1 

### March 13, 2013 Meeting between Syngenta Crop Protection LLC, NMFS, EPA and USDA 8th Biological Opinion of the case of

Northwest Coalition for Alternative Pesticides v. National Marine Fisheries Service 

## Update on Prometryn Information and Data for the Assessment of Potential Effects on Threatened and Endangered Salmon in the Pacific Northwest2 

# Goals of Meeting

● Update use information and scientific data since last meeting of September 28, 2011



## - Briefly review the best available information and data submitted by Syngenta

- Describe changes in the amended volume

- Provide clarifications or answer any question NMFS, EPA or USDA 

## may have on these data

● Objective: Review best available data pertaining to the risk assessment of prometryn to listed salmonid species, their food resources or habitat

Syngenta is providing updates (shown in GREEN ) to the data and presentation provided on September 28, 2011. Updates will be presented in the main slides, and supporting slides from the September 28, 2011 

## meeting are provided as Appendices.3 

# Agenda

● Product Use and Characterization (Cherilyn Strader)

- General information and registered products



### - Label use restrictions



## ● Geographical Scope of Prometryn Use (JiSu Bang)

● Best Available Environmental Fate Data and Exposure Characterization (Theodore Valenti & Natalia Peranginangin)

● Best Available Ecotoxicology Data (Theodore Valenti)

● Conclusions (Cherilyn Strader)4 

# Product Use and Characterization

Detailed information available under Section 4.4 of the report “P rometryn : Review and Assessment of the Potential Impact of Prometryn on Endangered and Threatened Pacific Salmonid Species, Assessment Amendment 2” (Pages 28 to 32; Submitted March 8, 2013)5 

# General Information On Prometryn

● Used to control many annual broadleaf weeds and grasses

● Applied both pre

- and post

- emergence



## ● Acts by inhibiting photosynthesis at photosystem II

● A pproved for use in cotton, celery, carrot, cilantro, okra , parsley, rhubarb, celeriac, Chinese celery, Florence fennel, dill (CA & FL only), pigeon peas (PR only)

● Permitted for use on 24c labels: transplanted celery (CA); seed carrot, seed parsley, seed parsnip, and seed dill (WA); carrots , parsley, and coriander grown for seed (OR)



## ● Scheduled to begin Registration Review in March 20136 

# Registered Products

Technicals EPA Reg. No. Registrant Active Ingredient(s)

Prometryn Technical 100

- 542 Syngenta Crop Protection, LLC Prometryn

Prometrex ® Technical 46386

- 2 Verolit Chemical Manufacturing CO, LTD Prometryn

End Use Products

Caparol ® 4L 100

- 620 Syngenta Crop Protection, LLC Prometryn

Vegetable Pro®/Cotton Pro® 66222

- 15 Makhteshim Agan of North
America, Inc Prometryn

Prometryne 4L 9779

- 297 Winfield Solutions, LLC Prometryn

Prometryne 4L 34704

- 692 Loveland Products, Inc Prometryn

Formulated Mixture

Suprend ® (cotton only) 100

- 1163 Syngenta Crop Protection, LLC Prometryn + Trifloxysulfuron

# Prometryn Maximum Rates and Application Methods

Use a 

### Max. Single Appl. Rate (lb ai/A) Max. Number Appl . per Year
Celery 2 1

Cotton 2.4 Varies b



### Dill 1.6 1

Fennel 2 1
Parsley 2 1

Carrot 2 Varies c



### Celeriac 2 1

Cilantro 1.6 1

Chinese celery 2 1

Okra 1.5 1
Pigeon Peas 3 1



### Rhubarb 2 1

a IR

- 4 application to add snap beans is currently in review at EPA (PRIA date end of Sept., 2013)

b Application times: Pre

- plant (max application of 2.4 lb ai /A); post

- emergence (up to 3 applications totaling 2 lb
ai /A); lay

- by (maximum 1.6 lb AI/A); and winter weed control (maximum 2.4 lb ai /A); not to exceed annual total max
of 5.5 lb ai /A

c Application times: preemergence (max application of 2 lb ai /A); and postemergence (up to 2 applications of 2 lb
ai /A); not to exceed annual total max of 4 lb ai /A8 

# Examples of Labeled Use Restrictions Relevant to Endangered Species Assessments

● Maximum individual rates, number of allowable applications, timing

● Geographical and Soil Specific Rate Restrictions

- Use rates often state

- specific

- Soil

- type restrictions are state and crop specific

- Generally lower rates (or no use in certain states) on sand and sandy loam 

### soils, or lower organic matter; higher rates on all loamy, silt, fine texture soils, or higher organic matter



## ● Spray Drift Restrictions

- Spray droplet size/nozzles, wind speed, ground, aerial, and chemigation 

### specific restrictions



## ● Surface Runoff Restrictions:

- Do not apply to water, where surface water is present, below high

- tide mark, 

### or where runoff is likely to occur9 

# Example of Soil/Geography Specific Restrictions for Transplanted Celery, Chinese Celery & Florence Fennel

2.0 pt/acre Caparol 4L = 1.0 lb/acre prometryn10 

# Spray Drift Restrictions

● Apply only as a medium or coarser spray (ASABE standard 572.1) or a volume mean diameter of ≥300 microns for spinning atomizer nozzles

● Apply only when the wind speed is 2

- 10 mph

● Use high flow rate nozzles to apply the highest practical spray volume

● Use the minimum number of nozzles that provide uniform coverage

● Spray drift restrictions for ground boom application:

- Do not apply with a nozzle height greater than 4 feet above the crop
canopy pre

- plant, pre

- emergence and post

- emergence

- Pre

- plant incorporated or pre

- emergence: use flat fan nozzle tips

- Post

- emergence band: use drop extraction tubes off

- center nozzle tips



### - Post

- emergence broadcast: use flat fan or off

- center nozzle tips

● Spray drift restrictions for aerial application:

- Aerial applications only permitted on cotton

- None of the crops grown within the 28 salmon ESU/DPS’s allow aerial applications

# Prometryn in Glyphosate and/or ALS Resistant Weed Management

Untreated Check 

### Treated with herbicide program that included prometryn ( Caparol ® 

### 4L) 

## ● Diversity of weed control methods needed.

- Prometryn is an essential tool for many minor use crop growers.



## ● Prometryn enables application of herbicide with an additional mode of action (PSII

- inhibitor).

● Resistant palmer amaranth and horseweed have become significant problems in southern states, particularly in cotton.12 

# Prometryn Salmon BiOp Submissions of Best Available Information and Data to EPA & NMFS, 

# Docket EPA

- HQ

- OPP

- 2008

- 0654

● June 30, 2011

- Specific Use Restrictions & Product Labels to be Considered When Assessing the Potential Impact of Prometryn on Threatened & Endangered Pacific Salmonid Species (MRID 48541602)

- Review & Assessment of the Potential Impact of Prometryn on Endangered & Threatened Pacific Salmonid Species (MRID 48541604)



### ● July 18, 2011

- Specific Use Restrictions document (48541602) + Review & Assessment document (48541604)

- Aerobic Aquatic Degradation & Metabolism study (MRID 48541603)

- Acute Toxicity of Prometryn to Bluegill Sunfish (MRID 48541601) & Common Carp (MRID 48541606)

- Acute Toxicity of Formulation A1114U to Rainbow Trout (MRID 48541607), Common Carp (MRID 48541608) & Green Algae (MRID 48541611)

- Acute Toxicity of Formulation A3953F to Rainbow Trout (MRID 48541610), Daphnia magna (MRID 48541605) & Green Algae (MRID 48541609)



### ● December 20, 2011

- Amended assessment including: inert comparison, flowing water body modeling & corrected anaerobic aquatic degradation half

- life value (MRID 48697901)

- Rebuttal of CA Red

- legged frog end

- points (MRID 48697902)



### ● March 8, 2013

- Amended assessment including: updated water monitoring data, corrections to the environmental fate conceptual model & updated ecotoxicity endpoints

- Rainbow trout acute toxicity study13 

# Other Best Available Data Recently Submitted as Conditions of Registration 1



### Guideline Study MRID Subm . Date

860.1300 Nature of Residue

– Plants 48727502 1/24/2012

860.1500 Crop Field Trials

– Carrot 48727501 1/24/2012

870.7800 Immunotoxicity 48936501 9/11/2012

870.6200 Acute & Subchronic Neurotoxicity 49021201

- 04 12/17/2012

850.1350 Aquatic Invertebrate Life

- cycle

(saltwater) 3/5/2013

1 Letter from J. Tompkins to J. Abbott, Subject: “Label Amendment (New Use on Carrot, Celeriac, Cilantro, Okra, Parsley, and Leaf Petioles (Crop Subgroup 4B) Prometryn Technical EPA Reg. No. 100

- 542 Caparol4L EPA Reg. No. 100

- 620 Application Dated August 13, 2008”, January 5, 2011.14 

# Geographic Scope of Prometryn Uses

The analysis has been updated using recent data that has become available since the original report was generated. Detailed information available under Section 4 of the report “P rometryn : Review and Assessment of the Potential Impact of Prometryn on Endangered and Threatened Pacific Salmonid Species, Assessment Amendment 2” (Pages 9 to 27; Submitted March 8, 2013)15 

## The analyses with new information show that use patterns have not appreciably changed since prior assessment.

• Prometryn use slightly increased in 2010 but total use pattern is similar since 2008

• Still no cotton use found within the 28 ESU/DPSs



## 0 

## 50 100 150 200 

## 250 300 350

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 Total Use (Thousand lb per year)



## Year Total Annual Use 

# Highlight of UpdatesAll Crop Uses 

# Prometryn Use Locations 

# Relative to the Listed Salmon ESU/DPS in CA

80% 20%

Total Prometryn Applications outside ESU/DPS

Total Prometryn Applications within ESU/DPS 

## Average Annual Use ( lbs / yr ) Reported in CA PUR Database

( 2000

– 2010 ) by Pesticide Use Reporting DistrictCotton Only



# Cotton Only 

# Prometryn Use Locations Relative to the Listed Salmon ESU/DPS in CA

100%

Total Prometryn Applications outside ESU/DPS Total Prometryn Applications within ESU/DPS 

## Average Annual Use ( lbs / yr ) Reported in CA PUR Database ( 2000

– 2010 ) by Pesticide Use Reporting District No Prometryn uses on Cotton between 2000 and 2010 in the CA ESU/DPS18 

# Summary of Comprehensive Spatial Analysis

● Additional data presented that was not included in amended report in order to provide the most up

- to

- date information



## ● The additional data presented in the current amended report do not change the conclusions

● There is minimal potential for prometryn use within the ESU/DPSs in Oregon, Washington, and Idaho

● No prometryn use on cotton within any of the 28 ESU/DPSs

- No aerial use of prometryn within any of the 28 ESU/DPSs



## ● There is minimal use of prometryn on other specialty crops within 

## the 28 ESU/DPSs

● Overall, the results indicate that current and potential use of prometryn within or adjacent to the 28 ESU/DPS in the Pacific 

## Northwest and California is minimal19 

# Environmental Fate and Exposure

Monitoring data presented in the slides have been updated using additional data sources and up to 2012 data. Detailed information available under Sections 5

- 8 of the report “P rometryn : Review and Assessment of the Potential Impact of Prometryn on Endangered and Threatened Pacific Salmonid Species, Assessment Amendment 2” (Pages 32 to 51; Submitted March 8, 2013 )20 

# Environmental Fate

Parameters Available Data and Source

Aerobic soil t1/2 (days) 270

MRID 00148338

Terrestrial field dissipation t1/2 (days) 70, 86, 71, 103

MRIDs 41546401

- 4, 42253901

- 4

Aerobic aquatic t1/2 (days) 110.4, 235.8, 38

MRID 48541603 and EU

FOOTPRINT

Koc ( mL /g) 57

– 3014 (>47 values)

MRID 41875901, Rao and Davidson (1982), Seol and Lee (2000), Baskaran and Kennedy (1999), Turin and Bowman (1997)
Mobility via column leaching Low (est. Koc =1228 mL /g)

MRID 41875904 

### ● Major dissipation pathways driven by aerobic soil degradation, aerobic aquatic degradation, sorption.

● No degradation via abiotic pathways 

### (e.g. aqueous and soil photolysis, volatilization, hydrolysis)

● Low mobility demonstrated in column leaching and terrestrial field 

### dissipation studies (no detection below 17.7 inches)

● Soil adsorption correlates to % OC and cation exchange capacity21 

# Physical and Environmental Fate Inputs in 

# PRZM/EXAMS Model

Parameter EPA Drinking Water 1 and CRLF 2 Assessments Best Available Value 3

Vapor Pressure at 25oC ( torr ) 1.0 x10

- 6 (DW) 1.0 x10

- 3 (CRLF) 1.24 x 10

- 6 (MRID 44339601)

Henry’s Law Constant (atm

- m3/mol) 9.1 x 10

- 9 7.40 x 10

- 9 (calculated from vapor pressure and solubility values)
Aerobic Aquatic Half Life (days) 1620 (6x single aerobic soil t1/2 value of 270) 237 (90 th percent confidence bound on the mean of 110.4,

235.8, 38)
Sorption Coefficient

, Koc ( mL /g) 244 577 (average of 47 values ranging from 57 to 3014) 

### ● Some of the environmental fate parameters EPA used in Drinking Water 1 

### and CRLF 2 

### assessments to model EECs are not consistent with best available data.

● Biotic degradation in aquatic systems via aerobic metabolism; low mobility

1 US EPA 2009. Prometryn (CAS Reg. No. 7287

- 19

- 16) Tier I Drinking Water Assessment for the Proposed New Uses on Carrots, Okra, Pa rsley, Cilantro, Celeriac, and Leafy Petioles. Memorandum from Silvia C. Termes to Barbara Madden. June 19, 2009. PC Code: 080805. DP Barcode: 357096, 357099.

2 US EPA 2009. Risk of Prometryn Use to Federally Threatened California Red

- legged Frog ( Rana aurora draytonii ). June 17, 2009.

3 Refer to previous slide for data source.22 

# Highlight of Updates

● To present the most up to date data, monitoring data presented in the slides were updated to include additional sources and up to 2012 data . The updates were not included in the amended report 

## (Assessment Amendment 2, submitted 3/8/13).

- 8 monitoring data sources in PNW and CA (see next slide)

• 10,739 samples ; 1,472 sites in PNW and CA*

• 9,054 samples ; 1,070 sites within ESU/DPS boundaries*

- No change to the maximum detected concentration reported previously 

### ( 3.13 μg/L within ESU/DPS boundaries, MRID 48541604 , 2012, Assessment Amendment 2 ).

* USGS NAWQA not included because majority of NAWQA samples and sites overlap with USGW NWIS23 

# Sampling Frequency Information for Federal and State Surface Water Monitoring Data in WA, OR, CA and ID: 

# Updated with up to 2012 data

Source Number of

samples (sites) Sites with >

100 samples Sites with >

25 samples Frequency description

USGS NAWQA 1490 (79) 4 18 Few days apart, weekly, bi

- weekly, monthly

- frequency is dependent on the site location

USGS NWIS 2528(330) 6 19 Dependent on site location, ranges from daily, weekly, bi

- weekly, monthly, several months and yearly

EPA STORET 363 (145) 0 0 Irregular, ranges from 1 per site to once per
month for a few months

CDPR 2278(327) 3 11 Ranges from 2 days, weekly, monthly or irregular spaced sampling

CEDEN 1428(306) 0 0 Ranges from 1 to 3 times per year (several months apart)

CILRP 329(78) 0 0 Ranges from monthly or 1 to several times per

year

OR DEQ 795 (143) 0 1 limited sampling per site and irregular sampling intervals

WA EIM 3018(143) 15 18 21 sites have periods of weekly sampling, 16 of which have multiple years of weekly sampling24 

# Highlight of updates

● Updated estimated exposure concentrations (EECs) from registered crop uses using flowing farm pond scenarios (no change from Assessment Amendment 2, submitted 3/8/13).

Parameter Low Flowing Farm Pond (504 m 3 /hr)

Peak 16.1

21

- d 6.3

60

- d 1.3 Estimated maximum EECs (90 th percentile of 30 yearly max. values), μg/L



### Note the above concentrations are based on surrogate PRZM crop scenarios in OR (static) and WA (flowing) where prometryn crop acreage is minimal and use 

### (poundage) is negligible. Furthermore, field location (Grant County) used in the WA crop scenario has minimal overlap with ESU/DPSs of concern.
Predicted maximum peak EEC from flowing farm pond is approximately within 5x higher than the single maximum concentration (3.13 μg/L) observed in aquatic 

### environment from the extensive water monitoring database within the ESU/DPS boundaries.25 

# Estimated Exposure from Registered Crop Uses

Hydrologically static water body (farm pond scenario without flow) compared

with flowing water body (farm pond scenario with low flow)

Parameter Static Farm Pond Low Flowing Farm Pond (504 m 3 /hr)

Peak 68.6 16.1

21

- d 67.7 6.3

60

- d 66.0 1.3 Estimated maximum EECs (90 th percentile of 30 yearly max. values), μg/L



## ● Conservative exposure estimates using best available inputs

- PRZM/EXAMS with standardized EPA input guidance and scenarios.

- Setbacks required by states, such as California (required setbacks of 60 and 300 feet for ground and aerial applications, respectively), were not included in the calculated exposure values (note: >97% prometryn crop acreage in WA, OR, ID, and CA occurs in CA).

- Use of 90 th 

### percentile of 30 yearly maximum (peak) concentration in risk 

### assessment, corresponding to >99 th 

### percentile of 10,957 daily concentration values in 30

- year period.26 

# Estimated Exposure from Registered Crop Uses

● A study by Sommer et al. (2001 )* involving the Yolo Bypass, the primary floodplain of the lower Sacramento River, California, 

## indicated that hydrology affects the quality of floodplain rearing habitats.

● Salmonid growth, survival, feeding success and prey availability

were greater when the flow

- pulses were higher and of longer 

## duration.

● These findings suggest that locations with higher flow

- rate are thus preferred by salmon, and will positively affect multiple factors that 

## influence growth, such as food supply or water temperature

.

* Sommer , T.R., M.L. Nobriga , W.C. Harrell, W. Batham and W.J. Kmmerer . 2001. Floodplain rearing of juvenile Chinook salmon: evidence of enhanced growth and survival. Can. J. Fish. Aquat . Sci. 58:325

- 333

.27 

# Summary

● This presentation contains the most up

- to

- date monitoring data and not all data are included in the amended report.

- No changes to the conclusions that are presented in the current amended 

### report.



## ● Modeling exposure in the flowing water body using static farm pond is unrealistic and highly conservative. Hydrologic flow should be incorporated in modeling exposure concentrations in flowing water bodies.



## ● Conservative prediction of maximum peak EEC in flowing water body (16.1 ug /l) is within 5x of the maximum concentration observed in water monitoring data (3.13 ug /l) from flowing water bodies within the ESU/DPS boundaries.28 

# Ecotoxicology and Potential Risk of 

# Prometryn to Salmonids

Detailed information available under Section 10 of the report “ P rometryn : Review and Assessment of the Potential Impact of Prometryn on Endangered and Threatened Pacific Salmonid Species, Assessment Amendment 2” (Pages 52 to 68; Submitted March 8, 2013 )29 

# Highlight of updates: Freshwater fish acute endpoint updated

Reasons Beliles et al. (1965) study is not best available data and should not be used in assessment.

• Nominal treatment concentrations only.

• Descriptions of solvent use unclear.

• Dissolved oxygen, pH, lighting, and photoperiod levels were not reported

.

• Water temperatures reached 17.2 ° C and deviated by ≥4.4 ° C during the study.

( OPPTS 850.1075 recommends 12 ± 2 ° C for rainbow trout )



### • Only 5 fish per treatment. (OPPTS 850.1075 requires a minimum of 7 fish) 

## Error in Table 15 corrected.

• The Rainbow Trout 96

- h LC50 value for the Hamaker study (1985a) should be 5460 μg ai /L (Study recently submitted with amended report).

• This endpoint replaces the Rainbow Trout 96

- h LC50 value of 2700 μg ai/L. from the Beliles et al. (1965) study.30 

# Direct Effects on Salmonids from Prometryn Use are 

# Unlikely

Species Test Material Endpoint (μg a.i ./L)

Rainbow Trout Technical 96

- h LC 50 

### = 5460

Fathead Minnow Technical 32

- d NOEC = 620



## Acute RQs ≤ 0.02
Chronic RQ ≤ 0.11 Maximum Modeled Values (μg/L) Maximum Monitoring Values (μg/L)

Static Farm Pond Low Flow Farm Pond



### Peak EEC 

### 60

- d

EEC 

### Peak EEC

with flow 

### 60

- d EEC

with flow CA DPR 

### USGS NAWQA WA EIM

68.6 66.0 16.1 1.3 3.13 0.621 No Detect


# TIER 1:31 

# Highlight of Changes: Additional chronic invertebrate endpoint

Marine invertebrate chronic toxicity test with Mysid conducted.

• Study submitted to Agency (3/5/13)

• No Observed Effects Concentration (NOEC) = 110 μg/L (Reproduction )

Static pond

Flowing pond Monitoring data32 

# Indirect Effects to Salmonids via Direct Effects on 

# Aquatic Invertebrates are Unlikely

Species Test Material Endpoint (μg a.i ./L)
Daphnia magna Technical 48

- h EC 50 

### = 18600
Daphnia magna Technical 21

- d NOEC = 1000
Americamysis bahia Technical 28

- d NOEC = 110 μg/L

Maximum Modeled Values (μg/L) Maximum Monitoring Values (μg/L)

Static Farm Pond Low Flow Farm Pond

Peak EEC 21

- d

EEC Peak EEC with flow 21

- d EEC

with flow CA DPR USGS NAWQA WA EIM



### 68.6 66.0 16.1 1.3 3.13 0.621 No Detect



## Acute RQs ≤ 0.01
Chronic RQ ≤ 0.62 

# TIER 1:33 

# Highlight of Changes: Additional aquatic plant endpoints

The GREEN BARS represent additional endpoints. 

## Additional values added to Table 17.

The addition of these data is useful for assessing 

### community

- level based effects.34 

# Highlight of Changes: Revised aquatic plant SSD

HC 20 

## = 8.4 μg/L35 

# Highlight of Changes: Static Farm Pond

- Peak EEC relative to HC 20



## HC 20 

## = 8.4 μg/L

Peak EEC (PRZM/EXAM no flow) 

### Potential effects predicted to 68.5 % of
taxa based on the maximum model concentration36 

# Highlight of Changes: Low Flow Farm Pond

- Peak EEC relative to HC 20



## HC 20 

## = 8.4 μg/L

Peak EEC 

### ( PRZM EXAM low flow ) Potential effects to 36.5% of taxa based on the refined model maximum concentration37 

# Highlight of Changes: Monitoring Data

- Peak EEC relative to HC 20



## HC 20 

## = 8.4 μg/L

Max. Measured EEC ( Monitoring data) Potential effects to 8.5 % of taxa based on 

### maximum detected concentration from monitoring data.38 

## Community

- level effects are minimal for refined exposure scenarios.

• Functional redundancy in ecosystems. 

# Indirect Effects to Salmonids via Direct Effects on Aquatic Plant Communities are Unlikely

Drost et. al (2003) 

## Aquatic plants rapidly recover from prometryn exposure.

• Triazine herbicides target Photosystem II



### • Drost et al. (2003) showed that Lemna minor quickly recovered from ametryn exposure ( based on growth rate).



## Periphyton communities relatively 

## insensitvity to prometryn exposure

.

• Schmitt

- Jansen and Altenburger ( 2009) showed that periphyton communities exposed to up to 80 μg/L prometryn were 

### functionally and structurally similar to control treatments. Control Prometryn (80 μg/L)

Chl. a (μg/disk) 1.5

- 2.9 2.14

Species 12

- 18 8
Biodiversity 0.96

- 1.63 0.98

Schmitt

- Jansen and Altenburger (2009)39 

# Highlight of Changes: Reanalysis of t errestrial plant endpoints

Inconsistencies among reported Terrestrial Plant Endpoints

• Canez 1988

– Original study reports ( MRIDs 41035903 + 41035904)

• US EPA Data Evaluation Record (1991)

• US EPA California Red

- legged Frog Assessment (2009)

• These inconsistencies highlighted in Assessment Amendment 2, Appendix 2



## Re

- Analysis of Tier II Terrestrial Plant Toxicity Study Data

• Seeding emergence



### • Vegetative vigor

• Values in Table 24 were updated in Assessment Amendment 2 of the Salmonid assessment

• Calculations appear in Assessment Amendment 2, Appendix 340 

## HC 20 

## = 0.026 lbs /A 

# Highlight of Changes: Revised terrestrial plant SSD (Dry Weight Vegetative Vigor)41 

# TerrPlant Screening

- Level Model: Exposure Values for Terrestrial Plants in Riparian Areas

Application Rate (lb/A) 0.5 0.8 1.0 1.5 1.6 2.0

Runoff Fraction 1 0.02 (dry area)

Spray Drift Fraction 2 0.01

Runoff Deposition (lb/A) 3 0.01 0.016 0.02 0.03 0.032 0.04

Spray Drift Deposition ( lb/A) 3 0.005 0.008 0.01 0.015 0.016 0.02

Runoff + Drift Deposition ( lb/A) 0.015 0.024 0.03 0.045 0.048 0.06

1 Highest result shown in bold font and highlighted

2 TerrPlant model guidance, based on prometryn solubility of 33 mg/L and assuming no soil incorporation

3 TerrPlant guidance for ground spray applications

4 Application rate x runoff or spray drift fraction 

## • Highly conservative exposure estimates42 

## HC 20 

## = 0.026 lbs /A 

# Highlight of Changes: Tier 1 EEC relative to HC 20



### Tier 1 Peak EEC ( TerrPlant Screening

- Level) 

### Potential effects to 29.5 % of taxa based on the model maximum 

### concentration43 

# Runoff Refinement Using PRZM Runoff Flux 1

Crop Use (PRZM Scenario) Max. Single Applied Rate (lb/A) Number of

Applications EEC Contributions (lb/A)

Runoff 2 Spray Drift 3 Runoff + Drift

Carrots

- Fall (CA row crop) 2 2 0.0004 0.02 0.0204 Carrots (ID potato) 2 2 0.0006 0.02 0.0206 Carrots (OR hops) 2 2 0.0007 0.02 0.0207 Carrots

- Spring (CA row crop) 2 2 0.0007 0.02 0.0207 Carrots (WA potato) 2 1 0.0014 0.02 0.0214 Celery

- Fall (CA row crop) 2 1 0.0004 0.02 0.0204 Celery (OR hops) 2 1 0.0008 0.02 0.0208 Celery (OR snap beans) 2 1 0.0013 0.02 0.0213 Celery

- Spring (CA row crop) 2 1 0.0006 0.02 0.0206 Celery (WA onion) 0.8 1 0.0002 0.008 0.0082 Okra

- PRE (CA tomato) 1.5 1 0.0014 0.015 0.0164 Okra

- PRE + POST (CA tomato) 0.8 2 0.0004 0.008 0.0084 Parsley

- Fall (CA lettuce) 0.5 1 0.0007 0.005 0.0057 Parsley

- Fall (CA row crop) 2 1 0.0006 0.02 0.0206 Parsley

- Spring (CA lettuce) 0.5 1 0.0010 0.005 0.0060 Parsley

- Spring (CA row crop) 2 1 0.0006 0.02 0.0206 Rhubarb (OR hops) 2 1 0.0008 0.02 0.0208 Rhubarb (OR snap beans) 2 1 0.0010 0.02 0.0210 Rhubarb (WA onion) 1.6 1 0.0003 0.016 0.0163

1 Highest result shown in bold font and highlighted

2 PRZM edge

- of

- field runoff flux based on maximum single application rate and maximum number of applications per year

3 Spray drift calculation from TerrPlant (1% of application rate)44 

## HC 20 

## = 0.026 lbs /A 

# Highlight of Changes: Tier 2 EEC relative to HC 20



## Tier 2 Peak EEC (Refined using PRZM Runoff Flux) 

## Potential effects to 18.5% of taxa based on the 

## refined model maximum concentration45 

# Prometryn Exposure to Wetland Riparian 

# Communities is Minimal

● No significant overlap of prometryn use areas with wetland riparian areas based on proximity analysis to site specific crop data

● The proportion (%) of potential crop growing areas registered for Prometryn use:

- W ithin a 100

- ft distance of the wetland locations within the ESU/DPS boundaries was extremely low, ranging from 0 to 0.66 % across the 28 ESU/DPS

- W ithin a 100

- ft area of the critical habitat streams was extremely low, ranging from 0 to 0.43 % across the 21 ESU/DPS (critical habitat spatial data available for only 21 ESU/DPS when data was processed)

### Image analysis to characterize vegetation changes within riparian zone of the critical habitat stream near historical prometryn use areas

Central Valley Steelhead DPS Modesto County (50M03S07E09) Total use: 328.5 ( a.i . lb) (94.2lb applied for Dill and 234.3lb for Parsley) Frequency of use:142 

# Prometryn Use Does Not Adversely Affect Riparian 

# Areas Adjacent to Use Sites

### Image analysis to characterize vegetation changes within riparian zone of the critical habitat stream near historical prometryn use areas 

# Prometryn Use Does Not Adversely Affect Riparian Areas Adjacent to Use Sites48 

### Satellite imagery shows that riparian vegetation areas near sites with years of prometryn use are not impacted based on Normalized Difference Vegetation Index (NDVI) 

# Indirect Effects to Salmonids via Direct Effects on Terrestrial Plant Communities are Unlikely

Image collected on June, 2001 Image collected on May, 2010

NDVI
Mean = 0.49 

### SD= 0.14 NDVI
Mean = 0.56 

### SD= 0.2049 

## Toxicity tests were performed with technical prometryn and formulated product with species representing various trophic levels.

These data indicate that formulated prometryn demonstrates toxicity that is comparable to TGAI.

Data is shown in Tables 15

- 17.
Green algae data point is based on a mean value from two tests for each test material. 

# Comparison of Prometryn Formulations: Ecotoxicity Endpoints50 

# Summary : Update of Risk Assessment

● Direct effects on Salmonids from prometryn exposure are highly unlikely

- Updating the freshwater fish acute endpoint did not alter conclusions

.



## ● I ndirect effects on Salmonids via direct effects on aquatic invertebrates are highly unlikely

- Including the marine invertebrate chronic endpoint did not alter the conclusions

.



## ● Indirect effects on Salmonids via direct effects on aquatic plants are unlikely due to the ability of aquatic plants to tolerate and recover from prometryn exposure.

- Including additional aquatic plant endpoints did not alter the conclusions

.

- SSD not included in Amended Assessment.



## ● Indirect effects on Salmonids via direct effects on terrestrial plants are likely minimal.

- Reanalyzing terrestrial plant toxicity endpoints did not alter conclusions

.

- SSD not included in Amended Assessment

.



## ● These data indicate that formulated prometryn demonstrates toxicity 

## that is comparable to TGAI

.51 

# Overall Conclusions

● Current and future potential prometryn use within or adjacent to the 28 ESU/DPSs is minimal

● No cotton use within the 28 ESU/DPSs

- No aerial application



## ● Monitoring data suggest that aquatic exposure is likely an order of magnitude lower than estimated exposure values from standard EPA static farm pond scenario

● I ncorporating hydrologic flow resulted in markedly lower estimated exposure values compared to standard EPA static farm pond scenario



## ● Potential effects to salmonids from prometryn use is highly unlikely

- Direct and indirect

● There is no indication that prometryn use will jeopardize the 

## continuing existence of 28 listed Pacific salmonids or adversely affect designated critical habitat for listed Pacific salmonids52 

# APPENDIX A: Geographic Scope of Prometryn Uses

The analysis has been updated using recent data that has become available since the original report was generated. Detailed information available under Section 4 of the report “P rometryn : Review and Assessment of the Potential Impact of Prometryn on Endangered and Threatened Pacific Salmonid Species, Assessment Amendment 2” (Pages 9 to 27; Submitted March 8, 2013)53 

## In this section, comprehensive spatial analyses were conducted;

● to understand historical and current prometryn use patterns

● to identify the area where prometryn registered crops have historically
grown



## ● to identify potential prometryn use areas within the 28 salmonid ESU/DPSs 

# Objectives54 

### GfK Kynetec Survey Data (2006

- 2011 ) USGS

- NAWQA Presenting Use Patterns (1999

- 2004) 

# Geographic Scope of Historical Prometryn Uses



# (Updated with 2011 GfK data )55 

## ● The California Department of Pesticide Regulation (CDPR) pesticide 

## use reporting (PUR) data from the California Pesticide Information Portal ( CalPIP ) [URL: http://www.cdpr.ca.gov/docs/pur/purmain.htm ]



## ● The latest available information for California pesticide use reports is for 2010, and over ten years (2000

– 2010 ) of PUR data were downloaded and summarized.



# Prometryn Uses in California

## The top 150 pesticides by pounds of active ingredients California 

## statewide in the most recent available PUR database 2009 & 2010

- 5 10 15 20 25 30 35 40 45 Millions Total Pesticide Use (lb)



## - Prometryn is 136 th 

## ranked pesticide
used in CA both in 2009 and 2010

- Only 0.03 % of total pesticide uses

in CA both in 2009 and 201057 

## Total Annual Use (lbs) of Prometryn Reported in CA PUR Database

(2000

– 2010 ) Updated with 2010 PUR data

0 50 100 150 200 250 300 350

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 Total Uses (Thousand lb per year)

Year 

## Total Annual Use58 

## Total Annual Use (lbs) of Prometryn per Crop Reported in CA PUR Database



## (2000

– 2010 ) Updated with 2010 PUR data

0 50 100 150 200 250 300 350

2000 2001 2002 2003 2004 2005 2006 2007 2008 2009 2010 

### OTHER CROPS


### PARSLEY
CELERY
COTTON Total Uses (Thousand lb per year)

YearAll Crop Uses 

# Prometryn Use Locations 

# Relative to the Listed Salmon ESU/DPS in CA

80% 20%

Total Prometryn Applications outside ESU/DPS

Total Prometryn Applications within ESU/DPS 

## Average Annual Use ( lbs / yr ) Reported in CA PUR Database

( 2000

– 2010 ) by Pesticide Use Reporting DistrictCotton Only



# Cotton Only 

# Prometryn Use Locations Relative to the Listed Salmon ESU/DPS in CA

100%

Total Prometryn Applications outside ESU/DPS Total Prometryn Applications within ESU/DPS 

## Average Annual Use ( lbs / yr ) Reported in CA PUR Database ( 2000

– 2010 ) by Pesticide Use Reporting District No Prometryn uses on Cotton between 2000 and 2010 in the CA ESU/DPS

## T op prometryn labelled crop 

## growing counties are Kern, Fresno, Kings, Merced, Tulare, Madera, Imperial, and Riverside counties in CA 

## accounting for > 90 % of total prometryn registered crop
acreage in CA, OR, ID, and WA. Total Acreage of All Crops Registered for Prometryn Use 

### (Average of Reported Acreages from 1997, 2002, and 2007 Agricultural Census)62 

## S patial analysis using crop 

## specific location information of cropland data layer (CDL) showed that t he proportion (%) of potential prometryn crop area 

## within the 28 ESU/DPS boundaries are extremely low, ranging from 0 to 4 % across the 28 ESU/DPS. 

# All Crop Locations Registered for Prometryn Use 

# ( 2007 to 2012 Cropland Data Layer: USDA

- NASS )63 

# Summary of Comprehensive Spatial Analysis

● Additional data presented that was not included in amended report in order to provide the most up

- to

- date information



## ● The additional data presented in the current amended report do not change the conclusions

● There is minimal potential for prometryn use within the ESU/DPSs in Oregon, Washington, and Idaho

● No prometryn use on cotton within any of the 28 ESU/DPSs

- No aerial use of prometryn within any of the 28 ESU/DPSs



## ● There is minimal use of prometryn on other specialty crops within 

## the 28 ESU/DPSs

● Overall, the results indicate that current and potential use of prometryn within or adjacent to the 28 ESU/DPS in the Pacific 

## Northwest and California is minimal64 

# APPENDIX B: Environmental Fate and Exposure

Monitoring data presented in the slides have been updated using additional data sources and up to 2012 data. Detailed information available under Sections 5

- 8 of the report “P rometryn : Review and Assessment of the Potential Impact of Prometryn on Endangered and Threatened Pacific Salmonid Species, Assessment Amendment 2” (Pages 32 to 51; Submitted March 8, 2013 )65 

# Objectives

● To present key environmental fate properties and inputs used in exposure modeling.

● To present monitoring data and to understand the behavior of prometryn through monitoring data (include additional data sources and 2012 

## data).

● To present estimated exposure concentrations from registered crop uses using static and flowing farm pond scenarios.66 

# Environmental Fate

Parameters Available Data and Source

Aerobic soil t1/2 (days) 270

MRID 00148338

Terrestrial field dissipation t1/2 (days) 70, 86, 71, 103

MRIDs 41546401

- 4, 42253901

- 4

Aerobic aquatic t1/2 (days) 110.4, 235.8, 38

MRID 48541603 and EU

FOOTPRINT

Koc ( mL /g) 57

– 3014 (>47 values)

MRID 41875901, Rao and Davidson (1982), Seol and Lee (2000), Baskaran and Kennedy (1999), Turin and Bowman (1997)
Mobility via column leaching Low (est. Koc =1228 mL /g)

MRID 41875904 

### ● Major dissipation pathways driven by aerobic soil degradation, aerobic aquatic degradation, sorption.

● No degradation via abiotic pathways 

### (e.g. aqueous and soil photolysis, volatilization, hydrolysis)

● Low mobility demonstrated in column leaching and terrestrial field 

### dissipation studies (no detection below 17.7 inches)

● Soil adsorption correlates to % OC and cation exchange capacity67 

# Physical and Environmental Fate Inputs in 

# PRZM/EXAMS Model

Parameter EPA Drinking Water 1 and CRLF 2 Assessments Best Available Value 3

Vapor Pressure at 25oC ( torr ) 1.0 x10

- 6 (DW) 1.0 x10

- 3 (CRLF) 1.24 x 10

- 6 (MRID 44339601)

Henry’s Law Constant (atm

- m3/mol) 9.1 x 10

- 9 7.40 x 10

- 9 (calculated from vapor pressure and solubility values)
Aerobic Aquatic Half Life (days) 1620 (6x single aerobic soil t1/2 value of 270) 237 (90 th percent confidence bound on the mean of 110.4, 235.8, 38 )

Sorption Coefficient

, Koc ( mL /g) 244 577 (average of 47 values ranging from 57 to 3014) ● Some of the environmental fate parameters EPA used in Drinking Water 1 and CRLF 2 assessments to model EECs are not consistent with best available data.

● Biotic degradation in aquatic systems via aerobic metabolism; low mobility

1 US EPA 2009. Prometryn (CAS Reg. No. 7287

- 19

- 16) Tier I Drinking Water Assessment for the Proposed New Uses on Carrots, Okra, Pa rsley, Cilantro, Celeriac, and Leafy Petioles. Memorandum from Silvia C. Termes to Barbara Madden. June 19, 2009. PC Code: 080805. DP Barcode: 357096, 357099.

2 US EPA 2009. Risk of Prometryn Use to Federally Threatened California Red

- legged Frog ( Rana aurora draytonii ). June 17, 2009.

3 Refer to previous slide for data source.68 

# Understanding Prometryn Behavior via Surface 

# Water Monitoring Data

● Data from high

- frequency sampling locations in or near prometryn use areas in the Pacific Northwest and CA suggest stream flow significantly reduces 

### prometryn exposure in aquatic systems.

● Predicted concentrations using non

- flowing water body assumption do not follow the monitoring trends.

Y

- axis is relative concentration (C/ Cmax ), x

- axis is years of observed and non site specific simulated concentrations0.0

0.2 0.4 0.6 0.8 1.0

0 1 2 3 4 5 6 7 8 Relative concentration (C/Cmax)

Year PRZM/EXAMS predicted normalized concentration using low flow (504 m3/hr) and static versions of EPA farm pond (fall carrots) compared with observation at San Joaquin River (Vernalis station)

San Joaquin River Observations

• Monitoring data shows brief periods (~2

- 3 weeks) of “detects” between longer period of “no or low detects”

• Aquatic degradation t1/2 = 38

- 236 days, indicating significant contribution of stream flow to rapid exposure reduction over 2

- 3 week period0.0

0.2 0.4 0.6 0.8 1.0

0 1 2 3 4 5 6 7 8 Relative concentration (C/Cmax)

Year PRZM/EXAMS predicted normalized concentration using low flow (504 m3/hr) and static versions of EPA farm pond (fall carrots) compared with observation at San Joaquin River (Vernalis station)

No flow farm pond San Joaquin River Observations

• Monitoring data shows brief periods (~2

- 3 weeks) of “detects” between longer period of “no or low detects”

• Aquatic degradation t1/2 = 38

- 236 days, indicating significant contribution of stream flow to rapid exposure reduction over 2

- 3 week period

• Static farm pond time series concentration fluctuates with detection throughout the years0.0

0.2 0.4 0.6 0.8 1.0

0 1 2 3 4 5 6 7 8 Relative concentration (C/Cmax)

Year PRZM/EXAMS predicted normalized concentration using low flow (504 m3/hr) and static versions of EPA farm pond (fall carrots) compared with observation at San Joaquin River (Vernalis station)

Flowing farm pond (504 m3/hr) No flow farm pond San Joaquin River Observations

• Monitoring data shows brief periods (~2

- 3 weeks) of “detects” between longer period of “no or low detects”

• Aquatic degradation t1/2 = 38

- 236 days, indicating significant contribution of stream flow to rapid exposure reduction over 2

- 3 week period

• Static farm pond time series concentration fluctuates with detection throughout the
years

• Flowing farm pond time series concentrations more closely resemble temporal patterns observed in monitoring data72 

# Sampling Frequency Information for Federal and State Surface Water Monitoring Data in WA, OR, CA and ID: 

# Updated with up to 2012 data

Source Number of

samples (sites) Sites with >

100 samples Sites with >

25 samples Frequency description

USGS NAWQA 1490 (79) 4 18 Few days apart, weekly, bi

- weekly, monthly

- frequency is dependent on the site location

USGS NWIS 2528(330) 6 19 Dependent on site location, ranges from daily, weekly, bi

- weekly, monthly, several months and yearly

EPA STORET 363 (145) 0 0 Irregular, ranges from 1 per site to once per
month for a few months

CDPR 2278(327) 3 11 Ranges from 2 days, weekly, monthly or irregular spaced sampling

CEDEN 1428(306) 0 0 Ranges from 1 to 3 times per year (several months apart)

CILRP 329(78) 0 0 Ranges from monthly or 1 to several times per

year

OR DEQ 795 (143) 0 1 limited sampling per site and irregular sampling intervals

WA EIM 3018(143) 15 18 21 sites have periods of weekly sampling, 16 of which have multiple years of weekly sampling

# Surface Water Monitoring Locations



# Updated with up to 2012 data

NAWQA

21 years
9637 samples

12.5% detection (1203/9637)

Max:3.73 μg/L(MS); 95 th percentile 0.19 μg/L WA EIM

19 years
3018 samples

No detects

CDPR

13 years
2278 samples

3.7% detection (84/2278)
Max. 3.13 μg/L; 95 th percentile 1.1 μg/L OR DEQ

6 years
795 samples

No detects NWIS

23 years
21918 samples

10.6% detection (2322/21918)
Max. 3.73 μg/L (MS); 95 th percentile 0.2 μg/L

EPA STORET
25 years
6626 samples

5.4% detection (358/6626)
Max. 1.82 μg/L (MS); 95 th percentile 0.257 μg/L CEDEN

10 years
1428 samples

1.4% detection (20/1428)

Max. 0.013 μg/L; 95 th percentile 0.013μg/L CILRP

5 years
329 samples

0.6% detection (2/329)
Max. 1.1 μg/L

# Surface Water Monitoring Locations in PNW and CA

Updated with up to 2012 data

NAWQA
21 years, 4 sites with > 100 samples

ESU/DPS boundaries: 74 sites, 1351 samples, max. 0.621 μg/L, 95 th percentile 0.126 μg/L WA EIM
19 years, 15 sites with > 100 samples

ESU/DPS boundaries : 94 sites, 2896 samples, no detects

CDPR
13 years, 3 sites with > 100 samples

ESU/DPS boundaries: 237sites, 1849 samples, max. 3.13 μg/L, 95 th percentile 0.51μg/L OR DEQ
6 years, 0 site with > 100 samples

ESU/DPS boundaries : 113 sites, 690 samples, no detects

NWIS
23 years, 6 sites with > 100 samples

ESU/DPS boundaries: 243 sites, 2209 samples, max. 1.4 μg/L, 95 th percentile 0.2 μg/L CEDEN
10 years, 0 sites with > 100 samples

ESU/DPS boundaries: 214 sites, 970 samples, max. 0.005 μg/L, 95 th percentile 0.005 μg/L
EPA STORET
25 years, 0 sites with > 100 samples

ESU/DPS boundaries: 134 sites, 297 samples, max. 0.236 μg/L, 95 th percentile 0.236 μg/L CILRP
5 years, 0 sites with > 100 samples

ESU/DPS boundaries: 35 sites, 143 samples,

No detects

# Surface Water Monitoring Locations in 

# California

Max detection location: Orestimba Creek at River Road

CA DPR: max 3.13 μg/L, 95 th percentile 1.1μg/L

NAWQA: max 0.621 μg/L, 95 th percentile 0.126 μg/L
NWIS: max1.4 μg/L, 95 th percentile 0.285 μg/L

EPA STORET: : max 0.236 μg/L, 95 th percentile 0.236 μg/L
CEDEN : max 0.013 μg/L, 95 th percentile 0.013 μg/L
CILRP: max 1.1 μg/L76 

# Summary

● This presentation contains the most up

- to

- date monitoring data and not all data are included in the amended report.

- No changes to the conclusions that are presented in the current amended report

.

● Predicted concentrations using non

- flowing water body assumption do not follow the monitoring trends

.



### ● Modeling exposure in the flowing water body using static farm pond is unrealistic and highly conservative. Hydrologic flow should be incorporated in modeling exposure concentrations in flowing water bodies.



### ● Conservative prediction of maximum peak EEC in flowing water body is within 5x of maximum concentration observed in water monitoring data from flowing water bodies within the ESU/DPS boundaries.77 

# APPENDIX C: F ormulations information

Detailed information available under Section 9 of the report “ P rometryn : Review and Assessment of the Potential Impact of Prometryn on Endangered and Threatened Pacific Salmonid Species, Assessment Amendment 2” (Pages 51 to 52; Submitted March 8, 2013 )78 

# Comparison of Prometryn Formulations

Component Caparol 4L A3593F 1 Suprend 2 A1114U 1 Prometryn X X X X Trifloxysulfuron X
Surfactant A X
Surfactant B X
Surfactant C X
Surfactant D X X
Surfactant E X
Surfactant F X Dispersing Agent 1 X Dispersing Agent 2 X Dispersing Agent 3 X
Antifreeze 1 X
Antifreeze 2 X
Antifreeze 3 X
Antifoam X X
Thickener X X
Biocide X X Encapsulating Agent X
Diluent 1 X X
Diluent 2 X Formulations used in ecotoxicity studies are similar to the 2 products registered and can be used as surrogate data to represent the general ecotoxicity of products formulated with prometryn.

X indicates component is present in formulation Green blocks represent same (or chemically & functionally equivalent) components present in more than 1 formulation

1 Ecotoxicity studies conducted on these formulations

2 Registered on cotton only