Page | 1 **UNITED ST AT**  **ES ENVIRONMENT AL**  **PROTECTION A GENCY**  WA SHINGTON, D.C. 20460 OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION February 19, 2015 **MEMORANDUM SUBJECT:**  Drinking Water Assessment for IR4 New Uses of Spinosad and Spinetoram on

Coffee, Berry

/L ow Growing Berry

(Subgroup 13 - 07G), Berry /Small Fruit/Vine Climbing (Subgroup 07 - 07F), Bulb Vegetables (Subgroup 3 - 07B), Cottonseed (Subgroup 20C ), and Dow New Proposed Uses on the Control of Root Maggot on Cabba ge Plant (Brassica (Cole) Leafy Vegetables, Subgroup 5). (PC 110003 - Spinosad, 110008/110009 - Spinetoram; DP Barcodes D41 5813 , 41 5815 ) **FROM:** Larry

L iu , Chemist , Ph.D. Environmental Risk Branch 5 Environmental Fate and Effects Division (7507P) **THROUGH:** Mah T. Shamim, Ph.D. , Branch Chief

Environmental Risk Branch 5 Environmental Fate and Effects Division (750 9 P) **TO:** Tom Bloem

Health Effects Division (7509 P) Barbara Madden; RM 05 Registration D ivision (750 5 P) 

## Summary Current ly proposed section 3 uses and the previously - modeled turf use of spinosad and spinetoram were modeled using the current ly- release d EFED models ( SWCC for surface water and PRZM - GW for ground water) . The results of the modeling exercise indicate that turf use results in higher EDWCs than all the proposed new use s . Therefore, the revised EDWCs are as follows: (a) For spinosad concentrations in surface water: the acute 1 - in - 10 years peak EDWC is 2 5.0 ppb, the non - cancer/chronic 1 - in - 10 years annual mean EDWC is 21.7 and the 1 - 10 - ye ars overallPage | 2

mean cancer/chronic is 14.2 ppb . For spin etoram concentrations in surface water: the acute 1 - in 10 years peak EDWC is 8.6 ppb, the non - cancer/chronic 1 - in - 10 years annual mean EDWC is 5.9 and the 1 - 10 - ye ars overall mean cancer/chronic is 3.8 ppb. (b) Due to the extremely high adsorption of spinosad and spinetoram with soil, even using 100 - ye ar weather records and all available scenario (DELMARVA_STD.SCN, FL CI TRUS_STD.SCN, FLPOTATO_STD.SCN, GACOASTAL_STD.SCN, NCCOASTAL

_STD.SCN, WI SANDS_STD.SCN) in PRZM - GW simulation, Post Breakthrough Mean Concentration (PBT) and Simulation Average Breakthrough Time (BT) were not achieve d (See Appendix E for further details). Although the use on coffee resulted in the highest groundwater EDWCs in all proposed uses, these values are below detection limits 

## Introduction The Environmental Fate and Effects Division (EFED) has completed its review of an IR- 4 petition for the new use s of Spinosad (Reg. numbers 62719 - 266, 62719 - 497, and 62719 - 621) and Spinetoram (Reg. no. 62719 - 539, 62719 - 545, 62719 - 541) on coffee, berry /low growing berry (subgroup 13 - 07G), berry /small fruit/vine climbing ( subgroup 07 - 07F), and bulb vegetables (subgroup 3 - 07B), and cottonseed (subgroup 20C). The other actions associated with the subject data package codes are conversions of crop groups, which do not include new uses for evaluation, for berry

subgroups 13 - 07 A and B, citrus fruit group 10 - 10, pome fruit group 11 - 10, stone fruit group 12 - 12, tree nut group 14 - 12, onion subgroup 3 - 07A, and fruiting vegetable subgroup 8 - 10. Furthermore, Dow AgroSciences has requested the addition of new proposed use for the control of root ma ggot (Brassica (Cole) Leafy Vegetables, Subgroup 5) at the base of cabbage plants and adjacent soils by utilizing banded applications .Page | 3



## Uses of Characterization Spin osad is an insecticide and currentl y registered on a variety of crops and non - crops in the US . It controls many

foliage feeding pests such as lepidopterous larvae (worms or caterpillars), leafminers, thrips, and red imported fire ants. This product’s active ingredient, Spinosad, is biologicall y derived from the fermentation of Saccharopolyspora spinosa , and it is formulated as an SC (s uspension concentrate) . **Table 1** summarizes the application rates from the product label for all proposed new uses of spinosad. **Table 1. Proposed New Uses of Spinosad** Products Crop Single Appl. Rate (lb ai/A) Max #

Appl./ Year Minimu m Appl. Interval (days) Max Appl.

Rate/Year (lb ai/A) Appl.

Methods Entrust SC® Insecticide Coffee 0.064 - 0.164 6 5 0.45 Spray /ground, chemigation and aerial Berry , Low Growing Berry (Subgroup 13 - 07G) except cranberry and lowbush berry Berry , Small Fruit, Vine Climbing (Subgroup - 13 - 07F) except fuzzy kiwifruit 0.064 -

0.096

0.064 - 0.120 5

5 3 - 7

5 0.45

0.45 Spray

/ground, chemigation and aerial

Spray /ground, chemigation and aerial Bulb Vegetables (Subgroup 3 - 07B) 0.040 -

0.120 5 4 0.45 Spray /ground, chemigation and aerial Cottonseed (Subgroup 20C) 0.046 -

0.096 unspec

ified 5 0.45 Spray /ground, chemigation and aerial Brassica (Cole) Leafy Vegetables, (Subgroup 5) for Control of Root Maggot on Cabbage Plant 0.078 -

0.156 6 4 0.45 Spray /groundPage | 4

Spinetoram is an insecticide and currentl y registered on a variety of crops in the US . Itcontrols or suppresses many foliage feeding pests such as lepidopterous larvae (worms, caterpillars), dipterous leafminers, thrips, and certain psyllids . This product’s active ingredient, Spinetoram, is derived from the fermentation of Saccharopolyspora spinosa , and it is formulated as SC ( suspension concentrate) and WG (dispersible granules ). **Table 2** summarizes the application rates from the various product labels for all proposed new uses of spinetoram. **Table 2. Prop osed New Uses of Spinetoram**  Products Crop Single Appl. Rate (lb ai/A) Max #

Appl./ Year Minimum Appl. Interval (days) Max Appl.

Rate/Year (lb ai/A) Appl.

Methods Delegate WG® Insecticide Radiant SC® Insecticide Coffee 0.032 - 0.080 6 5 0.305 Spray /ground, chemigation and aerial Berry , Low Growing Berry (Subgroup 13 - 07G) except cranberry and lowbush berry Berry , Small Fruit, Vine Climbing (Subgroup - 13 - 07F) except fuzzy kiwifruit 0.048 -

0.080 5 3 - 4 0.305 Spray /ground, chemigation and aerial

Bulb Vegetables (Subgroup 3 - 07B) 0.040 -

0.080 5 4 0.234 Spray /ground, chemigation and aerial Cottonseed (Subgroup 20C) 0.011 -

0.064 6 4 0.266 Spray /ground, chemigation and aerial Brassica (Cole) Leafy Vegetables, (Subgroup 5) for Control of Root Maggot on Cabbage Plant 0.039 -

0.078 6 4 0.266 Spray /groundPage | 5



## General Physical**- Chemical and Fate Properties**  Spinosad Spinosad (XDE - 105) is a mixture of two active naturally occurring secondary degradates (Spinosad A and Spinosad D) . Even though the two degradates have analogous fate properties ( i.e. , similar half

- lives in hydrol ys is, aqueous photolysis, soil photolysis, aerobic soil metaboli sm, etc ), the key distinction between the two spinosad components is that Factor D consists of an extra methyl group at carbon 4 on the central ring. In addition, spinosad A is the major component in parent spinosad is at approximately an 85:15 ratio . Both spinosad A and D have similar molecular weight (732 vs 746 g/mol respectivel y). Spino sad A has a greater water solubility than spinosad D and as pH increases water solubility decreases. **Table 3**  presents a summary of physicochemical properties of the two spinosad components. **Table 3 . Summary of Physico**  **chemical Properties of Spinosad Physical Property**  **Spinosad A Spinosad D**  Structure

CAS Registry Number 131929 - 60 - 7 131929 - 63 - 0 Em pirical Formula C 41 H 65NO 10 C 42 H 67NO 10 Molecular Weight 731.976 745.988 Odor Slightly stale water or earthy Relative Density (20  C) 0.512 Melting Point 84 - 99.5  C 161.5 - 170  C Vapor Pressure (25  C) 2.4E - 10 mmHg 3E - 11 kPa 1.6E - 10 mm Hg 2E - 11 kPa Octanol/Water Partition Coefficient (log Kow) pH 5 pH 7 pH 9 Distilled water 2.78 4.01 5.16 3.91 3.23 4.53 5.21 4.38 Dissociation Constant (pKa) (20  C) 8.10 7.87 Water Solubility (20  C)Page | 6

**Physical Property Spinosad A**  **Spinosad D** pH 5 pH 7 pH 9 Distilled water 290 mg/L 235 mg/L 16 mg/L 89.4 mg/L 28.7 mg/l 0.332 mg/L 0.053 mg/L 0.495 mg/L Spinosad A and spinosad D converted in an aerobic soil metabolism study to degradates that are very identical to the parent with half - lives of approximately

9 - 17 days. Similar degradates are formed under photoly

tic s ettings with a half

- life of < 1 day

at pH 7 in sterile water and about 10 days in soil. Spinosad A has a low to moderate water solubility and a low to slight mobility in sandy soils, and is immobile in silt loam and clay loam soils. In terrestrial field dissipation studies with Spinosad A on bare ground plots, the half - life was <1 day , no leaching was observed, and 3.1% of the applied was recovered in runoff. Spinosad has a high affinity for sediment and moves rapidl y from the water to the sediment phases where it , together with its ma jor degradates, is highly

persistent. In anaerobic aquatic metabolism studies, spinosad had a half - life of 161 - 250 days. In an aquatic microcosm dissipation outdoor study , spinosad residues in the sediment peaked at 8 days and had an observed half

- life of greater than 25 days (See **Appendix A**  for details). 

### Spinetoram Spinetoram (XDE - 175) is a new second generation spinosy n insecticide consisting of a mixture of spinetoram J and spinetoram L at roughl y 3:1 ratio. These two components are not isomers. Furthermore, spinetoram J is the major component in the spinetoram mixture , and the distinction between both components is that spinetoram L contains an extra methyl group at carbon 4 on the central ring. Spinetoram L is slightl y heavier (760 g/mol) than spinetoram J (748 g/mol), and spinetoram J has a lower wat er solubility than spinetoram L, that is, spinetoram L is more soluble in water at pH 5 and 7 (See **Table 4** ) . Based on laboratory

studies, both components of spinetoram dissipate rapidly by photolysis in pH 7 buffer soluti on, with half - lives of <1 day . Other major routes of dissipation are aerobic soil metabolism, with non - linear half - lives of 3 - 31 days, and photolysis in soil, with environmental half - lives of 19 - 88 days. In aerobic and anaerobic water/sediment s ys tems, spinetoram rapidl y associates with the sediment phase where dis sipation proceeds more slowl y. Half - lives in total aerobic water/sediment systems were 116 - 124 days, and in total anaerobic water/sediment systems were 385 - 1,386 days . In laboratory soil, spinetoram was generall y immobile (Kd = 84 and Koc =8,570). Under terrestrial and aquatic field conditions, spinetoram dissipated rapidly , with observed half

- lives of ≤1 day . Leaching was not significant under terrestrial field conditions, and migration into sediments was not significant under aquatic field conditions. The octanol/water partitioning coefficients for spinetoram J and spinetoram L are 12,303 and 30,903, respectivel y. Spinetoram (both components), does accumulate in fish. In rainbow trout exposed to spinetoram J, the bioconcentration factors (BCFs) for edible tissue, nonedible tissue, and whole fish were 11, 53, and 46 mL/g , respectively . In rainbow trout exposed to spinetoramPage | 7

L, the BCFs for edible tissue, nonedible tissue, and whole fish were 104, 330, and 344 mL/g , respectivel y (See **Appendix B**  for details). **Table 4. Physical/Chemical and F**  **ate P**  **roperties of Spinetoram**  **Spinetoram J**  **Spinetoram L**  Chemical Structure

Molecular Weight (g/mol) 748 760 Water Solubility -pH 5 423 ppm 1630 ppm

pH 7 11.3 ppm 46.7 ppm pH 9 8 ppm 2 ppm pH 10 6.3 ppm 0.7 ppm Log Kow 4.09 4.38 Vapor Pressure 5.3x10 - 5 Pa 2.1x10 - 5 PA Hydrolysis, pH 5 (half

life) S table stable Hydrolysis, pH 7 (half

life) S table stable Hydrolysis, pH 9 (half

life) S table 158 days Aqueous Photolysis (pH 7) (half

- life of parent) 0.5 day 0.2 day Soil Photolysis (half

life) 27.4 days 9.4 days Aerobic Soil Metabolism (half

- life) 26.5 days (CA) 17.9 days (CA) 8.6 days (VA) 3.2 days (VA) 22.7 days (MS) 19.1 days (MS) 30.8 days (IA) 15.3 days (IA) Anaerobic Aquatic Metabolism (half

- life) 385 days (total system) 1,386 days (total system) Aquatic Aerobic Metabolism (half

- life) 116 days (total system) 124 days (total system) Kd/Koc (loamy sand) 14/1800 31/3936 Kd/Koc (silt loam) 271/24648 483/43873 Kd/Koc (sandy loam) 38/5490 92/13185 Kd/Koc (loam) 12/2344 24/4816 Terrestrial Field Dissipation (half

- life) 23.7 days (CA) 6.1 days (VA) < 1 day (ID) < 1 day (Ontario, Canada)

O O O N

C H 3

H H H H H O

O O

O O

O O O O O N

C H 3

H H H H H O

O O

O O

O OPage | 8 < 1 day (Prince Edward Island, Canada)

Aquatic Field Dissipation(half

- life) < 1 day (GA)

1.3 days (IN) BCF (non - edible) 53/103 (low dose/high dose) 330/430 (low dose/high dose) BCF (edible) 11/43 (low dose/high dose) 104/214 (low dose/high dose) BCF (whole fish) 46/86 (low dose/high dose) 344/348 (low dose/high dose) Four major degradates were identified in spinetoram fate studies: N - demethyl - J, N - demethyl - L , O - demethyl - 175 - J, an d O - demethyl - 175 - L (see **Appendix C** for details). The registrant has submitted absorption studies for two major degradates (N - demethyl - J and N - demethyl - L) detected in spineto ram assessments. Results suggest that N - demethyl - J and N - demethyl - L are classified as slightl y mobile and hardy mobile , respectivel y ( **Table 5** ). **Table 5**  **. Physical, chemical, and fate properties for two major degradates (N -**  **demethyl -** **J and N**  **- demethyl** **- L) detected in the fate studies**  **for spinetoram J and spinetoram L**

**N -**  **demethyl -** **J N**  **- demethyl** **- L**  Chemical Structure

Molecular Weight (g/mol) 734 746 Kd/Koc (loamy sand) 16/2062 34/4270 Kd/Koc (silt loam) 133/12127 340/30918 Kd/Koc (sandy loam) 32/4642 81/11559 Kd/Koc (loam) 8/1631 19/3718 Average Kd/Koc 47/5116 119/ 12616 

## Drinking Water Assessment Tier II models ( SWCC and PRZM/GW) were used to estimate surface water and groundwater EDWCs, respectively , for the proposed uses of spinosad and spinetoram. A total residue method was used in estimating E DW Cs. This is because th e main ring structures in the transformation products which were tent atively characterized in the fate studies remain unchanged . For example, spinetoram - J has a molecular weight (MW) of 748g/mol whereas as its degradate (N demethyl - J) has a MW of 734 , due to the loss of a small methyl group . In the modeling, EFED assumed all the total spinosad and spinetoram residues ( full y or partially identified) are stable under the aqueous photolysis, aerobic soil metabolism , aerobic aquatic metabolism, and anaerob ic aquatic metabolism settings. **Table 6** lists the input parameters used in modeling. Due to the high adsorption of spinosad and spinetoram with soil, EDWCs in groundwater are negligible . O O O N H

C H 3

H H H H H O

O O

O O

O O O O O N H

C H 3

H H H H H O

O O

O O

O OPage | 9

**T able 6. Summary of Input Parameters for Spinosad and Spinetoram in**  **S WCC and**  **PRZM/GW**

The use of spinosad and spinetoram on coffee resulted in the highest surface water EDWCs in all the proposed uses, results are presented in **Table 7 (**  see **Appendix D )**  . However, since much highe st application rate on turf (i.e., 1.6 lb ai/A) in all proposed uses was modeled using FIRST in the 2002 spinosad DWA and the highest application rate on turf (i.e., 0.454 lb ai/A) was modeled using FIRST in the 2007 spinetoram DWA, in addition to the proposed new uses, EFED decided to use the recentl y released SWCC to generate EDWCs on the registered turf use. Although the peak EDWC for coffee is slightl y higher than that for turf, since the onl y available scenario for coffee is from P uerto Rico, EFED decided not to consider that those value s and recommended to use EDWCs from turf use in the current DWA . Due to the extremely

high adsorption of spinosad and spinetoram with soil, even using 100 - ye ar weather records and all six available scenario ( DELMARVA_STD.SCN , FL CI TRUS_STD.SCN , FLPOTATO_STD.SCN , GACOASTAL_STD.SCN , NCCOASTAL

_STD.SCN , WI SANDS_STD.SCN) in PRZM - GW simulation , Post Breakthrough Mean Concentration (PBT) and Simulation Average Breakthrough Time (BT) were not achieved (See **Appendix E** for further details). Although the use on coffee resulted in the highest groundwater EDWCs in all proposed uses , these values are below detection limits ( **Table 8** ). Input Parameter Spinosad Spinetoram Hydrolysis Stable Stable Aqueous Photolysis Stable Stable Aerobic Soil Metabolism Stable Stable Aerobic Aquatic Metabolism Stable Stable Anaerobic Aquatic Metabolism Stable Stable Koc 11,543 L/kg 12,511 L/kg Vapor Pressure 2.4x 10 - 10 torr 1.6x 10 - 7 torr Water Solubility 87.4 ppm 11.3 ppm Molecular Weight (g/mol) 734 760 Application Method Aerial AerialPage | 10

**Table 7. Surface Water EDWCs from the Proposed Crop Uses and the Registered Turf Use of Spinosad and Spinetoram.** 

**Table 8**  **. Groundwater**  **EDWCs from the Proposed Crop**  **Uses of Spinosad and Spinetoram**  **.** Coffee ChemicalID Scenario ID Peak(ppb) PBT Avg(ppb) SimAvg BT(d) spinosad DELMARVA_STD.SCN 1.42E - 11 Incomplete 7.24E - 13 Incomplete 0.0801 spinosad FLCITRUS_STD.SCN 0.000996 Incomplete 0.000117 Incomplete 0.0938 spinosad FLPOTATO_STD.SCN 1.37E - 12 Incomplete 1.13E - 13 Incomplete 0.0431 spinosad GACOASTAL_STD.SCN 0 Incomplete 0 Incomplete 0.0569 spinosad NCCOASTAL_STD.SCN 7.83E - 09 Incomplete 4.66E - 10 Incomplete 0.1008 spinosad WISANDS_STD.SCN 3.84E - 18 Incomplete 1.65E - 19 Incomplete 0.0698 Berry ChemicalID Scenario ID Peak(ppb) PBT Avg(ppb) SimAvg BT(d) spinosad DELMARVA_STD.SCN 1.35E - 11 Incomplete 6.90E - 13 Incomplete 0.0801 spinosad FLCITRUS_STD.SCN 0.00094 Incomplete 0.000111 Incomplete 0.0938 spinosad FLPOTATO_STD.SCN 1.29E - 12 Incomplete 1.06E - 13 Incomplete 0.0431 spinosad GACOASTAL_STD.SCN 0 Incomplete 0 Incomplete 0.0569 Crop (Registration Status) Estimated Environmental

Concentrations (ppb) Spinosad Spinetoram Coffee (proposed) Peak (1 - in - 10 y r) 13.8 9.4 365 - day Avg (1 - in - 10 y

r) 7.7 5.9 Entire Simulation Mean 5.7 4.6 Berry (proposed) Peak (1 - in - 10 y r) 6.9 4.4 365 - day Avg (1 - in - 10 y

r) 5.7 3.6 Entire Simulation Mean 3.4 2.0 Bulb Vegetables (proposed) Peak (1 - in - 10 y r) 9.1 4.0 365 - day Avg (1 - in - 10 y

r) 8.0 3.5 Entire Simulation Mean 4.6 2.0 Cottonseed (proposed) Peak (1 - in - 10 y r) 7.0 2.8 365 - day Avg (1 - in - 10 y

r) 3.5 2.3 Entire Simulation Mean 2.6 1.7 Cabbage (proposed) Peak (1 - in - 10 y r) 13.0 7.3 365 - day Avg (1 - in - 10 y

r) 6.1 3.4 Entire Simulation Mean 5.1 2.8 Turf (registered) Peak (1 - in - 10 y r) 25.0 8.6 365 - day Avg (1 - in - 10 y

r) 21.7 5.9 Entire Simulation Mean 14.2 3.8Page | 11

spinosad NCCOASTAL_STD.SCN 7.32E - 09 Incomplete 4.35E - 10 Incomplete 0.1008 spinosad WISANDS_STD.SCN 3.60E - 18 Incomplete 1.55E - 19 Incomplete 0.0698 Bulb Vegetables ChemicalID Scenario ID Peak(ppb) PBT Avg(ppb) SimAvg BT(d) spinosad DELMARVA_STD.SCN 1.35E - 11 Incomplete 6.90E - 13 Incomplete 0.0801 spinosad FLCITRUS_STD.SCN 9.40E - 04 Incomplete 1.11E - 04 Incomplete 0.0938 spinosad FLPOTATO_STD.SCN 1.29E - 12 Incomplete 1.06E - 13 Incomplete 0.0431 spinosad GACOASTAL_STD.SCN 0.00E+00 Incomplete 0.00E+00 Incomplete 0.0569 spinosad NCCOASTAL_STD.SCN 7.32E - 09 Incomplete 4.35E - 10 Incomplete 0.1008 spinosad WISANDS_STD.SCN 3.60E - 18 Incomplete 1.55E - 19 Incomplete 0.0698 Cottonseed ChemicalID Scenario ID Peak(ppb) PBT Avg(ppb) SimAvg BT(d) spinosad DELMARVA_STD.SCN 1.32E - 11 Incomplete 6.74E - 13 Incomplete 0.0801 spinosad FLCITRUS_STD.SCN 0.000944 Incomplete 0.000111 Incomplete 0.0938 spinosad FLPOTATO_STD.SCN 1.30E - 12 Incomplete 1.07E - 13 Incomplete 0.0431 spinosad GACOASTAL_STD.SCN 0 Incomplete 0 Incomplete 0.0569 spinosad NCCOASTAL_STD.SCN 7.52E - 09 Incomplete 4.48E - 10 Incomplete 0.1008 spinosad WISANDS_STD.SCN 3.71E - 18 Incomplete 1.60E - 19 Incomplete 0.0698 Cabbage ChemicalID Scenario ID Peak(ppb) PBT Avg(ppb) SimAvg BT(d) spinosad DELMARVA_STD.SCN 1.39E - 11 Incomplete 7.10E - 13 Incomplete 0.0801 spinosad FLCITRUS_STD.SCN 0.000998 Incomplete 0.000118 Incomplete 0.0938 spinosad FLPOTATO_STD.SCN 1.38E - 12 Incomplete 1.14E - 13 Incomplete 0.0431 spinosad GACOASTAL_STD.SCN 0 Incomplete 0 Incomplete 0.0569 spinosad NCCOASTAL_STD.SCN 7.94E - 09 Incomplete 4.73E - 10 Incomplete 0.1008 spinosad WISANDS_STD.SCN 3.91E - 18 Incomplete 1.68E - 19 Incomplete 0.0698 Coffee ChemicalID Scenario ID Peak(ppb) PBT Avg(ppb) SimAvg BT(d) spinetoram DELMARVA_STD.SCN 2.17E - 12 Incomplete 1.09E - 13 Incomplete 0.0739 spinetoram FLCITRUS_STD.SCN 0.000328 Incomplete 3.81E - 05 Incomplete 0.0865 spinetoram FLPOTATO_STD.SCN 2.34E - 13 Incomplete 1.92E - 14 Incomplete 0.0398 spinetoram GACOASTAL_STD.SCN 0 Incomplete 0 Incomplete 0.0525 spinetoram NCCOASTAL_STD.SCN 1.21E - 09 Incomplete 7.11E - 11 Incomplete 0.0931 spinetoram WISANDS_STD.SCN 3.12E - 19 Incomplete 1.30E - 20 Incomplete 0.0645 Berry ChemicalID Scenario ID Peak(ppb) PBT Avg(ppb) SimAvg BT(d)Page | 12

spinetoram DELMARVA_STD.SCN 2.06E - 12 Incomplete 1.03E - 13 Incomplete 0.0739 spinetoram FLCITRUS_STD.SCN 0.000327 Incomplete 3.80E - 05 Incomplete 0.0865 spinetoram FLPOTATO_STD.SCN 2.35E - 13 Incomplete 1.93E - 14 Incomplete 0.0398 spinetoram GACOASTAL_STD.SCN 0 Incomplete 0 Incomplete 0.0525 spinetoram NCCOASTAL_STD.SCN 1.24E - 09 Incomplete 7.28E - 11 Incomplete 0.0931 spinetoram WISANDS_STD.SCN 3.20E - 19 Incomplete 1.34E - 20 Incomplete 0.0645 Bulb Vegetables ChemicalID Scenario ID Peak(ppb) PBT Avg(ppb) SimAvg BT(d) spinetoram DELMARVA_STD.SCN 1.43E - 12 Incomplete 7.14E - 14 Incomplete 0.0739 spinetoram FLCITRUS_STD.SCN 2.26E - 04 Incomplete 2.63E - 05 Incomplete 0.0865 spinetoram FLPOTATO_STD.SCN 1.62E - 13 Incomplete 1.33E - 14 Incomplete 0.0398 spinetoram GACOASTAL_STD.SCN 0.00E+00 Incomplete 0.00E+00 Incomplete 0.0525 spinetoram NCCOASTAL_STD.SCN 8.54E - 10 Incomplete 5.03E - 11 Incomplete 0.0931 spinetoram WISANDS_STD.SCN 2.11E - 19 Incomplete 7.90E - 21 Incomplete 0.0645 Cottonseed ChemicalID Scenario ID Peak(ppb) PBT Avg(ppb) SimAvg BT(d) spinetoram DELMARVA_STD.SCN 1.86E - 12 Incomplete 9.36E - 14 Incomplete 0.0739 spinetoram FLCITRUS_STD.SCN 0.000288 Incomplete 3.35E - 05 Incomplete 0.0865 spinetoram FLPOTATO_STD.SCN 2.06E - 13 Incomplete 1.69E - 14 Incomplete 0.0398 spinetoram GACOASTAL_STD.SCN 0 Incomplete 0 Incomplete 0.0525 spinetoram NCCOASTAL_STD.SCN 1.08E - 09 Incomplete 6.34E - 11 Incomplete 0.0931 spinetoram WISANDS_STD.SCN 2.71E - 19 Incomplete 1.06E - 20 Incomplete 0.0645 Cabbage ChemicalID Scenario ID Peak(ppb) PBT Avg(ppb) SimAvg spinetoram DELMARVA_STD.SCN 1.86E - 12 Incomplete 9.36E - 14 Incomplete 0.0739 spinetoram FLCITRUS_STD.SCN 0.000288 Incomplete 3.35E - 05 Incomplete 0.0865 spinetoram FLPOTATO_STD.SCN 2.06E - 13 Incomplete 1.69E - 14 Incomplete 0.0398 spinetoram GACOASTAL_STD.SCN 0 Incomplete 0 Incomplete 0.0525 spinetoram NCCOASTAL_STD.SCN 1.08E - 09 Incomplete 6.34E - 11 Incomplete 0.0931 spinetoram WISANDS_STD.SCN 2.71E - 19 Incomplete 1.06E - 20 Incomplete 0.0645Page | 13



### Appendix **A: Environmental**  **Fate Properties of Spinosad** Degradation and Metabolism Spinosad and Spinosad A and spinosad D were relatively stable in pH 5, 7, and 9 sterile aqueous buffer solutions that were incubated in the dark at 25°C (MRID 43507301 ). In sterile buffered (pH 7) solutions, spinosad A and spinosad D phototransformed with half - lives of 0.8 - 0.9 days (MRID 43507302). The β - isomers of the 13,14 - dihydro of the pseudoagl ycone of spinosad A and of spinosad D were detected at a maximum of 20.2 - 24 .9% of the applied at 48 hours (study

termination). Inalkaline (pH 9.2) pond water, spinosad A and spinosad D phototransformed rapidly with half - lives of 0.54 - 0.55 days. On soil, spinosad A and spinosad D had photodegradation half - life of 8.68 - 9.71 days ( MRIDs 44597733 and 43507303) . The onl y transformation present at >5 % of the applied was N - demethyl - A, which reached 14.8% of the applied at 18 days post - treatment. These studies were not long enough to determine the fate of the degradate s . In aerobic silt loam soil, spinosad A and spinosad D converted to degradate s with initial halflives of 17.3 and 14.5 days, respectivel y (MRIDs 44597733 and 43507303). Spinosad A converted to degradate s with a half - life of 9.4 days in sandy

loam soil incubated under similar conditions. Approximately 75 - 90% of the applied spinosad converted to degradate s by 28 days. The major degradate of spinosad A was N - demethyl - A , which accumulated to a maximum 51 - 61% of the applied at 14 - 28 days post - treatment, then decreased to 12.27 - 21.72% at 9 months and 2.77 - 5.96% at 1 year. The major degradate of spinosad D was N - demethyl

–D , which accumulated to a maximum 68% of the applied at 28 days post - treatment and approximately 50% at 6 months. Several minor degradate s, each less than 10% of the applied, were isolated but not conclusively

identified. The anaerobic soil metabolism of spinosad could not be evaluated because no studies were submitted. In anaerobic flooded clay sediment, spinosad A and spinosad D converted to degradate s with hal f - lives of 161 and 250 days (MRID 43507305) . By 7 days post - treatment, >90% of the applied radioactivity

was associated with the sediment fraction. Three major degradate s of spinosad A, each present at a maximum 8 - 12% of the applied were identified: N - dem ethyl - A, reversepseudoagl yc one (806643), and ketoreversepseudoagl ycone (814426). One major degradate of spinosad D, N - demethyl - D , was present at a maximum 6.5% of the applied. The fate of spinosad under the aerobic aquatic environment is unknown. This is because the submitted study

(MRID 46642701) is classified as unacceptable and is scientifically invalid because significant variability in the results between sampling intervals and between s ys tems at the same sampling interval prevents any confident interpretation of the study results. Because of poor results in the initial experiment, the data presented in this MRID are a compilation of anal ys es of selected test systems from four separate experimental sets for each test substance and system. In additio n, degradate s comprising  10% of the applied may have been present and not identified.Page | 14

Soil sorption and mobility The mobility

of spinosad A, at nominal concentrations of 0.04 - 5.0 μg/mL, was investigated in sand, loamy

sand, sandy

loam, silt loam, and c lay loam soils (MRID 43507306) . Koc values were 2,862, 831, 4,237, 134,583, and 21,938, respectivel y. Freundlich Kdes values for both desorption phases for the sand, loamy sand, sandy loam, and silt loam soils were 8.4 - 9.2, 6.6 - 8.2, 27 - 30, 288 - 357 and 29 2 - 296, respectivel y; corresponding 1/n v alues ranged from 0.826 - 0.921. Adsorption coefficients for spinosad A were used in modeling. The mobility

of N - demethyl - A , the major degradate of spinosad A, was investigated at 0.05 - 5.0 μg/mLin sand, loamy

sand, s andy

loam, and silt loam soils (MRID 43816602) . Koc values were 2,138, 662, 2,881, and 74,583, respectivel y. Freundlich Kdes values for both desorption phases for the sand, loamy sand, sandy loam, and silt loam soils were 6.3 - 6.5, 5.3 - 6.3, 19 - 20, and 171 - 179, respectivel y; corresponding 1/n values ranged from 0.775 - 0.880. Spinosad A and D are not volatile; vapor pressures (25°C) are 2.0 to 3.0 x 10 - 11 kPa. CO 2 was the only volatile compound detected in metabolism studies. Field dissipation Radioactive spinosad A, formulated as an emulsifiable concentrate, degraded with half - lives of 0.5 days in bareground plots of silt loam soil in Mississippi and 0.3 day s in loam soil in California (MRID 43714301). Approximately 2 - 3% remained after 3 - 5 day s. The study did not include those major degradates detected in the laboratory fate studies as analy

tes. Spinosad A and its degradates were not detecte d below the 6 - inch soil depth. Unextracted [ 14 C] residues increased to a m aximum of 34 - 58% b y 38 - 40 days . At the Mississippi site, total radioactivity in the runoff accounted for 3.1% of the applied radioactivity . Pond water (pH 7.6, ca. surface area 2.2 m2 , depth 47.5 - 50 cm) and clay loam sediment (ca. depth 5.5 - 6 cm) maintained in outdoor tanks were treated once with a broadcast - spray application of the suspension concentrate at 100 g/ha to the water surface (MRID 43848803) . Spinosad ( including spinosad A and D ) dissipated rapidly from the water with a calculated halflife of 1.5 days, and total spinosad residues dissipated from the water with a calculated half - life of 4 days. In the water, the degradates N - demethyl - A and N - demethyl - D were detected at maximums of 2.3 ppb (8 hours) and 3.6 ppb (0 hour), respectivel y, and were <0.5 ppb at 15 days. In the se diment, spinosad A was detected at a maximum average 14.9 ppb at 4 days and was 14.3 ppb at 35 days. N - demethyl - A was detected at a maximum average 11.1 at 15 days and was ≤9.4 ppb at 35 days. Spinosad D was ≤4.2 ppb and N - demethyl - D was not detected (LOD 11.3 ppb) at any interval in the sediment. Total spinosad residues in the water had an observed half - life of <1 days. S pinosad residues (parent and its degradates) in the sediment reached a maximum concentration at 8 days post - treatment and had decreased b y approximately 25% b y 35 days. These field studies need to be re - evaluated because the half - lives may

reflect the transformation of the parent to other degradate s similar to the parent. Also the dissipation half - lives reflect the m ovement of the parent and degradate s from one media to another and do not show degradation of the product.Page | 15

Accumulation [ 14 C] Spinosad A and D accumulated in rainbow trout held under laboratory flow - through conditions for up to 28 days (MRIDs 44537734 an d 43557601) . In the high concentration experiments (19.0 ng/L for spinosad A and 33.0 ng/L for spinosad D), maximum BCFs for spinosad A were 28.8 mL/g (at Day 28) for the nonedible tissue, 7.5 mL/g (at Day 25) for the edible tissue, and 21.1 mL/g (at Day 7 ) for the whole fish tissue; and for spinosad D were 42 mL/g(at Day

11) for the nonedible tissue, 20.5 mL/g (at Day 11) for the edible tissue, and 41.9 mL/g(at Day

7) for the whole fish tissue. Registrant - calculated BCFs for total [ 14 C]residues were 103 - 152, 16 - 47, and 84 - 115 mL/gfor the nonedible, edible, and whole fish tissues, respectivel y. In fish exposed to spinosad A, parent accounted for 68.34% of the HPLC distribution in whole fish extracts on exposure day 1, and ≤29.74 % at later sampling intervals. Spinosad J was present at 125 ng/g in day

25 nonedible extracts and day 28 whole fish extracts; all other degradates were each <50 ng/g. In fish exposed to spinosad D, parent accounted for 83.43% of the HPLC distribution in whole fish tissue on exp osure day 1, 48.80% on day 7, 42.19% on day

14, and 35.44% on day

28. In the whole fish tissues, 15 - Pk4 and 20 - Pk4 [N - monomethylated, O demethylated Spinosad Factor D] was a maximum of 134 ng/g; 15 - Pk6 and 20 - Pk6 [N monomethylated, O - demethylated Spinosad Factor D] was a maximum of 230 ng/g; Spinosad Factor L was a maximum of 229 ng/g; Spinosad Factor O was a maximum of 173 ng/g; and N demethyl - D was a maximum of 544 ng/g. All other degradate s were <50 ng/g. Spinosad (i.e., spinosad A and D) has a relatively low bioconcentration factor (BCF’s of the parent ranged from 8 - 20, X, 29 - 42 X, and 21 - 42 X for muscle, viscera, and whole fish, respectivel y), and a relatively rapid rate of depuration (half - life of about one day). These factors generall y would prevent substantial bioconcentration of the material in the food web.Page | 16



### Appendix **B: Environmental**  **Fate Properties of Spinetoram** Degradation and Metabolism The total residue method was used in estimating EECs in the ecological risk assessment. This is because the main ring structures in the degradate s , which were tentativel y i dentified or partiall y characterized in the fate studies , are ess entially the same a s the parent. In the modeling of spinetoram , EFED used the same toxicity for spinetoram J and spinetoram L and the persistence of the spinetoram residues (including parent and its degradate s) under the aqueous photolysis, soil photolysis, aerobic soil meta bolism, and anaerobic aquatic metabolism conditions. Spinetoram is expected to dissipate relativel y rapidly under most environmentally relevant conditions with the apparent primary route of dissipation being via photol ys is in water and soil, and aerobic metabolism in soil. However, it should be noted that most of the degradates detected in the laboratory

studies still contain the major complicated ring structures. Parent spinetoram is stable to hydrol ys is and persistent under aerobic and anaerobic aquatic environments in the laboratory , but dissipates rapidly in terrestrial and aquatic field environments. Also, leaching and migration into sediments under field conditions was not significant. Spinetoram was stable to hydrol ys is at pH 5, and 7, and had <10% decline over 30 days at pH 9 (MRID 46695023) . The photodegradation half - life in pH 7 buffer solutions for spinetoram J and spinetoram L was 12 and 5 hours, respectively (MRID 46695022) . In moist loam soil, the photodegradation half

- life for spinetoram J and spinetoram L was 27.4 and 9.4 days, respectively (MRID 46695024) . In VA loam, MS loam, sandy loam and silt loam soils, spinetoram J dissipated with nonlinear half - lives of 9, 23, 27 and 31, respectivel y; spinetoram L dissipated with nonlinear hal f

- lives of 3, 19, 18 and 15 days, respectivel y (MRID 46695025) . In aerobic aquatic conditions, the half - life in water could not be determined as dissipation from the water phase was very rapid, with both test substances rapidl y associating with the sediment; spinetoram J and spinetoram L degraded in the sediment with nonlinear half - lives of 126 and 114 days, respectively ; and from the total system with half - lives of 116 and 124 days, respectively (MRID 46695027) . In anaerobic aquatic conditions, both te st substances again associated rapidly with the sediment; spinetoram J and spinetoram L degraded in the sediment with halflives of 408 and 1,386 days, respectivel y; and in the total system with half - lives of 385 and 1,386 days, respectively (MRID 46695026 ) . The proposed transformation pathway involves spinetoram J and spinetoram L degrading due to photolysis and/or microbial metabolism by de - methylation to yield N - demethyl - J and N demethyl - L, respectivel y (O - demethyl - J and O - demethyl - L, respectively , under anaerobic aquatic conditions), and several minor unidentified compounds. Further degradation occurs to form numerous increasingl y polar compounds over time, and ultimately mineralization to CO 2 . Soil Sorption and MobilityPage | 17

Spinetoram is expected to be generally immobile in soil (MRID 46695028) . Spinetoram J and spinetoram - L were classified as having low mobility to being immobile according to McCall’s Relative Mobility

classification system in loamy s and, silt loam, sandy loam and loam soils from the U.S., with a Koc of 1800 to 43873 mL/g. Field Dissipation Under terrestrial field conditions, the half - life for spinetoram ( - J + - L) in loam and sandy loam soil was 23.7 days and 6.1 days, respectively , while the observed half - life was ≤1 day

in each soil (MRIDs 46695029 and 47072901) . Spinetoram was not detected below the 0 - 15 cm soil depth at any sampling intervals. Under aquatic field conditions, spinetoram dissipated very quickly in water (MRID 46695030) , with no partitioning of re sidues into the sediment. Total spinetoram residues ( spinetoram J + spinetoram L) dissipated in the water with half - lives of 18.1 to 20.4 hours. No residues of spinetoram J or spinetoram L were detected in any pre - or post application sediment samples. A ccumulation Since the octanol/water partitioning coefficients for spinetoram J and spinetoram L are high (12,303 and 30,903, respectivel y), these two components are expected to bioconcentrate in fish. In rainbow trout exposed to spinetoram J at 17.3 ng/mL , the bioconcentration factors (BCFs) for edible tissue, nonedible tissue, and whole fish were 11, 53, and 46 mL/g , respectively (MRID 46695128) . After 1 day

of depuration, total [ 14 C] residues in the whole fish had decreased b y 28.2%. After 21 days of depuration, total [ 14 C] re sidues had decreased b y 88.7%. The elimination half

- lives for [ 14 C] residues in edible tissue, nonedible tissue, and whole fish were 2.3, and 4 .1, and 4.6 days, respectivel y. In rainbow trout exposed to spinetoram L at 22.3 ng/mL, the BCFs for edible tissue, nonedible tissue, and whole fish were 104, 330, and 344 mL/g , respectivel y (MRID 46695129) . After 1 day of depuration, total [ 14 C] residues in the whole fish h ad steadily

decreased by

9.5%. After 14 days of depuration, total [ 1 4 C] re sidues had decreased by 87.4%. The elimination half - lives for [ 14 C] residues in whole fish, edible tissue, and nonedible tissue were 4.5, 3.9, and 4.1 days, respectively . S pinetoram J and spinetoram L rapidly metabolized, yielding 2 - 4 more polar degradates; correspondingl y, N - demethyl - J and N demethyl - L were positively identified, along with 3’ - O - deethyl - XDE - 175 - L.Page | 18



### Appendix C: **Summary of Deg**  **radates in the Environmental Fate Studies for S**  **pinetoram Degradate**  **(Nam e)**  **Maximum Degradate**  **Concentration (% of applied) and Time (days) to Maximum Concentration in Study:**  **Degradate s Analyzed in Study:**  **Hydrolysis (161**  **- 1)**  **Aqueous**

**Photo. (161**  **- 2)**  **Soil**

**Photo. (161**  **- 3)**  **Aerobic**

**Soil (162**  **- 1)**  **Anaerobic**

**Aquatic (162**  **- 3)**  **Aerobic**

**Aquatic (162**  **- 4)**  **Field Diss.**

**(164 -**  **1) Aquatic** 

**Diss. (164**  **- 2)**  **Fish Study**

**(165 -**  **4)** N - demethyl - J 6.7% @ 30 d 6.6% @

0.33 d Not

Analyzed 68.1% @

125 d Not

Analyzed 8.9% @ 16

d 0.0590

mg/kg @ 26 d 0.373 μg/L

@ 1 h 7.141

mg/kg @ 21 d N - demethyl - L 11.9% @ 30 d 12.2% @

0.17 d Not

Analyzed 41.0% @ 32

d Not

Analyzed 9.6% @ 21

d (0.0039

mg/kg @ 0 d) 2 0.060 μg/L

@ 0.5 h Not

Reported 1 N - demethyl - J + N - demethyl - L Not Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed 0.410 ug/L

@ 6 h 1 Not

Analyzed O - demethyl - 175 - J Not Analyzed Not

Analyzed Not

Analyzed Not

Analyzed 26.7% @

365 d 2.8% @ 30

d Not

Analyzed Not

Analyzed Not

Analyzed O - demethyl - 175 - L Not Analyzed Not

Analyzed Not

Analyzed Not

Analyzed 10.4% @

365 d Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed 3’ - O - deethyl - 175 - J Not Analyzed Not

Detected Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Detected 3’ - O - deethyl - 175 - L Not Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Reported 1 N - demethyl - 175 - L + 3’ - O - deethyl - 175 - L Not Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed 16.034

mg/kg @ 28 d N - formyl - 175 - J Not Analyzed Not

Detected Not

Analyzed Not

Detected Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Detected Aglycone - 175 - J Not Analyzed Not

Detected Not

Analyzed Not

Detected Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Detected C9 -pseudoaglycone - 175 - J Not Analyzed Not

Detected Not

Analyzed Not

Detected Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Detected C9 -pseudoaglycone - 175 - L Not Analyzed Not

Detected Not

Analyzed Not

Detected Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Detected C9 - ketopseudoaglycone - 175 - J Not Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Detected C9 - ketopseudoaglycone - 175 - Not Not Not Not Not Not Not Not NotPage | 19

L Analyzed Analyzed Analyzed Analyzed Analyzed Analyzed Analyzed Analyzed Detected C17 -pseudoaglycone - 175 - J Not Analyzed Not

Detected Not

Analyzed Not

Detected Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Detected C17 -pseudoaglycone - 175 - L Not Analyzed Not

Detected Not

Analyzed Not

Detected Not

Analyzed Not

Analyzed Not

Analyzed Not

Analyzed Not

Detected

Carbon dioxide Not Analyzed Not

Analyzed 3.5% @

18 d spinetoram

J : from 5.0% @ 366 d (CA) to 35.2% @ 276 d (VA) spinetoram L: From 12.50% @ 276 d (CA) to 36.2% @ 365 d (VA) 0.2% @ 90

d 0.7% @ 2 d Not Analyzed Not

Analyzed Not

Analyzed

Nonextractable residues Not Analyzed Not

Analyzed 15.6% @

18 d 37.9% @

276 d 12.1% @

365 d 11.0% @ 21

d Not

Analyzed Not

Analyzed Not

Analyzed 1 Data from identified degradate s reported as a combined number. 2 Maximum concentration was <LOQ.Page | 20



### Appendix **D :**  **Surface Water Modeling of**  **Spinosad and USEPA Standard**  **Reservoir** Estimated Environmental Concentrations for spinosad are presented in Table 1 for the USEPA standard reservoir with the FLturfSTD field scenario. A graphical presentation of the year- to ye ar peaks is presented in Figure 1. These values were generated with the Surface Water Concentration Calculator (SWCC Version 1.106). Critical input values for the model are summarized in Tables 2 and 3. This model estimates that about 0.77% of spinosad applied to the field eventually reache s the water body. The main mechanism of transport from the field to the water body is b y spray drift (63.7% of the total transport), followed b y runoff (30.3%) and erosion (6.05%). In the water body, pesticide dissipates with an effective water column half - life of 551.8 days. (This value does not include dissipation by transport to the benthic region; it includes only processes that result in removal of pesticide from the complete s ys tem.) The main source of dissipation in the water column is washout (effec tive average half - life = 551.9 days) followed by volatilization (4767521 days). In the benthic region, pesticide is stable. The vast majority of the pesticide in the benthic region (99.92%) is sorbed to sediment rather than in the pore water. **Table 1. Es timated Environmental Concentrations (ppb) for spinosad.**  Peak (1 - in - 10 y

r) 25.0 4 - day Avg (1 - in - 10 y

r) 24.0 21 - day Avg (1 - in - 10 y

r) 23.3 60 - day Avg (1 - in - 10 y

r) 22.5 365 - day Avg (1 - in - 10 y

r) 21.7 Entire Simulation Mean 14.2 **Table 2. Summary of Model Inputs for spinosad.**  Scenario FLturfSTD Cropped Area Fraction 1.0 Koc (ml/g) 11543 Water Half

- Life (days) @ 25 °C 0 Benthic Half

- Life (days) @ 25 °C 0 Photolysis Half

- Life (days) @ 25 °L at 0 Hydrolysis Half

- Life (days) 0 Soil Half - Li fe (days) @ 25 °C 0 Foliar Half

- Life (days) 35Page | 21

Molecular Wt 734 Vapor Pressure (torr) 0.00000001 Solubility (mg/l) 87.4 **Table 3. Application Schedule for spinosad.** Date (Mon/Day

) Ty pe Amount (kg/ha) Eff. Drift 6/1 Foliar 0.448 0.95 0.16 6/8 Foliar 0.448 0.95 0.16 6/15 Foliar 0.448 0.95 0.16 6/22 Foliar 0.448 0.95 0.16 **Figure 1. Yearly Peak Concentrations**Page | 22



### Appendix E. Groundwater Analysis for spinosad and the Wisconsin Corn **- WI Central Sands Scenario**  Estimated groundwater concentrations and breakthrough times for spinosad are presented in Table 1 for the Wisconsin Corn - WICentral Sands groundwater scenario. A graphical presentation of the daily

concentrations in the aquifer is presented in Figure 1. These values were generated with the PRZM - GW (Version 1.07). Critical input values for the model are summarized in Tables 2 and 3. **Table 1. Groundwater Results for spinosad and the Wisconsin Corn -**  **WI Central Sands Scenario.**  Peak Concentration (ppb) 3.84E - 18 Post - Breakthrough Mean Concentration (ppb) In complete Entire Simulation Mean Concentration (ppb) 1.65E - 19 Average Breakthrough Time (days) In complete Throughputs 0.06983208 **Table 2. Chemical Properties for Groundwater Modeling of spinosad.** Koc (ml/g) 11543 Surface Soil Half Life (days) 0 Hydrolysis Half Life (days) 0 Diffusion Coefficint Air (cm2/day) 0.0 Henry's Constant 0.0 Enthalpy (kcal/mol) 0.0 **Table 3. Pesticide application scheme used for spinosad. This application scheme was applied every year of the simulation.**  Application Date (Month/Day) Application Method Application Rate (kg/ha) 6/1 Above canop y application 0.089 6/6 Above canop y application 0.089 6/11 Above canop y application 0.089 6/16 Above canop y application 0.089Page | 23

6/21 Above canop y application 0.089 6/26 Above canop y application 0.089 **Figure 1. Aquifer Breakthrough Curve for spinosad and the Wisconsin Corn -**  **WI Central Sands Scenario**