listed species LOCs are exceeded for birds thatconsume short grass, tall grass, broadleafplants, and small insects for all dodineuses based on both dietary-based and dose-based toxicity endpoints. Acute LOCsare exceeded even when non-conservative predicted mean residue values (exposureconcentrations) are used to assess risk.Sublethal effects noted in the laboratorystudies include depression, reduced reaction to stimuli, wing droop and loss ofcoordination.Chronic Risk to Birds Apples: 11.7 lbs ai/A/yr aerialCherries: 7.8 lbs ai/A/yr aerialCrab apples (OR): 2.04 lbs ai/A/yr aerialOrnamentals (OR): 5.1 lbs ai/A/yr aerialPeaches: 13.0 lbs ai/A/yr aerialPears: 11.7 lbs ai/A/yr aerialPecans: 13.0 lbs ai/A/yr aerialStrawberries: 6.5 lbs ai/A/yr aerialWalnuts: 13.0 lbs ai/A/yr aerialThe chronic LOC is exceeded for all dodine uses, based on reproductive effects,specifically, reduction in number of eggs laid, eggs set, viable embryos, viable 3-week embryos, hatchlings, 14-day old chick survivors and hatchling weight.Acute Risk toMammalsApples: 11.7 lbs ai/A/yr aerial***Cherries: 7.8 lbs ai/A/yr aerial ***Crab apples (OR): 2.04 lbs ai/A/yr aerial*Ornamentals (OR): 5.1 lbs ai/A/yr aerial**Peaches: 13.0 lbs ai/A/yr aerial***Pears: 11.7 lbs ai/A/yr aerial***Pecans: 13.0 lbs ai/A/yr aerial***Strawberries: 6.5 lbs ai/A/yr aerial**Walnuts: 13.0 lbs ai/A/yr aerial***Acute, acute restricted use and/or listed species LOCs are exceeded for mammalsthat consume short grass, tall grass, broadleaf plants, and small insects across mostweight classes for all dodine uses based on dose-based female-specific toxicityendpoint. Acute LOCs are exceeded evenwhen non-conservative predicted meanresidue values (exposure concentrations) are used to assess risk.Table 1.2. Summary of Environmental RiskConclusions for Terrestrial Organisms and PlantsRisk Category Use: Application Rate Summarized RiskCharacterization and Important UncertaintiesPage 7 of 219Chronic Risk toMammalsApples: 11.7 lbs ai/A/yr aerialCherries: 7.8 lbs ai/A/yr aerialCrab apples (OR): 2.04 lbs ai/A/yr aerialOrnamentals (OR): 5.1 lbs ai/A/yr aerialPeaches: 13.0 lbs ai/A/yr aerialPears: 11.7 lbs ai/A/yr aerialPecans: 13.0 lbs ai/A/yr aerialStrawberries: 6.5 lbs ai/A/yr aerialWalnuts: 13.0 lbs ai/A/yr aerialBased on both dietary-based and dose-based toxicity endpoints, the chronic LOC isexceeded for all use rates, for wild mammals that consume short grass, tall grass,broadleaf plants, and small insects, and in some cases fruits, pods, and largeinsects. Risk estimates are based on deleterious effects of dodine on body weightgain.Terrestrial Plants Assumed for all uses of Dodine A Tier I plant study shows a potential for dodine uses to adversely effect terrestrialplants. Without a Tier II study, risk to listed terrestrial plants is assumed. The lackof Tier II data is a major data gap and a source of uncertainty in this assessment.Non-target Insects None Based on acute contact toxicity studies on honeybees, dodine is classified aspractically non-toxic to these receptors.* Exceeds acute listed species LOC for terrestrial animals.** Exceeds acute listed species and acute restricted use LOC for terrestrial animals.*** Exceeds acute listed species, acute restricted use and acute LOC for terrestrial animals.Page 8 of 219 PRZM/EXAMS modeling suggests that even though erosi on was the dominant route of off-site transport of dodine, spray drift alone as a route of exposure to freshwater invertebrates may be of concern. Refined spray drift exposure estimates (AgDRIFT) were used to determine spray drift buffers for possibly mitigating risk to listed freshwater invertebrates in aquatic ecosystems that are within close proximity to agricultural fields that may be treated with liquid spray applications of dodine. Required buffer distances, based on maximum aerial application rates and screeni ng-level defaults, are expected to exceed the 1,000 foot limit of AgDRIFT. Modeled buffer requireme nts for listed freshwater invertebrates, based on maximum aerial application rates and a 10-foot release height in wind speeds < 10 mph, are expected to range from approximately >1,000 to 880 ft. for ASEA fi ne and ASEA medium droplet sizes, respectively. For orchard airblast applications for the lowest a nd highest national application rates, Tier I AgDRIFT modeling suggests that buffer distances of 154 and 76 ft., respectively, would be sufficient to reduce exposure concentrations below the LO C for listed freshwater invertebrates.
Based on acute risk to freshwater fish and both freshwater and saltwater invertebrates, indirect effects to Federally endangered and threatened (listed) species ( i.e. , fish, mammals, birds, reptiles, amphibians) that eat freshwater fish and freshwater or saltwater invert ebrates may occur. The potential for adverse effects to those listed obligate and general species that rely on aquatic plants for food a nd/or habitat and shelter also exists.

1.3 Conclusions - Exposure Characterization Dodine applied to an agricultural field is likely to beimmobile in soils and is generally not expected to persist longer than a few weeks. Based on a low estimated vapor pressure, volatilization is an unlikely route of dissipation from the field. Because of dodine’s high partitioning coefficient and relative rapid degradation in aerobic soils, the potential to reach aquatic ecosystems dissolved in runo ff or leachate is limited. Dodine may, however, be transported off-site to aquatic ecosystems adsorbedto eroded sediment or via spray drift during aerial, airblast or ground spray applications. In aquatic e nvironments, dodine is resistant to hydrolysis and photolysis. In aerobic aquatic environm ents, dodine is likely to be moderate ly persistent to persistent. In anaerobic aquatic environments, dodine is likely to be very persistent. Major environmental degradates (excluding CO 2 ) are not expected. For aquatic organisms, exposures to dodine are based on dodine dissolved in a water body. The routes of dodine exposure are the integument and respiratory surf aces such as gills in fish and cutaneous absorption as in some invertebrates and amphibians. Aquatic and terrestrial plants would be exposed to dodine dissolved in water as well. Estimated surface water exposure concentrations were derived from Tier II modeling with PRZM/EXAMS for all national uses of dodine. For birds and mammals, only the dietary route of exposure is considered. Estimates of resi dues on food items such as grasses, broadleaf plants and insects were obtained from the empirically determined Kenaga nomogram which relates pesticide application rate to residues on food items. Estimates of daily food ingestion rates are used in combination with the food item residue levels to determine daily exposure levels.
1.4 Conclusions - Effects CharacterizationPage 9 of 219 Dodine is practically non-toxic to honeybees, mammals , and estuarine/marine fish and slightly toxic to birds on an acute exposure basis. Dodine is hi ghly toxic to aquatic non-vascular plants, freshwater invertebrates, estuarine/marine invertebrat es and molluscs on an acute exposure basis. Dodine is slightly toxic to birds, mammals and fr eshwater invertebrates based on chronic exposures. In birds, chronic effects on mallard ducks include reduced numbers of eggs laid, eggs set, viable embryos, viable 3-week embryos, hatchlings, 14-day-old surv ivors and reduced adult f ood consumption, hatchling body weight and adult female body weight. For ma mmals, chronic effects were limited to reductions in body weight and body weight gain in rats. The r esults from the rat study were supported by a chronic study on dogs which also showed reductions in body weight in some exposed individuals.

1.5 Uncertainties and Data Gaps The major data gap is the lack of aquatic plant and terrestrial plant toxicity studies. For dodine, the only registrant-submitted aquatic plant study was on green alga ( Selenastrum capricornutum ). Results from this study indicate that dodine is green algae. However, there ar e insufficient data to generate a suitable understanding of the toxi city of dodine to aquatic

There was also no submitted fish bioconcentration ( BCF) study. This is a data gap and a source of uncertainty in this assessment. However, the H azardous Substances Data Bank (HSDB, 2005) reports an estimated BCF for dodine of 16 suggesting that the potential for bioaccumulation in aquatic organisms is low.Page 10 of 219 TABLE OF CONTENTS
1 EXECUTIVE SUMMARY

..................................................... 2 1.1 Nature of Chemical Stressor

.............................................. 2 1.2 Potential Risks to Non-target Organisms . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2 1.3 Conclusions - Exposure Characterization

.................................... 8 1.4 Conclusions - Effects Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 1.5 Uncertainties and Data Gaps . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9
2 PROBLEM FORMULATION

................................................. 13 2.1 Stressor Source and Distribution

.......................................... 13 2.1.1 Source and Intensity

....................................... 13 2.1.2 Physical/Chemical/Fate and Transport Properties

................ 14 2.1.3 Pesticide Type, Class and Mode of Action

..................... 14 2.1.4 Overview of Pesticide Usage

................................ 14 2.2 Receptors

............................................................ 15 2.2.1 Ecological Effects

........................................ 15 2.2.2 Ecosystems at Risk

....................................... 16 2.3 Assessment Endpoints

.................................................. 16 2.4 Conceptual Model . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 17 2.4.1 Risk Hypotheses

......................................... 17 2.4.2 Conceptual Model Diagram

................................. 17 2.5 Analysis Plan . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 20 2.5.1 Preliminary Identification of Data Gaps and Methods

............ 20 2.5.2 Measures to Evaluate Risk Hypotheses and Conceptual Model

..... 23 2.5.2.1 Measures of Exposure

........................ 23 2.5.2.2 Measures of Effect

........................... 23
3 ANALYSIS

................................................................ 26 3.1 Use Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 26 3.2 Exposure Characterization

............................................... 28 3.2.1 Environmental Fate and Transport Characterization

.............. 28 3.2.2 Measures of Aquatic Exposure

.............................. 31 3.2.2.1 Aquatic Exposure Modeling

.................... 31 3.2.2.2 Aquatic Exposure Monitoring and Field Data

..... 40 3.2.3 Measures of Terrestrial Exposure

............................ 40 3.2.3.1 Terrestrial Exposure Modeling

................. 41 3.2.3.2 Residue Studies

............................. 44 3.3 Ecological Effects Characterization . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 44 3.3.1 Aquatic Effects Characterization

...................... 45 3.3.1.1 Aquatic Animals

............................. 45 3.3.1.2 Terrestrial Animals

.......................... 48
4 RISK CHARACTERIZATION

................................................ 51 4.1 Risk Estimation - Integration of Exposure and Effects Data

..................... 52 4.1.1 Non-target Aquatic Animals and Plants

........................ 53 4.1.1.1 Freshwater Fish and Invertebrates

.............. 54 4.1.1.2 Estuarine/Marine Fish and Invertebrates

......... 54Page 11 of 219 4.1.1.3 Aquatic Plants

............................. 55 4.1.2 Non-target Terrestrial Animals

.............................. 56 4.1.2.1 Birds

...................................... 56 4.1.2.2 Mammals

.................................. 60 4.1.2.3 Plants

..................................... 65 4.1.3 RQs Based on Mean Kenaga Residues

........................ 65 4.2 Risk Description

....................................................... 72 4.2.1 Risks to Aquatic Organisms

................................. 73 4.2.1.1 Freshwater Fish

............................. 74 4.2.1.2 Freshwater Invertebrates

...................... 74 4.2.1.3 Saltwater Fish

.............................. 76 4.2.1.4 Saltwater Invertebrates

....................... 76 4.2.1.5 Aquatic Plants

.............................. 77 4.2.2 Risks to Terrestrial Organisms

............................... 77 4.2.2.1 Birds

...................................... 77 4.2.2.2 Mammals

.................................. 79 4.2.2.3 Plants

..................................... 80 4.2.3 Non-Target Insects

........................................ 80 4.2.4 Review of Incidents Data

................................... 80 4.2.5 Federally Threatened and Endangered (Listed) Species of Concerns

. 80 4.2.5.1 Action Area

................................ 82 4.2.5.2 Taxonomic Groups Potentially at Risk

........... 82 4.3 Description of Assumptions, Limitations, Uncertainties, Strengths and Data Gaps

.................................................................... 95 4.3.1 Assumptions and Limitations Related to Exposure for all Taxa

..... 95 4.3.2 Assumptions and Limitations Rela ted to Exposure for Aquatic Species

....................................................... 95 4.3.3 Assumptions and Limitations Related to Exposure for Terrestrial Species 96 4.3.3.1 Location of wildlife species

.................... 96 4.3.3.2 Routes of exposure

........................... 97 4.3.3.3 Incidental Pesticide Re leases Associated with Use

. . 98 4.3.3.4 Residue Levels Selection

...................... 98 4.3.3.5 Dietary Intake - The Differences Between Laboratory and Field Conditions

......................... 99 4.3.4 Assumptions and Limitations Related to Effects Assessment

....... 99 4.3.4.1 Age class and sensitivity of effects thresholds

...... 99 4.3.4.2 Lack of Effects Data for Amphibians and Reptiles

. 100 4.3.4.3 Use of the Most Sensitive Species Tested

......... 100 4.3.4.4 Data Gaps

................................ 100 4.3.5 Assumptions Associated with the Acute LOCs

................. 101
LITERATURE CITED

............................................................ 102
APPENDIX A. Maximum Use Rates Based on Current Labels Compiled by BEAD

......... 104
APPENDIX B. Environmental Fate Data

............................................. 109Page 12 of 219 APPENDIX C. Aquatic Exposure Modeling Assessment - PRZM/EXAMS Outputs

......... 115 APPENDIX D. Ecological Effects Characterization for Dodine and DGH

.................. 144
APPENDIX E. ECOTOX References not Used in Dodine Risk Assessment

................. 159 APPENDIX F. Spray Drift Assessment: Ag DRIFT Modeling Approach and Results

......... 161 APPENDIX G. Listed Species by State

............................................... 164 APPENDIX H. Guideline Sequence Bibliography for Dodine

............................ 217Page 13 of 219 2 PROBLEM FORMULATION
Problem formulation is used to establish the dir ection and scope of an ecological risk assessment. According to the Guidelines for Ecological Ri sk Assessment (USEPA, 1998), problem formulation consists of defining the problem and purpose for th e assessment, and developing a plan for analyzing and characterizing risk. The critical components of th e problem formulation are selection of the assessment endpoints, formulation of risk hypotheses and the concep tual model, and development of an analysis plan. The analysis plan and supporting rationale are aime d at determining whether the proposed uses of dodine on registered crops could result in exposures that cause unreasonable adverse effects (risk) to non-target organisms including those federally listed as threatenedor endangered (hereafter referred to as “listed”). This assessment was developed as part of the supporting information to determine the eligibility of dodine for re-registration. The Federal Insecticide, F ungicide and Rodenticide Act (FIFRA) requires that registered pesticide uses do not pose unreasonable adverse effects to the environment, and the Endangered Species Act requires that regulatory actions are not likely to adversely affect Federally listed species or their habitats.
2.1 Stressor Source and Distribution 2.1.1 Source and Intensity
The source of the stressor considered in this ecol ogical risk assessment is formulated dodine applied for agricultural and some non-agricultural uses. In addition, the dissociation product of dodine, dodecylguanidinium cation, is also derived from th e antimicrobial active ingredient, dodecylguanidine hydrochloride (DGH). Therefore, this assessment utili zes environmental fate and toxicity data for both dodine and DGH since these compounds behave the same under environmental conditions ( i.e. , in water and moist soil). DGH is an antimicrobial pesticide th at is used as a sanitizer, bacteriostat, microbiocide, microbiostat, fungicide, algicide, and molluscicide. Both dodine and DGH are water soluble salts of a strong base, dodecylguanidine, that are expected to dissociate to the same degree under any normal environmental conditions. As strong bases, these co mpounds will be completely dissociated in aqueous solutions at normal environmental pHs. At the low c oncentrations present in the environment, and in the presence of moisture, both compounds would be presen t as the dodecylguanidinium ion and either the acetate or chloride ion. DGH uses include: industrial once-through cooling wate r systems, auxiliary water and waste water systems, enhanced oil recovery systems, recirculati ng cooling water systems, oil field water systems, oil recovery drilling fluids, pulp and papermill systems, process waters and non-potable water treatment, preservation of pulp and papermill chemicals, adh esives, and coatings, sewage disposal lagoons, disposable diapers, food packaging, non-paper related aqueous systems, liquid concentrates, and air washers. Given the similarities between DGH and dodi ne, there is the potential for exposure to aquatic organisms to dodecylguanidinium based on both agricultural uses of dodine and industrial uses of DGH. However, current uses of DGH preclude a robust quantitative assessment of the likelihood of ecological exposure resulting from uses of DGH overlapping both spatially and temporally with the potential exposures resulting for the agricultural uses of dodine. Therefore, the ecological risks are not aggregated in this assessment. Dodine is applied via ground spray, airblast or aerial application to apples, cherries, peaches, pears, pecans, strawberries and walnuts. Terrestrial expos ure is based on direct spray application on food items including short grass, seeds, and broadleaf plants and insects resulting from applications of dodine at thePage 14 of 219 maximum label rates. Exposure to aquatic organisms is the result of runoff and spray drift from labeled applications and is functionally the amount of compound in the water that would directly contact organisms. The magnitude of exposure estimates ar e largely dependent on the biology of the receptor ( e.g. , food consumption rate), the use patterns and envi ronmental fate and transport, which are further explored later in this document. 2.1.2 Physical/Chemical/Fate and Transport Properties

There are no anticipated major environmental degradates of dodine. 2.1.3 Pesticide Type, Class and Mode of Action Dodine is a fungicide of the guanidine group of chemicals and is considered a general toxophore with several sites of action that may differ among member s of the guanidine group. Primarily, dodine’s mode of action is through disruptions of cell membranes. Dodine has been shown to cause extensive damage to the cytoplasmic membrane of the common plant pathogen, Pseudomonas syringae , as evidenced by cell death and leakage of K+, UV-absorbing materials, and ribose-containing molecules (Cabral, 1991). It is registered for control of a range of pathogenic f ungi that affect a number of agricultural and some ornamental crops. Current formulations for dodine include liquid flowable concentrate and wettable powder. Based on current label information, dodine is registered for use on apples, cherries, peaches, pears, pecans, strawberries, and black walnut; crab apple and ornamental shade trees (SLN OR). 2.1.4 Overview of Pesticide Usage Dodine is used as a pre- or post-infection fungicide that is formulated as a liquid flowable concentrate and wettable powder. Dodine has been used to c ontrol fungal diseases on apples, cherries, peaches, pears, pecans, strawberries and walnuts. Dodine may be a pplied to a number of stages of crop growth including delayed dormant, dormant, foliar, pre-bloom, early bloom, bloom, petal fall, postharvest, and popcorn (a developmental stage just before petals begin to open in peaches only). Mostly, dodine is applied by ground using an air blast sprayer and is app lied in a dilute or concentrate form. The National Center for Food and Agricultural Polic y (NCFAP) reported a total use of 264,664 lbs. of dodine in 1992. In 1997, the NCFAP reported a decrease from the 1992 total use to about 151,538 lbs. In both years, dodine was used most on apples followed by pears in 1992 and pecans in 1997. While these data provide some insight into the historic u se of dodine, fungicide use changes with the varying resistance of fungi; predicting total use prospec tively is difficult since it may be based on the susceptibility of a particular fungus to a specific fungicide.Page 15 of 219 

### 2.2 Receptors 2.2.1 Ecological Effects
Table 2.1 provides taxonomic groups and test species used to indicate the potential for ecological effects in this screening-level risk assessment. Within each of these very broad taxonomic groups, an acute and/or chronic endpoint is selected from the available test data (see Section 2.3). A complete discussion of all toxicity data available for this risk assessm ent and the resulting measurement endpoints selected for each taxonomic group are included in Appendix D.
Table 2.1 Taxonomic Groups and Most Sensitive Test Species Evaluated for Ecological Effects of Dodine. Taxonomic group Example(s) of representative species Endpoint Used Birds a Mallard duck ( Anas platyrhynchos ) Bobwhite quail ( Colinus virginianus ) Chronic, NOAEC Acute, LD 50/LC 50 Mammals Laboratory rat ( Rattus norvegicus ) Acute LD 50 and Chronic NOAEL/NOAEC Terrestrial insects Honeybees ( Apis mellifera ) Acute Oral LD 50 Freshwater fish b Rainbow trout ( Oncorhynchus mykiss ) Fathead minnow ( Pimephales promelas ) Acute LC 50 Chronic NOAEC
Freshwater invertebrates Water flea ( Daphnia magna ) Midge ( Chironomus riparius ) Acute LC 50 and Chronic NOAEC Chronic NOAEC (Benthic) Estuarine/marine fish Sheepshead minnow (Cyprinodon variegatus) Acute LC 50 Estuarine/marine invertebrates Mysid shrimp (Mysidopsis bahia ) Eastern oyster ( Crassostrea virginica ) Acute LC 50 Acute EC 50 Terrestrial plants c Monocots – corn ( Zea mays ) Dicots – soybean ( Glycine max ) Acute (Tier I, no EC 50 estimated) Aquatic plants and algae Green algae ( Selenastrum capricornutum ) Acute EC 50

a Birds are used as surrogates for terrestrial phase amphibians and reptiles (US EPA, 2004). b Freshwater fish are used as surrogates for aquatic phase amphibians (US EPA, 2004).

c Four species of two families of monocots, of which one is corn ; six species of at least four dicot families, of which one is soybeans.Page 16 of 219 2.2.2 Ecosystems at Risk An ecosystem can be defined as a functional unit cons isting of all the living organisms (plants, animals, and microbes) in a given area, and all the non-living physical and chemical factors of their environment, linked together through nutrient cycling and energy flow. An ecosystem can be of any size- a log, pond, field, forest, or the earth's biosphere- but it always functions as a whole unit. Ecosystems are commonly described according to the major type of vegetation, for example, forest ecosystem, old-growth ecosystem, or range ecosystem. The ecosystems that c ould be potentially at risk due to agricultural use of dodine include terrestrial and aquatic (lakes, ponds, streams) habitats in proximity to dodine use areas. Moreover, these habitats may be at risk from drif t and/or runoff of dodine from use areas. The estuarine/marine ecosystems are likely at less risk si nce they are typically further from agricultural areas and are characterized by large volumes of water. However, in some areas where agriculture dominates the landscape, risks to estuarine/mar ine ecosystems cannot be excluded.
To address specific ecosystems at risk in this screening-level assessment is beyond the scope of this effort. Generally, concerns of risk to ecosyst ems are addressed in the identification of assessment endpoints, which reflect ecological entities and their associated attributes. Functionally, this assessment specifically addresses risks at the individual level. Howe ver, given that the toxicity endpoints used in the assessment relate directly to higher-levels of biological organization, any risks identified are considered to provide insight into potential risks to ecosystems and ecosystem function.
2.3 Assessment Endpoints
Assessment endpoints are defined as “explicit expressions of the actual environmental value that is to be protected.” Operationally, the environmental value is represented by an ecological entity and associated attributes or characteristics. The assessment endpoint s for this ecological ri sk assessment are survival, growth, and reproduction of terrestrial and aquatic animals and plants. Specifically, this assessment addresses birds, mammals, reptiles, amphibians, terrestrial and aquatic invertebrates, terrestrial and aquatic plants, and fish. These endpoints, in turn , are meant to reflect population sustainability and community diversity within ecosystems. These are standard assessment endpoints that are considered for the majority of pesticides with agricultural uses.
Measures of effect and measures of exposure ar e explicit toxicity and exposure measurements or estimates that are used to identify risks. Measures of effect are u sed to relate pesticide exposure to potential effects on the assessment endpoints, which are not explicitly evaluated in the assessment. Measures of exposure are typically values derived fro m chemical use information and standard fate, transport and exposure models. The toxicity and e xposure values are used to generate a risk quotient, which is considered a screening-level estimate of risk , only. Additional refinements may be triggered if the screen identifies potentially unacceptable levels of risk. Refinements may include the selection of assessment endpoints more directly relevant to populations or communities, spatially-explicit identification of risks, and the use of probabilistic methods for risk estimation.
Assessing risks to reptiles and amphibians represents unique challenges. Currently, data on direct toxicity to reptiles and amphibians are not required as part of the standard dataset submitted to the Agency for pesticide registration or re-registration and these data are only occasionally available from the literature.Page 17 of 219 For ecological risk assessments in the Office of Pestic ide Programs (OPP), if risks to birds are below the level of concern, then risks to reptiles are also assu med to be low. For amphibians freshwater fish are considered a suitable surrogate for the aquatic life-st age and birds a suitable surrogate for the terrestrial life-stage.
2.4 Conceptual Model
2.4.1 Risk Hypotheses
The Office of Pesticide Programs uses a screening risk hypothesis for its initial risk assessments.
The risk hypothesis is that the use of dodine in accordance with the label results in adverse effects on survival and/or fecundity to non-target terrestrial and/or aquatic animals; and that the use of dodine according to the label results in adverse effects on survival, reproduction and/or growth to aquatic, semiaquatic and terrestrial plants.
2.4.2 Conceptual Model Diagram
The conceptual model used to depict the potential ecol ogical risk associated with dodine is fairly generic and assumes that as a fungicide, dodine can affect te rrestrial and aquatic organisms if environmental concentrations are sufficiently elevated as a result of proposed label uses. A diagram of the conceptual model is presented in Figure 2.1 . All of the use scenarios for dodine involve foliar application of the pesticide. Although not evident from the diagram, dodine degradation prior to runoff is explicitly considered. Runoff includes transport of dodine in a dissolved state as well as dodine adsorbed to eroded sediment.
As there may be multiple applications of the pestic ide to foliage in many of the labeled use patterns, degradation on the foliage between applications is considered in the terrestrial assessments. The dissipation rate from foliage used in the terrestrial assessments was 35 days, which is the default value. It represents an upper bound on expected foliar dissipati on rates across all pesticides, based on data in Willis and McDowell (1987). For aquatic assessments the microbial degradation on foliage was assumed stable, but wash-off of the foliage was considered us ing the default wash-off coefficient assumption of 0.5 cm -1 . Spray drift was directly considered in the aquatic assessments as a route of loading to the pond, with higher levels of spray drift for aerial applications vs . ground spray applications.
For terrestrial assessments, spray drift was not directly considered. However, since the evaluation of risk was done for on-field foliage, non-target foliage r eceiving spray drift should have reduced pesticide loading and the assessment based on the on-field residues would be protective of both. A variety of food types ( i.e. , short grass, long grass, broadleaf plants etc.) were assessed regardless of the type represented by the target crop, as a variety of food types will exist on and off the treated field.Page 18 of 219 For aquatic assessments, once dodine reaches a water body, the pesticide is partitioned between the water column, suspended sediment, and bed sediment based on its physical/chemical properties. Degradation by photolysis, abiotic hydrolysis, and microbial meta bolism is taken into account. The route of exposure is uptake of dodine dissolved in the wate r column through the gills and integument. No studies on the bioaccumulation of dodine in fish were availa ble for review. However, the Hazardous Substances Data Bank (HSDB, 2005) lists an estimated BCF fo r dodine of 16 suggesting that the potential for bioaccumulation in aquatic organisms is low.
For birds and mammals, only the dietary route of expos ure is considered. While there is a potential for dermal and inhalation exposure from the foliar use, th e data needed to assess these routes are not available for dodine. Furthermore, these routes are not usually assessed at the screening level. Although the inhalation route of exposure was also not assessed, dodine has a low vapor pressure, suggesting that inhalation is not likely to be significan t relative to other routes of exposure.Page 19 of 219 Stressor Dodine applied as a ground/aerial spray (aerial or ground)

Source/ Transport Pathways Direct Deposition Runoff/ Erosion Leaching (Infiltration/ Percolation

Source/ Exposure Media Terrestrial Food Items (foliage, fruit,

insects, seeds) Upland Foliage/Soil Riparian/ Wetland Foliage/Soil Receiving Water Body/

Sediment Groundwater

Exposure Route Ingestion Direct contact/ Root Uptake Direct contact/ Root Uptake Gill/ Integument

Uptake
Receptors

Attribute Changes Terrestrial Vertebrates Birds, Mammals, Reptiles, Terrestrial Phase Amphibians Terrestrial Upland Plants

Individual Animals

Reduced survival Reduced growth Reduced

reproduction Aquatic Invertebrates Aquatic Vertebrates Wetland/ Riparian Plants

Individual Plants

Seedling emergence Vegetative vigor Individual vertebrates and invertebrates

Reduced

survival Reduced

growth Reduced

reproduction Plant population

Reduced

population growth Aquatic Plants Uptake/ Adsorption Spray Drift Stressor Dodine applied as a ground/aerial spray (aerial or ground)

Source/ Transport Pathways Direct Deposition Runoff/ Erosion Leaching (Infiltration/ Percolation

Source/ Exposure Media Terrestrial Food Items (foliage, fruit,

insects, seeds) Upland Foliage/Soil Riparian/ Wetland Foliage/Soil Receiving Water Body/

Sediment Groundwater

Exposure Route Ingestion Direct contact/ Root Uptake Direct contact/ Root Uptake Gill/ Integument

Uptake
Receptors

Attribute Changes Terrestrial Vertebrates Birds, Mammals, Reptiles, Terrestrial Phase Amphibians Terrestrial Upland Plants

Individual Animals

Reduced survival Reduced growth Reduced

reproduction Aquatic Invertebrates Aquatic Vertebrates Wetland/ Riparian Plants

Individual Plants

Seedling emergence Vegetative vigor Individual vertebrates and invertebrates

Reduced

survival Reduced

growth Reduced

reproduction Plant population

Reduced

population growth Aquatic Plants Uptake/ Adsorption Spray Drift

Figure 2.1 Conceptual model of the fate/transport and effects dodine in the environment.Page 20 of 219 2.5 Analysis Plan
2.5.1 Preliminary Identification of Data Gaps and Methods
The primary method used to assess risk in this screen ing-level assessment is the risk quotient (RQ) and follows closely methods outlined in the EPA Overview Document (US EPA, 2004).

. The resulting RQ is then comparedto a specified level of concern (LOC), which represents a point of departure for c oncern; if the RQ exceeds the LOC, then risks are triggered.

Levels of concern are the policy tool for interpre ting risks from direct pesticide effects and have a magnitude, duration, frequency, and spatial extent. The magnitude is set by the risk presumption for each endpoint (described below). The frequency of potential risk is once every ten years for aquatic endpoints and one in every ten foliage samples for terrestrial risk . The spatial extent is defined by the use area, and the areas downstream and areas potentially affected by spray drift.
To evaluate the potential risk to non-target organi sms from the use of dodine, risk quotients (RQ) are calculated from the ratio of estimated environmental concentrations (EECs) to toxicity values. Risk quotients are then compared to the LOCs to indi cate potential risk to non-target organisms and the consequent need to consider regulatory action. Risk presumptions, along with the corresponding RQs, equations, and LOCs are summarized in Tables 2.2-2.5 . The exposure estimates in this screening assessment are derived using maximum label rates and minimum application intervals for each use.Page 21 of 219 Table 2.2 Risk presumptions for terrestri al animals (birds and wild mammals). Risk Presumption RQ LOC Acute EEC 1 /LC50 or LD50/ft 2 or LD50/day3 0.5

Acute Restricted Use EEC/LC50 or LD50/ft 2 or LD50/day (or LD50 < 50 mg/kg) 0.2

Acute Endangered Species EEC/LC50 or LD50/ft 2 or LD50/day 0.1

Chronic Risk EEC/NOEC 1

1 abbreviation for Estimated Environmental Con centration (ppm) on avian/mammalian food items

2 mg/ft 2 3 mg of toxicant consumed/day LD 50 * wt. of bird LD 50 * wt. of bird

Table 2.3 Risk presumptions for aquatic animals. Risk Presumption RQ LOC Acute EEC 1 /LC 50 or EC 50 0.5 Acute Restricted Use EEC/LC 50 or EC 50 0.1 Acute Endangered Species EEC/LC 50 or EC 50 0.05 Chronic Risk EEC/NOEC 1

1 EEC = (ppm or ppb) in water

Table 2.4 Risk presumptions for terrestrial and semi-aquatic plants. Risk Presumption RQ LOC Acute Risk EEC 1 /EC 25 1 Acute Endangered Species EEC/EC 05 or NOEC 1

1 EEC = lbs ai/APage 22 of 219 Table 2.5 Risk presumptions for aquatic plants. Risk Presumption RQ LOC Acute High Risk EEC 1 /EC 50 1 Acute Endangered Species EEC/EC 05 or NOEC/EC 05 or NOEC 1

1 EEC = (ppb/ppm) in water Generation of robust RQs is depende nt on the quality of data from both fate and toxicological studies. These studies should be conducted following Agency guide lines and are subjected to extensive review to ensure data quality. Estimates of exposure are generated using maxi mum label rates and minimum intervals between applications. Toxicity values used in the risk quo tient calculations are based on the most sensitive species tested for a given exposur e duration and taxonomic group. Although the lowest toxicity value from available studi es is used for RQ calculations, typically, only data from a few species are available. For example, the Agency usually receives avian toxicity studies for bobwhite quail and mallard ducks. Of the 650 avia n species in the United States, bobwhite quail or mallard ducks may not be the most sensitive. These species, in fact, were chosen primarily because they are easy to maintain and rear in the laboratory a nd they have some value as game species. The same argument holds for all toxicity estimates; in a ll likelihood the representative species are not the most sensitive. Similarly, for reptiles and amphibian, typi cally no toxicity data is available at all. In accordance with the EPA guidance (US EPA, 2004) birds are used as surrogates for terrestrial amphibians and reptiles and fish are used as surrogates for a quatic amphibians. This is thought to result in conservative estimates of risk for herpetofauna; however, due to the lack of available data, it is difficult to determine whether this is the case or not. Exposure estimates are generated from chemical fate studies and label information, particularly maximum application rates and minimum application interval s. Although exposure estimates using maximum label rates and minimum interval times generate maximum EECs, they represent requested use rates. Actual use rates may vary over the labeled range, particularly for certain uses. Exposure estimates for terrestrial species are gene rated assuming these species feed exclusively on the treated field soon after application of the pesticide. Moreover, the assumption is that these organisms will consume at a particular daily ingestion rate while on the treated field. Although some individuals at particular times may feed exclusively on a treated fiel d, the actual frequency and duration of this type of behavior is a source of uncertainty. While the current approach may overestimate exposure for some individuals, it does capture the potential exposures that may occur. The major data gap regarding dodine toxicity is the lack of aquatic plant toxicity studies and registrant submitted terrestrial plant studies. Agency guidelin es indicate that for outdoor pesticide uses, plant toxicity studies are required on a number of species including Selenastum capricornutum (green alga), Lemna gibba (duckweed), Skeletonema costatum (marine diatom), and Anabaena flos-asquae (blue-green alga). For dodine, the only registrant-submitte d aquatic plant study was on green alga ( Selenastrum capricornutum ). Results from this study indicate that dodine is highly to green alga; however, there are insufficient data to generate a suitable understa nding of the toxicity of dodine to aquatic plants.Page 23 of 219 Moreover, there are no registrant submitted Tier II data for the effects of dodine on terrestrial plants. Tier I terrestrial plant studies indicate some effects of dodine at the highest registered application rate. Without Tier II data, however, it is impossible to conduct a thorough assessment of risks to terrestrial plants from the use of dodine. This is particularly important in assessing risks to Federally listed species given the multitude of listed plant species and the dependence of many animal species on a wide variety of plant species.. The lack of toxicity data on aquatic and terrestrial plants represents a serious data gap in the toxicity profile of dodine. Another important data gap is the lack of chr onic toxicity studies on estuarine/marine fish and invertebrates. Acute studies on representative speci es from these taxa indicate low toxicity of dodine, which might suggest that chronic toxicity is low as well. Alternatively, freshwater invertebrates, in particular, are extremely sensitive to dodine under chr onic exposure conditions. In the absence of chronic toxicity data on estuarine/marine fish and invert ebrates, estimates of risk are highly uncertain. 2.5.2 Measures to Evaluate Risk Hypotheses and Conceptual Model Measures of exposure and measures of effect are used to evaluate the risk hypotheses and are listed in Tables 2.6 and 2.7 for a specific assessment endpoint. The RQ is obtained by dividing the measures of exposure for a particular assessment endpoint by the measures of effect for that endpoint. 2.5.2.1 Measures of Exposure Measures of exposure are estimates of exposure for a receptor determined by modeling and/or monitoring data. Measures of exposure for dodine in this assessm ent are obtained from modeling efforts only, since national-scale monitoring data were not identified. Exposure models used for this assessment include the suite of standard exposure models commonly used in pesticide risk assessments (EPA, 2004). Generally, aquatic exposure estimates are generated from EFED models and incorporate maximum proposed use rates and empirically-derived fate properties. Fu rther details of the expos ure models can be found in Section 3.2 and on the web http://www.epa.gov/oppefed1/models/water/index.htm

. Measures of exposure for terrestrial mammals, birds, reptiles and amphibians similarly incorporate maximum proposed use rates but rely less on fate properties. Instead, terrestrial exposure estimates are derived directly from empirically determined observati ons of pesticide residues on various terrestrial food items. The Kenaga nomogram, as modified by Fletcher et al., is used to relate pesticide application rates to residues on terrestrial food items. For numerous applications for a given use, the exposure model in corporates a first-order decay rate dependent on the soil half life of the chemical. The default foliar dissipation half-life of 35 days was used in this assessment. Review of the bibliography on dodine indicated that several studies may provide data for use in estimating a foliar dissipation half-life. The default foliar dissipation half-life was used since the uses of dodine involve multiple applica tions and some simulations indicated that changes in the foliar dissipation half-life did not have a significant effect on exposure estimates. The current terrestrial exposure model used by EFED is TREX v.1.1. 2.5.2.2 Measures of Effect Measures of effect are based on deleterious chang es in a receptor as a result of chemical exposure. Functionally, measures of effect typically used in risk assessments include changes in survival, reproduction, or growth as determined from standard laboratory toxicity tests. The focus on these effects for quantitative risk assessment is due to their clear relationship to higher-order ecological systems suchPage 24 of 219 as populations, communities, and ecosystems. Although effects other than survival, reproduction, and growth may be considered, rarely are they used qua ntitatively to estimate risks since, in many cases, the relationship between other effects and higher-ord er processes is tenuous at best. Commonly used laboratory-derived toxicity values include estimates of acute mortality ( e.g. , LD 50 , LC 50 ) and estimates of effects due to longer term, chronic exposures ( e.g. , NOAEC, NOAEL). In general, for a given assessment endpoint the lowest relevant measure of effect is used is calculating the RQ. More details concerning measures of effect used in this assessment can be found in Section 3.3.

Table 2.6 Terrestrial assessment endpoints. Assessment Endpoint Measures of Effect (Toxicity Endpoints) Measures of Exposure (Exposure Endpoints) Avian Survival acute avian oral LD 50 , dietary LC 50 for most sensitive bird tested, adjusted for size for 20-g bird maximum concentration on food items (foliar) or dose on planted

seeds consumed by 20 g bird
Avian Reproduction and/or Survival NOAEC/LOAEC from avian chronic study for most sensitive bird tested maximum residue on food items (foliar) or planted seeds

Mammalian Survival acute oral LD 50 , dietary LC 50 for most sensitive mammal tested maximum concentration on food items (foliar) or dose on planted seeds Mammalian Reproduction and/or Survival NOAEC/LOAEC from chronic mammalian study for most

sensitive mammal tested maximum concentration on food items
Non-target Beneficial Insect Survival Honey-bee acute contact LD 50 maximum application rate

Terrestrial Plants Survival and Growth Tier I, Tier II plant toxicity data; EC 25 estimates of runoff and spray drift to non-target areasPage 25 of 219 Table 2.7 Aquatic assessment endpoints Assessment Endpoint Measures of Effect (Toxicity Endpoints) Measures of Exposure (Exposure Endpoints) Freshwater Fish Survival 96-hr LC50 for most sensitive species tested 1-in-10 year peak concentration
Freshwater Fish Reproduction an/or Survival Fish Early Life Stage NOAEC/LOAEC for Growth 1-in-10 year 60-day average concentration Freshwater Invertebrate Survival 48-hr EC 50 based on mortality (immobility) for most sensitive species tested 1-in-10 year peak concentration

Freshwater Invertebrate Reproduction and/or Survival Invertebrate Life Cycle NOAEC for growth or reproductive effect 1-in-10 year 21-day average concentration

Marine/Estuarine Fish Survival 96-hr LC 50 for most sensitive species tested 1-in-10 year peak concentration

Marine/Estuarine Fish Reproduction and/or Survival Estuarine/Marine Fish NOAEC for growth 1-in-10 year 60-day average concentration Marine/Estuarine Invertebrate Survival 48-hr EC 50 based on mortality (immobility) for most sensitive species tested 1-in-10 year peak concentration

Marine/Estuarine Invertebrate Reproduction and/or Survival Estuarine/Marine Invertebrate NOAEC for reproduction for most sensitive species 1-in-10 year 21-day average concentration
Aquatic Vascular and Nonvascular Plant Survival and Growth Tier I, Tier II plant toxicity estimates; EC 25 1-in-10 year peak concentration

2.5.2.3 Measures of Ecosystem and Receptor Characteristics
The changes in ecosystems and free-ranging receptors in response to proposed uses of dodine are not explicitly quantified in this assessment. It would be nearly impossible to address the myriad of uses, ecosystems and receptors that may interact as a resu lt of dodine use. Instead, the measures of exposure and measures of effect are used to generate estimates of risk that can be applied to a wide variety of receptor/ecosystem combinations that are re presented by the specified assessment endpoints.
The assessment endpoints specified in Tables 2.6 and 2.7 can be summarized as survival, growth, and reproduction of terrestrial and aquatic receptors to include birds, mammals, reptiles, amphibian, fish, terrestrial and aquatic invertebrates and terrestrial and aquatic plants. The response of these receptors to dodine exposure is represented by a small number of toxicity studies on representative or surrogatePage 26 of 219 species. Hence, there is considerable uncertainty regarding the response of a free-ranging receptor since data for all species potentially exposed are not availabl e. The lowest available measure of effect for a given assessment endpoint is used to calculate RQs to accommodate for some of this inherent uncertainty. However, the extent to which this is sufficient is unknown.

3 ANALYSIS

3.1 Use Characterization
Dodine is used as a pre- or post-infection fungicide th at is formulated as a flowable liquid concentrate and wettable powder. Dodine is used to control f ungal diseases on apples, cherries, peaches, pears, pecans, strawberries and walnuts. It is also used to cont rol fungal diseases on ornamentals in Oregon (SLN 24c).

Dodine may be applied to a number of stages of crop growth including delayed dormant, dormant, foliar, pre-bloom, early bloom, bloom, petal fall, postharv est, and popcorn (a development stage just before petals open in peaches only). Mostly, dodine is applied by ground using an air blast sprayer and is applied in a dilute or concentrate form. Application by aircraft is also permitted.

Based on current labels and on inform ation provided by the registrant ( Dodine and DGH Use Closure Memo , dated 2/2/05), the maximum single application rates among all uses ranges from 0.34 to 2.6 lbs. a.i./A and maximum annual application rates range from 2.04 to 13.0 lbs. a.i./A/yr (Table 3.4). Complete maximum use rates and management practices by crop based on current labels are presented in Table A1 (in Appendix A) , compiled by BEAD, for all labels accepted as of 05/03/04.
Based on information compiled by the National Cent er for Food and Agricultural Policy (NCFAP) and reported from the U.S. Geological Survey as part of the National Pesticide Synthesis Project (NPSP, http://ca.water.usgs.gov/pnsp/ ), among agricultural crops, dodine is most frequently used on apples, pears, cherries and pecans. In the benchmark year 1997 (based on crop acreage in 1997 and pesticide use patterns for the years 1995–1998), the estimated annual ag ricultural use for these four crops, respectively, was 45,538 lbs., 41,910 lbs., 29,971 lbs. and 27,233 lbs., accounting for almost all of the agricultural use of dodine. Approximately 31% and 28% of the estimated national agricultural use of dodine in benchmark year 1997 was on apples and pears, respec tively. Cherries and pecans accounted for 20% and 19%, respectively, and all other crops on which dodi ne was used each accounted for less than 1.7% of the national use.
Based on a screening level usage analysis (SLUA; date d 3/31/05) of pesticide usage data for the years 1998–2003, compiled by BEAD, 10,000 - 30,000 lbs. of dodine was applied annually to each pears, pecans, apples and cherries ( Table 3.1 ). The National Center for Food and Agricultural Policy (NCFAP) reported a total use of 264,664 lbs. dodine in 1992. In 1997, the NCFAP reported a decrease from the 1992 total use to about 151,538 lbs.Page 27 of 219 Table 3.1 Screening-level estimates of agricultural uses of dodine for 1998-2003 (BEAD) Crop Pounds a.i. Pecans 30,000 Pears 30,000 Apples 20,000 Cherries 10,000 Peaches 3,000 Strawberries <500
Figure 3.1 shows estimated annual agricultural use of dodine for 1997 (NCFAP/NPSP). Dodine has been used historically in the Pacific Northwest on appl es and pears. Apple use also includes the south east (North Carolina), the mid-Atlantic (Pennsylvania), north central (Michigan and Ohio) and the north east (New York and Vermont). Dodine use on cherries is primarily in Michigan with approximately 30,000 lbs. applied in 1997 (NCFAP). In the south east, dodi ne has been primarily used on pecans (Georgia and Texas).Page 28 of 219 Figure 3.1 1997 Estimated annual agricultural use of dodine (NCFAP/NPSP).
3.2 Exposure Characterization
3.2.1 Environmental Fate and Transport Characterization
This environmental fate and transport characteri zation addresses dodine (dodecylguanidine acetate) and DGH (dodecylguanidine hydrochloride) as a combin ed data set because these compounds behave the same under environmental conditions ( i.e. , in water and moist soil). Both compounds are water soluble salts of a strong base (dodecylguanidine, CAS No. 112-65-2) that should dissociate to the same degree under any normal environmental conditions. DGH is miscible in water (MRID 409408-01), whereas the water solubility of dodine is 630 mg/L (product chemistry data). As strong bases, these compounds willPage 29 of 219 be completely dissociated in aqueous solutions at normal environmental pHs. At the low concentrations present in the environment, and in the presence of moisture, both compounds would be present as the dodecylguanidinium ion and either the acetate or ch loride ion. More complete information on the submitted environmental fate guideline studies can be located in Appendix B

. Dodine is likely to be immobile in soils, based on K ads values for DGH (K ads = 2202 - 18,019 L/kg, MRID 42148901) and is generally not expect ed to persist in aerobic soils (half-lives 17.5 - 22.3 d, MRID 43945201). Because of dodine’s high partitioning coefficient, the potential to reach aquatic ecosystems dissolved in runoff or leachate is limited. Based on a low estimated vapor pressure of 1.5 x 10 -7 torr for dodine (EPI Suite), volatilization is an unlikely route of dissipation. Dodine may, however, be transported off-site to aquatic ecosystems adsorbed to eroded sediment or via spray drift during aerial, airblast or ground spray applications. Once in aquatic environments, dodine is resistant to hydrolysis based on data for DGH (half-lives 576-1198 d, MR ID 42242601) and photolysis (half-lives 641-770 d, MRIDs 42419001, 46438203). In aerobic aquatic environm ents, dodine is likely to be moderately persistent to persistent (half-lives 38. 9, 59.8, 227 d, MRIDs 46438202, 42327401, 42414601). In anaerobic aquatic environments, dodine is likely to be very persistent based on data for DGH (half-life 2,492 d, MRIDs 42763100, 42763002). The general fate and physical-chemical property source data used for dodine aquatic exposure modeling are presented in Table 3.2

. There were two aerobic aquatic metabolism studies re viewed for this assessment, which showed varying degrees of degradation with total system half-liv es ranging from 38.9-59.8 d in the dodine study (MRID 46438202) and a half-life of 227 d reported in the DGH study (MRIDs 42327401, 42414601). In the DGH study, less than 10% of the parent was degraded throughout the 30 day study. In the dodine study at 84 days post-treatment, 14 CO 2 totaled 72-89% of the applied ra dioactivity, suggesting significant degradation. Both studies were scientifically validand can be used to meet the requirements for an aerobic aquatic metabolism study. Possible reasons fo r the observed variability in these two studies could include varying redox conditions and/ or varying microbial activity between the two studies. In the dodine study in both systems, redox potentials were measured at ca. +80 to ca. +180 mV andca. -300 to ca. -100 mV for the water layers and sediments, respectivel y. Redox potentials were not reported in the DGH study. Microbial activity was not measured in either study, but microbial biomass determined by total plate count analysis was reported at 1.5 x 10 5 and 5.8 x 10 7 CFU/g at day 0 and day 30, respectively, in the DGH study. The differing conditions between the two studies that resulted in the varying degrees of degradation may also occur in the natural environmen t, therefore, both studies were considered in this assessment.
In the field, dodine was almost exclusively confined to the 0-6 inch depth of bareground plots (MRID 44985701). This lack of leaching in the field is supported by a soil adsorption study in the laboratory in which DGH was immobile in soil (sand, sandy loam, clay loam, and silt loam), regardless of organic matter content (K ads values of 2,202 to 18,019). With adsorption occurring in the upper layer of soil and rapid degradation to aerobic soil metabolism, it is un likely that toxicologically-important concentrations of dodine will leach to ground water.
There was no submitted fish bioconcentration (BCF) study . This is a data gap and a source of uncertainty in this assessment. However, the Hazardous Substa nces Data Bank (HSDB, 2005) reports an estimated BCF for dodine of 16 suggesting that the potential for bioaccumulation in aquatic organisms is low.Page 30 of 219 Major degradates (excluding CO 2 ) were not identified in the available studies. Dodine degradation is most likely the result of beta-oxidation, whereby tw o carbons at a time are cleaved from the alkyl chain. The ultimate metabolite is CO 2 . Recovery of 14 CO 2 from dodine radiolabeled at the guanidine moiety was approximately 90% in the aerobic soil metabolism study in the laboratory.

Table 3.2 General fate and physical-chemical property source data used for dodine aquatic exposure modeling.

PARAMETER VALUE SOURCE Chemical Name Dodine (dodecylguanidine acetate) DGH (dodecylguanidine HCl) – Molecular Weight 287.44 263.85 – Water Solubility (25 o C) 630 mg/L no data product chemistry data Vapor Pressure (25 o C) 1.5 x 10 -7 torr no data EPI Suite Hydrolysis Half-life (25 o C) pH 5 pH 7 pH 9 no data 576 d 914 d 1198 d (< 10% in 30 days) MRID 42242601

Aqueous Photolysis Half-life 641 d (<10% in 30 days) 770 d (<10% in 30 days) MRID 46438203 (dodine) MRID 42419001 (DGH) Soil Photolysis Half-life 239 d no data MRID 46438204
Aerobic Soil Metabolism Half-life 17.5 d (sandy loam), 22.3 d (sandy loam) no data MRID 43945201

Anaerobic Soil Metabolism Half-life no data no data –Aerobic Aquatic Metabolism Halflife 38.9 d (loamy sand/sand), 59.8 d (silt loam) 227 d (sandy loam) (<10% in 30 days) MRID 46438202 (dodine) MRIDs 42327401, 42414601 (DGH)Anaerobic Aquatic Metabolism Halflife no data 2492 d (~10% in 12 months) MRIDs 42763100, 42763002

Soil Partition Coefficient (K ads , L/kg) no data 2202, 6440, 15228, 18019 MRID 42148901Page 31 of 219 3.2.2 Measures of Aquatic Exposure
The assessment involved Tier II modeling (PRZM/E XAMS) for selected scenarios representing all proposed dodine uses. Monitoring data were not considered because national-scale monitoring studies were not identified. For Tier II, two models are used in tandem. The Pesticide Root Zone Model, (PRZM, Carsel et al., 1997) simulates fate and trans port on the agricultural field. The version of PRZM used was PRZM 3.12 beta dated May 24, 2001. Th e water body is simulated with Exposure Analysis Modeling System (EXAMS), version 2.98, dated July 18, 2002 (Burns, 1997). Simulations are run for multiple (usually 30) years and the reported EECs re present the values that are expected once every ten years based on the thirty years of daily values generated during the simulation.
For aquatic endpoints, the exposure is estimated for the maximum application pattern to a 10-ha field bordering a 1-ha pond, 2-m deep (20,000 m 3 ) with no outlet. Exposure estimates generated using the standard pond are intended to represent a wide variety of vulnerable water bodies that occur at the top of watersheds including prairie pot holes, playa lakes, wetlands, vernal pools, ma n-made and natural ponds, and intermittent and first-order streams. As a group, there are factors that make these water bodies more or less vulnerable than the standard surrogate pond. St atic water bodies that have larger ratios of drainage area to water body volume would be expected to ha ve higher peak EECs than the standard pond. These water bodies will be either smaller in size or have large drainage areas. Smaller water bodies tend to have limited additional storage capacity and thus tend to ove rflow and carry pesticide in the discharge whereas the standard pond has no discharge. As watershed size increases beyond 10-ha, it becomes increasingly unlikely that the entire watershed is planted with a non-major single crop, which is all treated with the pesticide. Headwater streams can also have peak concentrations higher than the standard pond, but they tend to persist for only short periods of time and are then carried downstream.
OPP standard PRZM crop or orchard scenarios, wh ich consist of soils, weather and cropping practices that are location-specific, are used in the simulations to represent labeled uses of dodine. These scenarios are developed to represent high-end exposure sites in terms of vulnerability to runoff and erosion and subsequent off-site transport of pesticide.
3.2.2.1 Aquatic Exposure Modeling
Tier II Estimated Environmental Concentrations ( EECs) were estimated us ing EFED’s aquatic models PRZM and EXAMS (described in previous section). PR ZM is used to simulate pesticide transport as a result of runoff, erosion and spray drift from a 10-ha agricultural field and EXAMS considers environmental fate and transport of pesticides in surface water and predicts EECs in a standard pond (10,000-m 2 pond, 2-m deep), with the assumption that the small field is cropped at 100%. Simulations are carried out with the linkage program shell, PE4V01.pl (dated 8/13/2003), which incorporates the standard crop and orchard scenarios developed by EFED. Add itional information on these models can be found at: http://www.epa.gov/oppefed1/models/water/index.htm

. All dodine uses were considered in this assessment (appl es, cherries, peaches, pear s, pecans, strawberries, and walnuts; crab apples and ornamentals (SLN OR)). Various scenarios, where available, were simulated for specific crops to account for different geographical locations and agricultural practices ( e.g. , apples). A summary of the crop scenarios used to es timate dodine concentrations in the aquatic systemsPage 32 of 219 for ecological risk assessment is listed in Table , along with some characterization of why the scenario was chosen. The maximum application rate was chosen for each crop or group of crops.
A map showing the county-level dodine usage from the NCFAP (1992) and the locations of the EFED aquatic scenarios is also included in this assessment (Figure The 1992 NCFAP data were used to show the overlay with the PRZM scenarios because th e spatial data were available in-house while the 1997 data were not at the time that this assessment w as written. While these data provide some insight into the historic use of dodine, dodine use is likely to change with varying resistance of fungi. This point is illustrated by comparing the 1992 (Figure 3.2) a nd 1997 (Figure 3.1) NCFAP usage data for dodine. In 1992, there was no reported use of dodine in the stat e of Texas, whereas in 1997 some counties in Texas were amongst the highest use areas. Similarly, ther e are several states for which dodine use was reported in 1992 but not in 1997 ( e.g. , FL, AL, MS, CA etc.). Whether these discrepancies reflect changes in actual dodine use patterns or are an artifact of th e sampling/reporting, can not be determined without more information. This screening-level assessment, how ever, is designed to be protective at a national scale of all potential use sites. A map of the potential county-level use sites ( i.e. , total acreage of crops with dodine labeled uses) is shown in Figure 4.1 (AgCensus, 2002).
For this assessment, the apple use was modeled with scenarios in the Willamette Valley of Oregon, south eastern Pennsylvania, and in western North Carolina; all of these areas are high historic dodine use areas. Cherries were modeled in northern Michigan whic h is a high cherry-producing area as well as a high dodine use area. The peaches and pecans uses were represented by scenarios in central and southern Georgia, respectively. The pear and walnut uses were represented by scenarios in the central valley of California. Although the central valley of California do es not appear to be high in historic dodine use, it is an area of potential use. Additionally, since the p ear use pattern is similar to that of apples and the walnut use pattern is similar to that of pecans, the apple scenarios and th e GA pecan scenario can be viewed as surrogates for the pear and walnut uses as well. The strawberry use was represented by a scenario in central west Florida, the only curren tly available EFED strawberry scenario.

Table 3.3 Summary of crop scenarios used in estimating EECs
Dodine Uses (EPA Reg. #) Crop Scenario MLRA/ Met Station Scenario Characterization
Apple (55260-5); Crab Apples and Ornamentals (OR040025) OR apple : Marion County, Cornelius silt loam MLRA A2; W24229 Selected based on geographical location, agricultural practices, and use patterns. Only OR apple was used to represent OR SLN for crab apples and ornamentals PA apple : Lancaster County, Elioak silt loam MLRA 148; W14737 NC apple : Henderson County, Hayesville loam MLRA 130; W03812
Cherries 55260-6 MI cherries : Leelanau County, Kewaunee Silt Loam MLRA96; W14850 Selected based on agricultural practices and label information
Peaches 55260-5 GA peaches : Peach County, Greenville fine sandy loam MLRA 133; W93805 Selected based on agricultural practices and label informationTable 3.3 Summary of crop scenarios used in estimating EECs
Dodine Uses (EPA Reg. #) Crop Scenario MLRA/ Met Station Scenario Characterization

Page 33 of 219 Pears 55260-5 CA fruit : Central Valley, Exeter fine sandy loam MLRA 17; W93193 CA fruit scenario repr esents all non-citrus fruit grown in Central Valley CA. Selected based on label information
Pecans 55260-5 GA pecan : Mitchell and Dougherty Counties, Greenville Fine Sandy Loam MLRA 133A; W93805 Selected based on agricultural practices and label information

Strawberries 55260-5 FL strawberry : Hillsborough County, Myakka sand MLRA U-154; W12842 Selected based on agricultural practices and label information
Walnuts 55260-5 CA almond : San Joaquin County, Manteca fine sandy loam MLRA-17; W23232 CA almond scenario represents almond or walnut production. Selected based on label informationPage 34 of 219 Figure 3.2 1992 NCFAP county-level dodine usage (lbs./mi 2 ) relative to PRZM scenarios used in estimating exposure concentrations.
PRZM/EXAMS modeling of dodine was done for the ni ne scenarios identified in Table 3.3 using the current maximum label rate, maximum number of app lications per year and the minimum application interval of all the dodine uses represented by each scenario. The maximum number of applications per year and the minimum application interval were derived from the Dodine and DGH Use Closure Memo (dated 2/2/05), since these parameters are currently not specified on product labels. This assessment is contingent on these application restrictions being incorporated on product labels. Where applicable, modeling input parameters were selected according to current guidance ( Guidance for Selecting Input Parameters in Modeling the Environmental Fate and Transport of Pesticides Version II, EFED, February 28, 2002). Application-specific and chemical-speci fic input parameters for PRZM/EXAMS modeling are listed in Table 3.4 and Table 3.5 , respectively. All scenarios were simulated with aerial or ground spray applications (PRZM chemical application method, CAM = 2), and corresponding application efficiency and drift fractions equal to 0.95 and 0.05 respectivel y for air spray or 0.99 and 0.01 for ground spray. The condition for disposition of the pesticide re maining on foliage after harvest (PRZM variable IPSCND) was set to 1 (pesticide remaining on foliage is converted to surface application) for all uses consistent with deciduous orchards and strawberry cropping practices. Application dates were chosen based on the label information of the crop-stage to which dodine is applied, as well as on reported planting dates found in the documentation section of each crop scenario.Page 35 of 219 A soil partitioning coefficient (K ads ) for DGH of 10427 L/kg, the mean of four soils, was used. The 90% upper confidence bound on the mean was used for the aerobic soil and aerobic aquatic metabolism halflives (27.3 and 333 days, respectively). Since there was only one study for the anaerobic aquatic metabolism on DGH, three times the half-life was used to account for variability in the environment (7476 days). The maximum aqueous photolysis half- life, 770 days for DGH, was used and a hydrolysis half-life of 914 days also for DGH was used since the ecological water body is a constant pH 7.Page 36 of 219Table 3.4 PRZM/EXAMS application-specific input parameters.Dodine Use(s)(EPA Reg. #)PRZMscenariosMaximumsingle app. rate(lbs a.i./A)No. of app.per year/interval (d)1App. methoddrift/ app.efficiencyApplication timing2First applicationdateApples (55260-5);Crab apples andornamentals(OR040025)NC appleOR applePA apple1.95 6/5 aerial spray0.05/ 0.95Pre-bloom (scab) March 15April 1April 25Cherries(55260-6)MI cherries 1.3 6/7 aerial spray0.05/ 0.95Petal fall (leaf spot) May 10Peaches(55260-5)GA peaches 2.6 5/7 aerial spray0.05/ 0.95Shuck-split (bacterialspot)May 1Pears(55260-5)CA fruit 1.95 6/5 aerial spray0.05/ 0.95Pre-bloom (scab) March 10Pecans(55260-5)GA pecans 2.6 5/10 aerial spray0.05/ 0.95First leaves (scab) April 15Strawberries(55260-5)FL strawberries 1.3 5/7 ground spray0.01/ 0.99New growth (leafscorch)February 1Walnuts(55260-5)CA almond(walnuts)2.6 5/10 aerial spray0.05/ 0.95First leaves (leafblight)March 11 Maximum number of applications per yearand application intervals are currentlynot specified on product labels. The numberof applications and intervals are from theDodineand DGH Use Closure Memo(dated 2/2/05).2 Application timing information from product labels.Page 37 of 219 Table 3.5 PRZM/EXAMS chemical-specific inputs for all scenarios Parameter Value Source Comment Soil Partition Coefficient (K dL/kg) 10427 MRID 42148901 average of four values (2202, 6440, 15228, 18019) Aerobic Soil Metabolism Half-life (days) 27.3 MRID 434945201 90% upper confidence bound on the mean of two half-life values (17.5, 22.3) Molecular Weight (g/mol) 287.4 Vapor Pressure (torr) 1.5 x 10 -7 EPI Suite Henry’s Law Constant (atm-m 3

- mol) 9 x 10 -11 calculated
Solubility in Water at 25 o C (ppm) 6300 10x the water solubilityAerobic Aquatic Metabolism Halflife (days) 333 MRIDs 46438202, 42327401, 42414601 90% upper confidence bound on the mean of three half-life values

(38.9, 59.8, 227) Anaerobic Aquatic Metabolism Half-life (days) 7476 MRIDs 42763100, 42763002 3x the anaerobic aquatic metabolism half-life (2492) Hydrolysis Half-life @ pH 7 (days) 914 MRID 42242601 pond scenario pH 7 Aquatic Photolysis Half-life (day s) 770 MRID 42419001 maximum value reported Foliar Extraction 0.5 default Foliar Decay Rate 0 default stable with respect to foliar degradation
Simulated EECs for all scenarios are presented in Table 3.6. Copies of the input and output files are in Appendix C . Acute EECs range from 0.80 - 43 μg/L, 21-day chronic EECs range from 0.28 - 8.7 μg/L and 60-day average EECs range from 0.26 - 7.8 μg/L.Page 38 of 219 Table 3.6 Estimated aquatic exposure con centrations calculated with PRZM/EXAMS. Dodine uses (EPA Reg. # ) Scenario Yearly Max. App. Rate (lbs. a.i./A) 1-in-10 Year Acute (μg/L) 1-in-10 Year 21-day Chronic

(μg/L) 1-in-10 Year 60-day Chronic

(μg/L) Apples (55260-5); Crab apple, Ornamentals (OR040025) NC apple 11.7 7.5 3.1 2.8 OR apple 11.7 6.4 2.7 2.4 PA apple 11.7 43 8.7 7.8 Cherries (55260-6) MI cherries 7.8 24 4.5 4.0 Peaches (55260-5) GA peaches 13.0 16 3.2 2.9 Pears (55260-5) CA fruit 1 11.7 6.0 2.4 2.1 Pecans (55260-5) GA pecans 13.0 19 4.8 4.6 Strawberries (55260-5) FL strawberry 6.5 0.80 0.28 0.26
Walnuts (55260-5) CA almond 1 (walnut) 13.0 7.8 2.6 2.4

1 Scenario simulated without irrigation because of a known error in irrigation algorithms in PRZM 3.12 beta The highest acute EECs predicted are for the PA appl e scenario followed by the MI cherries scenario with EECs of 43 and 24 μg/L, respectively. Even though the highest annual application rates were for GA peaches, GA pecans and CA almond at 13.0 lbs a.i. /A, these did not produce the highest EECs. The average runoff and erosion and the loading of dodine in runoff, erosion and spray drift predicted by PRZM for each scenario are shown in Table 3.7 . The sum of the sediment loss, runoff and pesticide loading associated with these two compartments over the entire simulation was divided by the number of years in the simulation to obtain average yearly flux es. For spray drift, the exact yearly loading was calculated from the application rate, number of appli cations and the inputted fraction of drift (0.05 and 0.01 for aerial and ground spray, respectively). In all simulations, erosion was the dominant route of dodine loading to the pond relative to runoff, accoun ting for as much as 99.9% of the average yearly loading to the pond for PA apple and MI cherries. Both of these scenarios resulted in the highest EECs and are characterized by the highest average yearly erosion fluxes, 56 and 27 ton ha -1 yr -1 . Spray drift was the dominant route of dodine loading to the pond in one case accounting for 74.7% of the average yearly loading for CA fruit, a scenario characterized by both low runoff and low erosion. Even though spray drift was only the dominant route of off-site trans port for this one scenario and the resulting EECs are among the lowest, there is a possibility that the exposure due to spray drift alone could result in exceedances of aquatic levels of concern. This possib ility is further explored in section 4.2.1 in the Risk Description.Page 39 of 219 Table 3.7. Relative contribution of erosion, runoff and spray drift to PRZM-simulated loading to pond Average Erosion Average Runoff Average Dodine Loading to Pond
Erosion Runoff Drift
Scenario ton ha -1 yr -1 m 3 ha -1 yr -1 kg a.i. ha -1 yr -1 (% of total) NC apple 3.1 1589 279 (99.3) 1.2 (0.4) 0.66 (0.2) OR apple 0.92 756 23 (96.6) 0.13 (0.6) 0.66 (2.8) PA apple 56 1152 1750 (99.9) 1.0 (0.1) 0.66 (0.0) MI cherries 27 568 778 (99.9) 0.39 (0.1) 0.44 (0.1) GA peaches 2.6 677 219 (99.4) 0.69 (0.3) 0.73 (0.3) CA fruit 1 0.002 123 0.18 (20.5) 0.04 (4.8) 0.66 (74.7) GA pecans 11 3363 837 (99.5) 3.1 (0.4) 0.73 (0.1) FL strawberry 0.58 5527 14 (87.6) 1.9 (11.9) 0.07 (0.5) CA almond 1 (walnut) 0.07 359 8.2 (89.4) 0.24 (2.6) 0.73 (7.9) 1 Scenario simulated without irrigation because of a known error in irrigation algorithms in PRZM 3.12 beta The ecological pond modeled with EXAMS is a static water body of fixed volume with no outlet. Since dodine was assumed relatively persistent in aquatic e nvironments with inputted aquatic dissipation halflives ranging from 333 to 7476 d (see Table 3.5) and since the ecological pond has not outlet, there was an accumulation of dodine in the pond throughout the 30 year simulations. This was the case for all modeled scenarios and was verified by graphing daily concentrations over time (data not shown). Exposure endpoints, in this assessment, are based on y early peak concentrations. For scenarios where spray drift was a main route of off-site transport, pr edicted yearly peak concentrations increased over time with the simulation ( e.g. , CA fruit; see Appendix C). This is because spray drift is assumed constant for every application throughout the simulation ( i.e. , 1 and 5% for ground and aerial applications, respectively) and the yearly loading is, therefore, constant throughout the simulation. In these cases, a 1- in-10 year EEC does not reflect varying meteorological conditions that are expected once every 10 years, since the yearly peaks are not independent but ar e actually correlated to the previous year’s peak concentration. For scenarios where erosion was the main route of off-site transport, predicted yearly peakPage 40 of 219 concentrations are more variable and do not increase over time throughout the simulation ( e.g. , PA apple; see Appendix C). This is because erosion loadings are variable rather than constant throughout the simulation and the loading events are dependent on me teorological conditions relative to applications.
There is a known error in the irrigation algorithms in PRZM 3.12 beta and, therefore, scenarios that are historically simulated with irrigation were simulate d in a no-irrigation mode in this assessment. There is also a known compatibility error in the formatting of PRZM Record 9c (soil loss cover management factors -USLEC) in EFED standard scenarios with PR ZM 3.12 beta. Record 9 in the EFED scenarios is formatted according to a calendar-year starting on January 1 stand PRZM 3.12 beta expects the format to be according to a crop-year starting with emergence of the crop. This discrepancy may be important for compounds like dodine, for which erosion is a dominant route of off-site transport.
There is an interim version of PRZM, PRZM 9 date d 11/10/04, that has corrected irrigation routines and also corrects the formatting inconsistency in the Reco rd 9. This version was used to characterize the effect of the known errors described above. Using PRZM 9 to simulate irrigation for CA fruit and CA almond resulted in EECs that are not significantly di fferent than those estimated in the no-irrigation mode; in fact, the EECs were the same to two significant figures for both CA fruit and CA almond. Using PRZM 9 to correct the formatting inconsistency with Record 9c for the PA apple scenarios resulted in EECs that are slightly higher than those estimated with PRZM 3.12 beta. The acute, 21-day chronic and 60-day chronic EECs for PA apple simulated with PRZM 9 were 45, 9.1 and 8.2 ppb, respectively. These EECs are less than 5% higher than those predicted with PRZM 3.12 beta, which is well within the uncertainty of the model (Table 3.6).
3.2.2.2 Aquatic Exposure Monitoring and Field Data
No identifiable national scale monitoring studi es for dodine were available for the assessment.
3.2.3 Measures of Terrestrial Exposure
The measures of exposure for terrestrial receptors in Agency ecological risk assessments can be obtained from monitoring data, field studies, GIS analysis, and exposure modeling. Exposure modeling was used to generate measures of exposure for terrestrial or ganisms that may come in contact with areas where dodine may be used. GIS analyses of crops for wh ich dodine can be used were done to provide a perspective on the national use of dodine. In some refi nements, GIS analyses can be used to evaluate the likelihood of species specific exposure but these anal yses were not conducted in this assessment. Other data sources including monitoring efforts and field studies were not used to estimate dodine exposures because this information was not readily available.
This assessment focuses on the dietary route of exposure for terrestrial birds, mammals, and invertebrates as a result of spray applications of dodine. Even though other routes of exposure, primarily dermal, inhalation, and incidental soil ingestion, may contribute to overall exposure for a given receptor, frequently there is insufficient information availabl e to generate reasonable estimates of these exposure routes. Moreover, studies on the dermal or inhalation toxicity of a chemical may not exist, further inhibiting accurate estimates of risk as a function of these exposure routes. However, when pesticides are applied as a granular formulation, the exposure estimate is assumed to account for all methods ofPage 41 of 219 exposure. For dodine, there are no proposed uses for gra nular formulations; models were used to estimate dietary exposures resulting from spray applications only.
Exposure of free-ranging receptors is a function of th e timing and extent of pesticide application with respect to the location and behavior of identified r eceptors. EFED’s terrestrial exposure model generates exposure estimates assuming that the receptor is present on th e use site at the time that pesticide levels are their highest. The maximum pesticide residue con centration on food items is calculated from both initial applications and any additional applications taking into account pesticide degradation between applications. Although this is a conservative appr oach, it is not outside the realm of possibility, particularly when evaluating acute risks. Longer te rm exposure estimates used in generating chronic risk estimates also assume that a receptor is present when pesticide residue levels are highest, and furthermore assume the receptor uses the site to forage on a re peated basis although the exact frequency and duration of foraging events on the use site is not specified.
The duration of the exposure for estimates of acute risks is a single day and occurs when pesticide residues on food items are highest. The acute exposure level is the quantity of residues consumed in a single day associated with food requirements for that day.
The current approach to screening-level terrestrial e xposure estimation does not directly relate the timing of exposure to critical or sensitive population, community, or ecosystem processes. Given that for dodine, application timing and location are crop depe ndent, it is difficult to address the temporal and spatial co-occurrence of dodine use and sensitive ecol ogical processes. However, it is worth noting that pesticides are frequently used from spring through fall, which are times of active migrating, feeding, and reproduction for many wildlife species. The increasedenergy demands associated with these activities (as opposed to hibernation, for example) can increase the potential for exposure to pesticide contaminated food items since agricultural areas can represent a con centrated source of relatively easily obtained, highenergy food items. In this assessment, the spatial ex tent of exposure for terrestrial animal species is limited to the use area only. The majority of applied dodine will likely be limited to the use area although some spray drift is possible, particularly for air blast applications.

3.2.3.1 Terrestrial Exposure Modeling

3.2.3.1.1 Birds and Mammals
Estimated exposure concentrations for terrestrial recep tors were determined using the standard screeninglevel exposure model, TREX (v.1.1) . Maximum exposure levels were calculated for spray applications of dodine using maximum proposed application rates, maximum number ofPage 42 of 219 applications, and minimum application intervals for all proposed uses ( Table 3.8 ). These exposure estimates are based on a database of pesticide r esidues on wildlife food sources associated with a specified application rate. Essentially, for a single application, there is a linear relationship between the amount of pesticide applied and the amount of p esticide residue present on a given food item. These relationships for the various food items are dete rmined from the Kenaga nomogram as modified by Fletcher (Hoerger and Kenaga, 1972; Fletcher et al ., 1994). TREX (v.1.1) is a simulation model that, in addition to incorporating the nomogram relationship, al so includes pesticide degradation in the estimation of EECs.
TREX calculates pesticide residues on each type of food item on a daily interval for one year. A first order decay function is used to calculate the residue concentration at each day based on the concentrations present from both the initial and additional appli cations. The first-order rate equation is:


### C t 

### = C i 

### e -kt

Where C t is concentration at time t (days; t= 0 initially), C i is initial concentration after application, k is the foliar dissipation half-life, and t is time in days. The initial concentration, C i , is determined by multiplying the application rate by a constant specific to a food item. For 1.0 lb a.i. of pesticide per acre the upper-bound, food item concentration (ppm) is : 240 for short grass, 110 for tall grass, 135 for broadleaf plants and small insects, and 15 for fruits, pods, and large insects. In many cases, an empirically determined foliar dissipation half-life valu e is not available, in which case the default value of 35 days is used (Willis and McDowell, 1987). The f ood item concentration on any given day is the sum of all concentrations up to that day taking into account the first-order degradation. The initial application is on day 0 (t = 0) and runs for 365 days. Over the 365 day run, the highest residue concentration is used in calculations of the RQ.

Importantly, TREX considers exposure only in th e area where dodine is applied. The underlying assumption is that most, if not all, of the applied p esticide will settle in the use area. However, depending on weather conditions and type of application, sp ray drift of pesticides may occur, increasing the likelihood of wildlife exposure outside the use area. Since dodine is applied via spray methods, spray drift in some cases is likely. Particularly for air blast applications, spray drift could be significant.

Table 3.8 Estimates of foliar resi dues of dodine for proposed uses

Crop Application Rate lbs. a.i./A (# apps / interval, days) Food Items Maximum EEC (mg/kg) 1

Apples, Pears 1.95
(6 / 5) Short grass 2224 Tall grass 1019 Broadleaf plants/small insects 1251Table 3.8 Estimates of foliar resi dues of dodine for proposed uses

Crop Application Rate lbs. a.i./A (# apps / interval, days) Food Items Maximum EEC (mg/kg) 1

Page 43 of 219 Fruits, pods, seeds, and large insects 139

Cherries 1.3
(6 / 7) Short grass 1361 Tall grass 624 Broadleaf plants/small insects 766 Fruits, pods, seeds, and large insects 85

Crab Apples (OR only) 0.34
(6 / 5) Short grass 388 Tall grass 178 Broadleaf plants/small insects 218 Fruits, pods, seeds, and large insects 24

Ornamental Shade Trees (OR only) 0.85
(6 / 10) Short grass 789 Tall grass 362 Broadleaf plants/small insects 444 Fruits, pods, seeds, and large insects 49

Peaches 2.6
(5 / 7) Short grass 2410 Tall grass 1105 Broadleaf plants/small insects 1356 Fruits, pods, seeds, and large insects 151

Pecans, Walnuts 2.6
(5/ 10) Short grass 2183 Tall grass 1000 Broadleaf plants/small insects 1228 Fruits, pods, seeds, and large insects 136

Strawberries 1.3
(5 / 7) Short grass 1205 Tall grass 552 Broadleaf plants/small insects 678 Fruits, pods, seeds, and large insects 75
1 Predicted maximum residues for specified a pplication rates are based on Hoerger and Kenaga (1972) as modified by Fletcher et al. (1994).Page 44 of 219 3.2.3.1.2 Terrestrial Plants
Dodine exposure to terrestrial plants was estimatedusing OPP’s Terr Plant(v 1.0) model. The model produces EECs for plants residing near a use area thatmay be exposed to pesticides via runoff and/or spray drift. The EECs apply to plants that inhab it both dry and semi-aquatic (wetland) habitats. The EECs are generated from one application at the maxi mum rate for a particular use and compound-specific solubility information. The EECs for terrestrial plan ts for a single application of dodine at the maximum label rate for different crops are presented in Table 3.9

.


### Table 3.9. EECs for Terrestrial Plants Near Dodine Use Areas

Application Rate, lbs a.i./A (crop) EECs (lbs. a.i./A)
Total Loading to Adjacent Areas (sheet runoff + drift) Total Loading to SemiAquatic Areas (channelized runoff + drift) Drift EEC

2.6 (peaches, pecans, walnuts) 0.208 0.910 0.130

1.95 (apples, pears) 0.156 0.683 0.096

1.3 (cherries, strawberries) 0.104 0.096 0.065

3.2.3.2 Residue Studies
Environmental residue studies can also provide usef ul information regarding the potential exposure of terrestrial wildlife receptors. These data can be used to corroborate modeling results or to provide additional insights into chemical fate with respect to exposure. For dodine, no studies are available; all estimates of exposure are based on modeling efforts. 3.3 Ecological Effects Characterization
The ecological effects characterization for dodine is based primarily on registrant-submitted toxicity studies. Toxicity data from both dodine and DGH we re considered for aquatic species only since these compounds behave similarly in water; both dissociate to form the dodecylguanidinium ion. Importantly, the DGH studies incorporated the use of formulated product for exposures. Review of the formulated product ingredients indicate that the active ingredient, dodecylguanidine hydrochloride is the only ingredient expected to result in toxic effects. A summary of acute and chronic toxicity data for dodine and DGH used to calculate RQs is provided here and in Tables 3.10 , 3.11 and 3.12 . Additional summaries of laboratory toxicity data can be f ound in Appendix D. All registrant-submitted studies provided useful information for this assessment.
Dodine is practically non-toxic to honeybees, birds, and mammals on an acute exposure basis. However, dodine is moderately to very highly toxic to aquatic non-vascular plants, freshwater aquatic invertebrates,Page 45 of 219 freshwater fish, estuarine/marine invertebrates, mollu scs, and estuarine/marine fish on an acute exposure basis. Also, dodine is somewhat toxic to birds, mammals and freshwater aquatic invertebrates under longer-term, chronic exposures. Importantly, results from dodine toxicity tests do not likely capture dodine toxicity to all species of birds, mammals, or aquatic organisms. Typically, only a few surrogate species are used to represent all fresh water fish, birds, mammals, invertebrates, and plants. For reptiles and amphibians there are no currently required toxicity tests; birds and fish are used as surrogates for these taxa. The representation of numerous species by a few commonly used laboratory species is a source of uncertainty.
In addition to the data submitted in support of re gistration and the information compiled through the Agency pesticide review process, the ECOTOX (ECOT OXicity) database was used to identify additional toxicity data from the open literature. The ECOT OX database is a user-friendly, publicly-available, quality-assured, comprehensive tool for locating toxic ity data from the open literature and is maintained by EPA Mid-Atlantic Ecology Division. More information on ECOTOX can be found at: http://www.epa.gov/ecotox. Research papers are thoroughly screened using standard procedures before being accepted into ECOTOX thereby ensuring consis tent, high quality information. For dodine, no studies were identified in ECOTOX that were suitable for use in this assessment (Appendix E).
3.3.1 Aquatic Effects Characterization
3.3.1.1 Aquatic Animals

3.3.1.1.1 Freshwater Fish
Acute toxicity studies using both bluegill sunfish ( Lepomis macrochirus ) and rainbow trout ( Oncorhynchus mykiss ) indicated that dodine is to freshwater fish on an acute exposure basis. Of the two species, the rainbow trout is slightly more sensitive with an LC 50 of 570 ppb (430-750 ppb) compared to the blue gill sunfish Both studies were classified as ACCEPTABLE (formerly CORE) despite the fact that no controls were reported; it was stated in the report that the study was conducted generally in acco rdance with the EPA Fish-Pesticide Acute Toxicity Test guidelines and also in accordance with the Fi sh Bioassay Procedure in the 1970 edition of the Standard Methods (APHA) except as noted in the report. The report did not mention exclusion of controls indicating that controls were included in the study. No other freshwater fish acute toxicity studies for dodine are available for review.
A freshwater fish early life-stage chronic toxicity test on fathead minnows ( Pimephales promelas) was used to evaluate the chronic toxicity of dodine. Results from the study indicated a No Observed Adverse Effect Level (NOAEL) of 99 ppb and an associated Lowest Observed Adverse Effect Level (LOAEL) of 200 ppb. The basis of these effect levels was an obser ved decrease in both larval weight and larval length of dodine-exposed fish (Sousa, 1995). No other early life-stage toxicity studies or full life-cycle toxicity studies for freshwater fish were available for review.Page 46 of 219 3.3.1.1.2 Freshwater Invertebrates
Three freshwater invertebrate acute toxicity studies indicated that dodine is very highly toxic to waterfleas ( Daphnia magna ). The lowest estimated 48 hour-EC 50 was 17.8 ppb (14.8-22.3 ppb) and was based on immobilization of waterfleas. This study is classified as ACCEPTABLE.
An aquatic invertebrate life cycle test was conducted to evaluate the chronic toxicity of dodine to the freshwater aquatic invertebrate, Daphnia magna . There were significant effects of dodine on survival of first-generation daphnids, number of young produced, dry weight of fi rst-generation daphnids, and length of first-generation daphnids. The most sensitive endpoint was the number of young produced with a NOAEC of 7.3 ppb and a LOAEC of 13 ppb.

3.3.1.1.3 Estuarine/Marine Fish
Results from a DGH study on sheepshead minnows, Cyprinodon variegatus , were used in this risk assessment since the LC50 for the DGH study was lower th an that of a comparable study on dodine (See Appendix D). Sheepshead minnows were exposed to DGH under flow-through conditions for 96 hours to generate an estimate of the acute toxicity to an estuarine/marine fish. The LC 50 was 1782 ppb. The LC 50 classifies dodine as moderately toxic to estuarine/ marine fish. The study was conducted in a scientifically sound manner and meets the requirements for an estuarine/marine fish acute flow-through toxicity study.
No tests of the chronic toxicity of dodine to estuarine/marine fish were available for this assessment.

3.3.1.1.4 Estuarine/Marine Invertebrates
The acute toxicity value for estuarine/marine inve rtebrates used in this assessment is based on a DGH study. Although a study on estuarine/marine invert ebrates was available for dodine, the dodine study indicated a lack of toxicity to mysid shrimp, Americamysis bahia , (LC 50 = 2335 ppb) whereas the DGH toxicity study showed that DGH was highly toxic to mysid shrimp on an acute exposure basis. For the study with DGH, the 96-hour LC 50 was 59.4 ppb a.i. and the NOAEC was < 46.2 ppb a.i. and the LOAEC was 46.2 ppb a.i. (lowest concentration tested). Similar to the results from the study on mysid shrimp, a 96-hour shell deposition study on eastern oysters ( Crassostrea virginica ) indicated that DGH was highly toxic to this mollusc species. There were significant, concentration-dependent effects of dodine on shell deposition. However, a NOAEC could not be determinedsince oysters at the lowest test concentration showed significantly reduced shell deposition. The 96-hour EC 50 was 69.3 ppb (95% C.I. = 52.8 and 99 ppb) with a corresponding LOAEC of 9.9 ppb. The st udy was considered scientifically sound and meets the guideline requirements for a 96-hour flow-thr ough mollusc shell deposition acute toxicity test.
The large difference in mysid shrimp LC50s for DGH and dodine is somewhat surprising. Review of the DGH formulation ingredients used in the mysid study indicated that toxicity was likely the result of exposure to the active ingredient only. The next mo st abundant chemical in the formulation (17.5% by weight) has an estimated LC 50 in brown shrimp of 1150 ppm suggesting that it is not a likely contributor to the lower LC 50 associated with DGH. Further, review of both the dodine and DGH studies did notPage 47 of 219 reveal any obvious explanation for the difference in acute toxicity. Indeed, DGH and dodine are expected to behave similarly in aquatic environments. If th is were true, results from toxicity tests on aquatic species would likely show similar results with one chemical more or less sensitive than the other in random fashion. Examination of the data, however, indicate that for saltwater species, DGH appears to be more toxic. Further analysis or research may be re quired to characterize the relative toxicity of DGH and dodine to aquatic species. Again, for purposes of this assessment, it is assumed that DGH and dodine behave similarly in aquatic environm ents and therefore, the lowest toxi city value is used in calculating RQs. Discussion of both the DGH and the dodine studies is found in Appendix D.

There were no chronic estuarine/marine invertebra te toxicity data available for this assessment.



### Table 3.10. Summary of Acute and Chronic Aquatic Toxicity Data for Dodine and DGH

Species Acute Toxicity Chronic Toxicity
96-hr LC 50 (μg a.i./L) 48-hr EC 50 (μg a.i./L) Acute Toxicity (MRID) NOAEC / LOAEC (μg a.i./L) Affected Endpoints (MRID)
Rainbow trout Oncorhynchus mykiss (TGAI) 570 – (a) Highly toxic (Acc.# 132149) -- --

Fathead Minnow Pimephales promelas (TGAI) -- -- -- 99/ 200 Larval length and weight (438765-02)
Water flea Daphnia magna (TGAI) -- 17.8 Very highly toxic (423396-01) 7.3/13 Number young produced (438765-01) Sheepshead minnow Cyprinodon variegatus 1782 (b)

-- Moderately toxic (434855-06) -- -- Eastern oyster Crassostrea virginica 69.3 (b)

-- Highly toxic (434855-08) -- -- Mysid shrimp Americamysis bahia 59.4 (b)

-- Highly toxic (434855-07) -- --

(a) Indicates toxicity value not available (b) Based on a DGH study 3.3.1.1.5 Aquatic Plants
Aquatic plant toxicity testing indicated that the nonvascular plant, Selenastrum capricornutum (green algae), is particularly sensitive to dodine at th e concentrations tested. The estimated 120-hour EC 50 was 0.95 and based on cell density effects. The corresponding 120-hour NOAEC for this effect was 0.082 ppb. Based on these results, dodine is classified as very highly toxic to green algae. A complete evaluation of the toxicity of a compound to aquatic pl ants requires at least one study on aquatic vascular plants. This study was not available for dodine.Page 48 of 219 Table 3.11 Summary of Aquatic Plant Toxicity Data for Dodine.
Species/ static or

static renewal % ai NOAEC/ EC 50 (μg a.i./L)

(measured) MRID No.

Green algae Selenastrum capricornutum (120-hour)/ Static 94.1 Technical /0.95 426951-01

3.3.1.2 Terrestrial Animals

3.3.1.2.1 Birds
Two studies on the acute toxicity of dodine to birds we re available for review. The studies indicated that dodine is practically non-toxic to mallard ducks, Anas platyrhynchos , and slightly toxic to bobwhite quail, Colinus virginianus , on an acute exposure basis (See Appendi x D). Since bobwhite quail showed more sensitivity to dodine, results from that study were used for this assessment. The bobwhite quail LD 50 was 690 mg a.i./kg body weight. In addition to mortality , observed sublethal effects included ruffled feathers and depression. Subacute dietary exposures of the same species indicated that dodine was practically non-toxic to both species with LC 50 s of 8413 ppm and >10000 ppm for bobw hite quail and mallard ducks, respectively. In the subacute bobwhite quail study, other toxic signs included depression, reduced reaction to external stimuli, wing droop, and coordinati on loss. No mortality was seen in the acute dietary study on mallard ducks.
Three avian toxicity tests were conducted to evaluatethe reproductive toxicity of dodine. Only one was considered useful for quantitative estimates of avia n risks; the other two suffered from design errorsand/or control mortalities (see Appendix D). In the one study classified as ACCEPTABLE, twenty-fourweek old mallard ducks, Anas platyrhynchos , were exposed to dodine in feed at several concentrations. There were significant effects of dodine on the number of eggs laid, eggs set, viable embryos, viable 3- week embryos, hatchlings, 14-day old survivors, a dult food consumption, hatchling body weights, and adult female body weights at diet concentrations > 600 ppm (mg a.i./kg feed). The NOAEC for these effects was 200 ppm. In a similar study conducted on bobwhite quail (Colinus virginianus ), no toxic effects were observed at any exposure level incl uding the highest exposure level (300 ppm) which was the reason for the classification of SUPPLEMENTAL. These data indicate that use of the mallard duck data likely represents the lowest available toxicity es timate. However, it is important to acknowledge that NOAECs generated from these studies are dependent on chosen exposure levels and estimates of true NOAECs are difficult to obtain.

3.3.1.2.2 Mammals
Wild mammal testing is required on a case-by-case basis only, and is dependent on the results of lower tier laboratory mammalian studies, intended use patterns, and pertinent environmental fate characteristics. In most cases, rat or mouse toxicity values obtaine d from the Agency’s Health Effects Division (HED) are used as surrogates for wild mammal toxicity testing.Page 49 of 219 The acute toxicity of dodine was evaluated using the common laboratory rat. The acute toxicity of dodine differed between male and female rats withfemales showing greater sensitivity. The LD 50 s were 1056 and 1698 mg/kg for females and males, respectively, with a combined LD 50 of 1379 mg/kg. For this assessment, the lower female-specific value of 1056 mg/kg was used.
As with the acute mammalian toxicity data, chronic toxicity data are obtained from the Agency’s HED and are considered representative of wild mammals. These studies provide adequate toxicity data on the potential effects of chronic dodine exposure in mammals . Chronic studies in both dogs and rats show that the endpoint most sensitive to dodine exposure seems to be reduced body weight/growth in adults and/or offspring. In rats ( Rattus norvegicus ), the NOAEL was 30.28 mg/kg/day for decreased male pup body weight, which corresponds to a dietary level of 400 ppm (mg a.i./kg feed). In dogs ( Canis familiaris ), the NOAEL was 2.0 mg/kg/day based on decreased food cons umption and decreased weight gain in female dogs that received dodine via capsule. For this assessmen t, the rat toxicity data were used since these studies are more commonly encountered and also, th e results from the dog study were based on a small number of experimental animals indicating a less robust experimental design. Growth or body size as a measure of effect for mammals is used because growth rate or body size can be important for survival and reproduction of wild mammals. Frequently, a larger size is associated with in creased chances of survival or competitive advantage and growth rate directly influences maturation rate, a strong contributor to population growth rate in many populations.

3.3.1.2.3 Terrestrial Invertebrates
Acute toxicity of dodine to terrestrial invertebrates was assessed in studies where honey bees ( Apis mellifera ) were exposed to dodine via both contact and oral routes. The contact LD 50 was more than 200 : g per bee, the highest dose tested. This charact erizes dodine as practically non-toxic to honey bees via contact exposure. In the oral toxicity test, susp ensions of dodine in 50% sucrose water were prepared such that four test concentrations were administered to test bees. Similar to the contact toxicity study, dodine did not cause significant mortality at the concentrations tested. The resulting LD 50 was > 200 : g per bee. Both the oral and contact studies were conducted in a scientifically sound manner and are classified as ACCEPTABLE.Page 50 of 219 Table 3.12 Summary of Acute and Chronic Toxi city Data for Terrestrial Organisms Exposed to Dodine.

Species Acute Toxicity Chronic Toxicity

LD 50 (mg/kg) Acute Oral Toxicity (MRID) 8-day LC 50 (mg/kg diet) Subacute Dietary Toxicity (MRID) NOAEC/LOAEC (mg/kg diet)

(MRID) Affected Endpoints

Northern bobwhite quail

Colinus virginianus 690 Slightly toxic (Acc.# 130888) 8413 Practically nontoxic (Acc.# 226855) <75/75 (458197-24) growth (14- day survivor

weight); reproduction (eggs cracked)

Mallard duck Anas platyrhynchos 2214 Practically non-toxic

(Acc.# 131455) >10000 Practically nontoxic (Acc.# 226855) 200/600 (432746-02) multiple reproductive

Dog Canis familiaris -- -- -- -- 2.0/10.0 Mg/kg/d (442461-01) body weight

Laboratory rat Rattus norvegicus 1056 Practically non-toxic (449224-01) -- -- 30.28 /60.5 (442460-01) decreased pup body weights

Honey bee Apis meliferus >200 (μg/bee contact) Practically non-toxic (4013155-05) -- -- -- --

(a) Toxicity data unavailable

3.3.1.2.4 Terrestrial Plants
Tier I plant studies were submitted in s upport of the re-registration of dodine ( Table 3.13 ). Tier I studies are aimed at quickly evaluating the phytotoxicity of a compound at the maximum single application rate, which for dodine is 2.6 lbs a.i./A. Tier II plant studies are triggered when effects from the Tier I studies exceed 25% of control. For dodine, cabbage showed a 25% reduction in plant dry weight compared to controls. This was the only effect greater than or equal to 25% although several effects were > 20%. No Tier II plant studies were submitted for review, precluding the calculation of RQs. In cases where no Tier II plant studies are available for review and at least one plant species shows effects > 25% for Tier I studies, risks are assumed for terrestrial plants.Page 51 of 219 Table 3.13 Tier I Results for the Effects of Dodine on Terrestrial Plants Crop Study Species % Reduction Compared to Controls Seedling Emergence Plant Height Plant Dry Weight Seedling Emergence (MRID# 426951-02) Monocots Corn 0 1 10 Oats 0 9 0 Onion 15 0 11 Ryegrass 0 5 0 Dicots Radish 0 1 9 Soybean 0 7 11 Lettuce 2.5 17 14 Tomato 6 0 0 Cucumber 0 2 14 Cabbage 3 22 25 Vegetative Vigor(MRID# 426951-03) Monocots Corn – (a) 0 0 Oats -- 2 0 Onion -- 5 20 Ryegrass -- 0 8 Dicots Radish -- 5 0 Soybean -- 0 3 Lettuce -- 14 0 Tomato -- 1 0 Cucumber -- 4 15 Cabbage -- 12 21

(a) This endpoint not measured

4 RISK CHARACTERIZATION
Risk characterization is the integration of expos ure and effects characterization to determine the ecological risk from the use of dodine and the likeli hood of effects on aquatic life, wildlife, and plants based on varying pesticide-use scenarios. The ri sk characterization provides an estimation and aPage 52 of 219 description of the risk; articulates risk assessment assu mptions, limitations, and uncertainties; synthesizes an overall conclusion; and provides the risk manage rs with information to support regulatory decision making.

4.1 Risk Estimation - Integration of Exposure and Effects Data
Results of the exposure and toxicity effects data ar e used to evaluate the likelihood of adverse ecological effects on non-target species. For the assessment of dodinerisks, the risk quotient (RQ) method is used to compare exposure and toxicity values. Estimated e nvironmental concentrations (EECs) are divided by acute and chronic toxicity values. The resulting RQs are compared to the Agency’s levels of concern (LOCs). These LOCs are the Agency’s interpretive po licy and are used to analyze potential risk to nontarget organisms and the need to consider regulator y action. These criteria are used to indicate when a pesticide’s use as directed on the label has the potential to cause adverse effects on non-target organisms. A summary of toxicity values used to calculate Rqs is provided in Table 4.1; a more detailed discussion of dodine toxicity can be found in section 3.3 and Appendix D.

Table 4.1 Summary of Toxicity Data for Most Sensitive Test Species Used to Calculate Risk Quotients to Evaluate Ecological Risks of Dodine Use. Taxonomic Group Most Sensitive Species Exposure Category Toxicity Value

Birds a Bobwhite quail ( Colinus virginianus ) Mallard duck ( Anas platyrhynchos ) Acute (LD 50/LC 50 )
Chronic (NOAEC) 690 mg/kg LD50 8413 mg/kg-feed LC50 200 ppm (feed) Mammals Laboratory rat ( Rattus norvegicus ) Acute LD 50 and Chronic NOAEL/NOAEC 1056 mg/kg LD50 30.28 mg/kg (chronic) 400 ppm (chronic diet) Terrestrial insects Honeybees ( Apis mellifera ) Acute Oral LD 50 > 200 : g a.i./bee

Freshwater fish b Rainbow trout ( Oncorhynchus mykiss ) Fathead minnow ( Pimephales promelas ) Acute LC 50
Chronic NOAEC 570 ppb
99 ppb

Freshwater invertebrates Water flea ( Daphnia magna )
Midge ( Chironomus riparius ) Acute LC 50 and Chronic NOAEC

Chronic NOAEC (Benthic) 17.8 ppb 7.3 ppb
380 ppb (pore-water)Table 4.1 Summary of Toxicity Data for Most Sensitive Test Species Used to Calculate Risk Quotients to Evaluate Ecological Risks of Dodine Use. Taxonomic Group Most Sensitive Species Exposure Category Toxicity Value

Page 53 of 219 Estuarine/marine fish Sheepshead minnow (Cyprinodon variegatus) Acute LC 50 1782 ppb

Estuarine/marine invertebrates Mysid shrimp (Mysidopsis bahia ) Eastern oyster ( Crassostrea virginica ) Acute LC 50
Acute EC 50 59.4 ppb
69.3 ppb Terrestrial plants c Monocots – corn ( Zea mays ) Dicots – soybean ( Glycine max ) Acute (Tier I, no EC 50 estimated) No EC 50 estimate due to lack of Tier II data - risks asssumed.
Aquatic plants and algae Green algae ( Selenastrum capricornutum ) Acute EC 50 0.95 ppb 0.082 ppb (NOAEC)

a Birds are used as surrogates for terrestrial phase amphibians and reptiles (US EPA, 2004).
b Freshwater fish are used as surrogates for aquatic phase amphibians (US EPA, 2004).

c Four species of two families of monocots, of which one is corn ; six species of at least four dicot families, of which one is soybeans. 4.1.1 Non-target Aquatic Animals and Plants
Surface water concentrations resulting from dodine application to agricultural and non-agricultural crops were predicted with the Tier II models PRZM-EXAMS. Nine scenarios that consisted of aerial or ground spray applications of dodine, including apples (in No rth Carolina, Oregon and Pennsylvania), crab apples (in Oregon), ornamentals (in Oregon), cherries (in Michigan), peaches (in Georgia), pears (in California), pecans (in Georgia), strawberries (in Florida) and wal nuts (in California) were modeled. The crab apple and ornamental use patterns were modeled with the OR apple scenario as a surrogate. The California fruit scenario is intended to be representative of pears. The California almond scenario is representative of the walnut use pattern.
To determine if spray drift is a major factor in estimating EECs, average yearly loadings of dodine in runoff, eroded sediment and spray drift were compared . Results, as indicated in Table 3.7, show that dodine adsorbed to eroded sediment was the dominant route of loading to the pond relative to runoff for all scenarios. Drift was only the dominant route of o ff-site transport for one scenario (CA pears) and the resulting EECs were some of the lowest.
One-in-10 year peak EECs were compared to acute toxicity endpoints to derive acute RQs and 1-in-10 year 21-day average EECs were compared to chronic toxicity endpoints to derive chronic RQs. Acute and chronic RQs for freshwater and saltwater organisms are summarized in Table 4.2 and Table 4.3.Page 54 of 219 Chronic RQ values could not be derived for estuarine/marine fish and invertebrates due to a lack of toxicity data for these taxa.

For aquatic non-vascular plants, 1-in-10 year peak EECs were compared to acute EC 50 values to derive acute non-listed species RQs. RQs for aquatic non-vascular plants are summarized in Table 4.2.

4.1.1.1 Freshwater Fish and Invertebrates

Table 4.2 lists the RQs for freshwater fish, aquatic- phase amphibians, and aquatic invertebrates potentially exposed to dodine. For freshwater fish and aquatic-phase amphibians, the acute RQ value of 0.08 based on aerial application of dodine to Penns ylvania apples (11.7 lb ai/A/yr) exceeds the listed species acute risk LOC. The acute RQ values associated with all other modeled scenarios are less than the listed species LOC. For freshwater fish and aquatic-phase amphibians, the chronic RQ values associated with all modeled scenarios are less th an the chronic risk LOC (RQ < 1).
For freshwater invertebrates, acute RQs for all mode led scenarios, except Florid a strawberry, exceed the acute restricted use and listed species LOCs (RQs = 0. 34 - 2.4). In addition, for the current application rates modeled, the acute risk LOC is exceeded for freshwater invertebrates for aerial applications to Pennsylvania apples (11.7 lb ai/A/yr; RQ = 2.4), Mich igan cherries (7.8 lb ai/A/yr; RQ = 1.4), Georgia pecans (13.0 lbs. a.i./A/yr; RQ = 1.1), and Georgia p eaches (13.0 lbs. a.i./A/yr; RQ = 0.9). For freshwater invertebrates, the chronic RQ value based on aerial application of dodine to Pennsylvania apples (11.7 lb ai/A/yr) exceeds the chronic LOC (RQ = 1.2).
In addition to toxicity studies on freshwater fish a nd invertebrates, a non-guideline 28-day toxicity study on sediment-water-dwelling larvae of Chironomus riparius was available for review (MRID#464382-01). This study showed that there were no significant eff ects of dodine at any of the concentrations tested. The highest pore-water concentration tested was 380 ppb. The 1-in-10 year, 21-day chronic estimated pore-water concentration from PRZM/EXAMS was 7. 3 ppb for the Pennsylvania apples scenario. The RQ based on these values is 0.02, which does not exceed any LOC. This analysis indicates that risk to benthic invertebrates is expected to be low.



### 4.1.1.2 Estuarine/Marine Fish and Invertebrates

Table 4.3 lists the RQs for estuarine/marine fish and i nvertebrates potentially exposed to dodine. Acute RQ values calculated for estuarine/marine fish for all modeled scenarios are less than the listed species acute risk LOCs (RQs < 0.05). were exceeded for for all modeled scenarios except Florida strawberry (RQs = 0.10 - 0.72). The acute risk LOC of 0.5 for non-liste d invertebrate species was exceeded for Pennsylvania apples (RQ = 0.72) For molluscs, acute RQs for all modeled scenarios, except Florida strawberry and California pear exceeded acute restricted use and listed species acute risk LOCs (RQs = 0.11 - 0.62). Additionally, the RQ for the Pennsyvannia apple scen ario exceeds the acute LOC of 0.5 for molluscs. The RQ for the California pear scenario exceeds th e listed species acute risk LOC (RQ = 0.09) forPage 55 of 219 molluscs.

4.1.1.3 Aquatic Plants

Table 4.2 lists the RQs for aquatic, non-vascular plants potentially exposed to dodine. For non-listed non-vascular plants, acute RQs for all modeled scenario s, except Florida strawbe rry, exceed the acute risk LOC (RQs = 6.3 - 45).Page 56 of 219 Table 4.2 Risk Quotients for Freshwater Fish, Aquatic Amphibians, Aquatic Invertebrates and Non-vascular Plants Exposed to Dodine Use Application Rate lbs. a.i./A (# app/ interval, days) EECs (ppb) Fish and Amphibian RQs

LC 50 = 570 ppb NOAEC = 99 ppb Invertebrate RQs EC 50 = 17.8 ppb NOAEC = 7.3 ppb Non-vascular Plant RQs EC 50 = 0.95 ppb NOAEC = 0.082 ppb
Acute 21-day 60-day acute chronic acute chronic acute (1) acute (2) Apples (PA) 1.95 (6/5) 43 8.7 7.8 0.08* 0.08 2.42*** 1.19 45.26 524

Cherries (MI) 1.3 (6/7) 24 4.5 4.0 0.04 0.04 1.35 *** 0.62 25.26 293

Peaches (GA) 2.6 (5/7) 16 3.2 2.9 0.03 0.0 0.90*** 0.44 16.84 195

Pears (CA) 1.95 (6/5) 6.0 2.4 2.1 0.01 0.02 0.34** 0.32 6.31 73

Pecans (GA) 2.6 (5/10) 19 4.8 4.6 0.03 1.07*** 0.66 20.00 232

Strawberries (FL) 1.3 (5/7) 0.80 0.28 0.26 0.00 0.04 0.04 0.84 10

Walnuts (CA) 2.6 (5/10) 7.8 2.6 2.4 0.01 0.44** 0.36 8.21 95

* exceeds LOC for acute risk to listed fish or invertebrate species (RQ $ 0.05) ** exceeds LOCs for acute risk to listed fish orinvertebrate species and restricted use (RQ $ 0.1) *** exceeds LOCs for acute risk, acute risk to listed fish or invertebra te species, and restricted use (RQ $ 0.5) (1) bolded numbers exceed LOC for acute ri sk to aquatic plant species (RQ > 1.0, calculated as EC 50/acute EEC) (2) bolded numbers exceed LOC for acute risk to endangered aquatic plant species (RQ > 1.0, calculated as NOAEC/acute EEC)Page 57 of 219 Table 4.3 Risk Quotients for Saltwater Fish and Invertebrates Exposed to Dodine Use Application Rate lbs. a.i./A (# app/ interval, days) EECs (ppb) Fish RQs LD 50 = 1782 ppb Invertebrate RQs EC 50 = 59.4 ppb Mollusc RQs EC 50 = 69.3 ppb Acute 21-day 60-day acute chronic acute chronic acute
Apples (PA) 1.95 (6/5) 43 8.7 7.8 0.02 NA 0.72*** NA 0.62***

Cherries (MI) 1.3 (6/7) 24 4.5 4.0 0.01 NA 0.40** NA 0.34**

Peaches (GA) 2.6 (5/7) 16 3.2 2.9 0.01 NA 0.27** NA 0.23**

Pears (CA) 1.95 (6/5) 6.0 2.4 2.1 0.00 NA 0.10** NA 0.09*

Pecans (GA) 2.6 (5/10) 19 4.8 4.6 0.01 0.32** 0.27**

Strawberries (FL) 1.3 (5/7) 0.80 0.28 0.26 0.00 0.00 0.00

Walnuts (CA) 2.6 (5/10) 7.8 2.6 2.4 0.00 0.13* 0.11**

* exceeds LOC for acute risk to listed species (RQ $ 0.05) ** exceeds LOCs for acute risk to lis ted species and restricted use (RQ $ 0.1) *** exceeds LOCs for acute risk , acute risk to listed speci es, and restricted use (RQ $ 0.5) 4.1.2 Non-target Terrestrial Animals
The EEC values for terrestrial exposure for spray applications of dodine were derived from the Kenaga nomograph, as modified by Fletcher et al . (1994), based on a large set of actual field residue data. EECs were calculated for all labeled uses (apple, cherries, crab apples, ornamentals, peaches, pears, pecans, strawberries and walnuts) with application rates ra nging from 0.34 to 2.6 lb ai/A. Risk quotients are based on the most sensitive studies that yielded the low est toxicity values. For this assessment, the lowest LC 50 and NOAEC values were used for birds and the lowest LD 50 and NOAEL were used for mammals (based on lab rat studies).
Acute and chronic RQs for birds are presented in Tables 4.4 and 4.5 , respectively; acute and chronic RQs for mammals are summarized in Tables 4.6 and 4.7 , respectively.

4.1.2.1 Birds

Table 4.4 summarizes the avian dose-based acute RQs for fo liar uses of dodine. Acute, acute restricted use and/or listed species acute risk LOCs are exceed ed for birds that consume short grass, tall grass, broadleaf plants, and small insects across most wei ght classes for all modeled scenarios and applicationPage 58 of 219 rates, with acute RQs ranging from 0.06 to 5.6. In addition, acute RQ values also exceed acute restricted use and/or listed species acute risk LOCs for bird s that consume fruits, pods, seeds, and large insects at application rates for all modeled scenarios, except crab apples, at the smallest weight class, and in some cases at the medium weight class (RQs that represent exceedances = 0.12 - 0.35).

Table 4.5 summarizes the avian dietary-based acute and chronic RQs for foliar uses of dodine. Acute, acute restricted use and/or listed species LOCs are exceeded for birds that consume short grass, tall grass (in most cases), broadleaf plants, and small insects based on the dietary-based toxicity endpoint for all modeled scenarios and application rates, with acu te RQs that represent exceedances ranging from 0.10 to 1.1. Importantly, the dietary-based acute RQs are provided for comparison purposes and are not the primary contributor to conclusions of avian risk sin ce there is less uncertainty with dose-based estimates. The avian chronic risk LOCs are exceeded for bird s that consume short grass, tall grass (in most cases), broadleaf plants, and small insects for all modeled scen arios and application rates, with chronic RQs that represent exceedances ranging from 1.09 to 12.

Table 4.4 Avian dose-based acute RQ values for proposed uses of dodine based on a bobwhite quail LD 50 = 690 mg/kg-bw and upper-bound Kenaga residues. Use Application Rate lbs. a.i./A (# app / interval, days) Body Weight, g Avian Acute Risk Quotients (based on upper-bound Kenaga residues)

Short Grass Tall Grass Broadleaf Plants/Small Insects Fruits/Pods/Seeds Large Insects

Apples 1.95 (6 / 5) 20 5.19*** 2.38*** 2.92*** 0.32**
100 2.32*** 1.07*** 1.31*** 0.15*
1000 0.73*** 0.34** 0.41** 0.05
Cherries 1.3
(6 / 7) 20 3.18*** 1.46*** 1.79*** 0.20**
100 1.42*** 0.65*** 0.80*** 0.09
1000 0.45** 0.21** 0.25** 0.03 Crab apples (OR) 0.34
(6 / 7) 20 0.90*** 0.41** 0.51*** 0.06
100 0.41** 0.19* 0.23** 0.03 1000 0.13 * 0.06 0.07 0.01 Ornamental Shade Trees (OR) 0.85
(6 / 10) 20 1.84*** 0.84*** 1.04*** 0.12* 100 0.83*** 0.38** 0.46** 0.05 1000 0.26** 0.12* 0.15* 0.02 Peaches 2.6
(5 / 7) 20 5.62*** 2.58*** 3.16*** 0.35** 100 2.52*** 1.15*** 1.42*** 0.16*
1000 0.80*** 0.36** 0.45** 0.05 Pears 1.95
(6 / 7) 20 5.19*** 2.38*** 2.92*** 0.32** 100 2.32*** 1.07*** 1.31*** 0.15* 1000 0.73*** 0.34** 0.41** 0.05Table 4.4 Avian dose-based acute RQ values for proposed uses of dodine based on a bobwhite quail LD 50 = 690 mg/kg-bw and upper-bound Kenaga residues. Use Application Rate lbs. a.i./A (# app / interval, days) Body Weight, g Avian Acute Risk Quotients (based on upper-bound Kenaga residues)

Short Grass Tall Grass Broadleaf Plants/Small Insects Fruits/Pods/Seeds Large Insects

Page 59 of 219 Pecans 2.6
(5 / 10) 20 5.09*** 2.33*** 2.87*** 0.32** 100 2.28*** 1.05*** 1.28*** 0.14* 1000 0.72*** 0.33** 0.41** 0.05 Strawberries 1.3
(5 / 7) 20 2.81*** 1.29*** 1.58*** 0.18 * 100 1.26*** 0.58*** 0.71*** 0.08 1000 0.40** 0.18* 0.22** 0.02 Walnuts 2.6
(5 / 10) 20 5.09*** 2.33*** 2.87*** 0.32** 100 2.28*** 1.05*** 1.28*** 0.14* 1000 0.72*** 0.33** 0.41** 0.05 * exceeds LOC for acute risk to listed species (RQ $ 0.1) ** exceeds LOCs for acute risk to listed species and restricted use (RQ $ 0.2) *** exceeds LOCs for acute risk, acute risk to listed species, and restricted use (RQ $ 0.5)

Table 4.5 Avian dietary-based acute and chroni c RQ values for proposed uses of dodine based on upper-bound Kenaga residues. Use/App. Method Application Rate lbs. ai/A (# app / interval, days) Food Items Upper Bound EEC (mg/kg) a Acute Dietary

RQ (EEC/ LC 50 ) b Chronic RQ (EEC/ NOAEC)

Apples 1.95
(6 / 5) Short grass 2224 0.26** 11.12 Tall grass 1019 0.12* 5.10 Broadleaf plants/small insects 1251 0.15* 6.25 Fruits, pods, seeds, and large insects 139 0.02 0.69

Cherries 1.3
(6 / 7) Short grass 1361 0.16* 6.81 Tall grass 624 0.07* 3.12 Broadleaf plants/small insects 766 0.09 3.83 Fruits, pods, seeds, and large insects 85 0.01 0.43Table 4.5 Avian dietary-based acute and chroni c RQ values for proposed uses of dodine based on upper-bound Kenaga residues. Use/App. Method Application Rate lbs. ai/A (# app / interval, days) Food Items Upper Bound EEC (mg/kg) a Acute Dietary

RQ (EEC/ LC 50 ) b Chronic RQ (EEC/ NOAEC)

Page 60 of 219 Crab Apples (OR) 0.34
(6 / 5) Short grass 388 0.05 * 1.94 Tall grass 178 0.02 0.89 Broadleaf plants/small insects 218 0.03 1.09 Fruits, pods, seeds, and large insects 24 0.00 0.12

Peaches 2.6
(5 / 7) Short grass 2410 0.29* 12.05 Tall grass 1105 0.13* 5.52 Broadleaf plants/small insects 1356 0.16* 6.78 Fruits, pods, seeds, and large insects 151 0.02 0.75

Pears 1.95
(6 / 5) Short grass 2224 0.26** 11.12 Tall grass 1019 0.12** 5.10 Broadleaf plants/small insects 1251 0.15* 6.25 Fruits, pods, seeds, and large insects 139 0.02 0.69

Pecans 2.6
(5 / 10) Short grass 2183 0.26** 10.91 Tall grass 1000 0.12* 5.00 Broadleaf plants/small insects 1228 0.15* 6.14 Fruits, pods, seeds, and large insects 136 0.02 0.68

Ornamental Shade Trees (OR) 0.85
(6 / 10) Short grass 789 0.09 3.95 Tall grass 362 0.04 1.81 Broadleaf plants/small insects 444 0.05* 2.22 Fruits, pods, seeds, and large insects 49 0.01 0.25Table 4.5 Avian dietary-based acute and chroni c RQ values for proposed uses of dodine based on upper-bound Kenaga residues. Use/App. Method Application Rate lbs. ai/A (# app / interval, days) Food Items Upper Bound EEC (mg/kg) a Acute Dietary

RQ (EEC/ LC 50 ) b Chronic RQ (EEC/ NOAEC)

Page 61 of 219 Strawberries 1.3
(5 / 7) Short grass 1205 0.14* 6.03 Tall grass 552 0.07* 2.76 Broadleaf plants/small insects 678 0.08* 3.39 Fruits, pods, seeds, and large insects 75 0.01 0.38

Walnuts 2.6
(5 / 10) Short grass 2183 0.26** 10.91 Tall grass 1000 0.12* 5.00 Broadleaf plants/small insects 1228 0.15* 6.14 Fruits, pods, seeds, and large insects 136 0.02 0.68

(a) Based on bobwhite quail LC 50 = 8413 ppm (b) Based on mallard duck NOAEC = 200 mg/kg feed * exceeds LOC for acute risk to listed species (RQ $ 0.1) ** exceeds LOCs for acute risk to lis ted species and restricted use (RQ $ 0.2) *** exceeds LOCs for acute risk to birds, acute risk to listed species, and restricted use (RQ $ 0.5)


### 4.1.2.2 Mammals

Table 4.6 summarizes the mammalian dose-based acute RQ s for foliar uses of dodine. Acute, acute restricted use and/or listed species acute risk LOCs are exceeded for mammals that consume short grass, tall grass, broadleaf plants, and small insects acro ss all weight classes for all modeled scenarios and application rates, except crab apples and ornament als, with acute RQs th at represent LOC exceedances ranging from 0.10 to 0.99.
Table 4.7 summarizes the mammalian dose-based chronic RQ s for foliar uses of dodine. The chronic LOC is exceeded for mammals that consume short grass, tall grass, and broadleaf plants and small insects across all weight classes for all modeled scenarios and application rates, with chronic RQs that represent exceedances ranging from 1.0 to 34. For mammals that consume fruits, pods, and/or large insects, RQs exceeded the chronic LOCs for all national uses w ith the exception of 1000 kg mammals in most cases. For seed eating mammals, no RQs exceededthe chronic LOC for any use.
Table 4.8 summarizes the mammalian dietary-based chronic RQs for foliar uses of dodine. The chronic LOC is exceeded for mammals that consume short grass, tall grass, broadleaf plants, and small insects for all modeled scenarios and application rates, except cr ab apples and ornamentals, with chronic RQs that represent exceedances ranging from 1.1 to 6.0.Page 62 of 219 Table 4.6 Mammalian dose-based acute RQ values for proposed uses of dodine based on a rat LD 50 = 1056 mg/kg-bw and upper-bound Kenaga values. Use Application Rate lbs. a.i./A (# app / interval, days) Body Weight, g Mammalian Acute Risk Quotients (upper-bound Kenaga residues)

Short Grass Tall Grass Broadleaf Plants/Small

Insects Fruits/pods/ large insects Seeds
Apples 1.95
(6 / 5) 15 0.91*** 0.42** 0.51*** 0.06 0.0
35 0.78*** 0.36** 0.44** 0.05 0.01
1000 0.41** 0.19* 0.23** 0.03 0.01
Cherries 1.3
(6 / 7) 15 0.56*** 0.26** 0.31** 0.03 0.01
35 0.48** 0.22** 0.27** 0.03 0.01 1000 0.25** 0.12* 0.14* 0.02 0.00 Crab apples (OR) 0.34
(6 / 5) 15 0.16* 0.07 0.09 0.01 0.00
35 0.14* 0.06 0.08 0.01 0.00 1000 0.07 0.03 0.04 0.00 0.00 Ornamental Shade Trees (OR) 0.85
(6 / 10) 15 0.32** 0.15* 0.18* 0.02 0.00 35 0.28** 0.13* 0.16* 0.02 0.00 1000 0.15* 0.07 0.08 0.01 0.00 Peaches 2.6
(5 / 7) 15 0.99*** 0.45** 0.55*** 0.06 0.01 35 0.85*** 0.39** 0.48** 0.05 0.01
1000 0.45** 0.20** 0.25** 0.03 0.01 Pears 1.95
(6 / 5) 15 0.91*** 0.42** 0.51*** 0.06 0.01 35 0.78*** 0.36** 0.44** 0.05 0.01 1000 0.41** 0.19* 0.23** 0.03 0.01 Pecans 2.6
(5 / 10) 15 0.89*** 0.41** 0.50*** 0.06 0.01 35 0.77*** 0.35** 0.43** 0.05 0.01 1000 0.40** 0.18* 0.23** 0.03 0.01 Strawberries 1.3
(5 / 7) 15 0.49** 0.23** 0.28** 0.03 0.01 35 0.42** 0.19* 0.24** 0.03 0.01 1000 0.22** 0.10* 0.13* 0.01 0.00 Walnuts 2.6
(5 / 10) 15 0.89*** 0.41** 0.50*** 0.06 0.01 35 0.77*** 0.35** 0.43** 0.05 0.01 1000 0.40** 0.18* 0.23** 0.03 0.01 * exceeds LOC for acute risk to listed species (RQ $ 0.1) ** exceeds LOCs for acute risk to listed species and restricted use (RQ $ 0.2)Page 63 of 219 *** exceeds LOCs for acute risk to mammals, acute risk to listed mammals, and restricted use (RQ $ 0.5)

Table 4.7 Mammalian dose-based chronic RQ values for proposed uses of dodine based on a rat reproductive NOAEL of 30.28 mg/kg-bw/day and upper-bound Kenaga residues. Use Application Rate lbs. a.i./A (# app / interval, days) Body Weight, g Mammalian Chronic Risk Quotients (upper-bound Kenaga values)

Short Grass Tall Grass Broadleaf Plants/Small

Insects Fruits/pods/ large insects Seeds
Apples 1.95
(6 / 5) 15 31.74* 14.55* 17.86* 1.98* 0.44
35 27.26* 12.49* 15.33* 1.70* 0.39
1000 14.32* 6.56* 8.06* 0.90 0.18
Cherries 1.3
(6 / 7) 15 19.43* 8.91* 10.93* 1.21* 0.27
35 16.68* 7.65* 9.38* 1.04* 0.24 1000 8.77* 4.02* 4.93* 0.55 0.11 Crab apples (OR) 0.34
(6 / 5) 15 5.53* 2.54* 3.11* 0.35 0.08
35 4.75* 2.18* 2.67* 0.30 0.07 1000 2.50* 1.14* 1.40* 0.16 0.03 Ornamental Shade Trees (OR) 0.85
(6 / 10) 15 11.27* 5.16* 6.34* 0.70 0.16 35 9.68* 4.43* 5.44* 0.60 0.14 1000 5.08* 2.33* 2.86* 0.32 0.06 Peaches 2.6
(5 / 7) 15 34.41* 15.77* 19.35* 2.15* 0.48 35 29.54* 13.54* 16.62* 1.85* 0.42
1000 15.52* 7.11* 8.73* 0.97 0.19 Pears 1.95
(6 / 5) 15 31.74* 14.55* 17.86* 1.98* 0.44 35 27.26* 12.49* 15.33* 1.70* 0.39 1000 14.32* 6.56* 8.06* 0.90 0.18 Pecans 2.6
(5 / 10) 15 31.16* 14.28* 17.53* 1.95* 0.43 35 26.76* 12.26* 15.05* 1.67* 0.38 1000 14.06* 6.44* 7.91* 0.88 0.18 Strawberries 1.3
(5 / 7) 15 17.20* 7.88* 9.68* 1.08* 0.24 35 14.77* 6.77* 8.31* 0.92 0.21 1000 7.76* 3.56* 4.37* 0.49 0.10 Walnuts 2.6
(5 / 10) 15 31.16* 14.28* 17.53* 1.95* 0.43 35 26.76* 12.26* 15.05* 1.67* 0.38 1000 14.06* 6.44* 7.91* 0.88 0.18
* exceeds the chronic risk LOC (RQ > 1.0) for non-listed and listed species.Page 64 of 219 Table 4.8 Mammalian dietary-based chronic RQ val ues for proposed uses of dodine based on a rat reproductive NOAEC of 400 mg/kg feed and upper-bound Kenaga residues. Use Application Rate lbs. ai/A (# app / interval, days) Food Items Upper Bound EEC (mg/kg) a Chronic RQ (EEC/ NOAEC)

Apples 1.95
(6 / 5) Short grass 2224 5.56 * Tall grass 1019 2.55* Broadleaf plants/small insects 1251 3.13* Fruits, pods, seeds, and large insects 139 0.35

Cherries 1.3
(6 / 7) Short grass 1361 3.40* Tall grass 624 1.56* Broadleaf plants/small insects 766 1.92* Fruits, pods, seeds, and large insects 85 0.21

Crab Apples (OR) 0.34
(6 / 5) Short grass 388 0.97 Tall grass 178 0.45 Broadleaf plants/small insects 218 0.55 Fruits, pods, seeds, and large insects 24 0.06

Ornamental Shade Trees (OR) 0.85
(6 / 10) Short grass 789 1.97* Tall grass 362 0.91 Broadleaf plants/small insects 444 1.11* Fruits, pods, seeds, and large insects 49 0.12

Peaches 2.6
(5 / 7) Short grass 2410 6.03* Tall grass 1105 2.76* Broadleaf plants/small insects 1356 3.39* Fruits, pods, seeds, and large insects 151 0.38

Pears 1.95
(6 / 5) Short grass 2224 5.56* Tall grass 1019 2.55* Broadleaf plants/small insects 1251 3.13* Fruits, pods, seeds, and large insects 139 0.35Table 4.8 Mammalian dietary-based chronic RQ val ues for proposed uses of dodine based on a rat reproductive NOAEC of 400 mg/kg feed and upper-bound Kenaga residues. Use Application Rate lbs. ai/A (# app / interval, days) Food Items Upper Bound EEC (mg/kg) a Chronic RQ (EEC/ NOAEC)

Page 65 of 219 Pecans 2.6
(5 / 10) Short grass 2183 5.46* Tall grass 1000 2.50* Broadleaf plants/small insects 1228 3.07* Fruits, pods, seeds, and large insects 136 0.34

Strawberries 1.3
(5 / 7) Short grass 1205 3.01* Tall grass 552 1.38* Broadleaf plants/small insects 678 1.70* Fruits, pods, seeds, and large insects 75 0.19

Walnuts 2.6
(5 / 10) Short grass 2183 5.46* Tall grass 1000 2.50* Broadleaf plants/small insects 1228 3.07* Fruits, pods, seeds, and large insects 136 0.34

* exceeds the chronic risk LOC (RQ > 1.0) for non-listed and listed species.
4.1.2.3 Plants
Risk quotients for terrestrial plants could not be calculated because Tier II toxicity studies were not submitted for review and therefore toxicity values used to calculate RQs were not available. Tier I plant studies indicated some deleterious effects of dodine on some species of plants. In the absence of suitable Tier II toxicity data and when Tier II effects > 25% are evident, risks to terrestrial plants are assumed.
4.1.3 RQs Based on Mean Kenaga Residues

Tables 4.9 - 4.13 summarize acute and chronic avian and mammalian RQs using mean Kenaga residue values. These RQs do not form the basis of risk conclusion for birds and mammals but are provided for comparison purposes. Using the mean Kenaga residue values for calculating RQs would not protect birds and mammals that consume food items that have resi dues on the higher end of the residue distribution. An analysis of the residue distribution for the different food items using input values from Fletcher et al. (1994) and assuming a log-normal distribution of r esidues on food items was conducted. The analysis shows that the mean Kenaga values range from about the 62-87 percentile indicating that up to 38% of the higher-end food item residue estimates are not captured by using the mean Kenaga values. Importantly, if the actual distribution differed from log-normal, these estimates could changePage 66 of 219 substantially. The implications and utility of these values is described furthe r in the Risk Description section.

Table 4.9 Acute dose-based RQ values for small (20-g), intermediate (100-g) and large (1,000-g) birds exposed to dodine based on a bobwhite quail LD 50 = 690 mg/kg-bw and mean Kenaga residues. Use Application Rate lbs. a.i./A (# app / interval, days) Body Weight, g Avian Acute Risk Quotients (mean Kenaga residues)

Short Grass Tall Grass Broadleaf Plants/Small Insects Fruits/pods/ large insects

Apples 1.95 (6 / 5) 20 1.84*** 0.78*** 0.97*** 0.15 *
100 0.82*** 0.35** 0.44** 0.07
1000 0.26** 0.11* 0.14* 0.02
Cherries 1.3
(6 / 7) 20 1.13*** 0.48** 0.60*** 0.09
100 0.50*** 0.21** 0.27** 0.04
1000 0.16* 0.07 0.08 0.01 Crab apples (OR) 0.34
(6 / 7) 20 0.32** 0.14* 0.17* 0.03
100 0.14* 0.06 0.08 0.01 1000 0.05 0.02 0.02 0.00 Ornamental Shade Trees (OR) 0.85
(6 / 10) 20 0.65*** 0.28** 0.35** 0.05 100 0.29** 0.12* 0.15* 0.02 1000 0.09 0.04 0.05 0.01 Peaches 2.6
(5 / 7) 20 1.99*** 0.84*** 1.05*** 0.16 * 100 0.89*** 0.38** 0.47** 0.07
1000 0.28** 0.12* 0.15* 0.02 Pears 1.95
(6 / 5) 20 1.84*** 0.78*** 0.97*** 0.15 * 100 0.82*** 0.35** 0.44** 0.07 1000 0.26** 0.11* 0.14* 0.02 Pecans / Walnuts 2.6
(5 / 10) 20 1.80*** 0.76*** 0.96*** 0.15 * 100 0.81*** 0.34** 0.43** 0.07 1000 0.26** 0.11* 0.14* 0.02 Strawberries 1.3
(5 / 7) 20 1.00*** 0.42** 0.53** 0.08 100 0.45** 0.19* 0.24** 0.04 1000 0.14* 0.06 0.07 0.01 * exceeds LOC for acute risk to listed species (RQ $ 0.1) ** exceeds LOCs for acute risk to listed species and restricted use (RQ $ 0.2) *** exceeds LOCs for acute risk to birds, acute risk to listed birds, and restricted use (RQ $ 0.5)Page 67 of 219 Table 4.10 Acute and chronic dietary-based RQ values for birds exposed to dodine based on mean Kenaga residues. Use Application Rate lbs. ai/A (# app / interval, days) Food Items Mean EEC (mg/kg) a Acute Dietary

RQ (EEC/ LC 50 ) b Chronic RQ (EEC/ NOAEC)

Apples 1.95
(6 / 5) Short grass 788 0.09 3.94 Tall grass 334 0.04 1.67 Broadleaf plants/small insects 417 0.05 2.08 Fruits, pods, seeds, and large insects 65 0.01 0.32

Cherries 1.3
(6 / 7) Short grass 482 0.06 2.41 Tall grass 204 0.02 1.02 Broadleaf plants/small insects 255 0.11* 1.28 Fruits, pods, seeds, and large insects 40 0.01 0.20

Crab Apples (OR) 0.34
(6 / 5) Short grass 137 0.02 0.69 Tall grass 58 0.01 0.29 Broadleaf plants/small insects 73 0.01 0.36 Fruits, pods, seeds, and large insects 11 0.001 0.06

Ornamental Shade Trees (OR) 0.85
(6 / 10) Short grass 280 0.03 1.40 Tall grass 118 0.01 0.59 Broadleaf plants/small insects 148 0.02 0.74 Fruits, pods, seeds, and large insects 23 0.003 0.12

Peaches 2.6
(5 / 7) Short grass 854 0.10* 4.27 Tall grass 362 0.04 1.81 Broadleaf plants/small insects 452 0.05 2.26 Fruits, pods, seeds, and large insects 70 0.01 0.35Table 4.10 Acute and chronic dietary-based RQ values for birds exposed to dodine based on mean Kenaga residues. Use Application Rate lbs. ai/A (# app / interval, days) Food Items Mean EEC (mg/kg) a Acute Dietary

RQ (EEC/ LC 50 ) b Chronic RQ (EEC/ NOAEC)

Page 68 of 219 Pears 1.95
(6 / 5) Short grass 788 0.09 3.94 Tall grass 334 0.04 1.67 Broadleaf plants/small insects 417 0.05 2.08 Fruits, pods, seeds, and large insects 65 0.01 0.32

Pecans/ Walnuts 2.6
(5 / 10) Short grass 773 0.09 3.87 Tall grass 327 0.04 1.64 Broadleaf plants/small insects 409 0.05 2.05 Fruits, pods, seeds, and large insects 64 0.01 0.32

Strawberries 1.3
(5 / 7) Short grass 280 0.03 2.13 Tall grass 118 0.01 0.90 Broadleaf plants/small insects 148 0.02 1.13 Fruits, pods, seeds, and large insects 23 0.003 0.18

(a) Based on bobwhite quail LC 50 = 8413 ppm (b) Based on mallard duck NOAEL = 200 mg/kg feed * exceeds LOC for acute risk to listed species (RQ $ 0.1) ** exceeds LOCs for acute risk to lis ted species and restricted use (RQ $ 0.2) *** exceeds LOCs for acute risk to birds, acute risk to listed species, and restricted use (RQ $ 0.5)Page 69 of 219 Table 4.11 Mammalian acute dose-based RQ values for proposed uses of dodine based on a rat LD 50 = 1056 mg/kg-bw and mean Kenaga residues. Use Application Rate lbs. a.i./A (# app / interval, days) Body Weight, g Mammalian Acute Risk Quotients (based in mean Kenaga residues)

Short Grass Tall Grass Broadleaf Plants/Small

Insects Fruits/pods/ large insects Seeds
Apples 1.95
(6 / 5) 15 0.32** 0.14* 0.17* 0.03 0.01
35 0.28** 0.12* 0.15* 0.02 0.01
1000 0.15* 0.06 0.08 0.01 0.00
Cherries 1.3
(6 / 7) 15 0.20** 0.08 0.10 * 0.02 0.00
35 0.17* 0.07 0.09 0.01 0.00 1000 0.09 0.04 0.05 0.01 0.00 Crab apples (OR) 0.34
(6 / 5) 15 0.06 0.02 0.03 0.00 0.00
35 0.05 0.02 0.03 0.00 0.00 1000 0.03 0.01 0.01 0.00 0.00 Ornamental Shade Trees (OR) 0.85
(6 / 10) 15 0.11* 0.05 0.06 0.01 0.00 35 0.10* 0.04 0.05 0.01 0.00 1000 0.05 0.02 0.03 0.00 0.00 Peaches 2.6
(5 / 7) 15 0.35** 0.15* 0.18* 0.03 0.01 35 0.30** 0.13* 0.16* 0.02 0.01
1000 0.16* 0.07 0.08 0.01 0.00 Pears 1.95
(6 / 5) 15 0.32** 0.14* 0.17* 0.03 0.01 35 0.28** 0.12* 0.15* 0.02 0.01 1000 0.15* 0.06 0.08 0.01 0.00 Pecans/ Walnuts 2.6
(5 / 10) 15 0.32** 0.13* 0.17* 0.03 0.01 35 0.27** 0.12* 0.14* 0.02 0.01 1000 0.14* 0.06 0.08 0.01 0.00 Strawberries 1.3
(5 / 7) 15 0.17* 0.07 0.09 0.01 0.00 35 0.15* 0.06 0.08 0.01 0.00 1000 0.08 0.03 0.04 0.01 0.00 * exceeds LOC for acute risk to listed species (RQ $ 0.1) ** exceeds LOCs for acute risk to listed species and restricted use (RQ $ 0.2) *** exceeds LOCs for acute risk to mammals, acute risk to listed mammals, and restricted use (RQ $ 0.5)Page 70 of 219 Table 4.12 Mammalian dose-based chronic RQ valu es for proposed uses of dodine based on a rat reproductive NOAEL of 30.28 mg/kg-bw/day and mean Kenaga values. Use Application Rate lbs. a.i./A (# app / interval, days) Body Weight, g Mammalian Chronic Risk Quotients (based on mean Kenega residues)

Short Grass Tall Grass Broadleaf Plants/Small

Insects Fruits/pods/ large insects Seeds
Apples 1.95
(6 / 5) 15 11.24* 4.76* 5.95* 0.93 0.20
35 9.65* 4.09* 5.11* 0.79 0.18
1000 5.07* 2.15* 2.69* 0.42 0.08
Cherries 1.3
(6 / 7) 15 6.88* 2.91* 3.64* 0.57 0.13
35 5.91* 2.50* 3.13* 0.49 0.11 1000 3.10* 1.31* 1.64* 0.26 0.05 Crab apples (OR) 0.34
(6 / 5) 15 1.96* 0.83 1.04* 0.16 0.04
35 1.68* 0.71 0.89* 0.14 0.03 1000 0.88 0.37 0.47 0.07 0.01 Ornamental Shade Trees (OR) 0.85
(6 / 10) 15 3.99* 1.69* 2.11* 0.33 0.07 35 3.43* 1.45* 1.81* 0.28 0.06 1000 1.80* 0.76 0.95 0.15 0.03 Peaches 2.6
(5 / 7) 15 12.19* 5.16* 6.45* 1.00* 0.22 35 10.46* 4.43* 5.54* 0.86 0.20
1000 5.50* 2.33* 2.91* 0.45 0.09 Pears 1.95
(6 / 5) 15 11.24* 4.76* 5.95* 0.93 0.20 35 9.65* 4.09* 5.11* 0.79 0.18 1000 5.07* 2.15* 2.69* 0.42 0.08 Pecans/ Walnuts 2.6
(5 / 10) 15 11.04* 4.67* 5.84* 0.91 0.20 35 9.48* 4.01* 5.02* 0.78 0.18 1000 4.98* 2.11* 2.64* 0.41 0.08 Strawberries 1.3
(5 / 7) 15 6.09* 2.58* 3.23* 0.50 0.11 35 5.23* 2.22* 2.77* 0.43 0.10 1000 2.75* 1.16* 1.46* 0.23 0.05
* exceeds the chronic risk LOC (RQ > 1.0) for non-listed and listed species.Page 71 of 219 Table 4.13 Mammalian dietary-based chronic RQ val ues for proposed uses of dodine based on a rat reproductive NOAEC of 400 mg/kg feed and mean Kenaga residues. Use Application Rate lbs. ai/A (# app / interval, days) Food Items Mean EEC (mg/kg) a Chronic RQ (EEC/ NOAEC)

Apples 1.95
(6 / 5) Short grass 788 1.97 * Tall grass 334 0.84 Broadleaf plants/small insects 417 1.04* Fruits, pods, seeds, and large insects 65 0.16

Cherries 1.3
(6 / 7) Short grass 482 1.21* Tall grass 204 0.51 Broadleaf plants/small insects 255 0.64 Fruits, pods, seeds, and large insects 40 0.10

Crab Apples (OR) 0.34
(6 / 5) Short grass 137 0.34 Tall grass 58 0.15 Broadleaf plants/small insects 73 0.18 Fruits, pods, seeds, and large insects 11 0.03

Ornamental Shade Trees (OR) 0.85
(6 / 10) Short grass 280 0.70 Tall grass 118 0.30 Broadleaf plants/small insects 148 0.37 Fruits, pods, seeds, and large insects 23 0.06

Peaches 2.6
(5 / 7) Short grass 854 2.14* Tall grass 362 0.91 Broadleaf plants/small insects 452 1.13* Fruits, pods, seeds, and large insects 70 0.18

Pears 1.95
(6 / 5) Short grass 788 1.97* Tall grass 334 0.84 Broadleaf plants/small insects 417 1.04* Fruits, pods, seeds, and large insects 65 0.16Table 4.13 Mammalian dietary-based chronic RQ val ues for proposed uses of dodine based on a rat reproductive NOAEC of 400 mg/kg feed and mean Kenaga residues. Use Application Rate lbs. ai/A (# app / interval, days) Food Items Mean EEC (mg/kg) a Chronic RQ (EEC/ NOAEC)

Page 72 of 219 Pecans 2.6
(5 / 10) Short grass 773 1.93* Tall grass 327 0.82 Broadleaf plants/small insects 409 1.02* Fruits, pods, seeds, and large insects 64 0.16

Strawberries 1.3
(5 / 7) Short grass 427 1.07* Tall grass 181 0.45 Broadleaf plants/small insects 226 0.56 Fruits, pods, seeds, and large insects 35 0.09

Walnuts 2.6
(5 / 10) Short grass 773 1.93* Tall grass 327 0.82 Broadleaf plants/small insects 409 1.02* Fruits, pods, seeds, and large insects 64 0.16

* exceeds the chronic risk LOC (RQ > 1.0) for non-listed and listed species. 4.2 Risk Description

The available data on the fate and effects of dodine were sufficient to address the risk hypothesis for most, but not all taxa. The results of this screen ing-level risk assessment indicate acceptance of the risk hypothesis and that there is po tential for direct a dverse acute effects to non-target aquatic freshwater invertebrates, non-vascular aquatic plants, saltwater invertebrates and molluscs, birds, mammals and chronic effects to birds and mammals, based on modele d aerial application rates of dodine of 2.0 to 13.0 lb ai/A/yr. These yearly application rates represent most of the proposed uses of dodine applied at the maximum label rate. In addition, based on modeled aerial applications to apples (Pennsylvania; 11.7 lbs. a.i./A/yr) there is the potential for direct adverse acute effects on Federally listed freshwater fish and chronic effects on freshwater invertebrates. D odine is not likely to pose an acute risk to saltwater/estuarine fish nor is it likel y to pose a chronic risk to freshwaterPage 73 of 219 A description of the potential direct effects associated with exposure to dodine is provided for each of the taxonomic groups below. Table 4.14 provides a summary of the direct effects for Federally listed species of concern, including the range of RQ values and th e acute dose-response slopes used in evaluating the probability of individual effects.

Table 4.14. Summary of Direct E ffects for Federally Listed Species Listed Species Taxonomic Group of Concern Direct Effects Slope a RQ Range

Freshwater fish Acute: mortality <LOC - 0.08 Freshwater invertebrates Acute: mortality/immobilization Chronic: growth/reproduction <LOC - 2.42 <LOC - 1.19 Saltwater mollusc Acute: shell deposition < LOC - 0.62 Aquatic Plants: Vascular Non-vascular no data Acute: reduced cell density NA no data <LOC - 45 Birds Acute: mortality/sublethal Chronic: reproduction <LOC - 5.62 <LOC - 12 Mammals Acute: mortality Chronic: <LOC - 0.99 <LOC - 286

therefore a default slope value and 95% confidence intervals were used (Urban and Cook, 1986). 4.2.1 Risks to Aquatic Organisms
The risk assessment for aquatic species is basedon data from both dodine and DGH since both compounds are expected to behave similarly in aquatic environments; both will dissociate to the dodecylguanidinium ion and their respective cation, acetate or chloride. Furthermore, review of DGH product formulations indicate that formulati on components other than the active ingredient (Dodecylquanidine hydrochloride) are unlikely to cause significant toxic effects. Given the similarities between DGH and dodine, there is the potential for e xposure to aquatic organisms to dodecylguanidine based on uses of DGH; however, current uses of DGH preclude a robust quantitative assessment of the likelihood of exposure. This assessment is based entirely on uses of dodine.Page 74 of 219 4.2.1.1 Freshwater Fish
Risk quotients indicate that there is a potential for direct effects to freshwater fish. The only LOC exceedance was for the 11.7 lb ai/A/yr aerial applica tion to apples, as simulated using the Pennsylvania apple scenario in PRZM/EXAMS (RQ = 0.08). Fo r this scenario, the acute EEC was 43ppb and the NOAEC for fish mortality based on the rainbow trout study was 320 ppb. The same dodine use, when modeled using the North Carolina and Oregon apple scen arios, results in risk quotients below the LOC. Predicted risks in Pennsylvania are likely the result of higher erosion and subse quent off-site transport of dodine adsorbed to eroded sediment into water bodies ad jacent to treated fields. As discussed in section 3.2.2.1, the highest annual use rates, simulated for peaches, pecans and walnuts (13.0 lbs. a.i./A/yr), did not produce EECs that resulted in LOC exceedances. The Pennsylvania apple scenario is characterized by an average annual sediment loss of 56 ton ha -1 yr -1 compared to 2.6, 11 and 0.07 ton ha -1 yr -1 for Georgia peaches, Georgia pecans and California walnut , respectively (Table 3.7). It is possible that dodine use at higher rates (peaches, pecans, walnuts; 13.0 lbs. a.i./A/yr) could result in higher EECs than seen in this aquatic modeling assessment if the site is as vulnerable to soil loss as the Pennsylvania scenario. Based on the screening-level RQs, chronic risks associated with freshwater fish exposure to dodine are not likely.
The freshwater fish toxicity data indicate that dodi ne is very highly toxic to rainbow trout, however, extrapolation to other freshwater fish is highly un certain. In all likelihood, more sensitive species are likely to exist. In cases, where dodine levels in wate r approach those where risks were identified, other fish species may also be at risk.

4.2.1.2 Freshwater Invertebrates
As detailed in section 4.1.1.1, acute restricted use and listed species LOCs for freshwater invertebrates are exceeded for all modeled uses, except strawberries in Florida. In add ition, for the current application rates modeled, acute LOCs are exceeded for fresh water invertebrates for aerial applications to Pennsylvania apples (11.7 lb ai/A/yr), Michigan ch erries (7.8 lb ai/A)/yr, Georgia pecans (13.0 lbs. a.i./A/yr), and Georgia peaches (13.0 lbs. a.i./A/yr). For freshwater invertebrates, the chronic LOC is exceeded based on aerial application of dodine to Pe nnsylvania apples (11.7 lb ai/A/yr) only. Analysis based on one study of benthic invertebrates indicated th at for benthic invertebrate species, the chronic risk LOC was not exceeded and risks are expected to be low.
The strawberry use modeled in Florida did not resu lt in exceedances because it is the use with the lowest application rate (6.5 lbs ai/A/yr) and it is only applied by ground spray which generally results in less spray drift than aerial applications. However, it im portant to note that much strawberry production uses full-bed plastic mulch (USDA Crop Profiles: http://www.ipmcenters.org/cropprofiles/docs/FLstrawberries.html ), which could result in increased runoff and off-site transport of pesticide. Currently, O PP does not have a standard approach for quantifying increased runoff and pesticide loading resulting from app lications to plastic mulch. For dodine, however, erosion and/or spray drift are the likely dominant routes of off-site transport.
PRZM/EXAMS simulations indicate that the greatest c ontribution to predicted dodine exposure in waterPage 75 of 219 is erosion, particularly for the Pennsylvania apple and Michigan cherries scenario s. In one case, pears in California, spray drift was the dominant route of off-site transport of dodine. The California fruit scenario, used to represent pears, is characterized by both low annual average runoff and erosion (Table 3.7). The modeling assessment suggests that dodine exposure is highly dependant not only on the application rate, but also on the vulnerability of the s ite to sediment loss. For example, the Pennsylvania apples (11.7 lb ai/A/yr) and Michigan cherries (7.8 lb ai/A/yr) scenarios had higher acute EECs than the Georgia peaches, Georgia pecans and California walnut , all of which had the highest annual application rates (13 lb ai/A/yr).
Even though spray drift was the only dominant route of off-site transport for one scenario, there is a possibility that spray drift alone could result in acute exposures that exceed LOCs for freshwater invertebrates. Aquatic acute EECs would have to be as low as 8.9, 1.8 or 0.89 ppb to reach RQ values for freshwater invertebrates that are l ess than acute, acute restricted use or listed species LOCs. Simulated acute EECs under drift-only conditions ( i.e. , application efficiency set to 0 and drift set to 0.05 in PRZM) for peaches, the highest maximum application rate (2.6 lbs ai/A/app; 5 applications; 7 day interval), and cherries, the lowest maximum national application rate for which aerial applications are allowed (1.3 lbs ai/A/app; 6 applications; 7 day inte rval) are 7.6 and 4.2 ppb, respectively, suggesting that spray drift alone as a route of exposure to freshwater invertebrates may be of concern.
Given that RQ values, based on spray drift only at app lication rates of 1.3 to 2.6 lb ai/A, are in excess of LOCs for freshwater invertebrates, the AgDRIFT model (Version 2.01) was used to refine the spray drift exposure estimate (Teske et al. , 2001). Downwind spray drift buffers were developed for possible use in mitigating risk for listed freshwater invertebrates in aquatic ecosystems that are within close proximity to agricultural fields that may be treated with liquid sp ray applications of dodine. The approach and results of the AgDRIFT modeling including downwind distance ar e presented in Appendix F. The results of the AgDRIFT modeling show that required buffer distances, based on aerial applications at 2.6 lb ai/A and assuming screening-level defaults for droplet size (A SEA fine), wind speed (15 mph) and release height (15 ft.), are expected to exceed the 1,000 foot limit of AgDRIFT. Modeled buffer requirements for listed invertebrates, based on aerial application of dodine (2.6 lb ai/A) at a 10 foot release height in wind speeds < 10 mph, are expected to range from approxima tely > 1,000 to 880 ft., for ASEA fine and ASEA medium droplet sizes, respectively. For orchard airblast applications at 2.6 and 1.3 lbs. ai/A, Tier I AgDRIFT modeling suggests buffer distances of 154 and 76 ft., respectively, would be sufficient to reduce exposure concentrations below the LOC for listedPage 76 of 219 4.2.1.3 Saltwater Fish

Acute risk to estuarine/marine fish is unlikel y, based on the results of the screening assessment.

4.2.1.4 Saltwater Invertebrates

The acute risks to saltwater invertebrates suggest the potential for ch ronic risks as well. Also, given the sensitivity of freshwater invertebrates to dodine, studies on the chronic toxicity of dodine to estuarine/marine invertebrates are warranted. Invertebrates are v itally important components of estuarine and marine environments providing food for a wide variety of species, including listed species. In addition to a potential reduction in biomass, mortality of inverteb rates could lead to a shift in the invertebrate community structure towards less sensitive species, which may or may not result in a change in ecosystem function (see Relyea, 2005).
For molluscs, acute restricted use and listed species LOCs are exceeded for all modeled scenarios (7.8- 13.0 lbs ai/A/yr) except strawberries (6.5 lbs ai/A/yr). Molluscs are important components of many nearshore saltwater ecosystems. Molluscs serve as prey to a number of aquatic and terrestrial species, can be a commercial commodity, and help clean water through filtration. The effects of dodine on molluscs are not all together unexpected as a structurally similar chemical, DGH, is used in control of some molluscan species. Dodine, however, is not used as a molluscicide.
The toxicity data on estuarine/marine invertebrat es (including molluscs) was based on data from studies using DGH. As previously explained (sec 3.3) , the active ingredient for both DGH and dodine is expected to be the dodecylguanidinium ion, and theref ore to have similar toxicities. Importantly, a drift assessment is not required for formulations of DGH sin ce the uses of this chemical are non-agricultural and therefore, drift is not possible.Page 77 of 219 4.2.1.5 Aquatic Plants
Based on predicted EECs for the modeled dodine use patterns and available toxicity data, LOCs are exceeded for non-listed and listed non-v ascular aquatic plants. Since there are no available toxicity data for aquatic vascular plants, the risk due to dodine use is unknown.
Specifically, LOCs for listed and non-listed non-vascular plants are exceeded for all modeled uses (7.8 - 13.0 lbs. ai/A/yr) except strawberries in Florida (6 .5 lbs ai/A/yr). As mentioned previously, the strawberry scenario does not account for increased runo ff due to applications to plastic mulch, which could result in an underestimation of exposure for this scenario. Aquatic acute EECs would have to be as low as 0.05 ppb to be sufficient to achieve RQ values fo r non-vascular aquatic plants that are less than the LOCs. Given the high toxicity of dodine to non-v ascular aquatic plants and the lack of sufficient information on the toxicity of dodine to aquatic v ascular plants, for the sake of this discussion both nonvascular and vascular aquatic plants are considered t ogether as “aquatic plants”. Aquatic plants are key components to all aquatic ecosystems and provide a mu ltitude of ecological functions. They provide food and shelter for a wide variety of aquatic anim al species and help maintain water quality through temperature modulation, filtration, and oxygen supply. Any effects on aquatic plants as a result of dodine use would be expected to result in significant ecosyst em-level effects. Most notably, there would likely be a near instant decrease in water quality associated w ith plant decay and depletion of oxygen. In turn, sedimentation would likely increase due to decay and a loss in filtering capacity. The depletion of oxygen and increased siltation could result in widespr ead fish and invertebrate mortality. The cascade of effects due to effects on aquatic plants would pose a risk to any aquatic listed species near the use area as well as terrestrial species that rely on aquatic organisms as food items such as piscivorous birds, mammals, or reptiles (see Relyea, 2005 for an example of pesticide-induced effects on aquatic communities).

4.2.2 Risks to Terrestrial Organisms

4.2.2.1 Birds
Using both dose-based (LD 50 = 690mg/kg-bw for bobwhite quail) and dietary-based (LC 50 = 8413 mg/kgdiet for bobwhite quail) toxicity values, acute, acu te restricted use and/or listed species LOCs are exceeded for birds that consume short grass, tall grass, broadleaf plants, and small insects for all modeled scenarios and application rates (2.04 - 13.0 lbs ai/A/yr). Based on the dose-based endpoint, acute restricted use and/or listed species LOCs are also exceeded for birds that consume fruits, pods, seeds, and large insects at application rates for all modeled scenarios, except crab apples (2.04 lbs ai/A/yr), at the smallest weight class, and in some cases at the medium weight class.
Risk quotients calculated using the dose-based toxic ity values are generally higher than RQs calculated using the dietary-based toxicity values.Page 78 of 219 To bound the estimates of risk to birds resulting fro m acute exposure to dodine, RQs using mean Kenaga residue values in addition to upper-bound values were calculated ( Tables 4.9 and 4.10 ). Even using the less conservative mean residue values, which do not include up to 38% of the higher-end residue estimates, LOCs are exceeded for birds, based on the dose-based, with dose-based RQs ranging from <LOC to 2.0. Using the data summarized in Fletcher et al. (1994) for input values, log-normal distributions were generated that describe residue levels on the various food items, assuming a log-normal distribution. In this case, the mean Kenaga resi due estimates typically fell within the 62-87 percentile, indicating that about 38-13% of the higher-end r esidue estimates were not captured in estimating exposure. In contrast, for the upper-end Kenaga r esidue estimates, about 3-13% of the upper-end residue estimates were not captured. This highlights th e fact that the upper-end Kenaga values are not a maximum exposure level. In addition to morta lity, sublethal effects to birds resulting from acute exposure to dodine in the field could include depressi on, reduced reaction to external stimuli, wing droop and loss of coordination.
Chronic risks to birds were evaluated using a mallard duck NOAEL value of 200 mg/kg-feed, based on reproductive effects including reduction in the number of eggs laid, eggs set, viable embryos, viable 3- week embryos, hatchlings, 14-day old chick survivor s and hatchling weight. Based on the mallard duck NOAEL of 200 mg/kg-feed, chronic LOCs are exceededfor birds that consume short grass, tall grass, broadleaf plants, and small insects for all modele d scenarios and application rates (2.04 - 13.0 lbs ai/A/yr). Even assuming non-conservative mean Kenaga residue values resulting from maximum application rates of dodine, risk from chronic e xposure is likely with RQs ranging from <LOC - 4.3 ( Table 4.10 ).

The estimates for chronic risks to birds were b ased on the NOAEL of 200 mg/kg-feed from a study on mallard ducks. A similar study using bobwhite quail showed that there were no effects associated with dodine exposure, even at the highest concentrati on of 300 mg/kg-feed. These data suggest that under chronic exposure conditions, mallard ducks are more sensitive than bobwhite quail, which contrasts with the acute toxicity data in which bobwhite quail were shown to be more sensitive. Chronic toxicity endpoints are largely a function of the exposure levels chosen for the experiment and, for dodine, the true NOAEL may lie between 200 and 600 ppm (the lowest LOAEL ). Simulations using different hypothetical NOAELs indicate that the NOAEL would have to exceed 550 ppm for the chronic risk toPage 79 of 219 birds to change significantly. Above 550 ppm, RQs fo r birds that consume tall grass would fall below the LOC, however, birds that consume short grass, broadl eaf plants, and large insects would still be at risk. Although it is possible that the true NOAEL is 550 ppm, it is unlikely to be so close to the LOAEL of 600 ppm. This analysis indicates that the overall risk to birds associated with chronic dodine exposure is adequately captured by results from submitted toxicity studies.

4.2.2.2 Mammals

Acute risks to wild mammals were evaluated using a common laboratory rat female-specific LD 50 value of 1056 mg/kg. Acute, acute restricted use and/ or listed species LOCs are exceeded for mammals that consume short grass, tall grass, broadleaf plants, and small insects across most weight classes for all modeled scenarios and application rates (2.04 - 13.0 lbs ai/A/yr). Even using the non-conservative mean residue values ( Table 4.11 ), LOCs are exceeded for mammals, b ased the dose-based female-specific endpoints, with RQs ranging from <LOC to 0.35.Page 80 of 219 4.2.2.3 Plants

, risks to terrestrial plants are assumed. Li sted plant species are assumed to be at risk or direct effects from some uses of dodine, particularly at higher use rates. Tier II plant studies are needed to conduct a robust assessment of risks to terrestrial plants. As a rough RQ estimate, it is assumed that the approximate EC 25 for dodine is 2.6 lbs. a.i./A based on a Tier I plant study. Comparing to the highest EEC generated from Terr Plant (v 1.0) of 0.910, the estimated RQ is 0.35. The LOC for non-listed plants is 1 suggesting that non-listed plants may not be at risk. Risk quotients for listed plant species are calculated using the EC 05 , which is unavailable for dodine. Overall, the available data indicate that risks to non-listed plant species may not be expected while the potential for risks to listed plant species remains unknown. Tier II plant studies are required to fully characterize risks to terrestrial plant species associated with uses of dodine.
Studies available in the open literature and obtai ned from a search of the ECOTOX database provide further insight into the effects of dodine on plants . Wood et al. (1985) showed that photosynthesis was reduced by 20% in foliage sprayed with dodine. Mo reover, treated foliage did not recover for 13-17 days after spraying. In contrast, dodine sprayed on apple trees caused no significant effects on photosynthesis (Sharma et al., 1977). While not exhaustive, the av ailable data on the effects of dodine on terrestrial plants suggests that studies are needed to mo re fully characterize dodine phytotoxicity.
4.2.3 Non-Target Insects
EFED currently does not estimate risk quotients fo r terrestrial non-target insects. However, an appropriate label statement is required to protect foraging honeybees when the LD 50 is < 11 μg/bee. Based on the acute contact toxicity study to honeybees, the LD 50 for dodine is >200 μg/bee. This classifies dodine as practically non-toxic to honeybees.

4.2.4 Review of Incidents Data
No incidents of wildlife or aquatic species poisonings associated with uses of dodine were found in the Ecological Incident Information System (EIIS) database.

Section 7 of the Endangered Species Act, 16 U.S.C. Section 1536(a)(2), requires all federal agencies to consult with the National Marine Fisheries Service (NMFS) for marine and anadromous listed species, or the United States Fish and Wildlife Services (FWS) fo r listed wildlife and freshwater organisms, if they are proposing an "action" that may affect listed species or their designated habitat. Each federal agency is required under the Act to insure that any action they authorize, fund, or carry out is not likely to jeopardize the continued existence of a listed species or result in the destruction or adverse modification of designated critical habitat. To jeopardize the c ontinued existence of a listed species means "to engagePage 81 of 219 in an action that reasonably would be expected, direc tly or indirectly, to reduce appreciably the likelihood of both the survival and recovery of a listed species in the wild by reducing the reproduction, numbers, or distribution of the species." 50 C.F.R. § 402.02.
To facilitate compliance with the requirements of the Endangered Species Act subsection (a)(2) the Environmental Protection Agency, Office of Pestic ide Programs has established procedures to evaluate whether a proposed registration action may directly or indirectly reduce appreciably the likelihood of both the survival and recovery of a listed species in the wild by reducing the reproduction, numbers, or distribution of any listed species (U.S. EPA 2004). After the Agency’s screening level risk assessment is conducted, if any of the Agency’s listed species LOCs ar e exceeded for either direct or indirect effects, an analysis is any listed or species may co-occur in the area of the proposed pesticide use or areas downstream or downw ind that could be contaminated from drift or runoff/erosion. If determined that listed or candi date species may be present in the proposed action areas, further biological assessment is undertaken. The exte nt to which listed species may be at risk then determines the need for the development of a more comprehensive consultation package as required by the Endangered Species Act.
The federal action addressed herein is the proposed re -registration of pesticide products that contain the Growing areas for these crops encompasses most of the United States ( Figure 4.1 ).Page 82 of 219 Figure 4.1. Total acreage of crops with dodine labeled u ses (apples, cherries (sweet and tart), peaches, pears, pecans, strawberries, walnuts) according to AgCensus 2002 ( http://www.nass.usda.gov/census/ ).

4.2.5.1 Action Area
For listed species assessment purposes, the action area is considered to be the area affected directly or indirectly by dodine use and not merely the immediate area where dodine is applied. At the initial screening-level, the risk assessment considers broadl y described taxonomic groups and so conservatively assumes that listed species within those broad groups ar e co-located with the p esticide treatment area. This means that terrestrial plants and wildlife are assu med to be located on or adjacent to the treated site and aquatic organisms are assumed to be located in a surface water body adjacent to the treated site. The assessment also assumes that the listed species are located within an assumed area which has the relatively highest potential exposure to the pestic ide, and that exposures are likely to decrease with distance from the treatment area. Section 1.0 of th is risk assessment presents th e pesticide use sites that are used to establish initial co-locati on of species with treatment areas.Page 83 of 219 4.2.5.2 Taxonomic Groups Potentially at Risk
If the assumptions associated with the screening-level action area result in RQs that are below the listed species LOCs, a "no effect" determination conclusion is made with respect to listed species in that taxa, and no further refinement of the action area is necessary. Furthermore, RQs below the listed species LOCs for a given taxonomic group indicate no concern for indirect effects on listed species that depend upon the taxonomic group for which the RQ was calculated. However, in situations where the screening assumptions lead to RQs in excess of the listed speci es LOCs for a given taxonomic group, a potential for a "may affect" conclusion exists and may be associat ed with direct effects on listed species belonging to that taxonomic group or may extend to indirect effects upon listed species that depend upon that taxonomic group as a resource. In such cases, additiona l information on the biology of listed species, the locations of these species, and the locations of use sit es are considered to determine the extent to which screening assumptions regarding an action area apply to a particular listed organism. These subsequent refinement steps will consider how this information would impact the action area for a particular listed organism and potentially include areas of exposure th at are downwind and downstream of the pesticide use site.
Assessment endpoints, exposure pathways, and the conceptual model addressing proposed dodine reregistration uses, and the associated exposure and effects analyses conducted for the dodine screeninglevel risk assessment are in The assessment endpoints used in the screening-level risk assessment include those defined operationally as reducedsurvival and reproductive impairment for both aquatic and terrestrial animal species and survival, reproduction, and growth of aquatic and terrestrial plant species from both direct acute and direct chronic exposures. These assessment endpoints address the standard set forth in the Endangered Species Act requiring federal agencies to ensure that any action they authorize does not reduce appreciably the likeli hood of both the survival and recovery of a listed species in the wild by reducing the reproduction, numbers, or distribution of the species. Risk estimates, RQs, integrating exposure and effects are calculated for broad based taxa groups for the screening-level risk assessment are presented in
Both acute endangered species and chronic risk LO Cs are considered in the screening-level risk assessment to identify direct and indirect effects to ta xa of listed species. This section identifies direct effect concerns, by taxa, triggered by exceeding endangered LOCs in the screening level risk assessment with an evaluation of the potential probability of individual effects for exposures that may occur at the established endangered species LOC. Data on exposure and effects collected under field conditions are evaluated to make determinations on the predic tive utility of the direct effect screening assessment findings to listed species. Additionally, the results of a screen for indirect effects to listed species, using direct effect acute and chronic LOCs for each taxonomic group, is presented and evaluated.
4.2.5.2.1 Listed Species Risk Quotients
Freshwater Fish and Amphibians
Listed species acute risk LOCs for direct effects on freshwater fish and amphibians were exceeded (RQ > 0.05) for dodine when used at the maximum label ra te for apples. There were no other exceedances. No chronic risk LOCs (RQ > 1.0) were exceeded for freshwater fish.Page 84 of 219 Freshwater Invertebrates
Listed species acute risk LOCs (RQ > 0.05) for direct effects on freshwater invertebrates were exceeded (RQ > 0.05) for all uses of dodine at the maximum label rates except strawberries. RQs ranged from 0.34 for pears to 2.42 for apples. The listed species chronic risk LOC (RQ > 1.0) was exceeded for freshwater invertebrates associated only with the use of dodine on apples at the maximum application rate.

Estuarine/Marine Fish
The listed species acute risk LOCs for estuarine/marine fish were not exceeded for any labeled uses of dodine when applied at the maximum label rates.

Estuarine/Marine Invertebrates
The listed species acute risk LOCs were exceeded for non-molluscan, estuarine/marine invertebrates for all uses of dodine except strawberries. Similarly for molluscs, the listed species acute risk LOCs were exceeded (RQ > 0.05) for uses of dodine on all labeled crops at the maximum labeled rate except for strawberries. No chronic toxicity data were ava ilable to use in calculating listed species chronic risk estimates for any estuarine/marine invertebrates.
Aquatic Plants
The listed species acute risk LOCs were exceeded fo r non-vascular aquatic plants for all uses of dodine (RQ > 1.0, calculated as NOAEC/EEC).

Birds
Listed species acute risk LOCs (RQ > 0.1) for direct effects of dodine to birds were exceeded for all uses of dodine for at least one body size/food item combination. Some RQs did not exceed the listed species acute risk LOCs for larger birds and for birds th at consume fruits, pods, seeds, and/or large insects. Similarly, listed species chronic risk LOCs (RQ > 1.0) were exceeded for all uses of dodine for at least one combination of body size and food item type. He re too, RQs were lower for birds that consume fruits, pods, seeds, and/or large insects. These results also apply to reptiles and amphibians since avian species are used as surrogates for these taxonomic groups.

Mammals
Listed species acute risk LOCs (RQ > 0.1) for direct effects of dodine on mammals were exceeded for all uses of dodine for at least one combination of body size and food item. However, there were no exceedances of the acute risk LOC for mammals that eat fruits, pods, large insects, or seeds. Also, for uses of dodine on crab apples and cherries (OR only) , there were less exceedances for some food types and larger mammals compared to other uses. Listed species chronic risk LOCs (RQ > 1.0) were exceeded for all uses of dodine for mammals that consume s hort grass, tall grass, broadleaf plants, and smallPage 85 of 219 insects. For mammals that consume fruits, pods, and/ or large insects, chronic risk LOCs were exceeded for smaller body size mammals for all national uses of dodine. Risk quotients for seed-eating mammals did not exceed the LOC for any dodine use.
4.2.5.2.2 Probit Dose-Response Analysis
Aquatic Listed Species Probability of Effects on Individuals
The probability of individual effects at the acute endangered species LOC (RQ = 0.05 which is equivalent to 1/20 of the LC 50 or EC 50 ) for each major listed species taxonomic group and the probability of individual effects at estimated acute RQs above th e endangered species acute risk LOC is provided in Table 4.13. In addition, extrapolation of low probability events such as those occurring at the LOC, are associated with a high degree of uncertainty. To a ddress this uncertainty, analyses of individual effects are also conducted at the upper and lower 95% confiden ce interval of the probit slope for each taxa. The probit slopes used in this analysis were obtained from dose-response relationships used in calculating RQs.
For freshwater fish, the probit dose-response slope was 8.16 (95% C.I. 4.88-11.45) based on the rainbow trout acute toxicity test. Should exposure to listed freshwater fish occur at the acute listed species LOC, the probability of one individual being affected is 1 in 1.0E+16. At the lower and upper 95% confidence limits, the probabilities are 1.0 in 9.19E+09 and 1.0 in 1.0E+16, respectively. Analyses of the probability of individual effects occurring at exposures that occu r at the EECs for these organisms indicate that for fish, the probability of individual effects is the same as at the LOC, 1 in 1.0E+16; a very low probability event.
The probability of individual effects to listed freshwa ter invertebrates should exposure occur at the LOC is 1.0 in 4.88E+11. The probit dose-response slope u sed for freshwater invertebrates was 5.33 (95% C.I.- 1.18 -11.84) based on a 48-h acute study on waterfl eas. At the lower and upper 95% confidence limits the probability of individual effects is 1.0 in 1.07E+ 00 and 1.0 in 1.00E+16, respectively. For freshwater invertebrates that might be exposed to levels of dodine corresponding to the crop-specific EECs, the probability of individual effects ranges from 1 in 160 for pears to 1 in 1.02 for apples. The probability of individual effects to molluscs was not calculated since the estimated EC 50 is based on effects of growth, a continuous endpoint.
For estuarine/marine non-molluscan invertebrates, the pr obability of individual effects is 1.0 in 1.02E+07. The analysis of the probability of effects to indivi dual listed estuarine/marine invertebrates was based on a probit dose-response slope of 4.2. The lower and upper 95% confidence limits were -0.24 and 8.31, respectively which correspond to probabilities of individua l effects of 1 in 2.56 and 1 in 1.00E+16. For exposures that occur at EECs for which LOCs were exceeded, the probabilities of individual effects ranged from 1.0 in 152 for apples to 1.0 in 1.59E+04 for pecans.Page 86 of 219 Table 4.13 Probability of Direct Individual Effects to Aquatic Organisms Associated with Maximum Use Rates of Dodine Crop Site Application Rate lbs a.i./A Freshwater Saltwater Fish and Amphibian Invertebrate Invertebrate (# applications/ interval, days) Probit Slope = 8.16 (a) Probit Slope = 5.33 (b) Probit Slope = 4.0 (c) LOC Federally Listed (0.05) 1 in 1.0E+16 1 in 4.88E+11 1 in 1.02E+07
Apples (PA) Maximum : 1.95 lb ai/acre (6/5) RQ = 0.08 1 in 1.0E+16 RQ = 2.42 1 in 1.02 Cherries (MI) Maximum : 1.3 lb ai/acre (6/7) – (f) RQ = 1.35 1 in 1.32 Peaches (GA) Maximum : 2.6 lb ai/acre (5/7) -- RQ = 0.90 1 in 2.48 Pears (CA) Maximum : 1.95 lb ai/acre (6/7) -- RQ = 0.34 1 in 160 Pecans (GA) Maximum : 2.6 lb ai/acre (5/10) -- RQ = 1.07 1 in 1.78 Strawberries (FL) Maximum : 1.3 lb ai/acre (5/7) -- --

Walnuts (CA) Maximum : 2.6 lb ai/acre (5/10) -- RQ = 0.44 1 in 34.9 Probit slope based on acute toxicity data for freshwater fish (rainbow trout). (b) Probit slope based on acute toxicity data for freshwater invertebrate (waterflea) (e) Probit slope based on DGH acute toxicity data for mysid shrimp (F) -- = endangered species acute LOC is not ex ceeded and the probability of an individual effect is less than the value listed for the endangered species LOC. Terrestrial Listed Species Probability of Effects on Individuals
The probability of individual effects at the acute endangered species LOC (1/10 of the LD 50 ) and the probability of individual effects at calculated acute RQs for the highest registered use rate (2.6 lb ai/A) of dodine for birds, reptiles, terrestrial amphibians, and mammals is provided in Table 4.14. For birds, reptiles and amphibians, the probability of one indivi dual being affected if exposed at the acute listed species LOC is one in 7050. This estimate is b ased on a probit dose-response slop of 3.63 (95% C.I. 1.13-6.12) obtained from an acute dose-based toxicity study on bobwhite quail. At the lower and upper 95% confidence limits the probability of individua l effects is 1.0 in 7.74 and 1.0 in 2.13E+09, respectively. For birds exposed to dodine as a resu lt of the highest registered use, the probability of individual effects ranges from 1.0 in 8.6E+05 to 1.0 in 1.00.
The probability of effects on individual mammals w as based on the default probit dose-response slope ofPage 87 of 219 4.5 since raw data were not available at the tim e of this assessment. The lower and upper confidence limits are assumed to be 2 and 9, respectively. The probability of individual effects is 1.0 in 2.94E+05. At the lower and upper confidence limits, the probability of individual effects is 1.0 in 44 and 1.0 in 1.0E+16, respectively. For mammals exposed to dodineat the highest application rate, the probability of individual effects ranges from 1.0 in 1.0E+16 to 1.0 in 2.03.
Table 4.14 Probability of Acute Mortality of anIndividual, by Taxa Group and Body Weight, Exposed at the Endangered Species LOC (1) and at the Highest Registered Use Rate (2.6 lbs a.i./A ) for Dodine Taxa Body Wt (g) Dietary Food Source LOC (1) Exposure 2.6 lbs a.i./A Application 5 apps./ 7 day interval Probability (2) of

effect at LOC

(1 in ___) EEC (3) (ppm) RQ (4) Probability (2) of Effect at RQ

(1 in ___ ) Birds 20 seeds 7050 151 0.35 20.4 100 seeds 7050 151 0.16 518 1000 seeds 7050 151 0.05 8.58E+05

20 insects 705 0 1356 3.16 1.04 100 insects 705 0 1356 1.42 1.41 1000 insects 7050 1356 0.45 9.61

20 short grasses 7050 2410 5.62 1.00 100 short grasses 705 0 2410 2.52 1.08 1000 short grasses 7050 2410 0.80 2.76 Mammals 15 seeds 2.94E+05 151 0.01 1.00E+16 35 seeds 2.94E+05 151 0.01 1.00E+16 1000 seeds 2.94E+05 151 0.01 1.00E+16

15 insects 2.94E+05 1356 0.55 8.24 35 insects 2.94E+05 1356 0.48 13.2 1000 insects 2.94E+05 1356 0.25 297

15 short grasses 2.94E+05 2410 0.99 2.03
35 short grasses 2.94E+05 2410 0.85 2.66 1000 short grasses 2.94E+05 2410 0.45 16.9 Reptiles, and

Terrestrial Amphibians 20 insects 2.94E+05 1356 3.16 1.04 100 insects 2.94E+05 1356 1.42 1.41 1000 insects 2.94E+05 1356 0.45 9.61

20 short grasses 2.94E+05 2410 5.62 1.00 100 short grasses 2.94E+05 2410 2.52 1.08Table 4.14 Probability of Acute Mortality of an Individual, by Taxa Group and Body Weight, Exposed at the Endangered Species LOC (1) and at the Highest Registered Use Rate (2.6 lbs a.i./A ) for Dodine Taxa Body Wt (g) Dietary Food Source LOC (1) Exposure 2.6 lbs a.i./A Application 5 apps./ 7 day interval Probability (2) of

effect at LOC

(1 in ___) EEC (3) (ppm) RQ (4) Probability (2) of Effect at RQ

(1 in ___ )

Page 88 of 219 1000 short grasses 2.94E+05 2410 0.80 2.76

At the estimated exposure levels for the highest regist ered use rate for dodine (5 applications at 7 day intervals of 2.6 lbs. a.i./A) the probability of an individual being affected is greater than the acute endangered species LOC for most taxonomic groups feeding on most dietary items (Table 4.14, Probability of Effect at RQ). The exceptions ar e large (1 kg) seed-eating birds and all seed-eating mammals (Table 4.14). For other dietary categories and taxa, the highest probability of an individual being affected is found in small birds and small reptiles/amphibians that consume insects or short grasses; these are near a 1 in 1 chance of effects. Generally, for all the taxa, the chance of effects is highest for smaller body-sized organisms and for those that cons ume short grass or insects. Note that the upper limit for the probability of effects is 1 in 1; which is equivalent to 100%.
Similar results as described in the preceding paragraph would be observed for other specified use rates for dodine since there are similar use rates for a numbe r of labeled crops. The exceptions are cherries, strawberries and crab apples and shade trees in Ore gon. These uses would result in lower probabilities of individual effects, however, it should be noted that, with the exception of cherries, these are relatively minor uses of dodine.
Since available data indicates that dodine is practi cally non-toxic to terrestrial invertebrates, the probability of individual effects at the listed species LOC was not calculated. There is no evidence available that suggests risk to terrestrial inverteb rates associated with uses of dodine. However, it is possible that some insects are more sensitive to dodine than honeybees.
A thorough assessment of risks to terrestrial plants was not possible given the lack of Tier II plant toxicity data. However, Tier I studies indicated that for some plants, effects >25% may be expected for the highest rates of dodine use. In cases where Tier II data is not available and Tier I studies indicate an effect, risks to terrestrial plants are assumed. A robust assessment of risks to terrestrial plants requires Tier II plant toxicity testing.
Uncertainties and Assumptions of the Probit Dose-Response AnalysisPage 89 of 219 Estimates of the probability of affecting individual organisms is based on extrapolation of very low probability events and is associated with considerable uncertainty in the resulting estimates. To provide a sense of possible probability values, the analysis was also conducted using the lower and upper 95% confidence limits of the probit dose-response slope. Fo r mammals, the default slope of 4.5 was used since data were unavailable to generate a specific estimat e of the probit dose-response slope. The lack of an experimentally determined estimate increases the uncertainty. To explore possible bounds to such estimates, upper and lower values (9 and 2) were u sed to calculate upper and lower estimates of the effects probability associated with the listed species LOC. In addition to noting the relatively large uncertainty bounds around the probabilities, care should be employed in interpreting these probabilities beyond their intended purpose as an indication of a margin of safety, or lack there of, for the endangered species risk estimates based on the quotient model.
4.2.5.2.3 Terrestrial and Aquatic Field Data
The screening assessment indicates that dodine use may pot entially affect a variety of terrestrial and aquatic receptors including birds, mammals, herpetof auna, aquatic invertebrates, molluscs, freshwater fish, and aquatic plants. There are no field data or incident reports indicating poisoning of species from these taxa associated with dodine use. However, a lack of documented incidents is not evidence that poisonings have not or will not occur. Typically, fi eld incident data is infre quent and can be ad-hoc. Moreover, many receptors may move from the site of poisoning precluding discovery, and given the status of these populations, the probability of detecti ng an effect to an individual is extremely low.Page 90 of 219 4.2.5.2.4 Indirect Effects
Pesticides have the potential to cause indirect effects to endangered or threatened species by, for example, perturbing forage or prey availability, altering the extent of nesting habitat, etc. The potential for indirect effects is determined by comparing RQs to the lis ted species LOCs. If the RQ exceeds the listed species LOC then there is the potential for indirect effects to listed species dependent on those taxa for which the RQ exceeded the listed species LOC.
For aquatic species potentially exposed to dodine, RQ s exceeded the listed species acute risk LOCs to varying degrees for freshwater fish, freshwater invert ebrates, estuarine/marine invertebrates, saltwater molluscs, and aquatic non-vascular plants. Aquatic non- vascular plants had the highest RQs and for all uses of dodine, the probability of individual effects was 1 in 1 molluscs and freshwater fish showed lower probabilities of individual effects associated with uses of dodine.
Given the sensitivities of the aquatic taxa to dodine, indirect effects to listed species would be expected most for species dependent on freshwater non-vascular (and perhaps vascular) plants and freshwater invertebrates based on the results of the above analysis . Given that both aquatic plants and invertebrates are important components of any aquatic ecosystem , indirect effects on a number of aquatic (and terrestrial) listed species is possible. The most obvious indirect effects would likely relate directly to reductions in food availability or ha bitat alterations associated with re duced aquatic plant and invertebrate biomass. Other, less obvious, indirect effects might include disruptions of listed species life cycles if certain life-cycle components are dependent on particular plant or invertebrate species.
Although the analysis suggests that indirect effects to listed species associated with dodine use would be dominated by effects on aquatic plants and inverteb rates, there are some risks for fish, saltwater nonmolluscan invertebrates, and molluscs that may result in indirect effects as well. Representative species from these taxa were less sensitive to dodine compared to aquatic plants and invertebrates; probability of effects for these taxa ranged from 1 in 216 (saltwater i nvertebrates; apples) to more than 1 in a million. Nevertheless, the possibility of indirect effects to listed species dependent on saltwater invertebrates or molluscs cannot be excluded. Importantly, with these taxa, the likelihood of indirect effects is increased with higher use rates.
For terrestrial species, the screening-level analysis indicated that, for most uses, dodine may cause deleterious effects in exposed bird and mammal popul ations (i.e., acute and chronic LOCs are exceeded for birds and mammals) (Section 4.1). This suggest s potential concern for indirect effects on listed organisms dependant upon vertebrate species (birds, ma mmals, reptiles and amphibians) as prey items. A potential drop in vertebrate biomass associated with dodine use may reduce a significant portion of the prey base. While it is likely that fields can be re populated by immigrants and living breeders after the use of pesticides, if the prey base is removed at a critical life-cycle juncture, over a large area or of if it is removed for a long enough duration, some species may have difficulty meeting energy needs. Also, some species may be particularly sensitive during reproductiv e or developmental periods. A starting point for evaluating the potential risk of such a scenario would be to first identify listed species likely to occur in dodine use areas, compare life histories of listed species in known dodine use areas and determine if use is likely to overlap with a sensitive life-cycle component.Page 91 of 219 Based on the calculated probabilities ( Tables 4.13-4.14-2.3.5), it appears likely that some taxa for most uses (birds, mammals, reptiles, terrestrial phase amphibians) will be affected by dodine. Therefore, further analyses of indirect effects are warranted for the listed species that are dependent or partially dependent on any of these taxonomic groups.
Because of the likelihood of direct impacts to birds and mammals under certain uses of dodine, there is also a potential for indirect effects to some liste d plant species through effects on pollinators. For example, if avian pollinators are negatively impacted by dodine, use during the reproductive period of a particular plant could reduce successful pollination. Th is particular indirect effect is dependent both on pollinator species affected and on the timing and manner of dodine use. A preliminary analysis could include first, identifying plants that could be at ri sk based on location and timing of pollination. Second, identifying potential pollinators and whether they woul d be affected by the intended use of dodine as not all uses may cause risk to all pollinators.
The information presented on indirect effects serves as a guide to establish the need for and extent of additional analyses that may be performed using Services-provided “species profiles” as well as evaluations of the geographical and temporal nature of the exposure to ascertain if a “not likely to adversely affect” determination can be made. The degree to which additional analyses are performed is commensurate with the predicted probability of adve rse effects from the comparison of the dose-response information with the EECs. The greater the probab ility that exposures will produce effects on a taxa, the greater the concern for potential indirect effects fo r listed species dependant upon that taxa, and therefore, the more intensive the analysis on the potential listed sp ecies of concern, their locations relative to the use site, and information regarding the use scenario (e .g., timing, frequency, and geographical extent of pesticide application).
4.2.5.2.5 Critical Habitat for Listed Species
In the evaluation of pesticide effects on designated cr itical habitat, consideration is given to the physical and biological features (constituent elements) of a critical habitat identified by the U.S Fish and Wildlife and National Marine Fisheries Services as essential to the conservation of a listed species and which may require special management considerations or protecti on. The evaluation of impacts for a screening-level pesticide risk assessment focuses on the biological features that are constituent elements and is accomplished using the screening-level taxonomic analys is (risk quotients, RQs) and listed species levels of concern (LOCs) that are used to evaluate direct and indirect effects to listed organisms.
The screening-level risk assessment has identified potentia l concerns for indirect effects on listed species for those organisms dependant light of the potential for indirect effects, the next step for EPA and the Service(s) is to identify which listed species and criti cal habitat are potentially implicated. Analytically, the identification of such species and critical habitat canoccur in either of two ways. First, the agencies could determine whether the action area overlaps criti cal habitat or the occupied range of any listed species. If so, EPA would examine whether the p esticide's potential impacts on non-endangered species would affect the listed species indirectly or directly affect a constituent element of the critical habitat. Alternatively, the agencies could determine which listed species depend on biological resources, or have constituent elements that fall into the taxa that may be directly or indirectly impacted by the pesticide. Then EPA would determine whether use of the pes ticide overlaps the critical habitat or the occupiedPage 92 of 219 range of those listed species.

This screening-level risk assessment for critical habitat provides a listing of potential biological features that, if they are constituent elements of one or mo re critical habitats, would be of potential concern. These correspond to the taxa identified above as bei ng of potential concern for indirect effects and include the following This list should serve as an initial step in problem formulation for further assessment of critical habitat impacts outlined above, should additional work be necessary.
4.2.5.2.6 Listed Species Occurrence Associated with Dodine Uses
A preliminary analysis of the co-occurrence of lis ted species and proposed re-registration of dodine uses was conducted using EFED’s LOCATES database. The objective was to provide insight into the potential for exposure of listed species and to iden tify those areas, crop uses, and listed species that warrant further attention. A tabulation of the number of unique listed species that occur in the vicinity of dodine use, by crop and by state is provided in
By this tabulation there are a total of potentially 796 listed species in counties where dodine can be used. Listed plant species account for almost half of this to tal followed by fish, clams, and birds and the other taxa. Although a lack of Tier II plant studies precludes a thorough assessment of the risks to terrestrial plants, at the very least, indirect effects on listed plant species are possible via direct effects on avian pollinators. Listed fish species are the second most numerous. The screening-level analysis indicated that the acute risk LOCs for freshwater fish were only exceeded for uses of dodine on apples. Most listed fish species (94%), however, are associated with or ar e in the vicinity of apple orchards. Currently, none of the listed taxa in Tables 4.15 and 4.16 can be di scounted since for many, direct effects are expected and, in addition, indirect effects may be important fo r some species in all taxa given the risks of dodine to aquatic plants and invertebrates.
In terms of states in which dodine might be used, a total of 46 states have listed species and crops for which dodine may be used. California has the highest number (271) of listed species that may co-occur with dodine use areas. Alabama is the second highest with 87 total species followed by Florida with 79, Tennessee with 70 and Texas with 65.
No estimate of the overlap of dodine use with speci al local needs for Oregon was conducted since those particular crops (crab apples, ornamental shad e trees) were not listed in the LOCATES database.
In general, for all labeled uses of dodine there is at least one, and usually more, listed species that may potentially occur in or near a use area. Appendix G lis ts the occurrence in each state of counties that have a listed species of a specified taxa and the total list of endangered species that may co-occur with labeled uses of dodine and a comprehensive list of speci es in counties where dodine may be used. This preliminary analysis indicates that there is a poten tial for dodine use to overlap with listed species and that a more refined assessment is warranted. The more refined assessment should involve clear delineation of the action area associated with uses of dodine and best available information on the temporal and spatial co-location of listed species with respect to the action area



### . This analysis has notPage 93 of 219 been conducted for this assessment.
Table 4.15 Tabulation by Taxonomic Group and Crop of Listed Species that Occur in Proposed Re-registration Dodine Use Areas.

Crop Taxonomic GroupBirdsMammalsReptilesAmphibiansFishCrustaceansArachnidsInsectsSnailsClamsPlants Total Apples 33 48 23 17 103 19 9 38 25 68 335 718 Cherries, sweet 19 26 7 3 26 7 0 15 4 3 139 249 Cherries, tart 17 14 5 3 22 3 0 9 3 3 64 143 Peaches 35 49 26 16 82 16 11 36 20 68 318 677 Pears 31 44 22 15 70 11 11 33 12 41 276 566 Pecans 31 35 20 15 65 11 10 18 15 48 179 447 Strawberries 28 36 18 9 45 14 0 28 5 40 240 463 Walnuts 14 26 8 6 20 8 0 19 1 0 165 267 Total Unique Species 38 55 28 18 109 19 11 41 26 70 381 796 Total States 46 44 18 11 39 11 3 23 11 27 46

Table 4.16 Tabulation by State and Taxonomic Group of Listed Species that Occur in Proposed Re-registration Dodine Use Areas.

State Taxonomic GroupBirdsMammalsReptilesAmphibiansFishCrustaceansArachnidsInsectsSnailsClamsPlants Total Alabama 4 4 5 3 14 1 10 29 17 87 Arizona 8 8 2 2 15 1 13 49 Arkansas 3 3 3 2 1 1 6 4 23 California 15 21 8 6 23 8 20 1 169 271 Colorado 2 2 5 6 15 Connecticut 3 2 1 1 1 2 10 Delaware 22 1 2 7Table 4.16 Tabulation by State and Taxonomic Group of Listed Species that Occur in Proposed Re-registration Dodine Use Areas.

State Taxonomic GroupBirdsMammalsReptilesAmphibiansFishCrustaceansArachnidsInsectsSnailsClamsPlants Total

Page 94 of 219 Florida 9 8 10 1 4 1 1 7 38 79 Georgia 4 2 2 1 7 1 15 15 47 Idaho 1 3 5 4 3 16 Illinois 3 2 1 1 2 1 1 6 17 Indiana 1 2 1 1 9 14 Iowa 1 1 1 2 5 10 Kansas 4 2 4 1 2 13 Kentucky 3 2 3 1 17 5 31 Louisiana 4 2 2 2 2 1 13 Maine 3 2 2 3 10 Maryland 1 3 2 2 1 6 15 Massachusetts 3 2 1 1 3 3 13 Michigan 2 2 1 3 2 6 16 Minnesota 21 14 8 Mississippi 6 1 5 1 3 3 2 21 Missouri 2 2 6 1 4 7 22 Montana 12 2 2 7 Nebraska 3 14 Nevada 1 1 8 1 7 18 New Hampshire 11 1 12 6 New Jersey 3 2 1 5 11 New Mexico 5 5 1 1 11 1 2 12 38 New York 3 2 1 1 1 6 14 North Carolina 6 5 1 3 1 4 25 45 Ohio 1 1 1 1 1 5 4 14 Oklahoma 7 3 4 1 2 2 19 Oregon 5 1 18 2 1 10 37 Pennsylvania 22 22 8 Rhode Island 12 1 1 2 7Table 4.16 Tabulation by State and Taxonomic Group of Listed Species that Occur in Proposed Re-registration Dodine Use Areas.

State Taxonomic GroupBirdsMammalsReptilesAmphibiansFishCrustaceansArachnidsInsectsSnailsClamsPlants Total

Page 95 of 219 South Carolina 4 3 2 2 1 1 18 31 South Dakota 3 1 15 Tennessee 3 4 14 1 1 3 26 18 70 Texas 11 3 3 4 6 1 10 8 19 65 Utah 2 2 1 8 17 30 Vermont 11 12 5 Virginia 1 5 1 1 4 1 12 11 36 Washington 4 4 15 6 29 West Virginia 12 114 9 Wisconsin 11 2 1 5 Total Unique Species 38 55 28 18 109 19 11 41 26 70 381 796

4.3 Description of Assumptions, Limitations, Uncertainties, Strengths and Data Gaps
4.3.1 Assumptions and Limitations Related to Exposure for all Taxa
This screening-level risk assessment relies on proposed labeled statements of the maximum rate of dodine application, the maximum number of applications, and the shortest interval between applications. The frequency at which actual uses approach these maxima is dependant on agricultural conditions (presence of fungi) and market forces.

4.3.2 Assumptions and Limitations Rela ted to Exposure for Aquatic Species
Although there are uncertainties associated with us ing the standard PRZM/EXAMS runoff scenario (10 ha field draining into 20,000 m 3 pond with no outlet) for an aquatic exposure assessment, it is designed to represent pesticide exposure from an agricultural wate rshed impacting a vulnerable aquatic environment. Extrapolating the risk conclusions from this standard pond scenario may either underestimate or overestimate the potential risks.Page 96 of 219 Major uncertainties associated with the standard runoff scenario include the physical construct of the watershed and representation of vulne rable aquatic environments for di fferent geographic regions. The physicochemical properties (pH, redox conditions, etc.) of the standard farm pond are based on a Georgia farm pond. These properties are likely to be regionally specific because of local hydrogeological conditions. Any alteration in wate r quality parameters may impact th e environmental behavior of a pesticide. The farm pond represents a well mixed, static water body. Because the farm pond is a static water body (no flow through), it does not account for pesticide removal through flow through or water releases. The lack of flow through the farm pond provides an environmental condition for accumulation of persistent pesticides. The assumption of unifo rm mixing does not account for stratification due to thermoclines ( e.g. , seasonal stratification in deep water bodies) . Additionally, the dimensions of the standard runoff scenario assumes a watershed ar ea to water body volume ratio of 10 ha: 20,000m 3 . This ratio is recommended to maintain a sustainable cons tructed pond in the Southeastern United States. The use of higher watershed area to water body volume ratios (as recommended for sustainable ponds in drier regions of the United States) may lead to higher pes ticide concentrations when compared to the standard watershed area to water body volume ratio.

The standard runoff scenario assumes uniform soils and agronomic management practices across the standard 10 hectare field. Soils can vary substan tially across even small areas; this variation is not reflected in the model simulations. Additionally, the impact of unique soil characteristics and soil management practices ( e.g. , tile drainage) are not considered in the standard runoff scenario. The assumption of uniform site and management conditions is not expected to represent some site-specific conditions. Extrapolating the risk conclusions from the standard pond scenario to other aquatic habitats ( e.g. , marshes, streams, creeks, and shallow rivers, in termittent aquatic areas) may either underestimate or overestimate the potential risks in those habitats.
4.3.3 Assumptions and Limitations Related to Exposure for Terrestrial Species
4.3.3.1 Location of wildlife species
For screening terrestrial risk assessments for listed species, a generic bird or mammal is assumed to occupy either the treated field or adjacent areas receivi ng pesticide at a rate similar to the treatment rate on the field. This assumption leads to an overestimation of exposure to species that do not occupy the treated field. For screening risk assessment purposes, the actual habitat requirements of any particular terrestrial species are not considered, and it assumed that species occupy, exclusively and permanently, the treated area being modeled. This assumption l eads to an overestimate of exposure in the risk estimates fo a proportion of individuals of the e xposed population. Although this estimate represents higher levels of exposure, it is w ithin the range of possibility as some species may occupy habitats near the use site and use the use site to forage. Go rging can be a common opportunistic behavior in some animals whereby food items are consumed in excess of the daily requirement due to availability. This example is more likely to support an acute exposur e scenario. Chronic exposure is more difficult to ascertain since it occurs over a longer duration providing more opportunity for animals to move and seek forage elsewhere. Nonetheless, many animals do forage over a range that would be included in agricultural fields; all prey items for th ese species may come from agricultural use areas.
4.3.3.2 Routes of exposurePage 97 of 219 Screening-level risk assessments for spray applicati ons of pesticides consider dietary exposure alone. Other routes of exposure, not considered in this assessment, are discussed below:
4.3.3.2.1 Incidental soil ingestion exposure

This risk assessment does not consider incidental soil ingestion. Available data suggests that up to 15% of the diet can consist of incidentally ingested soil depending on the species and feeding A simple first approximation of soil concentr ation of pesticide from spray application shows the effect of not considering incidental soil ingestion:

For example a 20 g birds consumes approximately 22.8 g food daily. The amount of dodine ingested from short grass is approximately 50 mg (22.8 g food consumed x 2224 ppm in food). The amount of dodine ingested as a result of incidental soil ingestion is approximately 0.1 mg (0.15 x 22.8 x 29 ppm), which represents about 0.2% of the total exposure due to eating dodine-contaminated food-items.
4.3.3.2.2 Inhalation exposure
The screening risk assessment does not consider inhala tion exposure. Such exposure may occur through three potential sources: (1) spray material in droplet form at the time of application (2) vapor phase pesticide volatilizing from treated surfaces, and (3) air borne particulate (soil, vegetative material, and pesticide dusts).
Available data suggest that inhalation exposure at th e time of application is not an appreciable route of exposure for birds. According to research on mallards a nd bobwhite quail, respirable particle size in birds (particles reaching the lung) is limited to a maximum diameter of 2 to 5 microns . The spray droplet spectra covering the majority of pesticide application situations (AgDrift model scenarios for very-fine to coarse droplet applications) suggests that less than 1% of the applied material is within the respirable particle size. However, the particles s till may be ingested, and the model does not address this.
Theoretically, inhalation of pesticide active ingred ient in the vapor phase may be another source of exposure for some pesticides under some exposure situ ations. Considering dodine’s low vapor pressure, it is unlikely that dodine will exist in the gaseous phase at any considerable amount to cause any adverse effects via inhalation.Page 98 of 219 The impact from exposure to dusts contaminated with the pesticide cannot be assessed generically as partitioning issues related to application site soils and chemical properties render the exposure potential from this route highly situation specific.
4.3.3.2.3 Dermal exposure
The screening assessment does not consider dermal exposure, except as it is indirectly included in calculations of RQs based on lethal doses per unit of pesticide treated area. Dermal exposure may occur through three potential sources: (1) direct application of spray to terrestrial wildlife in the treated area or within the drift footprint, (2) incidental contact with contaminated vegetation, or (3) contact with contaminated water or soil.

The available measured data related to wildlife dermal contact with pesticides are extremely limited. The Agency is actively pursuing modeling techniques to acc ount for dermal exposure via direct application of spray and by incidental contact with vegetation.

4.3.3.3 Incidental Pesticide Re leases Associated with Use
This risk assessment is based on the assumption that the entire treatment area is subject to dodine application at the rates specified on the label. In reality, there is the potential for uneven application of dodine through such plausible incidents as changes in calibration of application equipment, spillage, and localized releases at specific areas of the treated field that are associat ed with specifics of the type of application equipment used ( e.g. , increased application at turnabouts when using older ground application equipment).

4.3.3.4 Residue Levels Selection
As discussed earlier in the exposure section of this document, the Agency relies on the work of Kenaga and Fletcher et al. (1994) for setting the assumed pesticide resi dues in wildlife dietary items. The Agency believes that these residue assumptions reflect a realistic upper-bound residue estimate, although the degree to which this assumption reflects a specific pe rcentile estimate is difficult to quantify. It is important to note that the field measurement efforts used to develop the Fletcher estimates of exposure involve highly varied sampling techniques. It is entirely possible that much of these data reflect residues averaged over entire above ground plants in the case of grass and forage sampling. Depending upon a specific wildlife species’ foraging habits, whole aboveground plant samples may either underestimate or overestimate actual exposure.
4.3.3.5 Dietary Intake - The Differences Between Laboratory and Field Conditions
The acute and chronic characterization of risk rely on comparisons of wildlife dietary residues with LC 50 or NOAEC values expressed in concentrations of pesticides in laboratory feed. These comparisons assume that ingestion of food items in the field occu rs at rates similar to those in the laboratory. Although the screening assessment process adjusts dry-wei ght estimates of food intake to reflect thePage 99 of 219 increased mass in fresh-weight wildlife food intake estimates, it does not allow for gross energy and assimilative efficiency differences between wildlife food items and laboratory feed.
On gross energy content alone, direct comparison of a laboratory dietary concentration- based effects threshold to a fresh-weight pesticide residue estimate would result in an underestimation of field exposure by food consumption by a factor of 1.25 - 2.5 for most food items. Only for seeds would the direct comparison of dietary threshold to residue estimate lead to an overestimate of exposure.
Differences in assimilative efficiency between laborat ory and wild diets suggest that current screening assessment methods do not account for a potentially important aspect of food requirements. Depending upon species and dietary matrix, bird assimilation of wild diet energy ranges from 23 - 80%, and mammal assimilation of diet ranges from 41 - 85% ( ). If it is assumed that laboratory chow is formulated to maximize assimilative efficiency ( e.g. , a value of 85%), a potential for underestimation of exposure may exist by assuming that consumption of f ood in the wild is comparable with consumption during laboratory testing. In the screening process, exposure may be underestimated because metabolic rates are not related to food consumption.
Finally, the screening procedure does not account for s ituations where the feeding rate may be above or below requirements to meet free living metabolic requi rements. Gorging behavior is a possibility under some specific wildlife scenarios ( e.g. , bird migration) where the food intake rate may be greatly has suggested that an upper-bound limit to this behavior might be the typical intake rate multiplied by a factor of 5.
In contrast, there is the potential for avoidance, operationally defined as animals responding to the presence of noxious chemicals in their food by reducing consumption of treated dietary elements. This response is seen in nature where herbivores avoi d plant secondary compounds. However, reduced food intake, particularly over an exte nded period, could result in reduced survival or reproductive output.Page 100 of 219 4.3.4 Assumptions and Limitations Related to Effects Assessment
4.3.4.1 Age class and sensitivity of effects thresholds

4.3.4.3 Use of the Most Sensitive Species Tested
Although the screening risk assessment relies on a select ed toxicity endpoint from the most sensitive species tested, it does not necessarily mean that the sel ected toxicity endpoints reflect sensitivity of the most sensitive species existing in a given environment. The relative position of the most sensitive species tested in the distribution of all possible species is a function of the overall variability among species to a particular chemical. The relationship between the sensitivity of the most tested species versus wild species (including listed species) is unknown and a source of significant uncertainty. The use of laboratory species has historically been driven by availability and ease of maintenance. A widespread comparison of species is lacking, however, even va riation within a species can be quite high. For example, in this assessment, acute studies on waterfl eas yielded three different values. Granted these were within an order of magnitude but examples ex ist where differences have been more extreme.Page 101 of 219 4.3.4.4 Data Gaps
The major data gap is the lack of aquatic vascular plant toxicity studies and registrant submitted Tier II terrestrial plant studies. For dodine, the only regi strant-submitted aquatic plant study was on green algae ( Selenastrum capricornutum ). Results from this study indicate that dodine is highly to green alga ( Selenastrum capricornutum ), however, there is insufficient data to generate a suitable understanding of the toxicity of dodine to aquatic plants.

argue for a robust understanding of the chronic toxicity of dodine to estuarine/marine invertebrates. To generate robust estimates of risk for estuarine/marine fish and inve rtebrates, chronic toxicity studies on representative species from these taxa are required.
4.3.5 Assumptions Associated with the Acute LOCsPage 102 of 219 LITERATURE CITED
Burns, Lawrence, 2004. Exposure Analysis Modeling System (EXAMS): User Manual and System Documentation. Ecosystem Research Division, National Exposure Research Laboratory. U. S. Environmental Protection Agency, Athens, GA.
Cabral, J.P.S. 1991. Damage to the Cytoplasm ic Membrane and Cell Death Caused by Dodine (Dodecylganidine Monoacetate) in Pseudomon as syringae ATCC 12271. Antimicrobial Agents and Chemotherapy 35(2):341-344.
Carsel, R. F., J. C. Imhoff, P. R. Humel, J. M. Cheplick, and A. S. Donigian, Jr. 1997. PRZM-3, A Model for Predicting Pesticide and Nitrogen Fate in the Crop Root and Unsaturated Zones: User’s Manual for Release 3.0. National Exposure Research Laboratory, Office of Research and Development, U. S. Environmental Protection Agency, Athens, GA.

Dodine. Hazardous Substances Data Bank. 2005. http://toxnet.nlm.nih.gov

.
Environmental Fate and Effects Division. 2002. Guidance for Selecting Input Parameters in Modeling the Environmental Fate and Transport of Pesticides , Version II . U. S. Environmental Protection Agency. Washington, D.C. http://www.epa.gov/oppefed1/models/water/input_guidance2_28_02.htm
Fletcher, J.S., J.E. Nellessen, and T.G. Pfleeger. 1994. Literature review and evaluation of the EPA food-chain (Kenaga) nomogram, and instrument for estimating pesticide residues on plants. Environmental Toxicology and Chemistry 13 (9):1383-1391.
Gianessi, L.P. and M.B. Marcelli. 2000. Pesticid e Use in U.S. Crop Production: 1997 National Summary Report. National Center for Food and Agricultural Policy, Washington D.C. http://www.ncfap.org/database/default.htm
Hoerger, F., and E.E. Kenaga. 1972. Pesticide r esidues on plants: Correlation of representative data as a basis for estimation of their magnitude in the environment. In F. Coulston and F. Korte, eds ., Environmental Quality and Safety: Chemistry, Toxicology, and Technology, Georg Thieme Publ, Stuttgart, West Germany, pp. 9-28.
Kirkwood, J.H. 1983. A limit to metabolizable ener gy intake in mammals and birds. Comp. Biochem. Physiol. 75A:1-3.
OPP EFED. 1999. Downwind Deposition Tolerance Bounds for Orchards. Scientific Advisory Panel background document. http://www.epa.gov/scipoly/sap/1999/july/airblast.pdf

. Relyea, R.A. 2005. Impacts of Insecticides a nd Herbicides on the Biodiversity and Productivity of Aquatic Communities. Ecologi cal Applications 15(2): 618-627.Page 103 of 219 Sharma, D.P., D.C. Ferree, and F.O. Harman. 1977. Multiple Applications of Dicofol and Dodine Sprays on Net Photosynthesis of Apple Leaves. Hortscience 12(2): 154-155.
Teske, M., S.L. Bird, D.M. Esterly, S.L. Ray, and S.G. Perry. 2001. A User’s Guide for AgDRIFT 2.01: A Tiered Approach for the Assessment of Spray Dr ift of Pesticides. Spray Drift Task Force. Macon, MO.
Thelin, G.P and L.P Gianessi. 2000. Method for Estimating Pesticide Use for County Areas of the Conterminous United States. U.S. GEOLOGICAL SURVEY. Open-File Report 00-250. Sacramento, CA. http://ca.water.usgs.gov/ pnsp/pesticide_use_maps_1997/
U.S. EPA. 2004. Overview of the Ecological Ri sk Assessment Process in the Office of Pesticide Programs. Office of Prevention, Pesticides and Toxic Substances. Office of Pesticides Programs. Washington, DC. January 23, 2004.
U.S. EPA. 1998. Guidelines for Ecological Risk A ssessment. Risk Assessment Forum, Washington, DC. EPA 630/R-95/002F April 1998.
U.S. EPA. 1993. Wildlife Exposure Factors Handbook. EPA/600/R-13/187a, Office of Research and Dvelopment, Washington, D.C.
U.S. EPA. 1990. Laboratory Test Methods of Expos ure to Microbial Pest Control Agents by the Respiratory Route to Nontarget Avian Species. Environmental Research Laboratory, Corvalis, OR. EPA/600/3-90/070.
Willis, G.H., and L.L. McDowell. 1987. Pesticide Persistence on Foliage in Reviews of Environmental Contamination and Toxicology . 100:23-73.
Wood, B.W. and J.A. Payne. 1985. Inhibition of Photosynthesis in Pecan Leaves by Fungicides. Plant Disease 69: 997-998.

### Page 104 of 219 APPENDIX A - Maximum Use Rates Based on Current Labels Compiled by BEADTable 1. Maximum Dodine use rates and manage ment practices by crop based on current labels. (Generalized Screening Level Portrayal Of Current Label Uses) Current As Of - 05/03/2004

Page 105 of 219

Use Site Max. Rate per App Max. Rate Unit/Area *UG Form Max.# Apps cc & yr Max. App Rate/ cc & yr Min. App Interval (days) Application Equipment //Type (Reg # Code)
NON-FOOD/NON-FEED USES cherry .3400~ lb A FlC 1/1 yr NS 7 Aircraft/ Sprayer //Low volume spray (concentrate)/ Spray (a) .3400~ lb A FlC NS NS 7 Aircraft/ Sprayer //Low volume spray (concentrate)/ Spray (b) crabapple .3400~ lb A FlC NS NS 5 Aircraft/ Sprayer //Low volume spray (concentrate)/ Spray (a) ornamental and/or shade trees .8500~ lb A FlC NS NS 10 Aircraft/ Sprayer //Low volume spray (concentrate)/ Spray (a)
FOOD/FEED USES apple 1.95 lb A WP NS NS 5 AN NS Aircraft/ High volume ground sprayer/ Low volume ground sprayer //High volume spray (dilute)/ Low volume spray (concentrate) (a) cherry 1.275 lb A FlC 1/1 yr NS 7 High volume ground sprayer/ Low volume ground sprayer/ Sprayer //High volume spray (dilute)/ Low volume spray (concentrate) (a)
1.6 lb A D NS NS 7 Aircraft/ Ground //Dust (b) peach 1.275 lb A FlC 1/1 yr NS NS High volume ground sprayer/ Low volume ground sprayer //High volume spray (dilute)/ Low volume spray (concentrate) (a)
2.6 lb A WP NS NS 7 NS High volume ground sprayer/ Low volume ground sprayer //High volume spray (dilute)/ Low volume spray (concentrate) (b) pear 1.95 lb A WP 6/cc NS 5 Aircraft/ High volume ground sprayer/ Low volume ground sprayer //High volume spray (dilute)/ Low volume spray (concentrate) (a) 1.95 lb A WP NS NS 5 Aircraft/ High volume groundTable 1. Maximum Dodine use rates and manage ment practices by crop based on current labels. (Generalized Screening Level Portrayal Of Current Label Uses) Current As Of - 05/03/2004

Use Site Max. Rate per App Max. Rate Unit/Area *UG Form Max.# Apps cc & yr Max. App Rate/ cc & yr Min. App Interval (days) Application Equipment //Type (Reg # Code)

Page 106 of 219 sprayer/ Low volume ground sprayer //High volume spray (dilute)/ Low volume spray (concentrate) (b) pecan 2.6 lb A WP NS NS 10 AN Aircraft/ High volume ground sprayer/ Low volume ground sprayer //High volume spray (dilute)/ Low volume spray (concentrate) (a) strawberry 1.3 lb A WP NS NS 7 High volume ground sprayer //High volume spray (dilute) (a) use 03009 2.6 lb A WP NS NS 10 High volume ground sprayer/ Low volume ground sprayer //High volume spray (dilute)/ Low volume spray (concentrate) (a) walnut (english/black) 2.6 lb A WP NS NS 10 High volume ground sprayer/ Low volume ground sprayer //High volume spray (dilute)/ Low volume spray (concentrate) (a)

Use Site/Registration Number(s) for Maximum Dosages with Reg # Codes

NON-FOOD/NON-FEED USES

cherry OR04002500(a,b) crabapple OR04002500(a) ornamental and/or shade trees OR04002500(a)

FOOD/FEED USES

apple 241-51(a), 55260-5(a) cherry 34704-153(b), 55260-6(a) peach 241-51(b), 55260-5(b), 55260-6(a) pear 241-51(b), 55260-5(a) pecan 241-51(a), 55260-5(a) strawberry 241-51(a), 55260-5(a)Table 1. Maximum Dodine use rates and manage ment practices by crop based on current labels. (Generalized Screening Level Portrayal Of Current Label Uses) Current As Of - 05/03/2004

Page 107 of 219

use 03009 241-51(a) walnut (english/black) 55260-5(a)Page 108 of 219 LEGEND

HEADER ABBREVIATIONS Use Site : The use site refers to the entity (crop, building, surface or article) where a pesticide is applied and/or which is being protected. Max.Rate per App : Maximum dose for a single application to a single site. System calculated. Max.Rate Unit/Area : Units and Area associated with the maximum dose. *UG : Use Group codes. Form : The physical form of the end use product found in the container. Max. # Apps cc & yr : The maximum number of applications. Max. App Rate/cc & yr : The maximum amount of pesticide product that can be applied to a site in one growing season (/cc) or during the span of one year (/yr). Min. App Interval (days): The minimum retreatment interval between applications in days (aggregated). Application Equipment : The equipment used to apply pesticide (aggregated). Application Type : The type of pesticide application (aggregated). Current as of - : The label data for the listed products in this report is current as of this date.

ABBREVIATIONS AN - As Needed. NA - Not Applicable. NS - Not Specified (on label). (L) - The dosage information provided is from the label in terms of product (e.g., ounces, gallons, or pounds of the product) because there was insufficient information (e.g., missing density, area, or active ingredient percentages) to provide converted dosage information. ~ - The tilde indicates a dosage that includes information from a SLN label.

APPLICATION RATE cwt :Hundred Weight. nnE-xx :nn times (10 power -xx), for instance, "1.234E-4" is equivalent to ".0001234". -- :No description available in LUIS unit conversion vocabulary.

FORMULATION CODES D : Dust FlC : Flowable Concentrate WP : Wettable Powder

### Page 109 of 219 APPENDIX B. ENVIRONMENTAL FATE DATA
Abiotic Degradation
Hydrolysis
Dodecylguanidine HCl is stable to hydrolysis at e nvironmentally relevant pHs and temperatures. In a hydrolysis study conducted for 30 days in darkness at 25°C, dodecylguanidine HCl ( 14 C-radio-labeled in the guanidine moiety) at a concentration of 10 μg/mL did not hydrolyze in sterile pH 5, 7 and 9 aqueous buffer solutions (MRID 42242601). Although materi al balances were occasionally variable, dodecylguanidine HCl was the only compound detected following HPLC separation with UV detection. The half-lives reported in the study (576 days @ pH 5, 914 days @ pH 7, and 1198 days @ pH 9) are of questionable value, as they were extrapolated bey ond the scope of the data (i.e., far beyond the 30-day study). The submitted study was classified as acceptable and provides adequate data for the risk assessment.
Aqueous Photolysis
Dodecylguanidine HCl did not photograde in water under favorable light conditions. 14 C-Radiolabeled dodecylguanidine HCl at 12 μg/mL did not appreciab ly photodegrade in sterile pH 5 aqueous buffered solution maintained at 25°C and irradiated con tinuously with a xenon arc lamp for 30 days (MRID 42419001). At 30 days posttreatment, 14 C-dodecylguanidine comprised $ 95.9% of the organosoluble residues; no other 14 C-compounds were detected. The half-life calculated by the authors of the study (770 days vs 1004 days for the dark control) is of ques tionable value, as it was extrapolated beyond the scope of the data. The study was classified as acceptable a nd provides useful data for the risk assessment.
Dodine is stable to photolysis unde r environmental light conditions. 14 C-Radiolabeled dodine decreased from 91.0% of the applied at day 0 to 82.1% at 30 days in sterile pH 7 aqueous buffered solution maintained at 25°C and irradiated continuously with a xenon arc lamp for 30 days (MRID 46438203). One transformation product was identified as guanidine (Rt 2.1-2.7 minutes) and was a maximum 14.7% and 7.3% of the applied in the irradiated soluti ons and in the dark controls, respectively . The environmental half-life calculated by the reviewer of the study (641 days) is of questionable value, as it was extrapolated beyond the scope of the data. The study was classified as acceptable and provides useful data for the risk assessment.
Soil Photolysis
Dodine is stable to photolysis unde r environmental light conditions. 14 C-Radiolabeled dodine decreased from 89.4% of the applied at day 0 to 71.4% at 30 days in a sandy loam soil [pH 6.2, organic matter 0.44%] from California maintained at 25 ± 3°C and i rradiated on a twelve hour light/dark cycle using a UV-filtered xenon lamp (MRID 46438204). No major tr ansformation products were identified. The environmental half-life calculated by the reviewer of the study (239 days) is of questionable value, as it was extrapolated beyond the scope of the data. The study was classified as acceptable and provides useful data for the risk assessment.

### Page 110 of 219 Metabolism

Aerobic Soil Metabolism

Dodine is metabolized in soil under aerobic cond itions (MRID 43945201). Dodine, radiolabeled on the guanidine carbon ( 14 C-guanidine), was added to flasks containing a high organic sandy loam soil (pH 5.3, organic carbon 2.2%) from the UK and a low organic sandy loam soil (pH 5.9, organic carbon 0.6%) from Mississippi at approximately the a nominal rate of 2.5 mg a.i./kg. Volatiles and carbon dioxide were collected in ethylene glycol and potassium hydroxide , respectively, over a period of 100 days. The soils were extracted at intervals, and the extracts were analyzed. Recoveries of applied radioactivity were generally 90-110%. The major metabolite trappe d in potassium hydroxide was carbon dioxide, 91-92% of the applied dose. The percent of material in th e soil extract fell with time from 90% on day 0 to 3% at day 100. The half lives in the US and UK soils were 22.3 (r 2 = 0.76) and 17.5 (r 2 = 0.91) days, respectively, calculated by log-linear regression. Degradates were not identified. The study was classified as acceptable and provides u seful data for the risk assessment.

Anaerobic Soil Metabolism

No studies were conducted on anaerobic soil metabolism.
Aerobic Aquatic Metabolism
Dodecylguanidine HCl is metabolized slow ly in flooded soil under aerobic conditions. [ 14 C]- dodecylguanidine HCl (radiolabeled in the guanidine moiety), at 12 ppm, degraded by 9.6% in aerobic sandy loam soil that was incubated in the dark at 25±1°C for 30 days (MRID 42327401). At 30 days, extractable 14 C-labeled soil residues were 87.3% of the applied, and dodecylguanidine HCl averaged 98.5% of the extractable residues. Unextracted soil 14 C residues were 5.3% of the applied, with 93.9, 4.8, and 1.4% in the humin, humic acid, and fulvic acid fractions, respectively. 14 C residue in the floodwater was 0.75%. A 14 C compound present in the floodwater at 0.01 ppm could not be identified. Floodwater 14 CO 2 averaged 2.3%. Based on the results of the study, microbially mediated metabolism of dodecylguanidine HCl in flooded aerobic soil is expected to proceed slowly in the environment. The half-life reported in the study (227 days) is of ques tionable value, as it was extrapolated beyond the scope of the data (i.e., beyond the 30-day study). This study was classified as acceptable and provides adequate data for the risk assessment.
Dodine is metabolized in flooded soil under aerobic conditions. [ 14 C]-dodecylguanidinium acetate (radiolabeled in the guanidine moiety) was studi ed in lake water-silt loam sediment and pond waterloamy sand/sand sediment systems from The Netherlands for 84 days under aerobic conditions in darkness at 20 ± 2°C (MRID 46438202). The sediment ex traction method consisted of organic solvents (methanol/dichloromethane/ n-hexane ) and resulted in a substantial pr oportion of nonextractable residues. Since dodine is a salt of a strong base, an acid/base extraction method (e.g., KOH in methanol/HCl in methanol), as used in the aerobic soil metabolism study (MRID 4394520) and the aerobic aquatic metabolism study for dodecylguanidine HCl (MRIDs 42327401, 42414601), would have been the preferred extraction method. Therefore, sediment and total system half-lives were calculated assuming the nonextractables were non-degraded parent dodine.

### Page 111 of 219 In a lake water-silt loam sediment systems, [ 14 C]dodine in the total system declined from 92.81% of the applied radioactivity at time 0 to 60.34% at 0.2 days (5 hours) to 21.76% at 1 day to 15.20% at 2 days to 5.03% at 5 days and was 0.32-1.75% at 9-84 days pos ttreatment (final sampling interval). In the water layers, [ 14 C]dodine declined from 92.81% at time 0 to 55.70% at 0.2 days (5 hours) to 16.63% at 1 day to 9.98% at 2 days to 1.36% at 5 days and was not reported at 9-84 days. In the sediments, [ 14 C]dodine was measured at 3.67-5.22% at 0.2-5 days and was 0.32- 1.75% at 9-84 days. In the water layer, the transformation product M2 averaged a maximum of 10.08% of the applied radioactivity at 2 days posttreatment (last sampling interval analyzed), and M1 (tentatively identified as urea) and M3 were 2.91% and 3.72% at 1 day, respectively. No tran sformation products were isolated from the sediment. Extractable [ 14 C]residues were 3.7-7.2% of the applied at 0. 2-9 days and declined to 0.8% at 84 days. Nonextractable [ 14 C]residues were a maximum of 57.7% of the applied at 1 day, declined to 21.7-23.0% at 20-48 days, and were 33.4% at 84 days. Assu ming the nonextractable residues are parent dodine, results in a total system half-life of 59.8 days.
In the pond water-loamy sand/sand sediment systems, [ 14 C]dodine in the total system declined from 96.73% of the applied radioactivity at time 0 to 57. 44% at 0.2 days (5 hours) to 26.44% at 2 days to 5.17% at 5 days and was 0.43-1.17% at 20-84 days pos ttreatment (final sampling interval). In the water layers, [ 14 C]dodine declined from 96.73% at time 0 to 29.93% at 0.2 days (5 hours) to 10.59% at 1 day to 5.16% at 2 days to 0.46% at 5 days and was not reported at 9-84 days. In the sediments, [ 14 C]dodine declined from 21.28-27.51% at 0.2-2 days to 3.37-4. 71% at 5-8 days and was 0.43-1.17% at 20-84 days. In the water layer, the transformation product M2 averaged a maximum of 13.95% of the applied radioactivity at 2 days posttreatment (last sampling in terval analyzed), and M1 (tentatively identified as urea) and M3 were 4.63% and 4.50% at 0.2 days, resp ectively. No transformation products were isolated from the sediment. Extractable [ 14 C]residues were 33.6% at 0.2 days posttreatment, declined to 8.2% at 5 days, and were 0.8% at 84 days. Nonextractable [ 14 C]residues were a maximum of 34.6% at 1 day posttreatment, declined to 9.4% at 20 days, and we re 13.8% at 84 days. Assuming the nonextractable residues are parent dodine, results in a total system half-life of 38.9 days. This study was classified as supplemental, but it’s scientifically valid and meet s the requirements for an aerobic aquatic metabolism study.
Anaerobic Aquatic Metabolism
Dodecylguanidine HCl is degraded very slow ly in flooded soil under anaerobic conditions. The biodegradation of 14 C-dodecylguanidine HCl (radio-labeled in th e guanidine moiety) was studied in sandy loam soil under anaerobic (nitrogen atmosphere) conditi ons in the dark at approximately 25°C for up to12 months (MRID 42763001). Analyses for the parent compound were performed immediately posttreatment, at 1, 3, 7, and 14 days, and at 1, 2, 3, 4, 6, 9, and 12 months post-treatment. In the soil substrate [ 14 C]dodecylguanidine HCl comprised 86.5-95.6% of the applied immediately post-treatment, ranged from 88.27 to 97.08% of the applied between 1 day and 9 months post-treatment (except for 79.8- 80.9% at 1 month) with no discernable pattern of decline, and comprised 77.8-82.8% at 12 months. Greater than 89% of the applied radioactivity was asso ciated with the soil at all sampling intervals, and [ 14 C]dodecylguanidine HCl comprised >95.6% of the ra dioactivity in the soil extracts at all sampling intervals. Other 14 C residues totaled 1.4-10.5% of the applied radioactivity through 30 days posttreatment (maximum at 0 days) and 0.6-1.5% at two through 12 months. Floodwater was not analyzed for degradates prior to 3 months. At 3 through 12 months, 14 C-dodecylguanidine HCl in floodwater was # 0.75% of that applied. At 12 months, 14 CO 2 was 0.69% of that applied.

### Page 112 of 219 A nonvolatile degradate, n -dodecylamino hydroxymethanamine was isolated from both the soil extracts and floodwater. This degradate accounted for 1.9- 3.9% of the applied compound at 12 months posttreatment (degradates were not characterized at earlier time points). Another nonvolatile degradate was present at approximately 1.2% in the soil at 12 m onths. This latter degradate was not identified.

Unextracted soil 14 C residues in the 12-month sample were differentiated into humin, humic acid, and fulvic acid fractions. The three respective fractions accounted for 8.7 (1.00 μg/g), 0.9 (0.10 μg/g), and 0.3% (0.04 μg/g) of the applied radioactivity.
Based on the results of this study, microbially mediated metabolism of dodecylguanidine HCl in anaerobic aqueous conditions is expected to proceed very slowly in the environment. The half-life reported in the study (2492 days) is of questionable value, as it was extrapolated beyond the time frame of the 12-month study. In addition, 14 C-residues in the floodwater were not accounted for. However, the study is scientifically sound and provides useful data for the risk assessment. The study fails to meet Subdivision N guidelines because radioactivity in the floodwater (approximately 7.1% of the applied dose) was not characterized through 2 months pos ttreatment and one degradate was not identified.
Mobility and Persistence
Adsorption/Desorption
Based on soil adsorption coefficient (K d ) values determined using Freundlich adsorption isotherms with batch equilibrium study data, dodecylguanidine HCl was determined to be immobile in soil, regardless of soil organic matter content. No data were available for degradates. A single batch equilibrium study was submitted for dodecylguanidine HCl (MRID 42148901); no data were submitted for dodine.
The soils were characterized as sand, sandy loam, cl ay loam, and silt loam. Organic carbon content and pH were not stated. The soils and adsorption/deso rption study results are presented in Table B1. The adsorption and desorption of guanidine 14 C-labeled- dodecylguanidine HCl was studied in four soils treated at concentrations of 0.67, 0.365, 0.557, or 0.770 μg/mL and maintained in the dark at 25°C for 72 hours. The soil:solution suspensions (0.01 N calcium chloride) were equilibrated on a mechanical shaker during the incubation. After the equilibration period, Freundlich K ads values were 6440 for the sand, 2202 for the sandy loam, 18,019 for the clay loam, and 15, 228 for the silt loam soils; n values were 0.45, 0.51, 1.01, and 0.83, respectively. Desorption (K des ) values were 294 for the sand, 3095 for the sandy loam, 2028 for the clay loam, and 760 for the silt loam soils. K oc values ranged from 5.51 x 10 5 to 1.29 x 10 7 for adsorption, and from 3.62 x 10 4 to 7.74 x 10 5 for desorption. However, adsorption did not appear to be correlated with organic matter content or clay. Material balances for the soil suspensions following desorption ranged from 89.81 to 116.15% of the applie d radioactivity. This study was classified as acceptable and provides data on the mobility of unaged dodecylguanidine HCl. Data on aged dodecylguanidine HCl and dodine were not submitted.

### Page 113 of 219 Table B1. Freundlich adsorption and desorption constants for dodecylguanidine HCl in four soils 1
Soil type (texture, OC %, pH) Adsorption Desorption
K (mL/g) n r 2 K (mL/g) 1/n r 2
sand (0.05%, 7.6) 6440 0.45 0.8770 294 2.22 0.9651

sandy loam (0.40 %, 6.5) 2202 0.51 0.9735 3095 1.96 0.9983

clay loam (0.65%, , 6.4) 18019 1.01 0.9955 2028 0.99 0.8164

silt loam (2.1%, 7.4) 15228 0.83 0.9962 760 1.2 0.9845

Laboratory Volatility
No laboratory studies were conducted on volatility.
Field Volatility
Field studies of the volatility of dodine or dodecylgua nidine HCl were not conducted. Based on the low vapor pressure of both chemicals (1.5 x 10 -7 mm Hg for dodine), volatilization is not expected to occur in the field.
Terrestrial Field Dissipation
Based on the results of a single terrestrial field dissi pation study, dodine is exp ected to be non-persistent in the field. The terrestrial field dissipation of dodine was studied in bareground plots (orchard use pattern) at four U.S. sites. Dissipation was not fully considered in the study as degradates of dodine were not analyzed (however, prior aerobic degradation studies had failed to show the presence of significant amounts of metabolites). There was some variation in dissipation among and within sites and rainfall/evaporation data were not always representative of normal site conditions, but, taken as a whole, the study was scientifically valid. The parent compound did not leach through soil.
The soil types were sand (Washington), loam (New Jer sey), sand (Georgia), and loamy sand (California). Dodine was broadcast applied six times as a spray, at 7-day intervals, at a nominal rate of 1.95 lb a.i./acre (total application 11.7 lb a.i./acre) (MRID 44985701). Following the sixth application, dodine dissipated from the respective sites with observed first half-liv es of <0.25 months, <0.25 months, between 0.25 and 0.5 months, and between 0.5 and 1 month (respective calculated first half-lives were 0.39 months, 0.28 months, 0.26 months, and 0.40 months. Dissipation was biphasic in all four plots, with an initial rapid phase occurring during the first month post-treatment.

### Page 114 of 219 At all four sites, dodine was present primarily in the 0- to 6-inch depth. Dodine was not detected below 6 inches with the following exceptions: (1) 6- to 12-inch depth once at the New Jersey site and once at the California site (each time, 1 of 4 replicates) and (2 ) 18-24-inch depth once at the Georgia site (1 of 4 replicates); all concentrations outside the 0- to 6-inch depth were # 0.034 ppm.

Table B2. Terrestrial field dissipation studies results (dodine).

MRID Soil Texture (pH, organic

matter content) Target Applic.

Rate (lb ai/A) Site Plot Type Dissipation Half-life (or

DT 50 ) in

Soil (days) Parent Maximum Leaching

Depth Major Degradates & Maximum Leaching Depth Application Type/ Formulation

44985701 sand (6.7; 1.2%) 11.7 1 WA bareground t 1/2 = 12 0-6" 2 Not applicable 3 broadcast as a spray “ loam (6.0; 2.3%) 11.7 NJ bareground t 1/2 = 8.4 0-6" Not applicable broadcast as a spray “ sand (7.1-7.4; 1.0-1.5%) 11.7 GA bareground t 1/2 = 7.8 0-6" Not applicable broadcast as a spray “ loamy sand (7.1; 0.5%) 11.7 CA bareground t 1/2 = 12 0-6" 4 Not applicable broadcast as a spray

1 Six applications of 1.95 lb a.i./A with 7-day intervals.

2 Although dodine was found at one or more lowe r depths at a single sampling interval, th e detections were low (<0.034 ppm) and q uantifiable concentrations were found in only 1 of 4 replicates.

3 Degradates were not identified.

Bioaccumulation

Bioaccumulation in Fish

Bioaccumulation studies were not conducted.

### Page 115 of 219 APPENDIX C. Aquatic Exposure Modeling Assessment - PRZM/EXAMS Outputs

NC Apple Aerial Application stored as NCapple.out Chemical: dodine PRZM environment: NCappleC.txt modified Satday, 12 October 2002 at 18:09:36 EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30 Metfile: w03812.dvf modified Wedday, 3 July 2002 at 10:05:50 Water segment concentrations (ppb)
Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1965 4.876 0.7837 0.6146 0.3134 0.2542 0.1276 1966 4.364 0.7525 0.6874 0.4268 0.3813 0.255 1967 4.495 0.8832 0.8183 0.5423 0.5005 0.3838 1968 4.674 1.014 0.9502 0.669 0.6112 0.4943 1969 4.731 1.119 1.058 0.7886 0.721 0.602 1970 4.838 1.252 1.171 0.8835 0.816 0.6939 1971 4.92 1.309 1.244 0.9663 0.902 0.785 1972 5.486 1.492 1.339 1.106 1.036 0.9146 1973 7.035 1.893 1.522 1.302 1.266 1.106 1974 7.394 2.126 1.761 1.465 1.389 1.246 1975 5.477 1.903 1.815 1.535 1.499 1.362 1976 5.606 2.273 1.98 1.665 1.645 1.504 1977 9.113 2.581 2.183 1.843 1.766 1.623 1978 6.18 2.243 2.179 1.903 1.836 1.705 1979 6.303 2.452 2.314 2.018 1.946 1.803 1980 6.919 2.529 2.414 2.132 2.07 1.917 1981 6.943 2.607 2.482 2.19 2.16 2.02 1982 6.239 2.627 2.563 2.284 2.221 2.099 1983 6.377 2.932 2.701 2.393 2.324 2.182 1984 6.991 2.872 2.781 2.507 2.436 2.289 1985 6.506 2.903 2.834 2.55 2.482 2.355 1986 6.561 2.95 2.886 2.604 2.538 2.41 1987 7.585 3.161 2.943 2.665 2.631 2.499 1988 6.714 3.161 3.041 2.763 2.694 2.561 1989 6.809 3.185 3.096 2.853 2.787 2.658

### Page 116 of 219 1990 6.884 3.39 3.23 2.954 2.884 2.746

Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.037037037037037 9.113 3.39 3.23 2.954 2.884 2.746 0.0740740740740741 7.585 3.185 3.096 2.853 2.787 2.658 0.111111111111111 7.394 3.161 3.041 2.763 2.694 2.561 0.148148148148148 7.035 3.161 2.943 2.665 2.631 2.499 0.185185185185185 6.991 2.95 2.886 2.604 2.538 2.41 0.222222222222222 6.943 2.932 2.834 2.55 2.482 2.355 0.259259259259259 6.919 2.903 2.781 2.507 2.436 2.289 0.296296296296296 6.884 2.872 2.701 2.393 2.324 2.182 0.333333333333333 6.809 2.627 2.563 2.284 2.221 2.099 0.37037037037037 6.714 2.607 2.482 2.19 2.16 2.02 0.407407407407407 6.561 2.581 2.414 2.132 2.07 1.917 0.444444444444444 6.506 2.529 2.314 2.018 1.946 1.803 0.481481481481481 6.377 2.452 2.183 1.903 1.836 1.705 0.518518518518518 6.303 2.273 2.179 1.843 1.766 1.623 0.555555555555556 6.239 2.243 1.98 1.665 1.645 1.504 0.592592592592593 6.18 2.126 1.815 1.535 1.499 1.362 0.62962962962963 5.606 1.903 1.761 1.465 1.389 1.246 0.666666666666667 5.486 1.893 1.522 1.302 1.266 1.106 0.703703703703704 5.477 1.492 1.339 1.106 1.036 0.9146 0.740740740740741 4.92 1.309 1.244 0.9663 0.902 0.785 0.777777777777778 4.876 1.252 1.171 0.8835 0.816 0.6939 0.814814814814815 4.838 1.119 1.058 0.7886 0.721 0.602 0.851851851851852 4.731 1.014 0.9502 0.669 0.6112 0.4943 0.888888888888889 4.674 0.8832 0.8183 0.5423 0.5005 0.3838 0.925925925925926 4.495 0.7837 0.6874 0.4268 0.3813 0.255 0.962962962962963 4.364 0.7525 0.6146 0.3134 0.2542 0.1276

0.1 7.4513 3.1682 3.0575 2.79 2.7219 2.5901 Average of yearly averages: 1.55158461538462
Inputs generated by pe4.pl - 8-August-2003

### Page 117 of 219 Data used for this run: Output File: NCapple Metfile: w03812.dvf PRZM scenario: NCappleC.txt EXAMS environment file: pond298.exv Chemical Name: dodine Description Variable Name Value Units Comments Molecular weight mwt 287.4 g/mol Henry's Law Const. henry 9e-11 atm-m^3/mol Vapor Pressure vapr 1.5e-7 torr Solubility sol 6300 mg/L Kd Kd 10427 mg/L Koc Koc mg/L Photolysis half-life kdp 770 days Half-life Aerobic Aquatic Metabolism kbacw 333 days Halfife Anaerobic Aquatic Metabolism kbacs 7476 days Halfife Aerobic Soil Metabolism asm 27.3 days Halfife Hydrolysis: pH 7 914 days Half-life Method: CAM 2 integer See PRZM manual Incorporation Depth: DEPI cm Application Rate: TAPP 2.19 kg/ha Application Efficiency: APPEFF .95 fraction Spray Drift DRFT .05 fraction of application rate applied to pond Application Date Date 15-3 dd/mm or dd/mmm or dd-mm or dd-mmm Interval 1 interval 5 days Set to 0 or delete line for single app. Interval 2 interval 5 days Set to 0 or delete line for single app. Interval 3 interval 5 days Set to 0 or delete line for single app. Interval 4 interval 5 days Set to 0 or delete line for single app. Interval 5 interval 5 days Set to 0 or delete line for single app. Record 17: FILTRA IPSCND1 UPTKF Record 18: PLVKRT PLDKRT FEXTRC 0.5 Flag for Index Res. Run IR Pond

### Page 118 of 219 Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

===================================================================== OR Apple Aerial Application stored as ORapple.out Chemical: dodine PRZM environment: ORappleC.txt modified Satday, 12 October 2002 at 18:16:34 EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30 Metfile: w24229.dvf modified Wedday, 3 July 2002 at 10:06:10 Water segment concentrations (ppb)
Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1961 4.264 0.7772 0.6019 0.3069 0.2384 0.1099 1962 4.348 0.813 0.6717 0.3985 0.3313 0.2058 1963 4.443 0.8316 0.7674 0.4948 0.4274 0.301 1964 4.537 0.9255 0.8605 0.5799 0.5136 0.39 1965 4.63 1.094 0.9691 0.678 0.61 0.4823 1966 4.715 1.104 1.039 0.7584 0.692 0.568 1967 4.8 1.188 1.123 0.8427 0.7762 0.6515 1968 4.882 1.27 1.205 0.9267 0.862 0.7364 1969 4.968 1.356 1.292 1.011 0.9441 0.8194 1970 5.049 1.437 1.373 1.092 1.025 0.8994 1971 5.134 1.588 1.48 1.184 1.115 0.9844 1972 5.212 1.601 1.536 1.255 1.188 1.062 1973 5.287 1.676 1.611 1.33 1.263 1.137 1974 5.363 1.751 1.686 1.405 1.338 1.212 1975 5.436 1.824 1.76 1.479 1.412 1.285 1976 5.509 1.897 1.833 1.552 1.485 1.358 1977 5.58 1.969 1.904 1.623 1.556 1.43 1978 5.653 2.041 1.976 1.698 1.631 1.502 1979 5.723 2.112 2.048 1.77 1.702 1.573 1980 5.792 2.181 2.117 1.835 1.768 1.641 1981 5.859 2.248 2.183 1.902 1.835 1.707 1982 6.003 2.329 2.263 1.974 1.906 1.776 1983 5.993 2.381 2.317 2.035 1.967 1.84 1984 6.062 2.496 2.406 2.112 2.042 1.909 1985 6.125 2.513 2.449 2.168 2.105 1.975

### Page 119 of 219 1986 6.19 2.578 2.514 2.232 2.165 2.036 1987 6.249 2.637 2.573 2.291 2.224 2.094 1988 8.659 3.005 2.695 2.383 2.31 2.168 1989 6.387 2.788 2.71 2.428 2.36 2.229 1990 6.44 2.841 2.765 2.484 2.416 2.285

Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.032258064516129 8.659 3.005 2.765 2.484 2.416 2.285 0.0645161290322581 6.44 2.841 2.71 2.428 2.36 2.229 0.0967741935483871 6.387 2.788 2.695 2.383 2.31 2.168 0.129032258064516 6.249 2.637 2.573 2.291 2.224 2.094 0.161290322580645 6.19 2.578 2.514 2.232 2.165 2.036 0.193548387096774 6.125 2.513 2.449 2.168 2.105 1.975 0.225806451612903 6.062 2.496 2.406 2.112 2.042 1.909 0.258064516129032 6.003 2.381 2.317 2.035 1.967 1.84 0.290322580645161 5.993 2.329 2.263 1.974 1.906 1.776 0.32258064516129 5.859 2.248 2.183 1.902 1.835 1.707 0.354838709677419 5.792 2.181 2.117 1.835 1.768 1.641 0.387096774193548 5.723 2.112 2.048 1.77 1.702 1.573 0.419354838709677 5.653 2.041 1.976 1.698 1.631 1.502 0.451612903225806 5.58 1.969 1.904 1.623 1.556 1.43 0.483870967741936 5.509 1.897 1.833 1.552 1.485 1.358 0.516129032258065 5.436 1.824 1.76 1.479 1.412 1.285 0.548387096774194 5.363 1.751 1.686 1.405 1.338 1.212 0.580645161290323 5.287 1.676 1.611 1.33 1.263 1.137 0.612903225806452 5.212 1.601 1.536 1.255 1.188 1.062 0.645161290322581 5.134 1.588 1.48 1.184 1.115 0.9844 0.67741935483871 5.049 1.437 1.373 1.092 1.025 0.8994 0.709677419354839 4.968 1.356 1.292 1.011 0.9441 0.8194 0.741935483870968 4.882 1.27 1.205 0.9267 0.862 0.7364 0.774193548387097 4.8 1.188 1.123 0.8427 0.7762 0.6515 0.806451612903226 4.715 1.104 1.039 0.7584 0.692 0.568 0.838709677419355 4.63 1.094 0.9691 0.678 0.61 0.4823 0.870967741935484 4.537 0.9255 0.8605 0.5799 0.5136 0.39 0.903225806451613 4.443 0.8316 0.7674 0.4948 0.4274 0.301

### Page 120 of 219 0.935483870967742 4.348 0.813 0.6717 0.3985 0.3313 0.2058 0.967741935483871 4.264 0.7772 0.6019 0.3069 0.2384 0.1099

0.1 6.3732 2.7729 2.6828 2.3738 2.3014 2.1606 Average of yearly averages: 1.27890333333333
Inputs generated by pe4.pl - 8-August-2003

Data used for this run: Output File: ORapple Metfile: w24229.dvf PRZM scenario: ORappleC.txt EXAMS environment file: pond298.exv Chemical Name: dodine Description Variable Name Value Units Comments Molecular weight mwt 287.4 g/mol Henry's Law Const. henry 9e-11 atm-m^3/mol Vapor Pressure vapr 1.5e-7 torr Solubility sol 6300 mg/L Kd Kd 10427 mg/L Koc Koc mg/L Photolysis half-life kdp 770 days Half-life Aerobic Aquatic Metabolism kbacw 333 days Halfife Anaerobic Aquatic Metabolism kbacs 7476 days Halfife Aerobic Soil Metabolism asm 27.3 days Halfife Hydrolysis: pH 7 914 days Half-life Method: CAM 2 integer See PRZM manual Incorporation Depth: DEPI cm Application Rate: TAPP 2.19 kg/ha Application Efficiency: APPEFF .95 fraction Spray Drift DRFT .05 fraction of application rate applied to pond Application Date Date 1-4 dd/mm or dd/mmm or dd-mm or dd-mmm Interval 1 interval 5 days Set to 0 or delete line for single app. Interval 2 interval 5 days Set to 0 or delete line for single app. Interval 3 interval 5 days Set to 0 or delete line for single app. Interval 4 interval 5 days Set to 0 or delete line for single app.

### Page 121 of 219 Interval 5 interval 5 days Set to 0 or delete line for single app. Record 17: FILTRA IPSCND1 UPTKF Record 18: PLVKRT PLDKRT FEXTRC 0.5 Flag for Index Res. Run IR Pond Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

======================================================================== PA Apple Aerial Application stored as PAapple.out Chemical: dodine PRZM environment: PAappleC.txt modified Satday, 12 October 2002 at 18:24:46 EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30 Metfile: w14737.dvf modified Wedday, 3 July 2002 at 10:06:12 Water segment concentrations (ppb)
Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1961 15.65 2.229 0.7058 0.4014 0.3465 0.191 1962 27.79 4.097 1.21 0.8065 0.726 0.5003 1963 4.805 1.193 1.129 0.8477 0.7907 0.6834 1964 8.642 1.883 1.32 1.101 1.035 0.8591 1965 5.117 1.506 1.441 1.166 1.1 0.9866 1966 5.31 1.626 1.565 1.283 1.216 1.107 1967 30.18 5.276 2.372 1.926 1.808 1.483 1968 24.08 9.08 3.393 2.517 2.358 1.96 1969 8.696 4.011 2.681 2.405 2.365 2.212 1970 9.91 3.368 2.827 2.538 2.516 2.378 1971 16.82 4.967 3.353 2.953 2.861 2.64 1972 43.19 8.322 4.268 3.66 3.503 3.094 1973 35.15 7.63 4.384 3.938 3.822 3.501 1974 23.64 6.881 4.663 4.175 4.061 3.817 1975 23.48 6.636 4.672 4.391 4.338 4.092 1976 12.02 5.304 4.676 4.409 4.337 4.229 1977 16.31 5.935 4.773 4.614 4.556 4.376

### Page 122 of 219 1978 25.89 8.123 5.585 5.017 4.917 4.65 1979 41.27 10.54 6.225 5.474 5.357 5.011 1980 9.289 5.992 5.671 5.363 5.283 5.118 1981 24.72 8.296 6.38 5.801 5.664 5.34 1982 48.67 11.46 7.377 6.402 6.236 5.778 1983 18.76 7.671 6.396 6.248 6.167 5.977 1984 33.22 9.965 7.743 6.997 6.833 6.374 1985 14.9 9.169 7.46 7.034 6.937 6.656 1986 21.98 9.295 7.507 7.107 7.011 6.814 1987 17.6 8.309 7.333 7.141 7.105 6.94 1988 42.39 14.75 8.857 7.895 7.749 7.315 1989 24.01 10.58 9.066 8.366 8.187 7.731 1990 42.88 12.68 9.317 8.557 8.446 8.076

Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.032258064516129 48.67 14.75 9.317 8.557 8.446 8.076 0.0645161290322581 43.19 12.68 9.066 8.366 8.187 7.731 0.0967741935483871 42.88 11.46 8.857 7.895 7.749 7.315 0.129032258064516 42.39 10.58 7.743 7.141 7.105 6.94 0.161290322580645 41.27 10.54 7.507 7.107 7.011 6.814 0.193548387096774 35.15 9.965 7.46 7.034 6.937 6.656 0.225806451612903 33.22 9.295 7.377 6.997 6.833 6.374 0.258064516129032 30.18 9.169 7.333 6.402 6.236 5.977 0.290322580645161 27.79 9.08 6.396 6.248 6.167 5.778 0.32258064516129 25.89 8.322 6.38 5.801 5.664 5.34 0.354838709677419 24.72 8.309 6.225 5.474 5.357 5.118 0.387096774193548 24.08 8.296 5.671 5.363 5.283 5.011 0.419354838709677 24.01 8.123 5.585 5.017 4.917 4.65 0.451612903225806 23.64 7.671 4.773 4.614 4.556 4.376 0.483870967741936 23.48 7.63 4.676 4.409 4.338 4.229 0.516129032258065 21.98 6.881 4.672 4.391 4.337 4.092 0.548387096774194 18.76 6.636 4.663 4.175 4.061 3.817 0.580645161290323 17.6 5.992 4.384 3.938 3.822 3.501 0.612903225806452 16.82 5.935 4.268 3.66 3.503 3.094 0.645161290322581 16.31 5.304 3.393 2.953 2.861 2.64

### Page 123 of 219 0.67741935483871 15.65 5.276 3.353 2.538 2.516 2.378 0.709677419354839 14.9 4.967 2.827 2.517 2.365 2.212 0.741935483870968 12.02 4.097 2.681 2.405 2.358 1.96 0.774193548387097 9.91 4.011 2.372 1.926 1.808 1.483 0.806451612903226 9.289 3.368 1.565 1.283 1.216 1.107 0.838709677419355 8.696 2.229 1.441 1.166 1.1 0.9866 0.870967741935484 8.642 1.883 1.32 1.101 1.035 0.8591 0.903225806451613 5.31 1.626 1.21 0.8477 0.7907 0.6834 0.935483870967742 5.117 1.506 1.129 0.8065 0.726 0.5003 0.967741935483871 4.805 1.193 0.7058 0.4014 0.3465 0.191

0.1 42.831 11.372 8.7456 7.8196 7.6846 7.2775 Average of yearly averages: 3.99631333333333
Inputs generated by pe4.pl - 8-August-2003

Data used for this run: Output File: PAapple Metfile: w14737.dvf PRZM scenario: PAappleC.txt EXAMS environment file: pond298.exv Chemical Name: dodine Description Variable Name Value Units Comments Molecular weight mwt 287.4 g/mol Henry's Law Const. henry 9e-11 atm-m^3/mol Vapor Pressure vapr 1.5e-7 torr Solubility sol 6300 mg/L Kd Kd 10427 mg/L Koc Koc mg/L Photolysis half-life kdp 770 days Half-life Aerobic Aquatic Metabolism kbacw 333 days Halfife Anaerobic Aquatic Metabolism kbacs 7476 days Halfife Aerobic Soil Metabolism asm 27.3 days Halfife Hydrolysis: pH 7 914 days Half-life Method: CAM 2 integer See PRZM manual Incorporation Depth: DEPI cm

### Page 124 of 219 Application Rate: TAPP 2.19 kg/ha Application Efficiency: APPEFF .95 fraction Spray Drift DRFT .05 fraction of application rate applied to pond Application Date Date 25-4 dd/mm or dd/mmm or dd-mm or dd-mmm Interval 1 interval 5 days Set to 0 or delete line for single app. Interval 2 interval 5 days Set to 0 or delete line for single app. Interval 3 interval 5 days Set to 0 or delete line for single app. Interval 4 interval 5 days Set to 0 or delete line for single app. Interval 5 interval 5 days Set to 0 or delete line for single app. Record 17: FILTRA IPSCND1 UPTKF Record 18: PLVKRT PLDKRT FEXTRC 0.5 Flag for Index Res. Run IR Pond Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

================================================================================ MI Cherries Aerial Application stored as MIcherries.out Chemical: dodine PRZM environment: MICherriesC.txt modified Satday, 27 March 2004 at 15:39:38 EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30 Metfile: w14850.dvf modified Wedday, 3 July 2002 at 10:05:40 Water segment concentrations (ppb)
Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1961 2.987 0.6592 0.2596 0.1892 0.1684 0.09118 1962 15.61 2.921 0.8968 0.5319 0.4669 0.2887 1963 8.713 1.471 0.7364 0.607 0.5491 0.424 1964 11.01 1.932 0.8256 0.6925 0.6598 0.5412 1965 3.396 0.9881 0.8227 0.7672 0.7228 0.6469 1966 5.063 1.313 0.9162 0.8463 0.8329 0.748 1967 3.61 1.477 1.123 1.003 0.9551 0.8497 1968 4.676 1.438 1.145 1.08 1.051 0.9432 1969 24.85 4.685 2.267 1.665 1.548 1.232

### Page 125 of 219 1970 4.134 1.817 1.566 1.505 1.46 1.386 1971 5.429 2.005 1.649 1.579 1.552 1.475 1972 12.25 3.472 2.045 1.803 1.764 1.626 1973 5.392 2.327 1.919 1.895 1.847 1.74 1974 16.92 4.38 2.496 2.178 2.101 1.91 1975 7.874 2.801 2.257 2.142 2.099 2.03 1976 4.923 2.478 2.3 2.227 2.186 2.105 1977 4.979 2.816 2.416 2.307 2.264 2.179 1978 5.675 3.008 2.536 2.445 2.394 2.283 1979 8.397 3.209 2.691 2.544 2.52 2.401 1980 10.09 3.513 2.87 2.683 2.628 2.504 1981 22.45 5.604 3.295 2.94 2.874 2.679 1982 17.83 4.907 3.256 2.999 2.96 2.829 1983 10.37 3.957 3.188 3.124 3.108 2.976 1984 6.736 3.56 3.322 3.208 3.161 3.072 1985 19.28 5.329 3.628 3.398 3.345 3.2 1986 29.75 6.978 4.6 3.957 3.834 3.51 1987 11.69 4.788 3.995 3.862 3.837 3.703 1988 6.537 4.129 3.965 3.896 3.867 3.772 1989 23.93 6.939 4.997 4.377 4.263 3.979 1990 20.21 6.874 4.932 4.49 4.416 4.2

Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.032258064516129 29.75 6.978 4.997 4.49 4.416 4.2 0.0645161290322581 24.85 6.939 4.932 4.377 4.263 3.979 0.0967741935483871 23.93 6.874 4.6 3.957 3.867 3.772 0.129032258064516 22.45 5.604 3.995 3.896 3.837 3.703 0.161290322580645 20.21 5.329 3.965 3.862 3.834 3.51 0.193548387096774 19.28 4.907 3.628 3.398 3.345 3.2 0.225806451612903 17.83 4.788 3.322 3.208 3.161 3.072 0.258064516129032 16.92 4.685 3.295 3.124 3.108 2.976 0.290322580645161 15.61 4.38 3.256 2.999 2.96 2.829 0.32258064516129 12.25 4.129 3.188 2.94 2.874 2.679 0.354838709677419 11.69 3.957 2.87 2.683 2.628 2.504 0.387096774193548 11.01 3.56 2.691 2.544 2.52 2.401

### Page 126 of 219 0.419354838709677 10.37 3.513 2.536 2.445 2.394 2.283 0.451612903225806 10.09 3.472 2.496 2.307 2.264 2.179 0.483870967741936 8.713 3.209 2.416 2.227 2.186 2.105 0.516129032258065 8.397 3.008 2.3 2.178 2.101 2.03 0.548387096774194 7.874 2.921 2.267 2.142 2.099 1.91 0.580645161290323 6.736 2.816 2.257 1.895 1.847 1.74 0.612903225806452 6.537 2.801 2.045 1.803 1.764 1.626 0.645161290322581 5.675 2.478 1.919 1.665 1.552 1.475 0.67741935483871 5.429 2.327 1.649 1.579 1.548 1.386 0.709677419354839 5.392 2.005 1.566 1.505 1.46 1.232 0.741935483870968 5.063 1.932 1.145 1.08 1.051 0.9432 0.774193548387097 4.979 1.817 1.123 1.003 0.9551 0.8497 0.806451612903226 4.923 1.477 0.9162 0.8463 0.8329 0.748 0.838709677419355 4.676 1.471 0.8968 0.7672 0.7228 0.6469 0.870967741935484 4.134 1.438 0.8256 0.6925 0.6598 0.5412 0.903225806451613 3.61 1.313 0.8227 0.607 0.5491 0.424 0.935483870967742 3.396 0.9881 0.7364 0.5319 0.4669 0.2887 0.967741935483871 2.987 0.6592 0.2596 0.1892 0.1684 0.09118

0.1 23.782 6.747 4.5395 3.9509 3.864 3.7651 Average of yearly averages: 2.04412933333333
Inputs generated by pe4.pl - 8-August-2003

Data used for this run: Output File: MIcherries Metfile: w14850.dvf PRZM scenario: MICherriesC.txt EXAMS environment file: pond298.exv Chemical Name: dodine Description Variable Name Value Units Comments Molecular weight mwt 287.4 g/mol Henry's Law Const. henry 9e-11 atm-m^3/mol Vapor Pressure vapr 1.5e-7 torr Solubility sol 6300 mg/L Kd Kd 10427 mg/L

### Page 127 of 219 Koc Koc mg/L Photolysis half-life kdp 770 days Half-life Aerobic Aquatic Metabolism kbacw 333 days Halfife Anaerobic Aquatic Metabolism kbacs 7476 days Halfife Aerobic Soil Metabolism asm 27.3 days Halfife Hydrolysis: pH 7 914 days Half-life Method: CAM 2 integer See PRZM manual Incorporation Depth: DEPI cm Application Rate: TAPP 1.46 kg/ha Application Efficiency: APPEFF .95 fraction Spray Drift DRFT .05 fraction of application rate applied to pond Application Date Date 10-5 dd/mm or dd/mmm or dd-mm or dd-mmm Interval 1 interval 7 days Set to 0 or delete line for single app. Interval 2 interval 7 days Set to 0 or delete line for single app. Interval 3 interval 7 days Set to 0 or delete line for single app. Interval 4 interval 7 days Set to 0 or delete line for single app. Interval 5 interval 7 days Set to 0 or delete line for single app. Record 17: FILTRA IPSCND1 UPTKF Record 18: PLVKRT PLDKRT FEXTRC 0.5 Flag for Index Res. Run IR Pond Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

================================================================================ GA Peaches stored as GApeaches.out Chemical: dodine PRZM environment: GAPeachesC.txt modified Satday, 12 October 2002 at 17:59:56 EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30 Metfile: w03813.dvf modified Wedday, 3 July 2002 at 10:04:32 Water segment concentrations (ppb)
Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1961 5.624 0.825 0.495 0.3392 0.2652 0.115

### Page 128 of 219 1962 5.74 1.295 0.6817 0.4687 0.3916 0.2357 1963 5.886 1.186 0.7553 0.5655 0.4944 0.3457 1964 5.977 1.315 0.8529 0.6874 0.6143 0.4583 1965 19.36 3.249 1.205 0.9777 0.9013 0.6738 1966 6.333 1.559 1.218 1.042 0.9658 0.8156 1967 6.427 1.628 1.33 1.138 1.065 0.9145 1968 9.633 2.118 1.507 1.269 1.187 1.021 1969 6.628 1.829 1.5 1.325 1.251 1.108 1970 6.711 1.912 1.583 1.406 1.336 1.191 1971 8.459 2.188 1.719 1.522 1.449 1.288 1972 6.889 2.09 1.761 1.595 1.52 1.37 1973 14.46 3.196 2.043 1.757 1.67 1.488 1974 7.101 2.486 2.008 1.806 1.729 1.58 1975 7.177 2.378 2.05 1.901 1.824 1.667 1976 9.692 3.37 2.365 2.062 1.97 1.78 1977 7.377 2.578 2.249 2.072 1.998 1.851 1978 7.435 2.636 2.307 2.13 2.058 1.91 1979 7.494 2.695 2.366 2.191 2.116 1.969 1980 7.552 2.753 2.424 2.247 2.176 2.027 1981 22.26 4.853 2.891 2.535 2.433 2.195 1982 7.808 3.009 2.681 2.503 2.429 2.281 1983 8.416 3.167 2.763 2.633 2.547 2.367 1984 16.35 5.062 3.209 2.825 2.731 2.515 1985 8.113 3.313 2.985 2.807 2.741 2.59 1986 8.16 3.36 3.032 2.854 2.777 2.638 1987 8.212 3.413 3.084 2.917 2.84 2.687 1988 8.256 3.457 3.128 2.95 2.877 2.73 1989 8.303 3.504 3.175 3.002 2.925 2.773 1990 8.339 3.54 3.211 3.034 2.957 2.809

Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.032258064516129 22.26 5.062 3.211 3.034 2.957 2.809 0.0645161290322581 19.36 4.853 3.209 3.002 2.925 2.773 0.0967741935483871 16.35 3.54 3.175 2.95 2.877 2.73 0.129032258064516 14.46 3.504 3.128 2.917 2.84 2.687

### Page 129 of 219 0.161290322580645 9.692 3.457 3.084 2.854 2.777 2.638 0.193548387096774 9.633 3.413 3.032 2.825 2.741 2.59 0.225806451612903 8.459 3.37 2.985 2.807 2.731 2.515 0.258064516129032 8.416 3.36 2.891 2.633 2.547 2.367 0.290322580645161 8.339 3.313 2.763 2.535 2.433 2.281 0.32258064516129 8.303 3.249 2.681 2.503 2.429 2.195 0.354838709677419 8.256 3.196 2.424 2.247 2.176 2.027 0.387096774193548 8.212 3.167 2.366 2.191 2.116 1.969 0.419354838709677 8.16 3.009 2.365 2.13 2.058 1.91 0.451612903225806 8.113 2.753 2.307 2.072 1.998 1.851 0.483870967741936 7.808 2.695 2.249 2.062 1.97 1.78 0.516129032258065 7.552 2.636 2.05 1.901 1.824 1.667 0.548387096774194 7.494 2.578 2.043 1.806 1.729 1.58 0.580645161290323 7.435 2.486 2.008 1.757 1.67 1.488 0.612903225806452 7.377 2.378 1.761 1.595 1.52 1.37 0.645161290322581 7.177 2.188 1.719 1.522 1.449 1.288 0.67741935483871 7.101 2.118 1.583 1.406 1.336 1.191 0.709677419354839 6.889 2.09 1.507 1.325 1.251 1.108 0.741935483870968 6.711 1.912 1.5 1.269 1.187 1.021 0.774193548387097 6.628 1.829 1.33 1.138 1.065 0.9145 0.806451612903226 6.427 1.628 1.218 1.042 0.9658 0.8156 0.838709677419355 6.333 1.559 1.205 0.9777 0.9013 0.6738 0.870967741935484 5.977 1.315 0.8529 0.6874 0.6143 0.4583 0.903225806451613 5.886 1.295 0.7553 0.5655 0.4944 0.3457 0.935483870967742 5.74 1.186 0.6817 0.4687 0.3916 0.2357 0.967741935483871 5.624 0.825 0.495 0.3392 0.2652 0.115

0.1 16.161 3.5364 3.1703 2.9467 2.8733 2.7257 Average of yearly averages: 1.64645333333333
Inputs generated by pe4.pl - 8-August-2003

Data used for this run: Output File: GApeaches Metfile: w03813.dvf PRZM scenario: GAPeachesC.txt

### Page 130 of 219 EXAMS environment file: pond298.exv Chemical Name: dodine Description Variable Name Value Units Comments Molecular weight mwt 287.4 g/mol Henry's Law Const. henry 9e-11 atm-m^3/mol Vapor Pressure vapr 1.5e-7 torr Solubility sol 6300 mg/L Kd Kd 10427 mg/L Koc Koc mg/L Photolysis half-life kdp 770 days Half-life Aerobic Aquatic Metabolism kbacw 333 days Halfife Anaerobic Aquatic Metabolism kbacs 7476 days Halfife Aerobic Soil Metabolism asm 27.3 days Halfife Hydrolysis: pH 7 914 days Half-life Method: CAM 2 integer See PRZM manual Incorporation Depth: DEPI cm Application Rate: TAPP 2.91 kg/ha Application Efficiency: APPEFF .95 fraction Spray Drift DRFT .05 fraction of application rate applied to pond Application Date Date 1-5 dd/mm or dd/mmm or dd-mm or dd-mmm Interval 1 interval 7 days Set to 0 or delete line for single app. Interval 2 interval 7 days Set to 0 or delete line for single app. Interval 3 interval 7 days Set to 0 or delete line for single app. Interval 4 interval 7 days Set to 0 or delete line for single app. Record 17: FILTRA IPSCND1 UPTKF Record 18: PLVKRT PLDKRT FEXTRC 0.5 Flag for Index Res. Run IR Pond Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

================================================================================ CA Fruit Aerial Application stored as CAfruit0.out Chemical: dodine

### Page 131 of 219 PRZM environment: CAfruit0C.txt modified Thuday, 17 June 2004 at 10:14:02 EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30 Metfile: w93193.dvf modified Wedday, 3 July 2002 at 10:04:24 Water segment concentrations (ppb)
Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1961 4.248 0.6364 0.5713 0.2909 0.2248 0.1073 1962 4.338 0.727 0.662 0.3815 0.3153 0.1972 1963 4.427 0.8155 0.7506 0.47 0.4037 0.2852 1964 4.514 0.9022 0.8373 0.5566 0.4903 0.3708 1965 4.598 0.9866 0.9218 0.6411 0.5746 0.455 1966 4.681 1.069 1.005 0.7236 0.657 0.5366 1967 4.761 1.149 1.085 0.8041 0.7374 0.6162 1968 4.839 1.227 1.162 0.8814 0.8147 0.693 1969 4.915 1.306 1.239 0.9583 0.8915 0.7696 1970 4.99 1.379 1.314 1.033 0.9662 0.8435 1971 5.063 1.451 1.387 1.106 1.039 0.916 1972 5.134 1.523 1.458 1.177 1.11 0.9862 1973 5.204 1.592 1.528 1.246 1.179 1.055 1974 5.271 1.659 1.595 1.314 1.246 1.122 1975 5.336 1.725 1.66 1.379 1.312 1.188 1976 5.403 1.791 1.727 1.445 1.378 1.253 1977 5.467 1.856 1.791 1.51 1.443 1.316 1978 5.526 1.916 1.85 1.569 1.502 1.375 1979 5.585 1.973 1.909 1.627 1.56 1.432 1980 5.64 2.028 1.964 1.683 1.615 1.488 1981 5.696 2.084 2.02 1.738 1.671 1.542 1982 5.748 2.137 2.073 1.791 1.723 1.596 1983 5.803 2.192 2.128 1.846 1.778 1.65 1984 5.854 2.242 2.178 1.896 1.828 1.698 1985 5.9 2.289 2.225 1.943 1.875 1.745 1986 5.946 2.335 2.271 1.989 1.921 1.791 1987 5.992 2.38 2.317 2.034 1.966 1.836 1988 6.038 2.427 2.363 2.081 2.013 1.882 1989 6.083 2.471 2.407 2.125 2.057 1.927 1990 6.127 2.516 2.452 2.17 2.102 1.971

### Page 132 of 219 Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.032258064516129 6.127 2.516 2.452 2.17 2.102 1.971 0.0645161290322581 6.083 2.471 2.407 2.125 2.057 1.927 0.0967741935483871 6.038 2.427 2.363 2.081 2.013 1.882 0.129032258064516 5.992 2.38 2.317 2.034 1.966 1.836 0.161290322580645 5.946 2.335 2.271 1.989 1.921 1.791 0.193548387096774 5.9 2.289 2.225 1.943 1.875 1.745 0.225806451612903 5.854 2.242 2.178 1.896 1.828 1.698 0.258064516129032 5.803 2.192 2.128 1.846 1.778 1.65 0.290322580645161 5.748 2.137 2.073 1.791 1.723 1.596 0.32258064516129 5.696 2.084 2.02 1.738 1.671 1.542 0.354838709677419 5.64 2.028 1.964 1.683 1.615 1.488 0.387096774193548 5.585 1.973 1.909 1.627 1.56 1.432 0.419354838709677 5.526 1.916 1.85 1.569 1.502 1.375 0.451612903225806 5.467 1.856 1.791 1.51 1.443 1.316 0.483870967741936 5.403 1.791 1.727 1.445 1.378 1.253 0.516129032258065 5.336 1.725 1.66 1.379 1.312 1.188 0.548387096774194 5.271 1.659 1.595 1.314 1.246 1.122 0.580645161290323 5.204 1.592 1.528 1.246 1.179 1.055 0.612903225806452 5.134 1.523 1.458 1.177 1.11 0.9862 0.645161290322581 5.063 1.451 1.387 1.106 1.039 0.916 0.67741935483871 4.99 1.379 1.314 1.033 0.9662 0.8435 0.709677419354839 4.915 1.306 1.239 0.9583 0.8915 0.7696 0.741935483870968 4.839 1.227 1.162 0.8814 0.8147 0.693 0.774193548387097 4.761 1.149 1.085 0.8041 0.7374 0.6162 0.806451612903226 4.681 1.069 1.005 0.7236 0.657 0.5366 0.838709677419355 4.598 0.9866 0.9218 0.6411 0.5746 0.455 0.870967741935484 4.514 0.9022 0.8373 0.5566 0.4903 0.3708 0.903225806451613 4.427 0.8155 0.7506 0.47 0.4037 0.2852 0.935483870967742 4.338 0.727 0.662 0.3815 0.3153 0.1972 0.967741935483871 4.248 0.6364 0.5713 0.2909 0.2248 0.1073

0.1 6.0334 2.4223 2.3584 2.0763 2.0083 1.8774 Average of yearly averages: 1.15478666666667

### Page 133 of 219 Inputs generated by pe4.pl - 8-August-2003

Data used for this run: Output File: CAfruit0 Metfile: w93193.dvf PRZM scenario: CAfruit0C.txt EXAMS environment file: pond298.exv Chemical Name: dodine Description Variable Name Value Units Comments Molecular weight mwt 287.4 g/mol Henry's Law Const. henry 9e-11 atm-m^3/mol Vapor Pressure vapr 1.5e-7 torr Solubility sol 6300 mg/L Kd Kd 10427 mg/L Koc Koc mg/L Photolysis half-life kdp 770 days Half-life Aerobic Aquatic Metabolism kbacw 333 days Halfife Anaerobic Aquatic Metabolism kbacs 7476 days Halfife Aerobic Soil Metabolism asm 27.3 days Halfife Hydrolysis: pH 7 914 days Half-life Method: CAM 2 integer See PRZM manual Incorporation Depth: DEPI cm Application Rate: TAPP 2.19 kg/ha Application Efficiency: APPEFF .95 fraction Spray Drift DRFT .05 fraction of application rate applied to pond Application Date Date 10-3 dd/mm or dd/mmm or dd-mm or dd-mmm Interval 1 interval 5 days Set to 0 or delete line for single app. Interval 2 interval 5 days Set to 0 or delete line for single app. Interval 3 interval 5 days Set to 0 or delete line for single app. Interval 4 interval 5 days Set to 0 or delete line for single app. Interval 5 interval 5 days Set to 0 or delete line for single app. Record 17: FILTRA IPSCND1 UPTKF Record 18: PLVKRT PLDKRT

### Page 134 of 219 FEXTRC 0.5 Flag for Index Res. Run IR Pond Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

===================================================================== GA Pecans Aerial Application stored as GApecan.out Chemical: dodine PRZM environment: GAPecansC.txt modified Tueday, 22 April 2003 at 08:57:20 EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30 Metfile: w93805.dvf modified Wedday, 3 July 2002 at 10:04:32 Water segment concentrations (ppb)
Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1961 5.624 0.8286 0.4858 0.3106 0.2463 0.1236 1962 5.751 0.9522 0.6104 0.4487 0.3896 0.2581 1963 5.895 1.233 0.7844 0.6357 0.5729 0.4281 1964 8.18 1.797 1.049 0.8917 0.8844 0.6897 1965 15.58 2.947 1.563 1.269 1.217 0.9977 1966 20.05 3.784 1.841 1.62 1.532 1.304 1967 8.231 2.813 1.982 1.712 1.652 1.486 1968 7.123 2.35 1.959 1.793 1.722 1.586 1969 7.192 2.405 2.052 1.896 1.857 1.724 1970 9.398 2.892 2.201 2.058 2.033 1.889 1971 7.508 2.709 2.382 2.198 2.154 2.027 1972 17.27 4.263 2.782 2.6 2.507 2.266 1973 15.69 4.933 3.111 2.847 2.748 2.511 1974 9.037 3.741 3.256 2.95 2.858 2.679 1975 9.327 4.046 3.302 3.105 3.032 2.855 1976 12.82 5.17 3.652 3.347 3.275 3.056 1977 8.654 3.854 3.515 3.39 3.311 3.163 1978 8.797 3.98 3.596 3.446 3.404 3.25 1979 18.71 6.233 4.243 3.773 3.709 3.464 1980 9.088 4.762 4.029 3.793 3.723 3.581 1981 9.147 4.347 4.011 3.837 3.773 3.625 1982 20.26 5.926 4.201 3.99 3.935 3.747 1983 9.359 5.096 4.311 4.124 4.05 3.859

### Page 135 of 219 1984 10.32 5.015 4.345 4.15 4.089 3.923 1985 14.46 5.456 4.332 4.234 4.193 4.017 1986 13.01 5.278 4.445 4.318 4.289 4.127 1987 13.4 6.205 4.839 4.609 4.531 4.303 1988 9.885 5.086 4.748 4.583 4.505 4.354 1989 12.43 5.694 4.867 4.757 4.707 4.484 1990 10.06 5.36 4.934 4.758 4.71 4.546

Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.032258064516129 20.26 6.233 4.934 4.758 4.71 4.546 0.0645161290322581 20.05 6.205 4.867 4.757 4.707 4.484 0.0967741935483871 18.71 5.926 4.839 4.609 4.531 4.354 0.129032258064516 17.27 5.694 4.748 4.583 4.505 4.303 0.161290322580645 15.69 5.456 4.445 4.318 4.289 4.127 0.193548387096774 15.58 5.36 4.345 4.234 4.193 4.017 0.225806451612903 14.46 5.278 4.332 4.15 4.089 3.923 0.258064516129032 13.4 5.17 4.311 4.124 4.05 3.859 0.290322580645161 13.01 5.096 4.243 3.99 3.935 3.747 0.32258064516129 12.82 5.086 4.201 3.837 3.773 3.625 0.354838709677419 12.43 5.015 4.029 3.793 3.723 3.581 0.387096774193548 10.32 4.933 4.011 3.773 3.709 3.464 0.419354838709677 10.06 4.762 3.652 3.446 3.404 3.25 0.451612903225806 9.885 4.347 3.596 3.39 3.311 3.163 0.483870967741936 9.398 4.263 3.515 3.347 3.275 3.056 0.516129032258065 9.359 4.046 3.302 3.105 3.032 2.855 0.548387096774194 9.327 3.98 3.256 2.95 2.858 2.679 0.580645161290323 9.147 3.854 3.111 2.847 2.748 2.511 0.612903225806452 9.088 3.784 2.782 2.6 2.507 2.266 0.645161290322581 9.037 3.741 2.382 2.198 2.154 2.027 0.67741935483871 8.797 2.947 2.201 2.058 2.033 1.889 0.709677419354839 8.654 2.892 2.052 1.896 1.857 1.724 0.741935483870968 8.231 2.813 1.982 1.793 1.722 1.586 0.774193548387097 8.18 2.709 1.959 1.712 1.652 1.486 0.806451612903226 7.508 2.405 1.841 1.62 1.532 1.304 0.838709677419355 7.192 2.35 1.563 1.269 1.217 0.9977

### Page 136 of 219 0.870967741935484 7.123 1.797 1.049 0.8917 0.8844 0.6897 0.903225806451613 5.895 1.233 0.7844 0.6357 0.5729 0.4281 0.935483870967742 5.751 0.9522 0.6104 0.4487 0.3896 0.2581 0.967741935483871 5.624 0.8286 0.4858 0.3106 0.2463 0.1236

0.1 18.566 5.9028 4.8299 4.6064 4.5284 4.3489 Average of yearly averages: 2.67744
Inputs generated by pe4.pl - 8-August-2003

Data used for this run: Output File: GApecan Metfile: w93805.dvf PRZM scenario: GAPecansC.txt EXAMS environment file: pond298.exv Chemical Name: dodine Description Variable Name Value Units Comments Molecular weight mwt 287.4 g/mol Henry's Law Const. henry 9e-11 atm-m^3/mol Vapor Pressure vapr 1.5e-7 torr Solubility sol 6300 mg/L Kd Kd 10427 mg/L Koc Koc mg/L Photolysis half-life kdp 770 days Half-life Aerobic Aquatic Metabolism kbacw 333 days Halfife Anaerobic Aquatic Metabolism kbacs 7476 days Halfife Aerobic Soil Metabolism asm 27.3 days Halfife Hydrolysis: pH 7 914 days Half-life Method: CAM 2 integer See PRZM manual Incorporation Depth: DEPI cm Application Rate: TAPP 2.91 kg/ha Application Efficiency: APPEFF .95 fraction Spray Drift DRFT .05 fraction of application rate applied to pond Application Date Date 15-4 dd/mm or dd/mmm or dd-mm or dd-mmm Interval 1 interval 10 days Set to 0 or delete line for single app. Interval 2 interval 10 days Set to 0 or delete line for single app.

### Page 137 of 219 Interval 3 interval 10 days Set to 0 or delete line for single app. Interval 4 interval 10 days Set to 0 or delete line for single app. Record 17: FILTRA IPSCND1 UPTKF Record 18: PLVKRT PLDKRT FEXTRC 0.5 Flag for Index Res. Run IR Pond Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

===================================================================== FL Strawberry Aerial Application stored as FLstraw.out Chemical: dodine PRZM environment: FLstrawberryC.txt modified Friday, 4 July 2003 at 21:12:58 EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30 Metfile: w12842.dvf modified Wedday, 3 July 2002 at 10:04:28 Water segment concentrations (ppb)
Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1961 0.5646 0.08305 0.04993 0.03324 0.02587 0.01396 1962 0.5783 0.09477 0.06196 0.04532 0.03777 0.0256 1963 0.5897 0.1151 0.07808 0.05838 0.05045 0.03758 1964 0.5993 0.1216 0.08609 0.06892 0.06125 0.04983 1965 0.6213 0.1337 0.09797 0.07975 0.07227 0.06025 1966 0.6216 0.1414 0.1084 0.08994 0.08258 0.07036 1967 0.6314 0.1498 0.1171 0.0997 0.09217 0.07979 1968 0.6405 0.159 0.1259 0.1086 0.1012 0.08895 1969 0.7254 0.1747 0.1372 0.1208 0.1128 0.1002 1970 0.6606 0.1791 0.1476 0.1306 0.1228 0.1096 1971 0.6808 0.1889 0.1551 0.1381 0.1308 0.1184 1972 0.687 0.1988 0.1653 0.1472 0.1396 0.1266 1973 0.6863 0.2047 0.1718 0.156 0.1484 0.1349 1974 0.6943 0.2127 0.1797 0.1628 0.1552 0.1424 1975 0.7068 0.2202 0.1872 0.1698 0.1623 0.1493 1976 0.7085 0.2269 0.1941 0.1766 0.1692 0.1568

### Page 138 of 219 1977 0.7163 0.2348 0.202 0.1844 0.1768 0.1632 1978 0.7282 0.2521 0.2114 0.1921 0.1842 0.1703 1979 0.7443 0.2633 0.2204 0.1997 0.1923 0.181 1980 0.7658 0.2622 0.2262 0.2088 0.2017 0.188 1981 0.8852 0.2786 0.2343 0.2165 0.2086 0.1947 1982 0.7531 0.2727 0.2406 0.2219 0.2143 0.2012 1983 0.7601 0.2786 0.2488 0.2313 0.2235 0.2093 1984 0.7958 0.2879 0.2545 0.2365 0.2288 0.2147 1985 0.7726 0.2911 0.258 0.2412 0.2335 0.2196 1986 0.7814 0.2957 0.2626 0.2472 0.2394 0.225 1987 0.8019 0.3034 0.2722 0.2555 0.2473 0.2324 1988 0.7914 0.3083 0.2768 0.2587 0.251 0.2369 1989 0.804 0.3146 0.2801 0.2625 0.2549 0.2407 1990 0.7985 0.3224 0.2857 0.2675 0.2596 0.2447

Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.032258064516129 0.8852 0.3224 0.2857 0.2675 0.2596 0.2447 0.0645161290322581 0.804 0.3146 0.2801 0.2625 0.2549 0.2407 0.0967741935483871 0.8019 0.3083 0.2768 0.2587 0.251 0.2369 0.129032258064516 0.7985 0.3034 0.2722 0.2555 0.2473 0.2324 0.161290322580645 0.7958 0.2957 0.2626 0.2472 0.2394 0.225 0.193548387096774 0.7914 0.2911 0.258 0.2412 0.2335 0.2196 0.225806451612903 0.7814 0.2879 0.2545 0.2365 0.2288 0.2147 0.258064516129032 0.7726 0.2786 0.2488 0.2313 0.2235 0.2093 0.290322580645161 0.7658 0.2786 0.2406 0.2219 0.2143 0.2012 0.32258064516129 0.7601 0.2727 0.2343 0.2165 0.2086 0.1947 0.354838709677419 0.7531 0.2633 0.2262 0.2088 0.2017 0.188 0.387096774193548 0.7443 0.2622 0.2204 0.1997 0.1923 0.181 0.419354838709677 0.7282 0.2521 0.2114 0.1921 0.1842 0.1703 0.451612903225806 0.7254 0.2348 0.202 0.1844 0.1768 0.1632 0.483870967741936 0.7163 0.2269 0.1941 0.1766 0.1692 0.1568 0.516129032258065 0.7085 0.2202 0.1872 0.1698 0.1623 0.1493 0.548387096774194 0.7068 0.2127 0.1797 0.1628 0.1552 0.1424 0.580645161290323 0.6943 0.2047 0.1718 0.156 0.1484 0.1349 0.612903225806452 0.687 0.1988 0.1653 0.1472 0.1396 0.1266

### Page 139 of 219 0.645161290322581 0.6863 0.1889 0.1551 0.1381 0.1308 0.1184 0.67741935483871 0.6808 0.1791 0.1476 0.1306 0.1228 0.1096 0.709677419354839 0.6606 0.1747 0.1372 0.1208 0.1128 0.1002 0.741935483870968 0.6405 0.159 0.1259 0.1086 0.1012 0.08895 0.774193548387097 0.6314 0.1498 0.1171 0.0997 0.09217 0.07979 0.806451612903226 0.6216 0.1414 0.1084 0.08994 0.08258 0.07036 0.838709677419355 0.6213 0.1337 0.09797 0.07975 0.07227 0.06025 0.870967741935484 0.5993 0.1216 0.08609 0.06892 0.06125 0.04983 0.903225806451613 0.5897 0.1151 0.07808 0.05838 0.05045 0.03758 0.935483870967742 0.5783 0.09477 0.06196 0.04532 0.03777 0.0256 0.967741935483871 0.5646 0.08305 0.04993 0.03324 0.02587 0.01396

0.1 0.80156 0.30781 0.27634 0.25838 0.25063 0.23645 Average of yearly averages: 0.146207333333333
Inputs generated by pe4.pl - 8-August-2003

Data used for this run: Output File: FLstraw Metfile: w12842.dvf PRZM scenario: FLstrawberryC.txt EXAMS environment file: pond298.exv Chemical Name: dodine Description Variable Name Value Units Comments Molecular weight mwt 287.4 g/mol Henry's Law Const. henry 9e-11 atm-m^3/mol Vapor Pressure vapr 1.5e-7 torr Solubility sol 6300 mg/L Kd Kd 10427 mg/L Koc Koc mg/L Photolysis half-life kdp 770 days Half-life Aerobic Aquatic Metabolism kbacw 333 days Halfife Anaerobic Aquatic Metabolism kbacs 7476 days Halfife Aerobic Soil Metabolism asm 27.3 days Halfife Hydrolysis: pH 7 914 days Half-life Method: CAM 2 integer See PRZM manual

### Page 140 of 219 Incorporation Depth: DEPI cm Application Rate: TAPP 1.46 kg/ha Application Efficiency: APPEFF .99 fraction Spray Drift DRFT .01 fraction of application rate applied to pond Application Date Date 1-2 dd/mm or dd/mmm or dd-mm or dd-mmm Interval 1 interval 7 days Set to 0 or delete line for single app. Interval 2 interval 7 days Set to 0 or delete line for single app. Interval 3 interval 7 days Set to 0 or delete line for single app. Interval 4 interval 7 days Set to 0 or delete line for single app. Record 17: FILTRA IPSCND1 UPTKF Record 18: PLVKRT PLDKRT FEXTRC 0.5 Flag for Index Res. Run IR Pond Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

===================================================================== CA Almond/Walnut Aerial Application stored as CAalmond0.out Chemical: dodine PRZM environment: CAalmond0C.txt modified Thuday, 17 June 2004 at 10:13:20 EXAMS environment: pond298.exv modified Thuday, 29 August 2002 at 17:33:30 Metfile: w23232.dvf modified Wedday, 3 July 2002 at 10:04:22 Water segment concentrations (ppb)
Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1961 5.624 0.8252 0.4832 0.3096 0.2406 0.1196 1962 5.725 0.9262 0.5842 0.4105 0.3415 0.2234 1963 5.834 1.036 0.7003 0.5235 0.4536 0.3298 1964 5.932 1.133 0.7914 0.6177 0.5485 0.4255 1965 6.027 1.228 0.8867 0.7126 0.6433 0.5201 1966 6.12 1.321 0.9791 0.8053 0.7359 0.6121 1967 6.211 1.413 1.072 0.8978 0.8283 0.7032 1968 6.299 1.501 1.159 0.9855 0.916 0.7907 1969 6.387 1.588 1.249 1.074 1.004 0.8781

### Page 141 of 219 1970 6.472 1.673 1.331 1.158 1.088 0.9622 1971 6.556 1.757 1.415 1.242 1.172 1.046 1972 6.637 1.838 1.497 1.323 1.254 1.126 1973 6.717 1.919 1.577 1.404 1.334 1.206 1974 6.795 1.996 1.655 1.481 1.411 1.284 1975 6.948 2.075 1.736 1.561 1.491 1.361 1976 6.977 2.152 1.807 1.633 1.563 1.433 1977 7.019 2.22 1.879 1.705 1.635 1.506 1978 7.091 2.293 1.951 1.778 1.708 1.578 1979 7.163 2.364 2.023 1.849 1.779 1.648 1980 7.231 2.432 2.091 1.917 1.847 1.717 1981 7.301 2.502 2.161 1.987 1.917 1.786 1982 7.968 2.633 2.254 2.066 1.994 1.86 1983 7.443 2.644 2.303 2.133 2.062 1.929 1984 7.505 2.707 2.366 2.192 2.121 1.988 1985 7.565 2.766 2.425 2.251 2.181 2.048 1986 7.625 2.826 2.485 2.311 2.241 2.108 1987 7.685 2.886 2.545 2.372 2.301 2.167 1988 7.74 2.941 2.601 2.428 2.357 2.222 1989 7.795 2.997 2.657 2.483 2.412 2.278 1990 7.851 3.052 2.712 2.538 2.468 2.333

Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.032258064516129 7.968 3.052 2.712 2.538 2.468 2.333 0.0645161290322581 7.851 2.997 2.657 2.483 2.412 2.278 0.0967741935483871 7.795 2.941 2.601 2.428 2.357 2.222 0.129032258064516 7.74 2.886 2.545 2.372 2.301 2.167 0.161290322580645 7.685 2.826 2.485 2.311 2.241 2.108 0.193548387096774 7.625 2.766 2.425 2.251 2.181 2.048 0.225806451612903 7.565 2.707 2.366 2.192 2.121 1.988 0.258064516129032 7.505 2.644 2.303 2.133 2.062 1.929 0.290322580645161 7.443 2.633 2.254 2.066 1.994 1.86 0.32258064516129 7.301 2.502 2.161 1.987 1.917 1.786 0.354838709677419 7.231 2.432 2.091 1.917 1.847 1.717 0.387096774193548 7.163 2.364 2.023 1.849 1.779 1.648

### Page 142 of 219 0.419354838709677 7.091 2.293 1.951 1.778 1.708 1.578 0.451612903225806 7.019 2.22 1.879 1.705 1.635 1.506 0.483870967741936 6.977 2.152 1.807 1.633 1.563 1.433 0.516129032258065 6.948 2.075 1.736 1.561 1.491 1.361 0.548387096774194 6.795 1.996 1.655 1.481 1.411 1.284 0.580645161290323 6.717 1.919 1.577 1.404 1.334 1.206 0.612903225806452 6.637 1.838 1.497 1.323 1.254 1.126 0.645161290322581 6.556 1.757 1.415 1.242 1.172 1.046 0.67741935483871 6.472 1.673 1.331 1.158 1.088 0.9622 0.709677419354839 6.387 1.588 1.249 1.074 1.004 0.8781 0.741935483870968 6.299 1.501 1.159 0.9855 0.916 0.7907 0.774193548387097 6.211 1.413 1.072 0.8978 0.8283 0.7032 0.806451612903226 6.12 1.321 0.9791 0.8053 0.7359 0.6121 0.838709677419355 6.027 1.228 0.8867 0.7126 0.6433 0.5201 0.870967741935484 5.932 1.133 0.7914 0.6177 0.5485 0.4255 0.903225806451613 5.834 1.036 0.7003 0.5235 0.4536 0.3298 0.935483870967742 5.725 0.9262 0.5842 0.4105 0.3415 0.2234 0.967741935483871 5.624 0.8252 0.4832 0.3096 0.2406 0.1196

0.1 7.7895 2.9355 2.5954 2.4224 2.3514 2.2165 Average of yearly averages: 1.33962333333333
Inputs generated by pe4.pl - 8-August-2003

Data used for this run: Output File: CAalmond0 Metfile: w23232.dvf PRZM scenario: CAalmond0C.txt EXAMS environment file: pond298.exv Chemical Name: dodine Description Variable Name Value Units Comments Molecular weight mwt 287.4 g/mol Henry's Law Const. henry 9e-11 atm-m^3/mol Vapor Pressure vapr 1.5e-7 torr Solubility sol 6300 mg/L Kd Kd 10427 mg/L

### Page 143 of 219 Koc Koc mg/L Photolysis half-life kdp 770 days Half-life Aerobic Aquatic Metabolism kbacw 333 days Halfife Anaerobic Aquatic Metabolism kbacs 7476 days Halfife Aerobic Soil Metabolism asm 27.3 days Halfife Hydrolysis: pH 7 914 days Half-life Method: CAM 2 integer See PRZM manual Incorporation Depth: DEPI cm Application Rate: TAPP 2.91 kg/ha Application Efficiency: APPEFF .95 fraction Spray Drift DRFT .05 fraction of application rate applied to pond Application Date Date 1-3 dd/mm or dd/mmm or dd-mm or dd-mmm Interval 1 interval 10 days Set to 0 or delete line for single app. Interval 2 interval 10 days Set to 0 or delete line for single app. Interval 3 interval 10 days Set to 0 or delete line for single app. Interval 4 interval 10 days Set to 0 or delete line for single app. Record 17: FILTRA IPSCND1 UPTKF Record 18: PLVKRT PLDKRT FEXTRC 0.5 Flag for Index Res. Run IR Pond Flag for runoff calc. RUNOFF none none, monthly or total(average of entire run)

=====================================================================

### Page 144 of 219 

### APPENDIX D: Ecological Effects Characterization for Dodine and DGH

Aquatic Organism Effects Characterization
Toxicity values used in assessing risks of dodine to aquatic organisms included data from both dodine and DGH studies. In water, these two compounds are expected to form the dodecylguanadinium ion and their respective salts. From a toxicological pers pective, it is likely that toxicity in aquatic media for both parent compounds will reflect effects of the dodecylguanidinium ion.
Acute Toxicity to Freshwater Invertebrates
Acute toxicity of dodine to daphnids ( Daphnia magna ) was determined under flow through conditions (MRID#423396-01). Two groups of ten daphnids each (20 per treatment total) were exposed to a negative control, solvent control and mean-measure d concentrations of 36.5, 19.6, 9.1, 5.4, and 5.3 μg a.i./l. There were no control mortalities or imm obilizations observed, however, 100, 55 and 1% of the daphnids in the 36.5, 19.6 and 5.4 μg a.i./l treatments were immobilized (Table D.1.). The 48-hour EC 50 was 17.8 μg a.i./l (95% C.I. = 14.8-22.3) calculated using the moving average method, which classifies dodine as VERY HIGHLY TOXIC to daphnids on an acute exposure basis. The NOAEC was 5.3 : g a.i./l. The study was classified as acceptable. Importantly, for this study, the mean-measured concentrations were QC-adjusted; the mean percen t quality control recovery was 73.4%. The solvent control received 0.075 ml methanol/l.
In another study on the acute toxicity of dodine to freshwater invertebrates, 20 daphnids per treatment were exposed to mean-measured concentrations of 12, 19, 29, 46, and 87 μg a.i./l along with appropriate controls (MRID#426535-01). There were no mortalities/immobilizations in the control groups but 100, 75, and 5% mortality/immobilizati on in the 87, 46, and 29 μg a.i./l treatments, respectively. The EC 50 was 40 μg a.i./l (95% C.I. = 36-45) calculated using the probit method (slope = 11.6 (95% C.I. = 6.2-17.0). The study was classified as acceptable and the results indicated that dodine could be classified as VERY HIGHLY TOXIC to daphnids on an acute exposure basis. In this study, daphnids were exposed to radiolabeled dodine, wh ich facilitated measurement in solution. The formulation (solvent) control received 0.0023 ml methanol/l.
An earlier study on the acute toxicity of dodine to freshwater invertebrates reported a higher EC 50 compared to the previous two studies (Acc.#226855). Twenty daphnids each were exposed to control conditions and 32, 56, 100, 180, and 320 ppb cytox 2160 ( 95% a.i. dodine). There was 100% mortality in the two highest treatments and 5% mortality in the lowest treatment. These results precluded use of the moving average or probit methods to calculate and EC 50. The binomial analysis provided an estimate of the EC50 of 134 (95% C.I. = 100-180).
An study on the acute effects of DGH to Daphnia magna was also considered for this assessment (MRID#407568-05). At the time of this assessment, howev er, information regarding the details of the study was not available, only the toxicity values. Results from this study indicate that toxicity from DGH exposure falls within the range of toxi city values for dodine. The LC50 was 29 : g a.i./l (95% C.I. = 25- 33), which is slightly higher than the lowest reported value of 17.8 : g a.i./l used for estimating risks.

### Page 145 of 219 Table D.1. Acute Toxicity Values for Freshw ater Invertebrates Exposed to Dodine and DGH

Study Type Species Endpoint EC50/LC50 : g a.i./l Tox Category MRID# Study

Invert. Acute flow through (72-2a) Daphnia magna Immobilization 17.8 (14.8-22.3) Very highly toxic 423396-01 (Putt, 1992) A

Invert. Acute flow through (72-2a) Daphnia magna Immobilization 40.2 (36.0-45.0) Very highly toxic 426535-01 (Putt, 1992) A

Invert. Acute flow through (72-2a) Daphnia magna Immobilization 134.6 (100-180) probit and moving avg. can’t be used: re-did w/binomial Very highly toxic Acc.# 226855 (Bauer, 1976) A

DGH Studies

Invert. Acute static on formulated product (33% a.i.) (72-2b) Daphnia magna Immobilization 88 (77 - 100) μg product/L [29 (25 -

33) μg a.i./L] MISSING DER Very highly toxic 407568-05 A

Chronic Toxicity to Freshwater Invertebrates
An aquatic invertebrate life cycle test was conduc ted to evaluate the chronic toxicity of dodine to the freshwater aquatic invertebrate, Daphnia magna (MRID#438765-01). Daphnids were exposed to negative and solvent control conditions and mean-measure d concentrations of 4.4, 7.3, 13, 25, and 52 μg a.i. dodine/l. There were significant effects of dodi ne on survival of first generation daphnids, number of young produced, dry weight of firs t generation daphnids, a nd length of fist generation daphnids. The most sensitive endpoint was the number of young produced with a NOEC of 7.3 μg a.i./l and a LOEC of 13 μg a.i./l (Table D.2.). The registrant reported results were lower than those reported here, however, the registrant reported results could not be repeat ed. The study was conducted in a scientifically sound manner and was classified as ACCEPTABLE (formerly CORE) meeting requirements for guideline study 72-4b. 

### Table D.2. Chronic Toxicity Values for Freshwater Invertebrates Exposed to Dodine

Study Type Species Endpoint NOEC : g a.i./l LOEC MRID# Study

### Page 146 of 219 Invert. Life Cycle (72-4b) Daphnia magna Reproduction 7.3 13 438765-01 (Putt, 1995) A

Acute Toxicity to Freshwater Fish

Two studies were conducted to evaluate the acute toxicity of dodine to freshwater fish. The methods for the two studies appear similar and were in accordance with 1970 Standard Methods (APHA). In one study, a warm water species ,bluegill sunfish ( Lepomis macrochirus ), were exposed to 0.75, 1.0, 2.1, 3.2, and 4.2 mg dodine/l; although no controls were reported, initial reviewers concluded that since the study followed guideline, controls must have b een included. In another study on the cold water species, rainbow trout ( Oncorhynchus mykiss ), fish were exposed to 0.32, 0.75, 1.2, 1.6, and 2.1 mg dodine/l. Similar to the bluegill study, no controls were reported yet it was assumed that controls had been included in the design since the original report stated that methods were generally in accordance with EPA guidelines and also in accordance with the Fish Bioassay Procedure in the 1970 edition of the Standard Methods (APHA). Sta tistical determination of the LC 50 was based on linear regression using logs and probits. The 96-h LC 50 for bluegill and rainbow trout were 0.86 and 0.57 mg dodine/l, respectively (Table D.3.). The NOAECs for blueg ill and rainbow trout were 0.75 mg a.i./l and 0.32 mg a.i./l, respectively. These studies were classified as CORE (ACCEPTABLE) despite the fact that data on control fish was not included in the original re port. Both estimates of the freshwater fish LC 50 fall within the HIGHLY TOXIC categorization.
A study on the acute toxicity of DGH to rainbow trout was also available for this assessment. Detailed information on this study was not available. Toxicity values, however, were available and indicate that for the conditions specific to the DGH test , toxicity to rainbow trout was similar to that of bluegill for dodine with an LC 50 of 0.890 mg a.i./l. 

### Table D.3. Acute Toxicity Values for Fr eshwater Fish Exposed to Dodine and DGH Study Type Species Endpoint EC50/LC50 : g a.i./l Tox Category MRID# or Acc. # Study

Freshwater fish Acute toxicity Lepomis macrochirus Mortality 860 (810-910) Highly toxic 132149 (Sleight,

1971) A

Freshwater fish Acute toxicity Oncorhynchus mykiss formerly ( Salmo

gairdneri ) Mortality 570 (430-750) Highly toxic 132149 (Sleight,

1971) A

DGH

### Page 147 of 219 Freshwater fish Acute toxicity 33% a.i. formulation Rainbow trout ( Oncorhynchus mykiss, formerly Salmo

gairdneri ) Mortality

MISSING DER 890 (790 - 1000) Highly toxic (a.i.) 434855-05 A

Chronic Toxicity to Freshwater Fish
A fish early life stage toxicity test was conducted to evaluate the toxicity of dodine to early life stage fathead minnows, Pimephales promales (MRID#438765-02) . Embryos less than 24 hours old were exposed to negative and solvent control conditions and mean-measured dodine concentrations of 26, 55, 99, 200, and 400 : g a.i./l. Results indicated that the most sensitive endpoints were larval length and weight with a NOAEC of 99 : g a.i./l and a LOAEC of 200 : g a.i./l. Also, there was a significant treatment-related effect on larval survival at 400 : g a.i./l. The study was conducted in a scientifically sound manor with no major deviations. The study sa tisfied the guideline requirements for a freshwater fish early life stage test (72-4a) and was classified as ACCEPTABLE (formerly CORE).



### Table D.4. Chronic Toxicity Values for Freshwater Fish Exposed to Dodine

Study Type Species Endpoint NOEC : g a.i./l LOEC : g a.i./l MRID# Study

Freshwater fish early life stage (72-4a) Pimephales promales Larval length and weight 99 200 438765-02 (Sousa, 1995) A

Acute Toxicity to Estuarine/Marine Invertebrates
Juvenile mysid shrimp, Americamysis bahia (formerly Mysidopsis bahia ), were exposed to dodine for 96 hours under flow-through conditions (MRID# 426535-04). Mean measured test concentrations of active ingredie nt were 310, 540, 980, 1700, and 3000 : g a.i./l (ppb) plus a negative control and a formulation blank control. Some mortality occurred in all groups except the 540 ppb and the controls. The LC 50 was 2335 ppb and was calculated using the moving average method; the probit method did not yield usable results (Table D.5). The NOAEC was 540 ppb. The study meets the guideline requirements for an acute toxicity study on an estuarine/marine invertebrate (72-3) and was classified as ACCEPTABLE.

### Page 148 of 219 A study on mysid shrimp, Americamysis bahia , was also conducted using DGH. Mysids < 24 hours old were exposed to DGH under flow-through c onditions for 96 hours at mean measured product concentrations of <0.03 (control), 140, 200, 450, 530, and 840 ppb formulated product, which correspond to 46, 66, 149, 176, and 279 ppb a.i. Mortality occurre d in all groups with one in the control and two in the 46 ppb mean-measured concentration. The estimated LC 50 for the active ingredient was 59.4 ppb (95% C.I. = 46 - 148 ppb) and a NOAEC < 46 ppb. The study meets the guideline requirements for an acute toxicity study on an estuarine/marine invert ebrate (72-3) and was classified as ACCEPTABLE. This study also represents the lowest available inverteb rate toxicity value and is used in the estimation of risks associated with dodine use.

The LC 50 from the DGH study on mysid shrimp, 59.4 ppb, is markedly lower than the LC 50 from the dodine study on mysid shrimp, which was 2335 ppb. Review of the DGH formulation used in the mysid study indicated that there were no formulation ingredients, other than the active ingredient, that could likely contribute to the lower LC 50 seen in this test. For example, one component that contributed 17.5% by weight to the formulation has an LC 50 for brown shrimp on the order of 1150 ppm. Review of both the dodine and DGH studies do not suggest any obvious reason for the disparity in the results of these tests. In general, it seems that the differences between DGH and dodine toxicity are more pronounced in saltwater tests. Although DGH and dodine are expected to behave similarly in aquatic environments, it is possible that in the presence of saltwater, the chemicals actually behave differently. More research may be needed to further understand the toxicity of DGH and dodine to estuarine and marine organisms.
A 96-hour shell deposition study was conducted to eval uate the acute toxicity of dodine to eastern oysters ( Crassostrea virginica ) under flow-through conditions. Forty oysters were placed in each of the treatments which included a dilution water control a formulation blank control and mean measured dodine concentrations of 110, 130, 260, 370, and 670 : g a.i./L. There were significant, concentration-dependent effects of dodine on shell deposition. However, a NOAE C could not be determined since oysters in the lowest test concentration showed significantly l ess shell deposition compared to controls. The 96-hour EC50 was 167 : g a.i./L (95% C.I. = 144 and 189 : g a.i./L) and was calculated using the probit method. Despite the fact that control oysters did not obtai n 2 mm of shell deposition, the study is considered scientifically sounds and meets the guideline requirements for a 96-hour flow-through mollusc shell deposition acute toxicity test. The study is classified as ACCEPTABLE.
A 96-hour shell deposition study was also conducte d to evaluate the acute toxicity of DGH to eastern oysters. Oysters were exposed, under flow-through conditions, to formulated product concentrations of < 0.015 (control), 0.03, 0.08, 0.12, 0.22, and 0.36 ppm. Oysters exposed to DGH showed significantly less shell deposition compared to controls. A NOAEC could not be determined since oysters at the lowest exposure level showed less shell deposition compared to controls. The estimated LC 50 for the formulated product was 210 ppb (95% C.I. 160 - 300 ppb) This corresponds to an estimated LC 50 for the active ingredient of 69.3 ppb ppb (95% C.I. = 52.8 - 99 ppb). The study was scientifically sound and classified as ACCEPTABLE. The LC 50 represents the lowest toxicity value for molluscs and was used in the assessment for estim ating risks associated with uses of dodine.
Another study was conducted to evaluate the toxic ity of DGH to saltwater invertebrates. At the time of this assessment, however, details regarding the study were not available for review. Blue crabs, Callinectes sapidus , were exposed to DGH under acute conditions. The resulting LC 50 for active

### Page 149 of 219 ingredient was 446 ppm (95% C.I. = 395 - 503 ppm). This classifies DGH as practically non-toxic to blue crabs. The study was classified as SUPPLEMENTAL, likely due to the fact that blue crabs are nonguideline species. 

### Table D.5. Acute Toxicity Values for Estuarine/Marine Invertebrates Exposed to Dodine

Study Type Species Endpoint EC50/LC50 : g a.i./l Tox Category MRID# Study

Estuarine shrimp Acute flow through (72-3) Americamysis bahia ( formerly

Mysidopsis

bahia Mortality 2335 (1831-3166) Practically nontoxic 426535-04 (Bettencourt1992) A

Mollusc 96-hour, flow-through shell deposition study (72-3) Crassostrea virginica Shell deposition 167 (144-189) Highly toxic 426535-03 (Dionne, 1992) A

DGH
Marine/Estuarine shrimp Acute flow through (72-3) (33% a.i. formulation) Americamysis bahia ( formerly

Mysidopsis

bahia Mortality 59.4 (46.2 - 148.5) NOEC < 46.2 based on mortality in lowest treatment group Very highly toxic 434855-07 (Jones and Davis, 1994) A

Marine/estuarine mollusk, Acute flow-through shell deposition test (72- 3) (33.2% a.i. formulation) Eastern oyster ( Crassostrea

virginica ) Shell deposition 69.3 (52.8 - 99) : g a.i./L] NOEC < 9.9 based on an 18% decrease in shell

deposition at lowest level tested Very highly toxic 434855-08 (Youngerman and

Davis, 1994) A

Marine/Estuarine invertebrate Acute (72-3) (40.6% a.i. formulation) Blue crab ( Callinectes

sapidus ) Mortality (446 (395 - 503) mg a.i./L) MISSING DER Practically nontoxic 40940802 S

Acute Toxicity to Estuarine/Marine Fish
Sheepshead minnow, Cyprinodon variegatus , were exposed to dodine under flow-through conditions for 96 hours. Treatments included a c ontrol and mean-measured dodine concentrations of 0.98, 1.5, 2.5, 4.1, and 8.3 mg a.i./L. Effects included loss of equilibrium, erratic swimming behavior, lethargy, and mortality. Mortality only occurred in the highest test concentration and was 100% by the end of the study. Lethargy was observed in one indi vidual in the 0.98 mg a.i./L treatment. Other sub-

### Page 150 of 219 lethal effects were limited to organisms in the 2.5, 4.1, and 8.3 mg a.i./L treatments with relatively more severe effects (in terms of number of organisms) asso ciated with higher concentrations of dodine. The LC 50 is 5.8 mg a.i./L and was estimated using the binomial test since only the highest concentration tested caused mortality (Table X6). The study was conducted in a scientifically sound manner and meets the requirements for an estuarine/marine fish acute flow-through toxicity study. The study is classified as ACCEPTABLE.
In a similar study on DGH, sheepshead minnows were exposed to <30 (control), 990, 1560, 2570, 4310, and 8220 ppb mean-measured concentrations fo r formulated product. The LC50 for active ingredient was calculated to be 1782 ppb (95% C.I. = 1419 - 2706) with a NOAEC of 858 ppb. The study was scientifically sound and classified as ACCEPTABLE. 

### Table D.6. Acute Toxicity Values for Estuarine/Marine Fish Exposed to Dodine

Study Type Species Endpoint EC50/LC50 : g a.i./l Tox Category MRID# Study

Estuarine/marine fish Acute flow through (72-3) Cyprinodon variegatus Mortality 5833(4100-8300) Mode rately toxic 426535-02 (Bettencourt1 993) A

DGH
Estuarine/marine fish Acute flow through test (72-3) (33.2% a.i. formulation) Sheepshead minnow, Cyprinodon variegatus Mortality 1782 (1419 - 2706) NOEC 858 Moderately toxic 43485506 (Youngerman

and Davis,

1994) A



### Terrestrial Organism Effects Characterization
Acute Toxicity to Terrestrial Invertebrates
Acute toxicity of dodine to terrestrial invertebrates was assessed by exposing honey bees, Apis millifera , to dodine via both contact and oral exposures. In the contact test, microliter of acetone solution which contained the test compound was applied to the ve ntral thorax of test bees. After exposure, bees were returned to their cages and observed for 24 hours. There were 40 bees in each group, which included controls and 10, 50, 100, and 200 : g per bee treatments. The contact LD 50 was more than 200 : g per bee, the highest dose tested. This charact erizes dodine as practically non-toxic to honey bees via contact exposure. The study was scientifically sound and classified as ACCEPTABLE.

### Page 151 of 219 As part of the effort to evaluate the acute t oxicity of dodine to honey bees, five suspensions of dodine in 50% sucrose water were prepared su ch that they contained 10, 50, 100, and 200 : g dodine/bee (if bee consumed 0.01 ml of test solution). Similar to the contact toxicity study, dodine did not cause significant mortality at the doses tested. The resulting LD50 was > 200 : g per bee. The study was conducted in a scientifically sound manne r and is classified as ACCEPTABLE.
Another acute contact toxicity study was conducted on honey bees, Apis mellifera , where bees were exposed to only one concentration, 12.09 : g a.i. per bee. Mortality at this dose was 2.45%. Although there was not enough data to generate an estimate of the LD50, the study authors and EFED reviewers concluded that dodine was relatively non-toxic to honey bees.



### Table D.7. Acute Toxicity Values for Honey Bees Exposed to Dodine

Study Type Species Endpoint LD50 : g a.i./bee Tox Category MRID# Study

Honey Bee
acute contact Apis mellifera Mortality > 200 Practically nontoxic 4013155-05 (Van Beek,

1984) A

Honey Bee acute oral Apis mellifera Mortality > 200 Practically nontoxic 4013155-05 (Van Beek,

1984) A

Honey Bee
acute contact Apis Mellifera Mortality 2.45% at 12.09 : g/bee Relatively nontoxic (Greywood and Macdonald, 1975) A

Acute and Sub-acute Toxicity to Birds
The acute toxicity of dodine to birds was eval uated using both bobwhite quail and mallard ducks. Bobwhite quail, Colinus virginianus , were given single oral doses by intubation of dodine at levels of 180, 320, 560, 1000, 1800, and 3200 ppm (mg/kg body weight ). Controls were also included in the study. The estimated LC50 is 690 mg/kg (95% C.I. = 511-932 mg/kg). Other signs of toxicity included depression and ruffled feathers. Generally, the study followed available guidelines for an acute oral avian toxicity study with several minor deviations. The age of birds was not specified beyond “young adults”, 10 birds used at controls and high dose while 20 we re used at other doses, and housing conditions were incompletely reported. The study is considered scientifically sounds and is classified as ACCEPTABLE.
In a similar study, mallard ducks, Anas platyrhynchos , were orally exposed to dodine via intubation. The study consisted of controls and dodine doses of 560, 1000, 1800, 3200, 5600, and 10,000

### Page 152 of 219 mg/kg body weight. The estimated LD50 is 2240 mg /kg (95% C.I. = 1659-3024 mg/kg). Other signs of toxicity included prostration, de pression, and huddling. Food consumption was at first reduced but was no significantly different from controls at 21 days. The study followed guidelines for an avian acute oral toxicity study and is classified as ACCEPTABLE.
Bobwhite quail (Colinus virginianus) were also usedin a study to evaluate the sub-acute dietary toxicity of dodine to a representative bird species. Bobwhite quail were provided with feed that had 0 (control), 464, 1000, 2150, 4640, and 10,000 ppm dodine. The calculated LC50 is 8413 ppm (95% C.I. = 5115-13,838 ppm). There was no mortality at the three lowest levels and 60% mortality at the highest exposure level. Other toxic signs included depression, reduced reaction to external stimuli, wing droop, and coordination loss. The study followed the guidelin es for an acute dietary avian toxicity study and is classified as ACCEPTABLE.
In a similar study, the dietary toxicity of dodi ne was also evaluated using mallard ducks ( Anas platyrhynchos ). The levels of dodine in feed provi ded to mallards was 0 (control), 464, 1000, 2150, 4640, and 10,000 ppm dodine. There was no mortality in this study so the LC50 was greater than 10,000 mg/kg. The study followed the guidelines for an acute dietary avian toxicity study and is classified as ACCEPTABLE. 

### Table D.8. Acute and Sub-acute Toxicity Values for Birds Exposed to Dodine

Study Type Species Endpoint LD50/LC50 mg/kg or ppm Tox Category MRID# Study

Avian acute oral Colinus virginianus Mortality 690 (511-932) Sli ghtly toxic Acc.# 130888 (Howard & Johnston

1971) A

Avian acute oral Anas platyrhynchos Mortality 2240 (1659-3024) Practically nontoxic Acc.# 131455 (Carter, 1971) A

Avian acute dietary Colinus virginianus Mortality 8413 (5115-13838) Practically nontoxic Acc.# 226855 (Fink 1976) A

Avian acute dietary Anas platyrhynchos Mortality >10000 Practically nontoxic Acc.# 226855 (Fink, 1976) A

Chronic Toxicity to Birds

Several studies were conducted to evaluate the chronic and reproductive toxicity of dodine to

### Page 153 of 219 avian species. In one study, 20-week old bobwhite quail ( Colinus virginianus ) were exposed to dodine mixed in commercial feed at concentrations of 0 (control), 200, 600, and 1000 ppm a.i. (mg dodine/kg feed) (Pedersen, 1994; MRID# 432746-01). There were st atistically significant effects of dodine on the number of day-14 survivors, female body weights, and day-14 brood weights. However, the study was considered INVALID since there was wi despread mortality in controls and in animals prior to the start of the study. In fact, the study authors attributed most of the observed effects to be non-related to treatments and result of using non-suitable birds. Pre-test morta lity was 8% and control mortality during the test was 16%.
An apparent follow-up study on bobwhite quail was conducted in a scientifically sound manner but did not satisfy guideline requirements (Peder sen, 1999; MRID# 449857-05) . In this study, 21-week old bobwhite quail were exposed to dodine in feed at concentrations of 0 (control), 75, 150, and 300 ppm a.i. (mg dodine/kg feed). There were no significant tr eatment-related effects and it was not stated whether the highest test concentration was at or above the maximum field residue level. The study is classified as supplemental but does not provide enough information to be used quantitatively in estimating risk to avian species.
An avian reproduction test was al so conducted using mallard ducks, Anas platyrhynchos

. Twenty-four-week old mallard ducks were exposed to dodi ne in feed at concentrations of 0 (control), 200, 600, and 1000 ppm a.i. (mg dodine/kg feed). There were significant effects of dodine on the number of eggs laid, eggs set, viable embryos, vile 3-week embryos, hatchlings, 14-day old survivors, adult food consumption, hatchling body wei ghts, and adult female body weights at diet concentrations > 600 ppm a.i. The NOAEC for these effects is 200 ppm a.i. The study was conducted in a scientifically sound manner, meets the requirements for an avian reproduction test and is classified as ACCEPTABLE. 

### Table D.9. Reproductive Toxicity Values for Birds Exposed to Dodine



### Study Type Species Endpoint NOAEL ppm (mg/kg feed) MRID# Study

Avian reproduction test Colinus virginianus Various None determined 432746-01 (Pedersen 1994) I

Avian reproduction test Anas platyrhynchos Various 200 432746-02 (Pedersen 1994) A

Avian reproduction test Colinus virginianus Mortality > 300 449857-05 (Pedersen 1999) S

Acute Toxicity to Mammals

### Page 154 of 219 Acute toxicity data for mammals used in this assessment was obtained from the EPA Health Effects Division (HED) (Table D.10). The acute oral LD 50 for rats was 1056 mg/kg body weight for females (MRID#44922401). Male rats appear l ess sensitive to dodine with an estimated LD 50 of 1698 mg/kg body weight. For purposes of this assessment, the value for females was used. 

### Table D.10. Acute Oral Toxicity of Dodine to Mammals Study Type Species Endpoint LD 50 mg/kg body weight Tox Category (HED designation) MRID#

Acute oral rat 870.1100 Ratus norvegicus Mortality 1056 females 1698 males III 449224-01

Chronic Toxicity to Mammals
Chronic toxicity data for mammals was obtained through HED. In one study, rats were exposed to dodine in feed at concentrations of 0 (c ontrol), 200, 400, and 800 ppm (MRID#442460-01). Exposures were continuous over the course of tw o generations. Concentrations of dodine in feed were measured as were food consumption rates. Significant effects on body weight were seen at the dodine exposure level of 400 ppm, however, effects at this level were not considered biologically significant (< 10% difference compared to controls). Hence, the LOAEL was c onsidered to be the 800 ppm treatment level, where differences in body weight exceeded 10% compar ed to controls. The NOAEL was 400 ppm which corresponds to a calculated dose (based on body wei ght and feed consumption) of 30.28 mg/kg-d. Decreased pup body weight likely relates directly to survival and or timing of reproduction in wildlife population, hence, this endpoint was considered ecol ogically significant. There were no other observed effects of dodine on rat reproduction or fertility.
Another chronic study was conducted on beagle dogs. The HED summary states:
“In a chronic toxicity study (MRID 44246101), Dodine (98.6% a.i., Batch No. 1174) was administered to 4 beagle dogs/sex/group in a gelatin capsule at doses of 0, 2, 10, and 20 mg/kg/day. The capsules were administered orally once a day, 7 days/week, for at l east 52 weeks. No statistically significant differences were observed for group mean values in absolute body weights, overall weight changes, food consumption, or food efficiency between the treated and control groups of either sex. However, one middose female, one high-dose female, and one high-do se male dog exhibited marked weight losses due to reduced food consumption during the first few weeks of the study. Therefore, the LOAEL for female beagle dogs is 10 mg/kg/day based on body weight loss by individual animals and the NOAEL for female beagle dogs is 2 mg/kg/day. The LOAEL for male beagle dogs is 20 mg/kg/day based on body weight loss by an individual animal and the NOAEL for male beagle dogs is 10 mg/kg/day.”
The results from this study were not used in th is risk assessment since there were no statistically significant results and the study lacked sufficient n to support use of these endpoints in the assessment.

### Page 155 of 219 Furthermore, data on rats is preferred to that of dogs due to the wider acceptability and availability of rat data and that the body size of rats is more likely to reflect that of most mammals in the wild that may be exposed to dodine. The study does, however, corr oborate effects seen in the rat study; decreased body weight in dodine exposed mammals.



### Table D.11. Chronic Toxicity Values for Mammals Exposed to Dodine Study Type Species Endpoint NOAEL (mg/kg bw) MRID#

870.3800 Reproduction and fertility effects (rat) Ratus norvegicus Primarily based on decreased pup body weights 30.28 442460-01

870.4100b Chronic toxicity (dog) Canus domesticus 2 mg/kg-d females 10 mg/kg-d males 442461-01

### Page 156 of 219 REFERENCES Acc. 130888. Howard, D.J. and C.D. Johnston. 1971. CYTOX 2160 - Safety Evaluation by Single Oral Administration to Bobwhite Quail. Unpublished Study Conducted by Woodard Research Corporation for American Cyanamid Co.
Acc. 131455. Johnston, C.D. 1971. CYTOX 2160 - Sa fety Evaluation by Single Oral Administration to Mallard Ducks. Unpublished Study Conducted by Woodard Research Corporation for American Cyanamid Co.
Acc.132149. Sleight, Bevier Hasbrouck. 1971. The Acute Toxicity of CYTOX 2160 (ST 45093) to Bluegill (Lepomis macrochirus) and Rainbow Trout ( Onchirynchus mykiss formerly Salmo gairdneri ). Unpublished Study Conducted by Bionomics, Inc. for American Cyanamid Co.
Acc. 226855. Fink, R. 1976. Eight-Day Dietary LC 50 - Bobwhite quail - CYTOX 2160. Unpublished Study Conducted by Wildlife International for Union Carbide Corp. Submitted by American Cyanamid Company.
Acc. 226855. Fink, R. 1976. Eight-Day Dietary LC 50 - Mallard Duck - CYTOX 2160. Unpublished Study Conducted by Wildlife International for Union Carbide Corp. Submitted by American Cyanamid Company.
Acc. 226855. Bauer, E.P. 1976. Acute Toxicity of CYTOX 2160 to the Water Flea, Daphnia magna Straus. Unpublished Study Conducte d by Aquatic Environmental Services, Union Carbide Corp. for American Cyanamid Company.
Acc. 403155-05. Van Beek, L. 1984. Acute Dermal T oxicity and Oral Toxicity Studies with Dodine in Honey Bees. Unpublished Study Conducted by the Netherlands Organization for Applied Scientific Research for Drexel Chemical Co.
MRID 423396-01. Putt, A.E. 1992. (Dodine Technical) - Acute Toxicity to Daphnids ( Daphnia magna ) Under Flow-Through Conditions. for RhonePoulenc Ag Company.
MRID 426535-01. Putt, A.E. 1992. Dodine 65W - Acute Toxicity to Daphnids (Daphnia magna) Under Flow-Through Conditions. for Rhone-Poulenc Ag Company.
MRID 426535-02. Bettencourt, M.J. 1993. Dodi ne 65W - Acute Toxicity to Sheepshead Minnow ( Cyprinodon variegatus ) Under Flow-Through Conditions. Unpub lished Study Conducted by Springborn Laboratories, Inc. for Rhone-Poulenc Ag Company.
MRID 426535-03. Dionne, E. 1992. Dodine 65W - Acute Toxicity to Eastern Oyster ( Crassostrea

### Page 157 of 219 virginica) Under Flow-Through Conditions . Unpublished Study Conducte d by Springborn Laboratories for Rhone Poulenc Ag Company.
MRID 426535-04. Bettencourt, M.J. 1992. Dodine 65W - Acute Toxicity to Mysid Shrimp (Mysidopsis bahia) Under Flow-Through Conditions. Unpublished Study Conducted by Springborn Laboratories, Inc. for Rhone-Poulenc Ag Company.
MRID 426951-02. Maggi, V.L. 1993. Tier I: Dete rmination of the Phytotoxic Effects of Dodine Fungicide on Seedling Emergence of Nontarget Pl ants. Unpublished Study Conducted by California Agricultural Research, Inc. fo r Rhone-Poulenc Ag Company.
MRID 426951-03. Maggi, V.L. 1993. Tier I: Dete rmination of the Phytotoxic Effects of Dodine Fungicide on Vegetative Vigor of Nontarget Plan ts. Unpublished Study Conducted by California Agricultural Research, Inc. fo r Rhone-Poulenc Ag Company.
MRID 432746-01. Pederson, C.A. 1994. Dodecy lguanidine Acetate (Dodine) Technical Grade: Toxicity and Reproduction Study in Bobwhite Qu ail. Unpublished Study Conducted by Bio-life Associates, Ltd. for Rhone-Poulenc Ag Company.
MRID 432746-02. Pederson, C.A. 1994. Dodecy lguanidine Acetate (Dodine) Technical Grade: Toxicity and Reproduction Study in Mallard Du cks. Unpublished Study Conducted by Bio-life Associates, Ltd. for Rhone-Poulenc Ag Company.
MRID 438765-01. Putt, A.E. 1995. Dodine Technical - The Chronic Toxicity to Daphnia magna Under Flow-Through Conditions. Unpublishe d Study Conducted by Springborn Laboratories, Inc. for RhonePoulenc Ag Company.
MRID 438765-02. Sousa, J.V. 1995. Dodine Technical: The Toxicity to Fathead Minnow ( Pimephales promelas) During an Early Life-Stage Exposure. Unpublished Study Conducted by Springborn Laboratories, Inc. for Rhone-Poulenc Ag Company.
MRID 449857-05. Pederson, C.A. 1999. Avian Re productive Toxicity Study with Dodecylguanidine Acetate (Dodine) Technical in Bobwhite Quail. Unpublished Study Conducted by Bio-life Associates, Ltd. for Rhone-Poulenc Ag Company.
MRID 464382-01. Desmares-Koopmans, M.J.E. 2002. Sediment-Water Chironomid Toxicity Test Using Water Spiked with Dodine Technical. Unpublished Study Conducted by Notox for ChimacAgriphar S.A.
MRID 44246001. 1996. Mammalian reproduc tion and fertility effects (rat).

### Page 158 of 219 MRID 44246101. 1996. Mammalian chronic oral toxicity (dog).
Atkins, E.L., E.A. Greywood, and R.L. Macdonald. 1975. Toxicity of Pesticides and Other Agricultural Chemicals to Honey Bees. Laboratory Studies. University of California, Division of Agricultural Sciences. Leaflet 2287, 38pp.

DGH Studies
MRID 434855-07. Jones, F., and J. W. Davis. 1994. CT-334-87 - Dodecylguanidine Hydrochloride (DGH): Acute Toxicity to the Mysid, Mysidopsis bahia , Under Continuous Flow-through Conditions. Unpublished Study. Conducted by Toxikon Envi ronmental Sciences for Cytec Industries.
MRID 434855-08. Youngerman, D., and J.W. Da vis. 1994. CT-334-87 - Dodecylguanidine Hydrochloride (DGH): Acute Effect on New Shell Growth of the Eastern Oyster, Crassostrea virginica. Unpublished Study. Conducted by Toxikon Envi ronmental Sciences for Cytec Industries.
MRID 434855-06. Youngerman, D., and J.W. Davis. 1994. CT-334-87 - Dodecylguanidine Hydrochloride (DGH): Acute Toxicity to the Sheepshead Minnow, Cyrpinodon variegatus, Under Continuous Flow-through Conditions. Unpublished Study Conducted by Toxikon Environmental Sciences for Cytec Industries.
MRID 434855-10. Helsten, B.R., and A. M. Solatycki. 1994. 8-Day Acute Dietay LC50 Study with CT334-87 (DGH) in Mallard Ducklings. Unpublished Study . Conducted by Bio-Life Associates, Ltd., for Cytec Industries.

Other DGH Studies (no DERs) MRID 40940802. MRID 43485505. MRID 40756805. MRID 41316904 MRID 41316905 MRID 41063003 MRID 40940803

### Page 159 of 219 APPENDIX E. ECOTOX References not Used in Dodine Risk Assessment
REFERENCE: Frear, D.E.H., and J.E. Boyd. 1967. Use of Daphnia magna for the Microbioassay of Pesticides. I. Development of StandardizedTechniques for Rearing Daphnia and Preparation of Dosage-M. J. Econ. Entomol. 60(5):1228-1236 JUSTIFICATION: Methods
REFERENCE: Grutzmacher, A.D., O. Zimmermann, A. Yousef, and S.A. Hassan. 2004. The SideEffects of Pesticides Used in Integrated Pr oduction of Peaches in Brazil on the Egg Parasitoid Trichogramma cacoeciae Marchal (Hym., Trichogra mmatidae). J. Appl. Entomol. 128(6):377- 383. JUSTIFICATION: Terrestrial invertebrate; dermal exposure
REFERENCE: Koller, W. and W.F. Wilcox. 2000. In teractive Effects of Dodine and the DMI Fungicide Fenarimol in the Control of Apple Scab. Plant. Dis. 84:144-156. JUSTIFICATION: Mixture
REFERENCE: Maheshwari, S.K., S.K. Gandhi, and P.C. Gupta. 1996. Effects of Fungicides on Yield and Incidence of Purple Blotch in Onion. Tests Agrochem. Cultiv. 17:12-13. JUSTIFICATION: Field efficacy study
REFERENCE: Masood, K.J., M.F. Rahman, J. Narsaiah, and M. Mustafa. 1991. Hematological and Biochemical Alterations in Rats Subjected to De rmal Application of Dodine. Indian J. Comp. Anim. Physiol. 9(1):27-31. JUSTIFICATION: Dermal study
REFERENCE: Mayer, F.L.J., and M.R. Ellersieck. 1986. Manual of Acute Toxicity: Interpretation and Data Base for 410 Chemicals and 66 Species of Freshwater Animals. Resour. Publ. No. 160, U.S. Dep. Interior, Fish Wildl. Serv., Washington, D.C.: 505pp. (USGS Data File) JUSTIFICATION: Summary/review
REFERENCE: Mitjans, M., and M.P. Vinardell. 1998. Effects of Dodine (n-Dodecylguanidine Acetate) Subchronic Treatment on Intestinal Morphology a nd Brush Border Enzymatic Activity in Rats. Pestic. Biochem. Physiol. 62(2)96-101. JUSTIFICATION: Endpoint not used to assess risks.
REFERENCE: Mitjans, M., and M.P. Vinardell. 1999. Hematological and Biochemical Parameters in the Rat Following Subchronic Oral Administrati on of Dodine (n-Dodecylguanidine Acetate). Pestic. Biochem. Physiol. 65(3):151-159. JUSTIFICATION: No effects

### Page 160 of 219 REFERENCE: Reilly, C.C., and B.W. Wood. 1996. No Adverse Effect of Early Season Fungicide and Zinc Sprays on Leaf Area, Fruit Set, and Nut Quality of Pecan. Hortscience 31(5):808-810. JUSTIFICATION: Mixed trials - dodine combined with other chemicals.

### Page 161 of 219 APPENDIX F. Spray Drift Assessment: AgDRI FT Modeling Approach and Results
The AgDRIFT model (Version 2.01) was used to re fine the spray drift exposure estimate for aquatic invertebrates. Downwind spray drift buffers were developed for possible use in mitigating risks to endangered freshwater invertebrates in aquatic ecosystem s that are within close proximity to agricultural fields that may be treated with liquid spray applications of dodine. The model was used to estimate spray buffer distances for aerial and orchard airblast appli cation to reach the EEC in the ecological water body for which the endangered species LOC for inve rtebrates would not be exceeded (0.89 ppb).
A summary of the results of the AgDRIFT modeling fo r aerial and orchard airblast applications of dodine is presented in Table F-1 . Spray drift buffers or distances required to reduce spray drift such that endangered species LOCs for invertebrates are not ex ceeded are estimated for aerial and orchard airblast applications of dodine at the highest and lowest maximum national use rates. The range of dissipation distances is dependant on a number of input vari ables including droplet size, release height, canopy characteristics etc., which are discussed in further detail for aerial and orchard airblast applications below.

Drift dissipation distances for endangered species, based on aerial applications, are expected to exceed the 1,000 foot limit of the AgDRIFT Tier II aerial model based on conservative defaults ( i.e. , fine spray, 15 foot release height and 15 mph wind speed). Modele d dissipation distances for endangered invertebrates, based on aerial application of dodine at 1.3 and 2. 6 lbs ai/A assuming a 10 foot release in wind speeds of 10 mph and a medium droplet size, are expected to range from approximately 643 to 880 feet. Tier I modeled dissipation distances for endangered inverteb rates , based on orchard airblast application of dodine at 1.3 and 2.6 lbs ai/A, are expected to ra nge from approximately 76 to 154 feet. Label language that requires spray drift mitigation measures ( i.e. , lower release heights, wind speed restrictions, and specification of spray droplet sizes) is recommended.

Table F-1. Summary of AgDRIFT Modelin g Results for Endangered Invertebrates Crop/ Application rate Tier II Aerial Model Inputs Buffer Distance for Aerial Application a (ft) Buffer Distance for Orchard

Airblast Application b (ft) ASEA 572 Droplet Size Release Height (ft) Wind Speed (mph) Pecans, peaches, walnuts 2.6 lbs ai/A Fine 15 15 > 1,000 154 10 10 > 1,000 Medium 15 15 > 1,000 10 10 880 Cherries 1.3 lbs ai/A Fine 15 15 > 1,000 76 10 10 > 1,000 Medium 15 15 > 1,000

### Page 162 of 219 10 10 643

a Tier II aerial model b Tier I orchard airblast model with a co rrection factor of three to account for vari ability in field trial data used in model
Orchard Airblast Application
The most important factors affecting spray drift from orchard airblast applications are canopy characteristics such as canopy height, density, and spaci ng. Tall, very dense, or sparse orchards tend to result in higher off-target drift. Other factors th at also affect drift are wind speed and application parameters such as the amount of spray being di rected above tree height, spraying in spaces between trees, and turning off outwardly pointed nozzles at ends of rows and outside rows. Airblast sprays tend to be relatively fine. Very fine sprays, such as tho se produced with mist blower equipment may result in higher downwind deposition at greater distances than pr edicted based on airblast sprayer data. Shrouded sprayers, wraparound sprayers, or tower sprayers wh ich direct spray horizontally or downward tend to minimize spray drift relative to radial airblast sprayers which can direct a significant portion of spray upwards.
The orchard airblast model of AgDRIFT is empirically based on field data. Presently, the orchard airblast portion of AgDRIFT is the least conservativ e because the data do not capture relatively high drift conditions and instead reflect typical to low drift application conditions for many orchards. The airblast data is consistent with applica tions in relatively low wind speeds (<10 mph), shutting off outward pointed nozzles when turning corners, wind direction perpendi cular to orchard rows, minimizing spray above tree tops, and incomplete analytical recoveries.
Although the product labels for dodine contain the st atement, “Do not apply when weather conditions favor drift from treated areas”, they do not specify ca nopy characteristics, wind speeds, or specific drift reduction measures for airblast applications. Ther efore, for this screening-level assessment in order to account for field trial variability, the orchard depositi on results were multiplied by a correction factor. Based on the variability in field trial data, a three -fold correction factor was used to estimate a 95 th percentile deposition for orchards in general (OPP EFED, 1999). Specifically, for determining the buffer sizes for orchard airblast applications with dodine, the toxicological endpoint for endangered freshwater invertebrates, 0.89 ppb, was divided by 3(0.297 ppb) and was used as the initial average concentration in the EPA-defined pond.
Tier I modeled buffer distances for endangered invert ebrates , based on orchard airblast application of dodine at 1.3 and 2.6 lbs ai/A, are expected to range from approximately 76 to 154 feet (Table F1).
Aerial Application
The most important factors affecting drift from aerial applications are spray droplet size, release height, and wind speed. The aerial part of the AgDRIFT m odel predicts mean dissipation distances based on the inputs provided. When wind speed and/or release height is lower than the modeled values, the spray drift levels would expected to be lower. Conversely, ininstances where applications may be made in higher

### Page 163 of 219 wind speeds or at a higher release height, these inputs may not be adequately conservative and higher tier modeling may be necessary.
Although the product labels for dodine contain the st atement, “Do not apply when weather conditions favor drift from treated areas”, they do not specify re lease heights, wind speeds, or spray droplet sizes for aerial applications. Although the label does not speci fy a droplet size for aerial application of dodine, fixed winged applications (applicati ons made by airplanes) are limited in the coarsest droplet size that can be sprayed. Typical fixed wing aerial application speeds exceed 120 mph. At these speeds, coarse droplets shatter and produce medium or finer sprays. Therefore, it is generally inappropriate to model coarse sprays for fixed wing applications without some restriction on flight speed.
For aerial applications, the model contains three tiers of increasing complexity.
Tier I Aerial Modeling
The AgDRIFT Tier I model for aerial application limits the input parameters to droplet size only. The output of the Tier I AgDRIFT model provides distances required to dissipate spray drift to the endangered species invertebrate toxicological endpoint (0.89 ppb) . Based on a fine to medium default spray, dissipation distances from the edge of the field that are protective of both endangered invertebrates were >1,000 ft and 824 ft for 2.6 and 1.3 lbs ai/A, respectively.
Tier II Aerial Modeling
Tier II aerial spray drift estimates were also derived for dodine because this level of modeling allows for greater control over input and output options. With the exception of droplet size, wind speed, and release height, AgDRIFT default parameters were used for a ll other variables in the Tier II model. Tier II modeling was done for a combination of input paramete rs: application rate (2.6 and 1.3 lbs ai/A), wind speed (15 and 10 mph), release height (15 and 10 ft), and droplet size (fine and medium). The results suggest that for all combinations, except for the l east conservative scenario (medium spray with a 10 ft release height and 10 mph winds), the required no-spra y zone would exceed the 1,000 ft limit in the Tier II model. The modeled no-spray buffers, assuming a 10 foot release in wind speeds of 10 mph and a medium droplet size, were 643 to 880 ft for 1.3 and 2.6 lbs ai/A, respectively (Table F1).

### Page 164 of 219 APPENDIX G. Listed Species by State 

# Species Details by State for Preliminary Assessment Cherries, sweet (188), Cherries, tart (198), Peaches (142), Pears (144), Pecans (145), Strawberries (180), Walnuts, English (62) Minimum of 100 Acres.



### Alabama (49 species) Group Critical Habitat AMPHIANTHUS, LITTLE Plant No BAT, GRAY Mammal No BAT, INDIANA Mammal Yes CAMPELOMA, SLENDER Snail No CLUBSHELL, OVATE Clam No CLUBSHELL, SOUTHERN Clam No DARTER, BOULDER Fish No DARTER, SLACKWATER Fish Yes EAGLE, BALD Bird No ELIMIA, LACY Snail No FERN, AMERICAN HART'S-TONGUE Plant No HARPERELLA Plant No HEELSPLITTER, INFLATED Clam No KIDNEYSHELL, TRIANGULAR Clam No MOCCASINSHELL, COOSA Clam No MOUSE, ALABAMA BEACH Mammal Yes MOUSE, PERDIDO KEY BEACH Mammal Yes PEARLYMUSSEL, CUMBERLAND MONKEYFACE Clam No PEARLYMUSSEL, ORANGE-FOOTED Clam No PEARLYMUSSEL, PINK MUCKET Clam No PIGTOE, HEAVY (=JUDGE TAIT'S MUSSEL) Clam No

### Page 165 of 219 PIGTOE, ROUGH Clam No PITCHER-PLANT, ALABAMA CANEBRAKE Plant No PLOVER, PIPING Bird Yes POCKETBOOK, FINE-LINED Clam No POCKETBOOK, SHINY-RAYED Clam No
Thursday, April 21, 2005 Page 1 of 27

### Page 166 of 219 POTATO-BEAN, PRICE'S Plant No PRAIRIE-CLOVER, LEAFY Plant No QUILLWORT, LOUISIANA Plant No RIVERSNAIL, ANTHONY'S Snail No ROCKSNAIL, PAINTED Snail No ROCKSNAIL, PLICATE Snail No SALAMANDER, FLATWOODS Amphibian No SALAMANDER, RED HILLS Amphibian No SHINER, CAHABA Fish No SNAIL, ARMORED Snail No SNAIL, TULOTOMA Snail No SNAKE, EASTERN INDIGO Reptile No STORK, WOOD Bird No STURGEON, ALABAMA Fish No STURGEON, GULF Fish Yes SUNFLOWER, EGGERT'S Plant No TORTOISE, GOPHER Reptile No TREEFROG, PINE BARRENS Amphibian No TRILLIUM, RELICT Plant No TURTLE, ALABAMA RED-BELLIED Reptile No TURTLE, FLATTENED MUSK Reptile No TURTLE, LOGGERHEAD SEA Reptile No WOODPECKER, RED-COCKADED Bird No 

### Arizona (33 species) Group Critical Habitat AGAVE, ARIZONA Plant No BAT, LESSER (=SANBORN'S) LONG-NOSED Mammal No CACTUS, ARIZONA HEDGEHOG Plant No

### Page 167 of 219 CACTUS, COCHISE PINCUSHION Plant No CACTUS, NICHOL'S TURK'S HEAD Plant No CATFISH, YAQUI Fish Yes Chub, Gila Fish No

Thursday, April 21, 2005 Page 2 of 27

### Page 168 of 219 CHUB, YAQUI Fish Yes CLIFFROSE, ARIZONA Plant No DOCK, CHIRICAHUA Plant No EAGLE, BALD Bird No FALCON, NORTHERN APLOMADO Bird No FLYCATCHER, SOUTHWESTERN WILLOW Bird Yes FROG, CHIRICAHUA LEOPARD Amphibian No JAGUAR Mammal No Jaguarundi, Sinaloan Mammal No LADIES'-TRESSES, CANELO HILLS Plant No MINNOW, LOACH Fish Yes OCELOT Mammal No OWL, MEXICAN SPOTTED Bird Yes PLOVER, MOUNTAIN Bird No PRONGHORN, SONORAN Mammal No PUPFISH, DESERT Fish Yes PYGMY-OWL, CACTUS FERRUGINOUS Bird Yes RAIL, YUMA CLAPPER Bird No RATTLESNAKE, NEW MEXICAN RIDGE-NOSED Reptile Yes SALAMANDER, SONORA TIGER Amphibian No SHINER, BEAUTIFUL Fish Yes SPIKEDACE Fish Yes SUCKER, RAZORBACK Fish Yes TOPMINNOW, GILA (YAQUI) Fish No UMBEL, HUACHUCA WATER Plant Yes WOLF, GRAY Mammal Yes 

### Arkansas (10 species) Group Critical Habitat

### Page 169 of 219 BAT, GRAY Mammal No DARTER, LEOPARD Fish Yes EAGLE, BALD Bird No MUSSEL, SCALESHELL Clam No

Thursday, April 21, 2005 Page 3 of 27

### Page 170 of 219 PEARLYMUSSEL, PINK MUCKET Clam No POCKETBOOK, FAT Clam No ROCK-POCKETBOOK, OUACHITA (=WHEELER'S PM) Clam No STURGEON, PALLID Fish No TERN, INTERIOR (POPULATION) LEAST Bird No WOODPECKER, RED-COCKADED Bird No 

### California (233 species) Group Critical Habitat ADOBE SUNBURST, SAN JOAQUIN Plant No ALLOCARYA, CALISTOGA Plant No ALOPECURUS, SONOMA Plant No AMBROSIA, SAN DIEGO Plant No Amole, Camatta Canyon Plant Yes AMOLE, PURPLE Plant Yes ASTER, DEL MAR SAND Plant No BACCHARIS, ENCINITAS Plant No BARBERRY, ISLAND Plant No BARBERRY, NEVIN'S Plant No BEDSTRAW, EL DORADO Plant No BEDSTRAW, ISLAND Plant No BEETLE, DELTA GREEN GROUND Insect Yes BEETLE, MOUNT HERMON JUNE Insect No BEETLE, OHLONE TIGER Insect No BEETLE, VALLEY ELDERBERRY LONGHORN Insect Yes BIRD'S-BEAK, PALMATE-BRACTED Plant No BIRD'S-BEAK, PENNELL'S Plant No BIRD'S-BEAK, SALT MARSH Plant No BIRD'S-BEAK, SOFT Plant No

### Page 171 of 219 BLUEGRASS, NAPA Plant No BLUEGRASS, SAN BERNARDINO Plant No BRODIAEA, THREAD-LEAVED Plant No BROOM, SAN CLEMENTE ISLAND Plant No

Thursday, April 21, 2005 Page 4 of 27

### Page 172 of 219 BUCKWHEAT, IONE (IRISH HILL) Plant No BUSH-MALLOW, SAN CLEMENTE ISLAND Plant No BUSHMALLOW, SANTA CRUZ ISLAND Plant No BUTTERFLY, BAY CHECKERSPOT Insect Yes BUTTERFLY, BEHREN'S SILVERSPOT Insect No BUTTERFLY, CALLIPPE SILVERSPOT Insect No BUTTERFLY, EL SEGUNDO BLUE Insect No BUTTERFLY, LANGE'S METALMARK Insect No BUTTERFLY, LOTIS BLUE Insect No BUTTERFLY, MYRTLE'S SILVERSPOT Insect No BUTTERFLY, PALOS VERDES BLUE Insect Yes BUTTERFLY, SMITH'S BLUE Insect No BUTTERWEED, LAYNE'S Plant No BUTTON-CELERY, SAN DIEGO Plant No CACTUS, BAKERSFIELD Plant No CEANOTHUS, COYOTE Plant No CEANOTHUS, PINE HILL Plant No CHECKER-MALLOW, KECK'S Plant Yes CHECKER-MALLOW, KENWOOD MARSH Plant No CHUB, MOHAVE TUI Fish No CLARKIA, PISMO Plant No CLARKIA, PRESIDIO Plant No CLARKIA, SPRINGVILLE Plant No CLARKIA, VINE HILL Plant No CLOVER, MONTEREY Plant No CLOVER, SHOWY INDIAN Plant No CONDOR, CALIFORNIA Bird Yes COYOTE-THISTLE, LOCH LOMOND Plant No

### Page 173 of 219 CRAYFISH, SHASTA Crustacean No CROWN-BEARD, BIG-LEAVED Plant No CYPRESS, GOWEN Plant No CYPRESS, SANTA CRUZ Plant No

Thursday, April 21, 2005 Page 5 of 27

### Page 174 of 219 DUDLEYA, CONEJO Plant No DUDLEYA, MARCESCENT Plant No DUDLEYA, SANTA CLARA VALLEY Plant No DUDLEYA, SANTA CRUZ ISLAND Plant No DUDLEYA, SANTA MONICA MOUNTAINS Plant No DUDLEYA, VERITY'S Plant No EAGLE, BALD Bird No EVENING-PRIMROSE, ANTIOCH DUNES Plant Yes EVENING-PRIMROSE, SAN BENITO Plant No FIDDLENECK, LARGE-FLOWERED Plant Yes FLANNELBUSH, MEXICAN Plant No FLANNELBUSH, PINE HILL Plant No FLY, DELHI SANDS FLOWER-LOVING Insect No FLYCATCHER, SOUTHWESTERN WILLOW Bird Yes FOX, SAN JOAQUIN KIT Mammal No FOX, SAN MIGUEL ISLAND Mammal No FOX, SANTA CATALINA ISLAND Mammal No FOX, SANTA CRUZ ISLAND Mammal No FOX, SANTA ROSA ISLAND Mammal No FRINGEPOD, SANTA CRUZ ISLAND Plant No FROG, CALIFORNIA RED-LEGGED Amphibian No FROG, MOUNTAIN YELLOW-LEGGED Amphibian No GILIA, HOFFMANN'S SLENDER-FLOWERED Plant No GILIA, MONTEREY Plant No GNATCATCHER, COASTAL CALIFORNIA Bird Yes GOBY, TIDEWATER Fish Yes GOLDEN SUNBURST, HARTWEG'S Plant No GOLDFIELDS, BURKE'S Plant No

### Page 175 of 219 GOLDFIELDS, CONTRA COSTA Plant Yes GRASS, CALIFORNIA ORCUTT Plant No GRASS, COLUSA Plant Yes GRASS, HAIRY ORCUTT Plant Yes

Thursday, April 21, 2005 Page 6 of 27

### Page 176 of 219 GRASS, SACRAMENTO ORCUTT Plant Yes GRASS, SAN JOAQUIN VALLEY ORCUTT Plant Yes GRASS, SLENDER ORCUTT Plant Yes GRASS, SOLANO Plant Yes GRASSHOPPER, ZAYANTE BAND-WINGED Insect Yes JEWELFLOWER, CALIFORNIA Plant No KANGAROO RAT, FRESNO Mammal Yes KANGAROO RAT, GIANT Mammal No KANGAROO RAT, MORRO BAY Mammal Yes KANGAROO RAT, STEPHENS' Mammal No KANGAROO RAT, TIPTON Mammal No LARKSPUR, SAN CLEMENTE ISLAND Plant No LARKSPUR, YELLOW Plant Yes LAYIA, BEACH Plant No LILY, PITKIN MARSH Plant No LIVEFOREVER, LAGUNA BEACH Plant No LIVEFOREVER, SANTA BARBARA ISLAND Plant No LIZARD, BLUNT-NOSED LEOPARD Reptile No LIZARD, ISLAND NIGHT Reptile No LUPINE, CLOVER Plant No LUPINE, NIPOMO MESA Plant No MALACOTHRIX, ISLAND Plant No MALACOTHRIX, SANTA CRUZ ISLAND Plant No MALLOW, KERN Plant No MANZANITA, DEL MAR Plant No MANZANITA, IONE Plant No MANZANITA, MORRO Plant No MANZANITA, PALLID Plant No

### Page 177 of 219 MANZANITA, SANTA ROSA ISLAND Plant No MEADOWFOAM, BUTTE COUNTY Plant Yes MEADOWFOAM, SEBASTOPOL Plant No MILK-VETCH, BRAUNTON'S Plant No

Thursday, April 21, 2005 Page 7 of 27

### Page 178 of 219 MILK-VETCH, CLARA HUNT'S Plant No MILK-VETCH, COASTAL DUNES Plant No MILK-VETCH, VENTURA MARSH Plant Yes MINT, OTAY MESA Plant No MINT, SAN DIEGO MESA Plant No MONARDELLA, WILLOWY Plant No MORNING-GLORY, STEBBINS Plant No MOTH, KERN PRIMROSE SPHINX Insect No MOUNTAIN BEAVER, POINT ARENA Mammal No MOUNTAINBALM, INDIAN KNOB Plant No MOUNTAIN-MAHOGANY, CATALINA ISLAND Plant No MOUSE, PACIFIC POCKET Mammal No MOUSE, SALT MARSH HARVEST Mammal No MURRELET, MARBLED Bird Yes NAVARRETIA, FEW-FLOWERED Plant No NAVARRETIA, MANY-FLOWERED Plant No NAVARRETIA, SPREADING Plant No OTTER, SOUTHERN SEA Mammal No OWL, NORTHERN SPOTTED Bird Yes OWL'S-CLOVER, FLESHY Plant Yes PAINTBRUSH, SAN CLEMENTE ISLAND INDIAN Plant No PAINTBRUSH, SOFT-LEAVED Plant No PAINTBRUSH, TIBURON Plant No PELICAN, BROWN Bird No PENTACHAETA, LYON'S Plant No PENTACHAETA, WHITE-RAYED Plant No PHACELIA, ISLAND Plant No PIPERIA, YADON'S Plant No

### Page 179 of 219 PLOVER, MOUNTAIN Bird No PLOVER, WESTERN SNOWY Bird No POLYGONUM, SCOTT'S VALLEY Plant Yes POTENTILLA, HICKMAN'S Plant No

Thursday, April 21, 2005 Page 8 of 27

### Page 180 of 219 PUPFISH, DESERT Fish Yes PUSSYPAWS, MARIPOSA Plant No RABBIT, RIPARIAN BRUSH Mammal No RAIL, CALIFORNIA CLAPPER Bird No RAIL, LIGHT-FOOTED CLAPPER Bird No ROCK-CRESS, HOFFMANN'S Plant No ROCK-CRESS, MCDONALD'S Plant No ROCK-CRESS, SANTA CRUZ ISLAND Plant No RUSH-ROSE, ISLAND Plant No SALAMANDER, CALIFORNIA TIGER Amphibian No SALAMANDER, SANTA CRUZ LONG-TOED Amphibian No SALMON, CHINOOK (CALIFORNIA COASTAL ESU) Fish Yes SALMON, CHINOOK (CENTRAL VALLEY SPRING RUN) Fish Yes SALMON, CHINOOK (SACRAMENTO RIVER WINTER RUN) Fish No SALMON, COHO (CENTRAL CALIFORNIA COAST POP) Fish No SALMON, COHO (SOUTHERN OR/NORTHERN CA COAST) Fish No SANDWORT, MARSH Plant No SEA-BLITE, CALIFORNIA Plant No SEAL, GUADALUPE FUR Mammal No SEDGE, WHITE Plant No SHEEP, PENINSULAR BIGHORN Mammal Yes SHREW, BUENA VISTA Mammal No SHRIKE, SAN CLEMENTE LOGGERHEAD Bird No SHRIMP, CALIFORNIA FRESHWATER Crustacean No SHRIMP, CONSERVANCY FAIRY Crustacean Yes SHRIMP, LONGHORN FAIRY Crustacean Yes SHRIMP, RIVERSIDE FAIRY Crustacean No SHRIMP, SAN DIEGO FAIRY Crustacean Yes

### Page 181 of 219 SHRIMP, VERNAL POOL FAIRY Crustacean Yes SHRIMP, VERNAL POOL TADPOLE Crustacean Yes SKIPPER, LAGUNA MOUNTAIN Insect No SMELT, DELTA Fish No

Thursday, April 21, 2005 Page 9 of 27

### Page 182 of 219 SNAIL, MORRO SHOULDERBAND Snail Yes SNAKE, GIANT GARTER Reptile No SNAKE, SAN FRANCISCO GARTER Reptile No SPARROW, SAN CLEMENTE SAGE Bird No SPINEFLOWER, BEN LOMOND Plant No SPINEFLOWER, HOWELL'S Plant No SPINEFLOWER, MONTEREY Plant Yes SPINEFLOWER, ORCUTT'S Plant No SPINEFLOWER, ROBUST Plant Yes SPINEFLOWER, SCOTTS VALLEY Plant Yes SPINEFLOWER, SLENDER-HORNED Plant No SPINEFLOWER, SONOMA Plant No SPURGE, HOOVER'S Plant Yes STEELHEAD, CALIFORNIA CENTRAL VALLEY POP Fish Yes STEELHEAD, CENTRAL CALIFORNIA POPULATION Fish Yes STEELHEAD, NORTHERN CALIFORNIA POPULATION Fish No STEELHEAD, SOUTH-CENTRAL CALIFORNIA POP Fish Yes STEELHEAD, SOUTHERN CALIFORNIA POPULATION Fish Yes STICKLEBACK, UNARMORED THREESPINE Fish Yes STICKYSEED, BAKER'S Plant No STONECROP, LAKE COUNTY Plant No SUCKER, SANTA ANA Fish Yes TARPLANT, GAVIOTA Plant Yes TARPLANT, OTAY Plant Yes TARPLANT, SANTA CRUZ Plant Yes TERN, CALIFORNIA LEAST Bird No THISTLE, CHORRO CREEK BOG Plant No THISTLE, FOUNTAIN Plant No

### Page 183 of 219 THISTLE, LA GRACIOSA Plant Yes THISTLE, SUISUN Plant No THORNMINT, SAN DIEGO Plant No TOAD, ARROYO SOUTHWESTERN Amphibian Yes

Thursday, April 21, 2005 Page 10 of 27

### Page 184 of 219 TORTOISE, DESERT Reptile No TROUT, LAHONTAN CUTTHROAT Fish No TROUT, LITTLE KERN GOLDEN Fish Yes TROUT, PAIUTE CUTTHROAT Fish No TUCTORIA, GREEN'S Plant Yes TURTLE, OLIVE (PACIFIC) RIDLEY SEA Reptile No VIREO, LEAST BELL'S Bird Yes WALLFLOWER, BEN LOMOND Plant No WALLFLOWER, CONTRA COSTA Plant Yes WALLFLOWER, MENZIE'S Plant No WATERCRESS, GAMBEL'S Plant No WHIPSNAKE (=striped racer), ALAMEDA Reptile Yes WOODLAND-STAR, SAN CLEMENTE ISLAND Plant No WOODRAT, RIPARIAN Mammal No WOOLLY-STAR, SANTA ANA RIVER Plant No WOOLLY-THREADS, SAN JOAQUIN Plant No YERBA SANTA, LOMPOC Plant Yes 

### Colorado (8 species) Group Critical Habitat CACTUS, UINTA BASIN HOOKLESS Plant No CHUB, BONYTAIL Fish Yes CHUB, HUMPBACK Fish Yes EAGLE, BALD Bird No FERRET, BLACK-FOOTED Mammal No SQUAWFISH, COLORADO Fish Yes SUCKER, RAZORBACK Fish Yes WILD-BUCKWHEAT, CLAY-LOVING Plant Yes 

### Connecticut (4 species)

### Page 185 of 219 Group Critical Habitat EAGLE, BALD Bird No MUSSEL, DWARF WEDGE Clam No STURGEON, SHORTNOSE Fish No

Thursday, April 21, 2005 Page 11 of 27

### Page 186 of 219 WHALE, NORTHERN RIGHT Mammal Yes 

### Delaware (5 species) Group Critical Habitat EAGLE, BALD Bird No PINK, SWAMP Plant No PLOVER, PIPING Bird Yes SQUIRREL, DELMARVA PENINSULA FOX Mammal No WHALE, NORTHERN RIGHT Mammal Yes 

### Florida (61 species) Group Critical Habitat ASTER, FLORIDA GOLDEN Plant No BANKCLIMBER, PURPLE Clam No BAT, GRAY Mammal No BAT, INDIANA Mammal Yes BEARGRASS, BRITTON'S Plant No BLAZING STAR, SCRUB Plant No BONAMIA, FLORIDA Plant No BUCKWHEAT, SCRUB Plant No CAMPION, FRINGED Plant No CARACARA, AUDUBON'S CRESTED Bird No CHAFFSEED, AMERICAN Plant No CLADONIA, FLORIDA PERFORATE Plant No DARTER, OKALOOSA Fish No EAGLE, BALD Bird No FRINGE TREE, PYGMY Plant No GOOSEBERRY, MICCOSUKEE (FLORIDA) Plant No HAREBELLS, AVON PARK Plant No HYPERICUM, HIGHLANDS SCRUB Plant No

### Page 187 of 219 JAY, FLORIDA SCRUB Bird No KITE, EVERGLADE SNAIL Bird Yes LUPINE, SCRUB Plant No MANATEE, WEST INDIAN (FLORIDA) Mammal Yes

Thursday, April 21, 2005 Page 12 of 27

### Page 188 of 219 MEADOWRUE, COOLEY'S Plant No MINT, LONGSPURRED Plant No MOCCASINSHELL, GULF Clam No MOCCASINSHELL, OCHLOCKONEE Clam No MOUSE, CHOCTAWHATCHEE BEACH Mammal Yes MOUSE, PERDIDO KEY BEACH Mammal Yes MUSTARD, CARTER'S Plant No PIGTOE, OVAL Clam No PINKROOT, GENTIAN Plant No PLOVER, PIPING Bird Yes PLUM, SCRUB Plant No POCKETBOOK, SHINY-RAYED Clam No POLYGALA, LEWTON'S Plant No RHODODENDRON, CHAPMAN Plant No ROSEMARY, SHORT-LEAVED Plant No SALAMANDER, FLATWOODS Amphibian No SANDLACE Plant No SAWFISH, SMALLTOOTH Fish No SHRIMP, SQUIRREL CHIMNEY CAVE Crustacean No SKINK, BLUE-TAILED MOLE Reptile No SKINK, SAND Reptile No SLABSHELL, CHIPOLA Clam No SNAKE, EASTERN INDIGO Reptile No SPARROW, FLORIDA GRASSHOPPER Bird No STORK, WOOD Bird No STURGEON, GULF Fish Yes STURGEON, SHORTNOSE Fish No THREERIDGE, FAT Clam No

### Page 189 of 219 TORREYA, FLORIDA Plant No TURTLE, GREEN SEA Reptile Yes TURTLE, LEATHERBACK SEA Reptile Yes TURTLE, LOGGERHEAD SEA Reptile No

Thursday, April 21, 2005 Page 13 of 27

### Page 190 of 219 WAREA, WIDE-LEAF Plant No WHALE, NORTHERN RIGHT Mammal Yes WHITLOW-WORT, PAPERY Plant No WINGS, PIGEON Plant No WIREWEED Plant No WOODPECKER, RED-COCKADED Bird No ZIZIPHUS, FLORIDA Plant No 

### Georgia (26 species) Group Critical Habitat AMPHIANTHUS, LITTLE Plant No BANKCLIMBER, PURPLE Clam No BAT, INDIANA Mammal Yes BEETLE, AMERICAN BURYING Insect No CAMPION, FRINGED Plant No DROPWORT, CANBY'S Plant No EAGLE, BALD Bird No MOCCASINSHELL, GULF Clam No PIGTOE, OVAL Clam No PITCHER-PLANT, GREEN Plant No PLOVER, PIPING Bird Yes POCKETBOOK, SHINY-RAYED Clam No PONDBERRY Plant No QUILLWORT, BLACK-SPORED Plant No QUILLWORT, MAT-FORMING Plant No RATTLEWEED, HAIRY Plant No SALAMANDER, FLATWOODS Amphibian No SNAKE, EASTERN INDIGO Reptile No STORK, WOOD Bird No

### Page 191 of 219 STURGEON, GULF Fish Yes STURGEON, SHORTNOSE Fish No THREERIDGE, FAT Clam No TORREYA, FLORIDA Plant No

Thursday, April 21, 2005 Page 14 of 27

### Page 192 of 219 TRILLIUM, RELICT Plant No TURTLE, LOGGERHEAD SEA Reptile No WOODPECKER, RED-COCKADED Bird No 

### Idaho (3 species) Group Critical Habitat EAGLE, BALD Bird No PEPPERGRASS, SLICK SPOT Plant No TROUT, BULL Fish No 

### Illinois (7 species) Group Critical Habitat AMPHIPOD, ILLINOIS CAVE Crustacean No ASTER, DECURRENT FALSE Plant No BAT, INDIANA Mammal Yes EAGLE, BALD Bird No POTATO-BEAN, PRICE'S Plant No STURGEON, PALLID Fish No TERN, INTERIOR (POPULATION) LEAST Bird No 

### Kansas (8 species) Group Critical Habitat BAT, GRAY Mammal No CRANE, WHOOPING Bird Yes EAGLE, BALD Bird No MADTOM, NEOSHO Fish No MILKWEED, MEAD'S Plant No PLOVER, PIPING Bird Yes SHINER, ARKANSAS RIVER Fish Yes TERN, INTERIOR (POPULATION) LEAST Bird No 

### Kentucky (4 species)

### Page 193 of 219 Group Critical Habitat BAT, INDIANA Mammal Yes EAGLE, BALD Bird No STURGEON, PALLID Fish No

Thursday, April 21, 2005 Page 15 of 27

### Page 194 of 219 TERN, INTERIOR (POPULATION) LEAST Bird No 

### Louisiana (10 species) Group Critical Habitat BEAR, LOUISIANA BLACK Mammal Yes EAGLE, BALD Bird No HEELSPLITTER, INFLATED Clam No PEARLSHELL, LOUISIANA Clam No QUILLWORT, LOUISIANA Plant No STURGEON, GULF Fish Yes STURGEON, PALLID Fish No TORTOISE, GOPHER Reptile No TURTLE, RINGED SAWBACK Reptile No WOODPECKER, RED-COCKADED Bird No 

### Maine (1 species) Group Critical Habitat WHALE, NORTHERN RIGHT Mammal Yes 

### Maryland (11 species) Group Critical Habitat BAT, INDIANA Mammal Yes BEETLE, PURITAN TIGER Insect No BULRUSH, NORTHEASTERN (=BARBED BRISTLE) Plant No DARTER, MARYLAND Fish Yes EAGLE, BALD Bird No HARPERELLA Plant No PINK, SWAMP Plant No SQUIRREL, DELMARVA PENINSULA FOX Mammal No STURGEON, SHORTNOSE Fish No TURTLE, BOG (NORTHERN POPULATION) Reptile No

### Page 195 of 219 WHALE, NORTHERN RIGHT Mammal Yes 

### Massachusetts (3 species) Group Critical Habitat EAGLE, BALD Bird No

Thursday, April 21, 2005 Page 16 of 27

### Page 196 of 219 POGONIA, SMALL WHORLED Plant No WHALE, NORTHERN RIGHT Mammal Yes 

### Michigan (9 species) Group Critical Habitat BUTTERFLY, KARNER BLUE Insect No BUTTERFLY, MITCHELL'S SATYR Insect No EAGLE, BALD Bird No GOLDENROD, HOUGHTON'S Plant No IRIS, DWARF LAKE Plant No MONKEY-FLOWER, MICHIGAN Plant No PLOVER, PIPING Bird Yes POGONIA, SMALL WHORLED Plant No THISTLE, PITCHER'S Plant No 

### Mississippi (20 species) Group Critical Habitat BEAR, LOUISIANA BLACK Mammal Yes COMBSHELL, SOUTHERN (=PENITENT MUSSEL) Clam No CRANE, MISSISSIPPI SANDHILL Bird Yes DARTER, BAYOU Fish No EAGLE, BALD Bird No FROG, DUSKY GOPHER (MISSISSIPPI DPS) Amphibian No PELICAN, BROWN Bird No PIGTOE, HEAVY (=JUDGE TAIT'S MUSSEL) Clam No PLOVER, PIPING Bird Yes PONDBERRY Plant No POTATO-BEAN, PRICE'S Plant No SNAKE, EASTERN INDIGO Reptile No STURGEON, GULF Fish Yes

### Page 197 of 219 STURGEON, PALLID Fish No TERN, INTERIOR (POPULATION) LEAST Bird No TORTOISE, GOPHER Reptile No TURTLE, LOGGERHEAD SEA Reptile No

Thursday, April 21, 2005 Page 17 of 27

### Page 198 of 219 TURTLE, RINGED SAWBACK Reptile No TURTLE, YELLOW-BLOTCHED MAP Reptile No WOODPECKER, RED-COCKADED Bird No 

### Missouri (11 species) Group Critical Habitat BAT, GRAY Mammal No BAT, INDIANA Mammal Yes BEETLE, AMERICAN BURYING Insect No CLOVER, RUNNING BUFFALO Plant No DARTER, NIANGUA Fish Yes EAGLE, BALD Bird No GEOCARPON MINIMUM Plant No MILKWEED, MEAD'S Plant No MUSSEL, SCALESHELL Clam No PEARLYMUSSEL, PINK MUCKET Clam No STURGEON, PALLID Fish No 

### Montana (6 species) Group Critical Habitat BEAR, GRIZZLY Mammal No CATCHFLY, SPALDING'S Plant No EAGLE, BALD Bird No HOWELLIA, WATER Plant No TROUT, BULL Fish No WOLF, GRAY Mammal Yes 

### New Jersey (10 species) Group Critical Habitat BAT, INDIANA Mammal Yes BEAKED-RUSH, KNIESKERN'S Plant No

### Page 199 of 219 CHAFFSEED, AMERICAN Plant No EAGLE, BALD Bird No JOINT-VETCH, SENSITIVE Plant No PINK, SWAMP Plant No

Thursday, April 21, 2005 Page 18 of 27

### Page 200 of 219 PLOVER, PIPING Bird Yes STURGEON, SHORTNOSE Fish No TURTLE, BOG (NORTHERN POPULATION) Reptile No WHALE, NORTHERN RIGHT Mammal Yes 

### New Mexico (24 species) Group Critical Habitat Amphipod, Noel's Crustacean No CACTUS, KUENZLER HEDGEHOG Plant No CACTUS, LEE PINCUSHION Plant No CACTUS, SNEED PINCUSHION Plant No EAGLE, BALD Bird No FALCON, NORTHERN APLOMADO Bird No FERRET, BLACK-FOOTED Mammal No FROG, CHIRICAHUA LEOPARD Amphibian No GAMBUSIA, PECOS Fish No OWL, MEXICAN SPOTTED Bird Yes PENNYROYAL, TODSEN'S Plant Yes PLOVER, MOUNTAIN Bird No POPPY, SACRAMENTO PRICKLY Plant No SHINER, BEAUTIFUL Fish Yes SHINER, PECOS BLUNTNOSE Fish Yes Snail, Koster's Tryonia Snail No Snail, Pecos Assiminea Snail No Springsnail, Roswell Snail No SUNFLOWER, PECOS Plant No TERN, INTERIOR (POPULATION) LEAST Bird No THISTLE, SACRAMENTO MOUNTAINS Plant No TROUT, GILA Fish No

### Page 201 of 219 WILD-BUCKWHEAT, GYPSUM Plant Yes WOLF, GRAY Mammal Yes 

### New York (12 species) Group Critical Habitat

Thursday, April 21, 2005 Page 19 of 27

### Page 202 of 219 AMARANTH, SEABEACH Plant No BAT, INDIANA Mammal Yes EAGLE, BALD Bird No FERN, AMERICAN HART'S-TONGUE Plant No GERARDIA, SANDPLAIN Plant No MONKSHOOD, NORTHERN WILD Plant No PLOVER, PIPING Bird Yes POGONIA, SMALL WHORLED Plant No STURGEON, SHORTNOSE Fish No TERN, ROSEATE Bird No TURTLE, BOG (NORTHERN POPULATION) Reptile No WHALE, NORTHERN RIGHT Mammal Yes 

### North Carolina (7 species) Group Critical Habitat CAHOW Bird No EAGLE, BALD Bird No LOOSESTRIFE, ROUGH-LEAVED Plant No PONDBERRY Plant No SILVERSIDE, WACCAMAW Fish Yes WHALE, NORTHERN RIGHT Mammal Yes WOODPECKER, RED-COCKADED Bird No 

### Ohio (3 species) Group Critical Habitat BAT, INDIANA Mammal Yes EAGLE, BALD Bird No ORCHID, EASTERN PRAIRIE FRINGED Plant No 

### Oklahoma (18 species) Group Critical Habitat

### Page 203 of 219 BAT, GRAY Mammal No BAT, INDIANA Mammal Yes BAT, OZARK BIG-EARED Mammal No BEETLE, AMERICAN BURYING Insect No

Thursday, April 21, 2005 Page 20 of 27

### Page 204 of 219 CAVEFISH, OZARK Fish No CRANE, WHOOPING Bird Yes CURLEW, ESKIMO Bird No DARTER, LEOPARD Fish Yes EAGLE, BALD Bird No MADTOM, NEOSHO Fish No MUSSEL, SCALESHELL Clam No ORCHID, EASTERN PRAIRIE FRINGED Plant No ORCHID, WESTERN PRAIRIE FRINGED Plant No PLOVER, PIPING Bird Yes SHINER, ARKANSAS RIVER Fish Yes TERN, INTERIOR (POPULATION) LEAST Bird No VIREO, BLACK-CAPPED Bird No WOODPECKER, RED-COCKADED Bird No 

### Oregon (33 species) Group Critical Habitat BUTTERFLY, FENDER'S BLUE Insect No BUTTERFLY, OREGON SILVERSPOT Insect Yes CHECKER-MALLOW, NELSON'S Plant No CHUB, OREGON Fish No DAISY, WILLAMETTE Plant No DEER, COLUMBIAN WHITE-TAILED Mammal No EAGLE, BALD Bird No FRITILLARY, GENTNER'S Plant No LOMATIUM, BRADSHAW'S Plant No LOMATIUM, COOK'S Plant No LUPINE, KINCAID'S Plant No MEADOWFOAM, LARGE-FLOWERED WOOLY Plant No

### Page 205 of 219 MURRELET, MARBLED Bird Yes OWL, NORTHERN SPOTTED Bird Yes PELICAN, BROWN Bird No PLOVER, WESTERN SNOWY Bird No

Thursday, April 21, 2005 Page 21 of 27

### Page 206 of 219 POPCORNFLOWER, ROUGH Plant No SALMON, CHINOOK (LOWER COLUMBIA RIVER) Fish Yes SALMON, CHINOOK (SNAKE RIVER FALL RUN) Fish No SALMON, CHINOOK (SNAKE RIVER SPRING/SUMMER) Fish Yes SALMON, CHINOOK (UPPER COLUMBIA RIVER SPRING) Fish Yes SALMON, CHINOOK (UPPER WILLAMETTE RIVER) Fish Yes SALMON, CHUM (COLUMBIA RIVER POPULATION) Fish Yes SALMON, COHO (OREGON COAST POPULATION) Fish Yes SALMON, COHO (SOUTHERN OR/NORTHERN CA COAST) Fish No SALMON, SOCKEYE (SNAKE RIVER POPULATION) Fish No SHRIMP, VERNAL POOL FAIRY Crustacean Yes STEELHEAD, LOWER COLUMBIA RIVER POPULATION Fish Yes STEELHEAD, MIDDLE COLUMBIA RIVER POPULATION Fish Yes STEELHEAD, SNAKE RIVER BASIN POPULATION Fish Yes STEELHEAD, UPPER COLUMBIA RIVER POPULATION Fish Yes STEELHEAD, UPPER WILLAMETTE RIVER POPULATION Fish Yes TROUT, BULL Fish No 

### Pennsylvania (7 species) Group Critical Habitat BAT, INDIANA Mammal Yes BULRUSH, NORTHEASTERN (=BARBED BRISTLE) Plant No CLUBSHELL Clam No EAGLE, BALD Bird No PLOVER, PIPING Bird Yes RIFFLESHELL, NORTHERN Clam No TURTLE, BOG (NORTHERN POPULATION) Reptile No 

### South Carolina (26 species) Group Critical Habitat

### Page 207 of 219 AMARANTH, SEABEACH Plant No AMPHIANTHUS, LITTLE Plant No ARROWHEAD, BUNCHED Plant No CHAFFSEED, AMERICAN Plant No

Thursday, April 21, 2005 Page 22 of 27

### Page 208 of 219 CONEFLOWER, SMOOTH Plant No DROPWORT, CANBY'S Plant No EAGLE, BALD Bird No HARPERELLA Plant No HEARTLEAF, DWARF-FLOWERED Plant No HEELSPLITTER, CAROLINA Clam Yes IRISETTE, WHITE Plant No LOOSESTRIFE, ROUGH-LEAVED Plant No MANATEE, WEST INDIAN (FLORIDA) Mammal Yes PINK, SWAMP Plant No PITCHER-PLANT, MOUNTAIN SWEET Plant No PLOVER, PIPING Bird Yes PONDBERRY Plant No STORK, WOOD Bird No STURGEON, SHORTNOSE Fish No SUNFLOWER, SCHWEINITZ'S Plant No TREEFROG, PINE BARRENS Amphibian No TRILLIUM, RELICT Plant No TURTLE, LOGGERHEAD SEA Reptile No WHALE, NORTHERN RIGHT Mammal Yes WOLF, RED Mammal No WOODPECKER, RED-COCKADED Bird No 

### Tennessee (4 species) Group Critical Habitat BAT, INDIANA Mammal Yes EAGLE, BALD Bird No STURGEON, PALLID Fish No TERN, INTERIOR (POPULATION) LEAST Bird No

### Page 209 of 219 Texas (59 species) Group Critical Habitat AMPHIPOD, PECK'S CAVE Crustacean No BEAR, LOUISIANA BLACK Mammal Yes

Thursday, April 21, 2005 Page 23 of 27

### Page 210 of 219 BEETLE, COFFIN CAVE MOLD Insect No BEETLE, COMAL SPRINGS DRYOPID Insect No BEETLE, COMAL SPRINGS RIFFLE Insect No BEETLE, HELOTES MOLD Insect Yes BEETLE, KRETSCHMARR CAVE MOLD Insect No BEETLE, TOOTH CAVE GROUND Insect No CACTUS, BLACK LACE Plant No CACTUS, SNEED PINCUSHION Plant No CACTUS, TOBUSCH FISHHOOK Plant No CICURINA VENII (NCN) Arachnid Yes CRANE, WHOOPING Bird Yes CURLEW, ESKIMO Bird No DARTER, FOUNTAIN Fish Yes DAWN-FLOWER, TEXAS PRAIRIE (=TEXAS BITTERWEED Plant No DOGWEED, ASHY Plant No EAGLE, BALD Bird No FALCON, NORTHERN APLOMADO Bird No GAMBUSIA, CLEAR CREEK Fish No GAMBUSIA, PECOS Fish No GAMBUSIA, SAN MARCOS Fish Yes HARVESTMAN, BEE CREEK CAVE Arachnid No HARVESTMAN, BONE CAVE Arachnid No HARVESTMAN, ROBBER BARON CAVE Arachnid Yes LADIES'-TRESSES, NAVASOTA Plant No MINNOW, DEVILS RIVER Fish No OCELOT Mammal No PELICAN, BROWN Bird No PHLOX, TEXAS TRAILING Plant No

### Page 211 of 219 PLOVER, MOUNTAIN Bird No PLOVER, PIPING Bird Yes POPPY-MALLOW, TEXAS Plant No PRAIRIE-CHICKEN, ATTWATER'S GREATER Bird No

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### Page 212 of 219 PSEUDOSCORPION, TOOTH CAVE Arachnid No PUPFISH, LEON SPRINGS Fish Yes RHADINE EXILIS (NCN) Insect Yes RHADINE INFERNALIS (NCN) Insect Yes SALAMANDER, BARTON SPRINGS Amphibian No SALAMANDER, SAN MARCOS Amphibian Yes SALAMANDER, TEXAS BLIND Amphibian No SAND-VERBENA, LARGE-FRUITED Plant No Snail, Pecos Assiminea Snail No SNAKE, CONCHO WATER Reptile Yes SNOWBELLS, TEXAS Plant No SPIDER, GOVERNMENT CANYON CAVE Arachnid Yes SPIDER, MADLA'S CAVE Arachnid Yes SPIDER, ROBBER BARON CAVE Arachnid Yes SPIDER, TOOTH CAVE Arachnid No SPIDER, VESPER CAVE Arachnid Yes SUNFLOWER, PECOS Plant No TERN, INTERIOR (POPULATION) LEAST Bird No TOAD, HOUSTON Amphibian Yes TURTLE, KEMP'S (ATLANTIC) RIDLEY SEA Reptile No TURTLE, LOGGERHEAD SEA Reptile No VIREO, BLACK-CAPPED Bird No WARBLER (WOOD), GOLDEN-CHEEKED Bird No WILD-RICE, TEXAS Plant Yes WOODPECKER, RED-COCKADED Bird No 

### Utah (15 species) Group Critical Habitat BEAR-POPPY, DWARF Plant No

### Page 213 of 219 CACTUS, SILER PINCUSHION Plant No CHUB, VIRGIN RIVER Fish Yes EAGLE, BALD Bird No LADIES'-TRESSES, UTE Plant No

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### Page 214 of 219 MILK-VETCH, DESERET Plant No MILK-VETCH, HOLMGREN Plant No MILK-VETCH, SHIVWITS Plant No OWL, MEXICAN SPOTTED Bird Yes PHACELIA, CLAY Plant No PRAIRIE DOG, UTAH Mammal No SUCKER, JUNE Fish Yes TORTOISE, DESERT Reptile No TROUT, LAHONTAN CUTTHROAT Fish No WOUNDFIN Fish Yes 

### Virginia (9 species) Group Critical Habitat BAT, VIRGINIA BIG-EARED Mammal Yes BITTERCRESS, SMALL-ANTHERED Plant No BULRUSH, NORTHEASTERN (=BARBED BRISTLE) Plant No ISOPOD, MADISON CAVE Crustacean No LOGPERCH, ROANOKE Fish No SNEEZEWEED, VIRGINIA Plant No SPINYMUSSEL, JAMES RIVER Clam No SPIRAEA, VIRGINIA Plant No WHALE, NORTHERN RIGHT Mammal Yes 

### Washington (23 species) Group Critical Habitat BEAR, GRIZZLY Mammal No CHECKER-MALLOW, WENATCHEE MOUNTAINS Plant Yes DEER, COLUMBIAN WHITE-TAILED Mammal No EAGLE, BALD Bird No HOWELLIA, WATER Plant No

### Page 215 of 219 MURRELET, MARBLED Bird Yes OWL, NORTHERN SPOTTED Bird Yes RABBIT, PYGMY Mammal No SALMON, CHINOOK (LOWER COLUMBIA RIVER) Fish Yes

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### Page 216 of 219 SALMON, CHINOOK (PUGET SOUND) Fish Yes SALMON, CHINOOK (SNAKE RIVER FALL RUN) Fish No SALMON, CHINOOK (SNAKE RIVER SPRING/SUMMER) Fish Yes SALMON, CHINOOK (UPPER COLUMBIA RIVER SPRING) Fish Yes SALMON, CHUM (COLUMBIA RIVER POPULATION) Fish Yes SALMON, SOCKEYE (SNAKE RIVER POPULATION) Fish No STEELHEAD, LOWER COLUMBIA RIVER POPULATION Fish Yes STEELHEAD, MIDDLE COLUMBIA RIVER POPULATION Fish Yes STEELHEAD, SNAKE RIVER BASIN POPULATION Fish Yes STEELHEAD, UPPER COLUMBIA RIVER POPULATION Fish Yes STEELHEAD, UPPER WILLAMETTE RIVER POPULATION Fish Yes STICKSEED, SHOWY Plant No TROUT, BULL Fish No WOLF, GRAY Mammal Yes 

### West virginia (4 species) Group Critical Habitat BAT, INDIANA Mammal Yes BULRUSH, NORTHEASTERN (=BARBED BRISTLE) Plant No EAGLE, BALD Bird No HARPERELLA Plant No 

### Wisconsin (4 species) Group Critical Habitat DRAGONFLY, HINES EMERALD Insect No EAGLE, BALD Bird No IRIS, DWARF LAKE Plant No THISTLE, PITCHER'S Plant No

### Page 217 of 219 Appendix H. Guideline Sequence Bibliography for Dodine
161-1 Hydrolysis

MRID Citation Reference
00101402 Clarke, G.; Norris, M.; Bruesch, J.; et al. (1977) Report on Hydrolysis of Cytox 2160 Biocide. (Unpublished study received Nov 2, 1977 under 1730- 43; submitted by American Cyanamid Co., Consumer Products Research Div., Wayne, NJ; CDL:232157-A) 00134831 Betz Entec, Inc. (1973) ?Study--Chemical: Be tz Entec 348|. (Unpub- lished study received Jun 27, 1978 under 345-719; submitted by L and K Laboratories, Brooklyn, NY; CDL:234355-A) 00144366 Rozzi, T. (1984) Letter sent to E. Jones date d Nov 16, 1984: Hy- drolysis of dodecylguanidine hydrochloride. Prepared by Calgon Corp. 14 p. 42242601 Daly, D., K. Kabler, and K. Williamson. 1991. Hydrolysis of dodecylguanidine HCl as a function of pH at 25 C. ABC Final Report No. 38680. Unpublished study prepared by Analytical Bio-Chemistry Laboratories, Inc., Columbia, MO, fo r Calgon Corporation, P ittsburgh, PA, and submitted by American Cyanamid Company, Wayne, NJ. 

### 161-2 Photodegradation-aqueous

MRID Citation Reference
42419001 Daly, D., and K. Kabler. 1991. Determinati on of the photolysis rate of 14C-dodecylguanidine hydrochloride in pH 5 buffered solution at 25 C. Final Report No. 38681. Unpublished study performed by Analytical Bio-Chemistry Laboratories, Inc., Columbia, MO, and submitte d by Calgon Corporation, Pittsburgh, PA. 46438203 Slangen, D.J. and B. van N oorloos. 2004. Photodegradati on of dodine in water including amendment (attachment 1). Unpublished study prep ared by Notox BV, Hertogenbosch, The Netherlands; sponsored by Chimac-Agriphar S.A., Ougree, Belgiu m; and submitted by Ceres International LLC, West Chester, PA. Study Report No. 327061. Experimental start date October 31, 2001, and termination date March 3, 2004 (p. 4). Final report issued May 7, 2004. 

### 161-3 Photodegradation-soil

MRID Citation Reference
43506401 Jendrzejczak, N.; Maestracci, M. (1994) Dodine--UV-Visible Characteristics: Lab Project Numbers: 94-140: R&D/CRLD/AN/9416845: A521. Unpub lished study prepared by Rhone-Poulenc Secteur Agro. 19 p. 46438204 Mislankar, S.G. 2001. Photodegradation of dodine in soil. Unpublished study performed by Aventis CropScience, Raleigh, NC; sponsored by Chimac-Agriphar S.A., Ougree, Belgium; and

### Page 218 of 219 submitted by Ceres International LLC, West Chester , PA. Study Report No. 2000X18609. Experimental start date October 3, 2000, and expe rimental end date November 10, 2000 (Table IX, p. 39). Final report issued June 14, 2001.

162-1 Aerobic soil metabolism

MRID Citation Reference
00058169 Goldberg, M.C.; Wershaw, R.L. (1969) Bi odegradation of Dodecyl- guanidine acetate (Dodine). Geological Survey Research 1969. By ? N.P. (pp. D235-D239,~In~U.S. Geol. Survey Prof. paper 650-D, published study; CDL:232344-D) 43945201 Cooper, J.; Jones, M.; Lowden, P. (1996) (Carbon 14)-Dodine: Aerobic Soil Metabolism in Two Soils at 25 (degrees) C: Lab Project Numb er: P 94/162: 201088: 95/18. Unpublished study prepared by Rhone-Poulenc Agriculture Ltd. 156 p.
162-3 Anaerobic aquatic metabolism

MRID Citation Reference
00058169 Goldberg, M.C.; Wershaw, R.L. (1969) Bi odegradation of Dodecyl- guanidine acetate (Dodine). Geological Survey Research 1969. By ? N.P. (pp. D235-D239,~In~U.S. Geol. Survey Prof. paper 650-D, published study; CDL:232344-D) 42763001 Cady, C. 1993a. Anaerobic aquatic metabo lism of Metasol DGH. Final Report No. 38684. Unpublished study performed by Analytical Biochemi stry Laboratories, Inc., Columbia, MO, for Calgon Corporation, Pittsburgh, PA; and submitted by American Cyanamid Company, Wayne, NJ.
162-4 Aerobic aquatic metabolism

MRID Citation Reference
42327401 Cady, C., and W. Cranor. 1992a. Aerobic a quatic metabolism of Metasol DGH. Final Report No. 38682. Unpublished study performed by Analyti cal Bio-Chemistry Laboratories, Inc., Columbia, MO, and submitted by Calgon Co rporation, Pittsburgh, PA. 46438202 Slangen, D.J., and B. van Noor loos. 2004. The fate of dodine in two water/sediment systems. Unpublished study performed by Notox BV, Hertogenbosch, The Netherlands; sponsored by Chimac-Agriphar S.A., Ougree, Belgium; and submitte d by Ceres International LLC, West Chester, PA. Study Report No.: 344677. Study initiation January 21, 2002 and completion May 17, 2004; experiment initiation and completion dates were not reporte d (p. 4). Final report issued June 11, 2004.
163-1 Leach/adsorption/desorption

### Page 219 of 219 MRID Citation Reference
5001190 Helling, C.S.; Dennison, D.G.; Kaufman, D.D. (1974) Fungicide movement in soils. Phytopathology 64(8):1091-1100. 42148901 Williams, M., and S. Hargadine. 1991. Soil/sediment adsorption-desorption of DGH. ABC Final Report No. 38683. Unpublished study performed by Analytical Bio-Chemistry Laboratories, Inc., Columbia, MO, for Calgon Corporation, Pittsbur gh, PA, and submitted by American Cyanamid Company, Wayne, NJ.
164-1 Terrestrial field dissipation

MRID Citation Reference
00094615 Larsen, D.J. (1979) Spinach Foliar Fungicide Study. Includes method dated Apr 17, 1978. (Unpublished study, including letter dated Sep 25, 1979 from R.W. Vetro to C.F. Niven, Jr., received Feb 9, 1982 under 4E1474; submitted by Interregional R esearch Project No. 4, New Brunswick, N.J.; CDL:070669-H) 00101375 Larsen, D. (1979) Spinach Foliar Fungicide Study. (Unpublished study received Oct 29, 1979 under 4E1474; submitted by Inter- regional Research Project No. 4, New Brunswick, NJ; CDL: 099066- A) 44985701 Norris, F. (1999) Terrestrial Soil Dissipation After Application of SYLLIT Brand 65W Fruit Fungicide to Bare Ground Plots Simulating an Orchard or Grove: Lab Project Number: 45751: 96X10342: 10342-02. Unpublished study prepared by Qu alls Agricultural, Labs. and Excel Research Services, Inc. 1408 p. 44985702 Yang, J. (1998) Dodine: Valida tion of Method of Analysis for Dodine in Soil Using GC-MSD: Lab Project Number: EC-97-384: 45316. Unpublished study prepared by Rhone-Poulenc Ag Co. 138 p. {OPPTS 860.1340}