### UNITED STA TES ENVIRONMENTA L PROTECTION AGENCY WA SHINGTON D.C., 20460

OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES 

### PC Code No.: 085651 DP Barcode: D 370673 Date: March 1, 2010 

### MEMORANDUM SUBJECT: Estimated Drinking Water Concentrations of Parent Cyazofamid and its

Degradates of Concern CCIM, CCIM - AM and CTCA , for Use in Human Health Risk Assessment : New Use s on Brassica (Cole) Leafy Vegetables & Turnip Greens (Crop Group 5) , Spinach , and Hops TO: Laura Nollen, Risk Manager Reviewer

Barbara Madden, Review Manager #5 Daniel Rosenblatt , Chief Risk Integration, Minor Use and Emergency Response Branch Registration Division (7505P) AND: Nancy

Tsaur , Chemist Amelia Acierto , Chemist Paula Deschamp, Chief Registration Action Branch III Health Effects Division (7509P) FROM: José L . Meléndez, Chemist

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

Environmental Risk Branch V Environmental Fate and Effects Division (7507 P ) This memo randum presents the Estimated Drinking Water Concentrations (EDWCs) for cyazofamid , and for three of its major transformation products CCIM, CCIM - AM and CTCA , for use in the human he alth risk assessment ( for structures and nomenclature see Attachment A ) . The registrant seeks registration for the new uses of the chemical on b rassica (c ole) l eafy v egetables & turnip greens (Crop Group 5) , spinach, and hops . Based on a review of the us e information, it was found that the proposed new uses have much lower seasonal application rates (0.36 - 1.02 lb a.i./A), than those for turf and ornamentals (3.0 - 3.12 lb a.i./A, Table 1 - 1 ). EDWCs for the new uses should be smaller than those already

### 2 2 calcu lated for turf and ornamentals; therefore, a new drinking waters assessment (DWA) is not required. The values reported in the previous assessment can be used to cover the new crops. A copy of the last DWA is provided in Attachment A . As summarized in Ta ble 1 of Attachment A , the surface water acute EDWC is 38.2 ppb . The surface water non - cancer chronic value is 133.5 ppb and the cancer chronic EDWC is 77.3 ppb . The value for ground water is 2.18 ppb , which is suitable for both acute and chronic exposure s . The above stated values represent upper - bound estimates of the parent and individual degradates ’ concentrations that might be found in surface water and groundwater due to the use of cyazofamid on turf and ornamentals , as reported previously in DP Barc ode D319466 and D356839 ( Attachment A ). It is noted that this is still a screening - level analy sis . A more refined assessment could b e performed . Should any questions arise, please, contact EFED . Identification of specific data gaps : The environmental fate database consists of mostly supplemental studies. A degree of uncertainty exists in estimates of drinking waters concentrations ; however, new studies have been submitted to the Agency . These studies are currentl y in review. Use information : Cyazofamid is currently

used on crops like potatoes, cucurbits, turf, ornamentals, carrots , fruiting vegetables & okra, and grapes (East of the Rocky Mountains) . At this time, the registrant is petitioning registration for the uses on b rassica (c ole) l eaf y v eget ables & turnip greens (Crop Group 5) , spinach, and hops ( Table 1 - 1 ) . For Crop Group 5, spinach and hops, the maximum seasonal application rates are 1.02, 0.36 and 0.43 lb a.i./A, respectively , divided into 6 applications. In contrast, for turf and orname ntals, seasonal application rates are 3.0 and 3.12 lb/A, divided in 1 and 2 applications, respectivel y. The seasonal rates for the new crops are significantl y lower than for turf and ornamentals. T able 1 - 1 . Summary of use information for cyazofamid, base d on the proposed Ranman 400SC Fungicide label (EPA Reg. No. 71512 - 3). The proposed new crops are bolded and shaded gray.

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

APPS. SEASONAL

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

BETWEEN APPS. (days) APP. METHOD PHI (days) Brassica (Cole) Leafy Vegetables & Turnip Greens (Crop Group 5) [includes broccoli, Chinese broccoli (gai lon), broccoli raab (rapini), Brussels sprouts, cabbage, Chinese cabbage (bok choy), Chinese cabbage (napa), Chinese mustard (gai choy), cauliflo wer, cavalo broccoli, collards, kale, kohlrabi, mizuna, mustard greens, mustard spinach, rape greens, turnip greens] Transplant soil

drench (0.66), soil incorporation (0.52), foliar (0.071) 6

(1 soil + 5 foliar) 1.02 7 Transplant soil drench, soil incorpor ation, foliar, sprinkler irrigation 0

Spinach 0.054 - 0.071 5 0.36 7 G, sprinkler irrigation 0

### 3 3 T able 1 - 1 . Summary of use information for cyazofamid, base d on the proposed Ranman 400SC Fungicide label (EPA Reg. No. 71512 - 3). The proposed new crops are bolded and shaded gray.

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

APPS. SEASONAL

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

BETWEEN APPS. (days) APP. METHOD PHI (days) Hops 0.054 - 0.071 6 0.43 7 G 3 Fruiting Vegetables (Crop Group 8) and Okra [includes tomato, ground cherry, tomatillo, bell pepper, chili pepper, cooking pepper, pimento, sweet peppers, eggplant, pepino] 0.054 - 0.078 1 6 (@ 0.071) 0.43 7 To base of plant at transplanting or in transplant water, sprinkler irrigation2 0

Grapes (East of the Rocky Mountains) 0.054 - 0.071 6 0.43 10 G or A 30 Carrot 0.156 5 0.78 14 Pre - p lant incorporated or surface application (broadcast or band) or overhead irrigation system 14

Cucurbit Vegetables (Crop Group 9) [includes cantaloupe, chayote, Chinese waxgourd, citron melon, cucumbers, gherkin, gourds, honeydew melon, Momordica spp., mus kmelon, watermelon, pumpkin, squash,

zucchini] 0.054 - 0.071 6 0.43 7 In transplant water, sprinkler irrigation 0

Potato 0.036 - 0.071

(0.158 at planting; 0.071 lay - by

/ hilling) 10 0.71 7 At planting - over the seed pieces, Lay - by/ Hilling, Sprinkler Irrigation 7

Turf [such as golf courses (including greens, tees and fairways), sod farms, seed farms, college and professional sports fields, and commercial lawns] 0.5 - 1.0 3 3.0 14 - 21 G N/A

Ornamentals [including conifers, grown in containers in greenhouses, outdo or nurseries and

landscapes] 1.56 2 3.12 14 Soil drench or soil surface spray N/A

1 The use at 0.078 lb a.i. is for tomato greenhouse transplant production, for control of Pythium spp. 2 Includes center pivot, motorized lateral move, traveling gun, solid se t or portable (w heel move, side roll, end low , or hand mo ve) irrigation systems.

### 4 4 Attachment A. ELECTRONIC COPY OF DWA FOR CYA ZOFA MID UNITED STA

TES ENVIRONMENTAL PROTECTION AGENCY WA SHINGTON D.C., 20460

OFFICE OF PREVENTION, PESTICIDES AND TOXIC SU BSTANCES 

### PC Code No.: 085651 DP Barcode: D 356836 Date: March 24, 2009 

### MEMORANDUM SUBJECT: Estimated Drinking Water Concentrations of Parent Cyazofamid and its

Degradates CCIM, CCIM - AM and CTCA for Use in Human Health Risk Assessment (Use on Fruiting Vegetables, Crop Group 8 + Okra, and Grapes, East of the Rocky Mountains ). TO: Tony

Kish, PM Team Reviewer Janet Whitehurst, Risk Manager Reviewer Cy nthia Giles - Parker, Chief Fungicide Branch Registration Division (7505P) AND: Nancy

Tsaur, Chemist Paula Deschamp, Chief Registration Action Branch III Health Effects Division (7509P) FROM: José L . Meléndez, Chemist

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

Environmental Risk Branch V Environmental Fate and Effects Division (7507P) This memo randum presents the Estimated Drinking Water Concentrations (EDWCs) for cyazofamid (CAS No. 120116 - 88 - 3 ) , and fo r three of its major transformation products CCIM, CCIM - AM and CTCA, for use in the human health risk assessment (refer to appendix for the structures and nomenclature of these chemicals) . The registrant seeks registration for the new uses of the chemical on fruiting vegetables + okra, and grapes (East of the Rocky Mountains). Exposure to surface water is possible through surface water runoff, soil erosion and/ or off - target spray drift. The mobility of cyazofamid is moderate ( Kd 

### range 5.14 - 43.31 mL/g ; KOC 

### range 815 - 1 524 mL/g OC 

### , moderately to slightl y mobile ); however, cyazofamid is labile under many conditions ( e.g. , in metabolism studies and under aqueous photoly sis conditions). However, it

### 5

degrades to a number degradates, which appear to be persistent . F or cyazofamid and for its major transformation products CCIM, CCIM - AM and CTCA (as per HED’s request), calculated using tier 2 aquatic linked models PRZM/ EXAMS (surface water, applications to turf and ornamentals ) and the tier 1 aquatic model SCI - GROW (groundwater, applications to ornamentals ) , EDWCs were calculated. As summarized in Table 1, the surface water acute EDWC is 38.2 ppb . The surface water non - cancer chronic value is 133.5 ppb and the cancer chronic EDWC is 77.3 ppb . The value for ground water is 2.18 ppb , which is suitable for both acute and chronic exposures . The above stated values represent upper - bound estimates of the parent and individual degradates ’ concentrations that might be found in surface water and groundwater due to the use of cyazofamid on turf and ornamentals , as reported previously in DP Barcode 319466. It is noted that this is still a screening - level anal ys is . A more refined assessment could b e performed . Should any

questions arise, please, contact José L. Meléndez at melendez.jose@epa.gov . Identification of specific data gaps : The environmental fate database consists of mostly supplemental studies. A degree of uncertainty exists in estimates of drinking waters concentrat ions until new studies are submitted. EXECUTIVE SUMMARY Cyazofamid (CAS name: 4 - Chloro - 2 - cyano -N,N - dimethyl - 5 - (4 - methylphenyl) - 1H - imidazole - 1 - sulfonamide ; IUPAC name: 4 - chloro - 2cyano -N,N - dimethyl - 5 -

p - tol yl imidazole - 1 - sulfonamide ; CAS No. 120116 - 88 - 3 : PC code 085651) is a cyanoimidazole selective fungicide. The pesticide’s mode of action is to target the fungi cytochrome bc1 (ubiquinone reductase) at Q1 site. Cyazofamid is currently used on potatoes, cucurbits, turf, tomatoes and carrots and it is pro posed to be used on fruiting vegetables + okra, and grapes (East of the Rocky Mountains) through an IR - 4 tolerance petition. This memorandum is a drinking waters assessment (DWA) that presents the EDWCs for parent cyazofamid, and the degradates CCIM, CCIM - AM and CTCA for use in an FQPA human health risk assessment. Cyazofamid fungicide and/or its degradates may reach both surface and groundwater under some conditions. The degradates’ EDWCs were modeled individually (as opposed to the use of the total resi due approach). This was done because sufficient data were available on the degradates to model them individually (although some assumptions were made, see below). Itis noted that DWAs were previously issued as follows: Summary of Cyazofamid Drinking Wa ter Exposure Assessments Date DP Barcode Uses included 4/28/04 301099 Cucurbits, potatoes and tomatoes 9/6/06 319466 Turf and Ornamentals 3/5/08 342613 Carrots This assessment 356839 Fruiting vegetables + okra, and grapes (East of the Rocky mountains) 

### This DWA builds largel y upon the previous assessments. Additional runs were performed to cover the new crops; the highest EDWCs of all crops (past and present) were obtained for turf and ornamentals (surface waters) and ornamentals (ground water). The screening - level surface

### 6

water and ground water EDWCs were obtained using the tier 2 linked aquatic models PRZM/ EXAMS and the tier 1 aquatic model SCI - GROW , respectivel y. EDWCs are summarized in Table 1 for three scenarios as follows:  1 st 

### scenario: the p arent is applied at the maximum rate;  2 nd 

### scenario: the degradates CCIM and CCIM - AM (and CTCA) are applied at the parent molar equivalent amounts , spreading the application rate through the degradates, according to the molecular ratios and the adjusted max imum percentages of the degradates observed in the environmental fate studies ; and  3 rd 

### scenario: the terminal degradate, CTCA, is applied assuming application of 100% molar conversion of the parent to the degradate. Based on the results presented in Table 1 below and a time - line of exposure, the surface water acute EDWC is 38.2 ppb ( equal to the Parent “ 14.362 ppb” + CCIM “ 17.106 ppb” + CCIM - AM “ 6.699 ppb”). CTCA is not included in the surface water acute EDWC because it is not expected to be present in this time frame. The surface water non - cancer chronic is 133.5 ppb and the cancer chronic is 77.3 ppb (equal to the value for the terminal degradate , CTCA). For ground water, the EDWC is 2.18 ppb , which is suitable for acute and chronic exposures (equal to the value for the terminal degradate , CTCA). Table 1. M axima of surface and ground water EDWCs for cyazofamid and its relevant ma jor degradates. Turf and ornamentals use pattern, previously reported in D319466 (dated 9/6/06) . Scenario Chem ical Surface water EDWCs (ppb) Ground water EDWC (ppb) Acute Chronic “ N on Cancer” Chronic

“Cancer” 1 st Scenario Cyazofamid 14.362 0.377 0.279 0.01180 2 nd Scenario CCIM 17.106 12.094 10.600 0.00061

CCIM - AM 6.699 6.312 3.611 0.00270 3 rd Scenario CTCA 136.242 133.458 77.270 2.180

EDWCs 38.2 133.5 77.3 2.18 

### The above stated values represent upper - bound estimates of the parent, individual degradates and/or terminal degradate concentrations that might be found in surface water and gro undwater due to the use of cyazofamid on turf and ornamentals . EFED emphasizes that this is a screening level anal ys is, and should there be a need b y HED, additional refinements can be made. The EDWCs for cyazofamid were determined based on laboratory an d fate data from mostly supplemental studies. EFED suspects the possible poor extraction efficiency may have underestimated the half

- lives of cyazofamid , which could result in lower model values for EDWCs. In this respect, it is noted that major identifie d degradates (CCIM, CCIM - AM and CTCA) may

not constitute a significant part of the late accumulated un - characterized bound residue (due to the apparent adequate extraction of these degradates). A degree of uncertainty exists in such estimates until new studies with proven extraction procedures are submitted.

### 7

PROBLEM FORMULATION This is a drinking water assessment that uses modeling and monitoring data, if available, to estimate the ground water and surface water concentrations of pesticides in drinking water source water (pre - treatment) resulting from pesticide use on sites that are highl y vulnerable. Background This assessment addresses exposure to parent cyazofamid and its degradation products CCIM, CCIM - AM and CTCA. As indicated above, three DWAs have been conducted for cyazofamid. Final EDWCs were presented for the use on turf and ornamentals, which were covered in one of the previous assessments. In the DWA for turf and ornamentals, the highest acute EDWCs were observed for the use on turf for the parent and CCIM, and ornamentals for CCIM - AM. The highest chronic EDWCs were observed for the use on ornamentals. The application rate for ornamentals was 1.56 lb a.i./A (two applications), and for turf 1.02 lb a.i./A (three applications). It should be noted that there are no substantial changes in the DWA methodology since the last assessment . There are no new data in the fate database. Onl y the new crops were modeled. Cyazofamid is characterized by a high molecular weight (324.79 g/mole), has a relatively low solubility (0.107 ppm @ pH 7) and a low vapor pressure and Henry ’s Law Constant ( <1.0 x10 - 7 

### mmHg, and <4.0x10 - 7 

### atm * m 3 

### / mole , respectivel y). Therefore, cyazofamid is not expected to partition substantially

into the air from water or from dry or wet soil surfaces. Available data suggest that cyazofamid has the potential to be bio - concentrated b y aquatic organisms such as fish (KO/W 

### > 1000), but EFED does not have a valid bio - accumulation in fish study at this time. Available environmental fat e studies suggest that cyazofamid is not very mobile, and that it quickly degrades into various products, depending on the environmental conditions. Among the three major degradates for cyazofamid (CCIM, CCIM - AM and CTCA), the two terminal degradates are C CIM and CTCA. CCIM is the major one in bodies of water with low biological activity because it is the result of abiotic hydroly sis of the parent. CTCA is expected to be the major terminal degradate in biologicall y active soils and in water/sediment syste ms. Both CCIM and CTCA are stable to abiotic hydrol ys is and susceptible to leaching but only CCIM is susceptible to biodegradation. Cyazofamid could potentially reach surface water via spray drift or runoff under certain environmental conditions but the potential for it to reach ground water is low. CCIM and CTCA could potentially be the terminal degradates in surface water bodies affected b y spray

drift and/ or runoff depending on the level of biological activity . However, only CTCA has a high potential to contaminate groundwater due to its high persistence and mobility . Use Characterization Cyazofamid is currently

used on carrots, cucurbit vegetables, potatoes and tomatoes. In addition, it is used on turf and ornamental plants, including container gro wn plants and field grown (bed) plants.

### 8

Table 2. Summary of new use information for cyazofamid, based on the proposed Ranman 400SC Fungicide label (EPA Reg. No. 71512 - 3 ).

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

OF AP PS. SEASONAL

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

BETWEEN APP S . (days) APP.

METHOD PHI (days) Fruiting Vegetables (Crop Group 8) and Okra [includes tomato, ground cherry, tomatillo, bell pepper, chili pepper, cooking pepper, pimento, sweet peppers, eggplant a

nd pepino] 0.054 - 0.078 2 6 (@ 0.071) 0.426 7 Sprinkler Irrigation 1 0 Grapes (East of the Rocky Mountains) 0.054 - 0.071 6 3 0.426 3 10 G or A 30 1 Includes center pivot, motorized lateral move, traveling gun, solid set or portable (w heel move, side roll, end l ow , or hand move) irrigation systems. 2 The use at 0.078 lb a.i. is for greenhouse transplant production, for control of Pythium spp. 3 The registrant indicated that the maximum rate is 6x0.071 lb a.i./A or 0.426 lb a.i./A/season. 

### The label indicates that the product “may be applied with all ty

pes of spray equipment normally used for ground and aerial applications.” The label further specifies that a maximum of three applications in a series are allowed, and that they should be alternated with a fungicide of different mode of action, to manage/ prevent resistance. Aerial applications to grapes are allowed. The label does not have a requirement of an established buffer strip to prote ct bodies of water. For cucurbits vegetables, the label was amend ed. The new label now allows the use of cyazofamid for greenhouse transplant production at 0.078 lb a.i./A to control Pythium spp . However, for cucurbits, the most cons ervative scenario still is 6 applications at 0.071 lb a.i./A (same one previously

assessed) . In addition to the above mentioned label, EFED evaluated the label amendment for Cyazofamid 400SC Turf and Ornamental s Fungicide (EPA Reg. No. 71512 - 13) to include applications to residential lawns by professionals. The major change is the inclusion of re sidential uses for turf. There are no changes in the maximum application rates for turf or ornamentals; therefore, these changes were not assessed hereb y . Both products are flowable suspension concentrates (SC). Both products contain 34.5% active ingredient or 3.33 lb a.i./gallon. Based on the crops listed for cyazofamid, use is expected all throughout the USA. There is a single geographical label restriction on the use on grapes, that it may be used only

East of the Rocky Mountains (consequently , it m ay not be used on the high use area on grapes in the state of California). At this time, there is no readily available ty

pical use or usage information for cyazofamid.

### 9

Conceptual Model The conceptual model is a written description and visual represent ation of potential routes of offsite movement of the pesticide or degradates of concern into surface or ground water that may be a source of drinking water. The conceptual model describes the approach that will be used in the anal ys is phase and includes two components: the risk hy pothesis and the conceptual site model for surface and ground water. For cyazofamid, the following drinking water hy pothesis is being employed for this assessment: Cyazofamid use in accordance with the label, results in potentia l contamination of surface water resources; it does not result in contamination of ground waters because it is relatively labile. Degradates of concern of cyazofamid, CCIM, CCIM - AM and CTCA, result in substantial contamination of surface and ground water resources because they are formed in large quantities and /or persist

. 

### The conceptual site model is a generic graphic depiction of the risk hy pothesis. Through a preliminary

iterative process of examining available data, the conceptual model ( i.e. , the drinking water h ypothesis) is refined to reflect the likely exposure pathway s that are most relevant and applicable to this assessment (refer to the following figure).

Cyazofamid is applied to the field (on numerous crops). It appears that crop uptake i s unlikely or minimal because the KOC 

### for the chemical is moderate ly high (ranged from 657 - 2900). In addition, the chemical shows a relatively low solubility (0.107 ppm) and a high octanol/ water partition coefficient (KOW 

### = 1585) . Cyazofamid is not expe cted to move substantially on/in the soils horizontally because it is not very persistent. On the other hand, spray drift is an important factor in the contamination of nearb y surface waters when cyazofamid is applied to the field since it may be applied by aerial or ground methods. Since

### 10

the field may

be kept irrigated, large runoff events and events accompanied with erosion may be a factor in horizontal movement for cyazofamid’s degradates CCIM and CCIM - AM, resulting in acute exposure. Since cyazofamid is a labile compound, it may not be available for long periods of time in the field; on the other hand, the degradate CTCA appears to be more persistent. CTCA is expected to be present in surface waters on a chronic basis. Vertical movement to subsurfac es is expected to be an important component for CTCA, particularl y after repeated applications per ye ar and year to year. Volatilization is expected to be a minor route of dissipation for the active ingredient (Henry ’s Law Constant <4.0x10 - 7 

### atm* m 3 

### /mol) . ANALYSIS Fate and Transport Characterization : A summary

of phy sicochemical properties of cyazofamid is shown in Table 3. The chemical is a relativel y insoluble compound in acidic, neutral and alkaline conditions. The low vapor pressure and Henry ’s Law constant of cyazofamid suggest partitioning into the air from water and/or dry or wet soil surfaces will not be an important route of its dissipation in the environment. Cyazofamid has a KOW 

### >1,000 suggesting that it will potentially be bio - concentrated b y aquatic organisms such as fish. However, at this time, EFED does not have a valid bioaccumulation in fish study . Table 3. Nomenclature and physicoch emical properties of cyazofamid Parameter Value MRID 1 Chemical Classification c yanoimidazole Molecular Formula C 13 H 13 ClN 4 O 2 S 454090 - 38 Chemical Name (IUPAC) 4 - chloro - 2cyano -N,N - dimethyl - 5 -

p - tolylimidazole - 1 - sulfonamide Chemical Name (CAS) 4 - Chloro - 2 - cyano -N,N - dimethyl - 5 - (4 - methylphenyl) - 1H imidazole - 1 - sulfonamide Cyazofamid data sheet CAS Number 120116 - 88 - 3

454090 - 38 Pesticide Classification Fungicide Molecular Weight 324.79 Phy sical State Crystalline solid Water Solubility (ppm) 0.121 @ pH 5, 0.107 @ pH 7, 0.109 @ pH 9 Vapor pressure (25 o C) < 1.33 x10 - 5 Pa or <9.9810 - 8 mmHg or <1.32x10 - 10 atm. EPA Fact sheet Henry's La w Constant <4.0x10 - 7 atm. m 3 mo le - 1 Calculated Octanol/Water Partition, KOW 1,585 (log KOW 3.2 @ 25°C) 454090 - 38 1 Study reference is an MRID number. 

### Cyazofamid and degradates fate and transport properties are based on previously submitted studies and reports (EPA Risk Assessments dated 2004, 2006 and 2008). Although, EFED

### 11

requested additional studies, no new studies have been submitted. Cyazofamid’s environmental fate data are summarized in Table 4. Table 4. Summary of environmental fate data for cyazofamid Parameter Value1 

### MRID

Hydroly sis t 1⁄2 ~ 11.9 days @ 25 o C, pH 4

t 1⁄2 ~12.9 days @ 25 o C, pH 5 t 1⁄2 ~ 11.9 days @ 25 o C, pH 7 t 1⁄2 ~10.8 days @ 25 o C, pH 9 t 1⁄2 ~ 13.4, 12.4, 11.2, 9.3 hrs @ 50 o C , pH’s 4, 5 , 7, 9, respectively Major degradates (of the recovered) : CCIM (74 - 83%) and CCIM - AM (9 - 10% only at pH 9) 454090 - 39 465377 - 01 467027 - 01 Aqueous photolysis at pH 5 t 1⁄2 ~ 30 Minutes

Major degradates : CCTS (37.9% at 0.13 day), CCIM (39.6% at 0.25 and 2 days) , HTID (18.5% at 21 days), and CDTS (9.6% at 36 days). The degradate p - Toluamide (12.1% at 36 days) was identified only in the [benzene 14 C] cyazofamid. 454091 - 02 465377 - 03 467027 - 03 Photolysis on soil t 1⁄2 ~ 47 days

Major degradates : None. Minor degradate s: CCIM (6%), CCBA (2%), CTCA (1%), and CCIM - AM (<1%). 454091 - 03 465377 - 04 467027 - 04

Aerobic soil metabolism 2 t 1⁄2 = 6.1 - 6.4 days in a loamy sand soil from Ohio, Soil 1 (pH 6.5, %OC 0.66)

Major degradates: CCIM, CCIM - AM, and CTCA 454091 - 06 465377 - 05 t 1⁄2 = 3.7 - 4.0 days in a Sandy loam soil from England, Soil 2 (pH 7.6, %OC= 1.2) t 1⁄2 = 4.3 - 4.4 days in a Sandy loam soil from England, Soil 3 (pH 6.9, %OC= 3.0) t 1⁄2 = 4.9 - 6.0 days in a Sandy soil from Germany, Soil 5 (pH 5.9, %OC= 0.63) Major degradates: CCIM, C CIM - AM and CTCA 454091 - 08 465377 - 06 Aerobic aquatic metabolism 2 t 1⁄2 = 14.7 - 18.0 days (total system): River water/Sandy loam (~3:1)

t 1⁄2 = 9.5 - 10.9 days (total system): Creek water/Sandy loam (~3:1) Major degradates: CCIM (up to 47%), CTCA (up to 31%) , and CCIM - AM (up to 11%) 454091 - 10 465377 - 12 467027 - 07 Anaerobic aquatic metabolism 2 t 1⁄2 = 5.6 - 6.2 Days (total system): Milli - Q water/Sandy loam (~2:1)

Major degradates (of the applied) : CCIM (25%), CCIM - AM (17%); CTCA (22%) 454091 - 09 465377 - 11 467027 - 06 Adsorption/ Desorption (Kd and Koc in L Kg - 1 ) [Imidazole - 4 - 14 C]/[Benzene - U 14 C]:

Loamy sand (Ohio), Soil 1 : Kd = 9.99/ 6.96 and Koc = 1,524/1,062 Sandy loam (UK), Soil 2 : Kd = 43.31/87.00 and Koc = 1,444/2,900 Sandy loam (UK), Soi l 3 : Kd = 14.11/13.49 and Koc = 1,176/1,124 Sand (Germany), Soil 5 : Kd = 5.14/ 4.14 and Koc = 815/ 657 454091 - 12 465377 - 13 Mobility in Soils: Column Un - aged Leaching (4 soils) > 98% of the applied radioactivity remained on the top 10 cm with very limited leaching.

Observed rate and pattern of degradation we re similar to aerobic soil (Major degradates: CCIM, CCIM - AM). Leachate constituted <0.3% of the applied radioactivity. 454091 - 13 465377 - 16 Mobility in Soils: Aged Leaching (one soil) >95% of the radioactivity remained on the top 10cm with very limited leaching. Observed

rate and pattern of degradation we re similar to aerobic soil (Major degradates: CCIM, CCIM - AM, and minor degradate CTCA). Leachate constituted nearly 1% of the applied radioactivity and was dominated by the degradate CTCA only . In com parison with unaged soils, radioactivity profile indicated aging may have caused increased mobility 454091 - 11 465377 - 15 Accumulation in Fish Invalid study 454091 - 38 454091 - 39 465377 - 24 1 S oil 1 : Loamy Sand, Ohio (pH 6.5, %OC= 0.66); Soil 2 : Sandy loam, England (pH 7.6, %OC= 1.2); Soil 3 : Sandy loam, England (pH 6.9, %OC= 3.0); Soil 4: Loamy sand, England (pH 7.6, %OC= 1.1); Soil 5: Sandy soil, Germany (pH 5.9, %OC= 0.63). 2 Soil and aquatic systems range of h alf - lives are values for the two labels. It is noted that longer half - lives were observed for the aerobic/anaerobic aquatic systems in late intervals (a range of 19 to 30 days). 

### Available environmental fate studies suggest cyazofamid i s not very mobile and degrades

### 12

relativel y rapidl y into various products, according to the prevalent environmental conditions. Among the three major degradates for cyazofamid, relevant to this assessment (CCIM, CCIM AM and CTCA), the two terminal degradates are CCIM and CTCA. Of them, CCIM is a major hydrol ys ate. It is expected to be the major terminal degradate in bodies of water with low biological activity . In contrast, CTCA is expected to be the major terminal degradate in biologicall y active soils and water/sediment s ys tems. Both CCIM and CTCA are stable to abiotic hydrol ys is and susceptible to leaching but only CCIM is highl y susceptible to biodegradation. Given these fate characteristics, cyazofamid could potentially reach surface water via spray

drift, or runoff under certain environmental conditions, but the potential for it to reach ground water is low. CCIM and/or CTCA could potentially be the terminal degradates in surface water bodies affected b y spray drift and/or runoff depending on the level of biological activity . However, onl y CTCA has a high potential to contaminate groundwater due to its high persistence and mobility . Based on the referenced data, the main process involved in cyzofamid fate in aqueous systems is direct photoly sis follow ed by hydrol ys is. Its fate in the soil sy stem appears to be controlled by biotic degradation as well as its strong affinity for adsorption to the soil. Mobility of cyazofamid in natural environments is expected to be limited because of its strong affinity to adsorption. Available fate and transport data on cyazofamid major degradates CCIM, CCIM - AM and CTCA, are presented in Table 5. Table 5. Environmental fate data summary for the major and relevant degradates of cyazofamid. Parameter 1 Value (t 1⁄2 for [phenyl

- U14 C] - t1⁄2 for [imidazole- 4- 14 C] MRID () CCIM CCIM - AM CTCA Hydrolysis All three were relatively stable @ 50 o C for 5 days in pHs 4, 7, and 9. 454091 - 01 465377 - 02 467027 - 02

Aerobic soil metabolism 3 Soil 3 t 1⁄2 = 1.9 2 - 1.3 days t 1⁄2 = 6.3 - 6.6 days t 1⁄2 >120 days (relatively stable) in all three soils CCIM 454091 - 07 465377 - 07 465524 - 01 CCIM - AM 454091 - 04 465377 - 09 467027 - 05 CTCA 454091 - 05 465377 - 10 Soil 4 t 1⁄2 = 1.3 - 0.9 days t 1⁄2 = 10.0 - 6.6 days Soil 5 t 1⁄2 = 2.9 - 2.6 days t 1⁄2 = 20 .2 - 12.3 days Major degradates CCIM - AM, CTCA,

CCBA - AM. CTCA (max. 49.5 -

57.4% of the applied) None identified Adsorption/ Desorption ( Kd and Koc in L Kg - 1 ) Using: [Benzene U 14 C] Soil 1 Kd= 3.91 Koc = 594 Kd= 22.43

Koc = 3,398 Kd= 8.96

Koc = 1,357

454091 - 14 465377 - 14 Soil 2 Kd= 5.70

Koc = 475 Kd= 23.30

Koc = 1,941 Kd= 9.8 0

Koc = 816 Soil 3 K d= 23.57

Koc = 786 K d= 62.47

Koc = 2,082 K d= 17.16

Koc = 572 Soil 5 K d= 7.3

Koc = 1,158 K d= 13.64

Koc = 2,165 K d= 3.77

Koc = 599

### 13

Table 5. Environmental fate data summary for the major and relevant degradates of cyazofamid. Parameter 1 Value (t 1⁄2 for [phenyl

- U14 C] - t1⁄2 for [imidazole- 4- 14 C] MRID () CCIM CCIM - AM CTCA 1 Soil 1 : Loamy Sand, Oh io (pH 6.5, %OC= 0.66); Soil 2 : Sandy loam, England (pH 7.6, %OC= 1.2); Soil 3 : Sandy loam, England (pH 6.9, %OC= 3.0); Soil 4: Loamy sand, England (pH 7.6, %OC= 1.1); and Soil 5: Sandy soil, Germany (pH 5.9, %OC= 0.63). 2 New submittals changed this valu e from 1.4 days to 1.9 days; this slight change may not significantly impact the values used in modeling. 3 Range of half

- lives are values for the two labels. It is noted that longer half - lives were observed at later in the experiments (a range of 2 - 7 day s for CCIM and 14 - 28 days in the first two soils and >112 days for the third soil for CCIM - AM. 

### Data on h ydrol ys is suggest that the three degradates are stable to this abiotic process. Various conclusions are derived from the data on aerobic soil metabol ism and mobility . The first major degradate, CCIM , appears to be susceptible to leaching but is short - lived. CCIM - AM is similar to its parent in its low persistence/mobility . Finally , the degradate CTCA appears to be susceptible to leaching with high persistence. The major terminal - degradate in biologicall y active soil and aquatic environments is expected to be CTCA because of the apparent transformation of CCIM to CCIM - AM and finally into the persistent CTCA. Cyazofamid reaching surface water is expect ed to be highl y affected b y h ydrol ys is, which transforms it into CCIM, which is stable to abiotic hydrol ys is. Therefore, CCIM is expected to be the major terminal degradate in bodies of surface water with low biological activity . Details on fate and tran sport studies including the transformation profile are included in the three previously completed EFED chapters (EPA 2004, 2006 and 2008). A summary

of previously

submitted field studies is shown in Table 6. Table 6. Summary of the terrestrial field di ss ipation study on cyazofamid Location (MRID) Half - life 1 Soil Dissipation of Cyazofamid and its Degradation Products Grant County, WA 454091 - 16 (O) 465377 - 17 (R) 465524 - 02 (A) t 1⁄2 = 1.5 days Loamy sand pH: 6.5 OM: 0.60% Cyazofamid: was not detected belo w 0 - 15 cm.

Degradation Products: CCIM - AM and CTCA (detected through 540 days). CTCA was detected 8 times in the 15 - 30 cm soil layer throughout the 540 - day experiment. Wayne County, NY 454091 - 17 (O) 465377 - 20 (R) 465524 - 03 (A) t 1⁄2 =8.5 days Sandy loam pH: 6.1 OM: 3.33% Cyazofamid: was not detected below 0 - 15 cm.

Degradation Products: CCIM - AM (detected through 28 days), and CCBA (detected sporadically at 0.03 - 0.01 ppm); CCIM and CTCA detected at 0.01 - 0.02 ppm through the 540 - day study. Degradates were not generally detected below 0 - 15 cm with the exception of CTCA which was sporadically detected in the 15 - 30 cm layer. Montezuma, GA 456385 - 12 (O) 465377 - 23 (R) 467842 - 01 (A) t 1⁄2 = 2.0 days Loam pH: 6.2 OM: 0.55% Cyazofamid: was not detected below 15 cm.

Degr adation Products: CCIM, CCIM - AM and CTCA (detected through 540 days). Only CCIM

- AM was sporadically detected in the 15 - 30 cm layer.

### 14

Table 6. Summary of the terrestrial field di ss ipation study on cyazofamid Location (MRID) Half - life 1 Soil Dissipation of Cyazofamid and its Degradation Products Watsonville, CA 456385 - 13 (O) 465377 - 22 (R) 467842 - 02 (A) t 1⁄2 = 15 days loam pH: 6.5 OM: 2.38% Cyazofamid: was detected on ly once below 15 cm.

Degradation Products: CCIM - AM and C TCA were detected through 582 days with maximum concentrations reaching >10%, CCBA (detected through 582 days), and CTCA detected at the end of the study period. Degradates were not detected below 0 - 15 cm, except of CCIM - AM which was sporadically detected. Pikeville, NC 465871 - 01 t 1⁄2 days:

Grass: 7 Thatch: 29 - 32 Soil: 15 - 120 Sandy loam

pH: 5.7 OM: 2.2% Cyazofamid: was detected only once in the 7.5 - 15 cm soil layer.

Degradation Pr oducts: CCIM, CTCA, CCIM - AM, and CCBA were all detected in minor amounts (<10%) in the three layers while only CCIM - AM was detected at >10% of the total applied parent in the thatch layer only. Ashland, VA 465711 - 02 t 1⁄2 days:

Grass: 3 Thatch: 09 - 26 Soil: 10 - 25 Sandy loam

pH: 6.8 OM: 1.1% Cyazofamid: was detected only once in the 7.5 - 15 cm soil layer.

Degradation Products: CCIM, CTCA, CCIM - AM, and CCBA were all detected in minor amounts in grass and thatch layers while only CTCA was det ected in minor amounts in the soil layer. 1 t 1⁄2 = first order half

- life; DT 50 = Dissipation time of 50% of the compound. 

### The major uncertainties in the environmental fate database are related to the fact that the halflives were obtained from supplemental aerobic soil, and aerobic and anaerobic aquatic metabolism studies. It is suspected that poor extraction may have caused an underestimation of the half - lives of cyazofamid and degradates. On the other hand, the major identified degradates (CCIM, CCIM - AM and CTCA) may not be a significant portion of the late accumulated un characterized bound residues. The extraction of these degradates appeared to be adequate; however, a degree of uncertainty exists in the half

- life estimates until new studies are submitt ed with proven extraction procedures. No data were submitted by the registrant t o suggest that reasonable attempts were made to extract or anal yze significant soil or sediment bound radioactivity . Drinking Water Exposure Modeling In order to model the n ew crops, representative scenarios were chosen : CA tomato, FL peppers and PA tomato , to represent fruiting vegetables and okra; and NY grapes, to represent grapes - East of the Rocky Mountains . The maximum application rate allowed b y the label was utiliz ed.

 Model Selection : Models SCI

- GROW (Screening Concentration in Ground Water v.2.3 ) (S G23.exe, July 29, 2003 ) is a regression model used as a screening tool to estimate pesticide concentrations found in ground water used as drinking water. SCI - GROW was developed by fitting a linear model to groundwater concentrations with the Relative Index of Leaching Potential (RILP) as the independent variable. Groundwater concentrations were taken from 90- day average high concentrations from Prospective Ground W ater studies; the RILP is a function of aerobic soil metabolism and the soil- water partition coefficient. The output of

### 15

SCI - GROW represents the concentrations that might be expected in shallow unconfined aquifers under sandy soils, which is representative o f the ground water most vulnerable to pesticide contamination likely to serve as a drinking water source. (Ref. 8) . For agricultural uses, exposure concentrations for surface drinking waters assessments were estimated based on EFED’s Tier 2 aquatic model PRZM/ EXAMS. A graphical user interface (PE5 v. 5.0, November 15, 2006), developed by the EPA < http://www.epa.gov/oppefed1/models/water >, was used to facilitate inputting chemical and use specific parameters into the appropriate PRZM input files (inp) and EXAMS chemical files. The Pesticide Root Zone Model (PRZM v. 3.12.2, May 12, 2005) field or orchard crop scenario is the basic file which describes the local or regional climatological informatio n, soil hydrology, soil characteristics, crop characteristics, and the pesticide properties necessary to determine pesticide loadings to surface (or ground) water. This basic file constitutes the first part of the “exposure scenario.” It simulates the processes in the agricultural field, such as runoff and erosion, on a daily time step. The runoff and erosion flux output data from PRZM are used as chemical loadings to the Exposure Analysis Modeling System (EXAMS v. 2.98.04.06, April 25, 2005), which simu lates surface water, in order to predict the E DW C s. E DW C s were determined using a reservoir scenario which describes a vulnerable surface drinking waters scenario for the EXAMS compon ent of the modeling exercise .  Scenario Selection. As indicated earlier , representative scenarios were chosen. The crop scenarios , selected to represent fruiting vegetables and okra , were CA tomato es , FL peppers and PA tomato es (selected to represent different regions of the USA). The crop scenario chosen to represent grape s - East of the Rocky Mountains , is NY grape s (this is the single standard grape scenario available in the East of the USA ). The application dates were selected according to the met file, to represent ty pical use of a fungicide on the crops listed above.

 Approach to calculati on of EDWCs for cyazofamid and its degradates Cyazofamid is a relatively new fungicide and no surface water monitoring data are available. For this reason, the Agency based this report on simulated screening values using modeling. The screening level surface water and ground water estimates are calculated using tier 2 linked PRZM/EXAMS models and the tier 1 SCI - GROW model, respectivel y. It is noted that:

 EDWCs for cyazofamid and its degradates were generated from the models in which the K OC 

### and aerobic soil half

- life values used were obtained from supplemental studies;  Solubility of the degradates were considered to be the same as parent (0.107 ppm);  Direct photolysis half - life for the degradate CCIM was estimated from its formation and decline curve in the aqueous photolysis study conducted on the parent (a half - life of 31.52 days);  The degradates CCIM - AM and CTCA were considered to be stable to direct photolysis in water as they were not identified in the parent aqueous photolysis study, and therefore, half - lives could not be calculated; and  The initial residue levels for degradates used in the models were based on molecular ratios; assuming time zero 100% conversion of parent to a mixture of degradates based on weight

### 16

adjuste d maximums in fate studies. EFED believes that this assumption is reasonable and conservative. The calculated initial residue levels are presented in Table 7 . 

### Table 7. C alcula ted application rate s used in modeling of scenarios 1 (parent only), 2 (mix of degradates), and 3 (CTCA only, terminal degradate)

Chem ical Molecular

Weight * Molecular

Ratio Determined Maximum (% Parent Equivalent) Application Rate** (lb a.i./A) Value Adjusted Value Fate Study Used Fruit. Veg. Grapes Parent 324.79 1 100% 100% A ssumed 0.071 0.071 CCIM 217.66 0.6702 83% 63% Hydroly sis 0.0300 0.0300 CCIM - AM 235.67 0.7256 17% 13% Anaerobic Aquatic 0.00670 0.00670 CTCA 236.66 0.7287 31% 24% Aerobic Aquatic 0.0124 0.0124 Total 131% 100% CTCA 236.66 0.7287 100% 100% Assumed 0.0517 0.0517 * Molecular weights for degradates of cyazofamid were calculated by deduction/ addition of elements, when compared to the parent structure. ** Rate for each degradate = Parent Rate x Molecular Ratio x adjusted maximum found in fate studies; for ex am ple the rate for CCIM application on fruiting vegetables = 0.071 x 0.6702 x 63% = 0.0300 lb a.i/A . 

### Based on the procedure outlined above, the application rates (in kg a.i./A, the units used in PRZM/ EXAMS) used for the different runs are included, alon g with other modeling parameters, in Table 8. Table 8. Modeling parameters for cyazofamid and degradates

Scenario Modeled

Chem ical Max. Single Rate (kg a.i./ha)* Other parameters

Fruit. Veg. Grapes Fruiting Vegetables Number of applications: 6 Min imum interval : 7 - day** Scenario (application date) : CA (11 - 03) and PA tomato (26 - 04); FL pepper (11 - 09) Application Efficiency : 0.99 Drift: 0.01 Intervals: 7, 7, 21, 7, 7 days Grapes Num ber of applications: 6 Minimum interval : 10 - day ** Scenario (applicati on date) : NY grape (05 - 05) Application Efficiency : 0.95 Drift: 0.05 Intervals: 10, 10, 30, 10, 10 days First Parent 0.0796 0.0796 Second CCIM 0.0336 0.0336

CCIM - AM 0.0075 0.0075 CTCA 0.0139 0.0139 Third CTCA 0.0579 0.0579 * By multiplyin g label rates in lb/A by the conversion factor 1.1208; for example for fruiting vegetables, parent: Application Rate = 0.071 x 1.1208 = 0.0796 kg/ha 

### . **T he label instructs not to make more than two or three consecutive applications of the product; instead , follow with at least two or three applications of a fungicide with a different mode of action. Intervals are as indicated. 

### Fate and transport input parameters are summarized in Table 9 .

### 17

Table 9. PRZM/EXAMS input parameter s for modeling surface water ’s EDWCs of cyazofamid Input Parameter Chem ical Value 1 Reference

Molecular Weight (gram mo le - 1 ) Parent 324.79

MRID 454090 - 38 CCIM 217.66 CCIM - AM 235.67 CTCA 236.66 Vapor Pressure ( mmHg ) All 1.0x10 - 7 EPA Factsheet H enry’s Law Constant (atm- m 3 mole - 1 ) All 4.0x10 - 7 Calculated Aerobic Soil Metabolism Half

- life (days) Parent 5.5 The 90 th percentile t 1⁄2 from eight values for the parent and six values for each degradate (MRID s 454091 06/08/07/04/05). CCIM 2.2 2 CCIM - AM 13.58 CTCA Stable Water column Half

- life (days) (Aerobic Aquatic Metabolism half

- life) Parent 16.4 The 90 th percentile t 1⁄2 from four values for the parent (MRID 454091 - 10). For the degradates , twice the aerobic soil metabolism input since the degradates are stable to hydrolysis, as per guidance (US EPA, 2002) CCIM 4.44 CCIM - AM 27.16 CTCA Stable Benthic sediment Half

life (days) (Anaerobic Aquatic Metabolism half

- life) Parent 17.7 One half - life value; 3x5.9=17.7 (MRID 454091 - 09) Degradate s Stable No anaerobic aquatic metabolism data Application Rate (Kg a.i./ha) All; Refer to Table 8 Application Number (Method of application) All; Refer to Table 8 Product Label Application Interval All; Refer to Table 8 Product Label IPSCND (dispo sition of pesticide remaining on foliage after harvest) All 1 Pesticide remaining on foliage is converted to surface application to the top soil layer UPTKF = PLVKRT = PLDKRT All 0 A s per Guidance for Selecting Input Parameters . 1 FEXTRC All 0.5 A s per Guidance for Selecting Input Parameters . 1 Depth of Incorporation (cm) Parent 0.0 CAM=2/ linear foliar based on crop canopy (label) ; parent is applied by ground or aerial methods Degradates 5.08 CAM=4/soil application (Product Label); degradate is expected to form, from parent in the top soil Spray Drift (fraction) Parent and Degradates 0.064 for fruiting vegetables and 0.16 for grapes ; degradates are expected to

form in the surface water

### 18

Table 9. PRZM/EXAMS input parameter s for modeling surface water ’s EDWCs of cyazofamid Input Parameter Chem ical Value 1 Reference Application Efficiency (fraction) Parent and Degradates 0.99 for fruiting vegetables and 0.95 for grapes Solubility (ppm) Parent and Degradates 1.07 10X the solubility as per guidance MRID 454090 - 38

KOC (L Kg - 1 ) Parent 1,338 Parent: Average of eight values (MRID 454091 - 12). Degradates: Average of four values for each o f degradates (MRID 454091 - 14). KOC mo del was determined to be appropriate. CCIM 753 CCIM - AM 2,397 CTCA 836 Hydroly sis Half

- life @ pH 7 (days) Parent 11.9 Maximum value at pH 7 (MRID 454090 - 39) Degradates Stable MRID 454091 - 01 Aqueous Photol ysis Half - life (day s) Parent 0.02 Maximum dark control corrected value (MRID 454091 - 02) CCIM 31.5 Other d egradates Stable No data 1 Parameters are selected as per Guidance for Selecting Input Parameters in Modeling the Environmental Fate and Transport of Pesticides; Version II, February 28, 2002. 

### Results of PRZM/EXAMS modeling are summarized in Table 10, noting that an 87% was used for Percent Crop Area (PCA). The value of 87% is the national default for all other crops.

Table 10. PRZM/EXAMS resu lts of this assessment (EDWCs in ppb) Crop/Scenario PCA (%) Chemical Peak Yearly All Years

CA Tomato 1 st 87% Parent 0.568 0.0184 0.0137

2 nd 87% CCIM 0.183 0.0171 0.0144

87% CCIM - AM 0.0689 0.0172 0.0148 3 rd 87% CTCA 1.90 1.35 1.16 FL pepper 1 st 8 7% Parent 3.50 0.0662 0.0407

2 nd 87% CCIM 0.541 0.0180 0.0122

87% CCIM - AM 0.191 0.0227 0.0166 3 rd 87% CTCA 7.93 1.37 0.992

PA tomato 1 st 87% Parent 1.04 0.0501 0.0245

2 nd 87% CCIM 0.189 0.0164 0.0130

87% CCIM - AM 0.117 0.0318 0.0211 3 rd 87% CTCA 3.80 1.95 1.49 NY grape 1 st 87% Parent 1.32 0.0552 0.0442

2 nd 87% CCIM 0.326 0.0385 0.0325

87% CCIM - AM 0.177 0.0703 0.0585 3 rd 87% CTCA 4.81 3.41 2.67 Maxima * P arent + CCIM + CCIM - AM 4.23 * ** CTCA only 3.41 ** 2.67 **

### 19

For ground water, SCI - GROW program , a high exposure tier one model, was used to arriv e at the Estimated Drinking Water Concentration (EDWC) for this chemical and its degradates from ground water sources. Modeling input and output values are summarized in Tables 11 and 12 , noting that the rates are the ones for the highest exposure (ornamentals). In addition, scenarios 1 and 2 are for information only , since the parent and the degradates CCIM and CCIM - AM are not likely to be observed in ground waters. Table 11. I nput data for SCI - GROW modeling for EDWCs fromground water for cyazofamid/ degradates Parameter Va lue* Reference (MRID Number) Crop/ Seasonal No. of Applications Soil Applied to Ornamentals/2 High Exposure (maximum rate/number); Product label Label Application Rate (lb a.i./acre) 1 st Scenario: Parent 1.56 Product label (lb a.i/A)

2 nd Scenario: CCIM 0.659 Calculated from molar ratios (refer to Table 8, above for a sample calculation (lb a.i/A) CCIM - AM 0.147 3 rd Scenario: CTCA 1.137 Aerobic Soil Metabol ism t1⁄2 (days) Cyazofamid 4.7 Median of 8 values (454091 - 06/08) CCIM 1.4 Median of 6 values (454091 - 07) CCIM - AM 8.3 Median of 6 values (454091 - 04) CTCA 10,000 Considered stable; half - life is >120 days (454091 - 05)

Koc (L Kg - 1 ) Cyazofamid 657 Lo west va lue (454091 - 12); variations >3 fold CCIM 690 Median of 4 values for each degradate (454091 - 14) CCIM - AM 2,124 CTCA 708 * Fate data values are chosen as per Guidance for Selecting Input Parameters in Modeling the Environmental Fate and Transport o f Pesticides; Version II February 28, 2002. Table 12. Summary of outputs fromSCI - GROW modeling for EDWCs fromground water for cyazofamid.

Parameter Value/ ppb Source Screening EDWC for ground water 1 st Scenario: Parent 0.0118 Output from SCI - GROW model runs

2 nd Scenario: CCIM 0.000607 CCIM - AM 0.00275 3 rd Scenario: CTCA 2.18 

### It is important to note that modeling for EDWCs from surface and ground water is performed using maximum application rate and frequency , and minimum intervals, which allows establishing first level values suitable for screening purposes. They may be referred to as likely upper bound values due to the use of the chemical at the maximum application rate and additional refinement s can be developed should they be needed.

### 20

Monitoring Data Monitoring d

ata provide different kinds of information than modeling estimates. For example, monitoring data consist of actual information from the field, reflecting current use pattern and usua lly underestimating frequency of occurrence. Monitoring data does not always include peak values, and inputs for monitoring cannot be adjusted as modeled ones can . In addition, monitoring is often conducted for purposes other than characterizing exposure from a particular pesticide, and as a consequence is used to complement modeling rather than to refine it. In general, a useful interpretation o f monitoring values requires in - depth assessment of the data, which is beyond the scope of a Tier I assessment. Cyazofamid is a relatively new fungicide and no surface water monitoring data is available. Drinking Water Treatment There are no data available related to drinking water treatment of cyazofamid and its degradates. EXPOSURE CHARACTERIZATION A drinking waters assessment was performed for cyazofamid and EDWCs were obtained for the parent and degradates CCIM, CCIM - AM and CTCA. These degradates were modeled as per request of HED. They

were present at high concentrations, were persistent and/ or were j udged to have a high degree of toxicity . Preliminarily , HED needs are point estimates (as opposed to distributions). Four standard crop scenarios were utilized to represent fruiting vegetables 1 

### and grapes (East of the Rocky

Mountains). Fruiting vegetabl es were represented by CA tomato, FL pepper and PA tomato. These scenarios are located in a variety of sites in the nation and could be considered representative of the proposed use areas. Furthermore, based on the crops represented 1 

### , the tomato and pepp er crops are appropriate crop scenarios. Grapes were represented by the standard scenario NY grape. This is the only grape scenario available in the East of the nation. Additional scenarios not considered in this assessment include: FL tomato (not used because another FL scenario was utilized); CA grape and CA wine grape RLF (these scenarios are not located in the intended use sites, also the CA wine grape scenario was developed for red legged frog endangered species assessments); and PA vegetable NMC an d S TX vegetable NMC (these are regional scenarios). For fruiting vegetables and grapes, the labeled range of application rates is 0.054 to 0.071 lb a.i./A per application. In addition, fruiting vegetables for greenhouse transplant production may receive applications at 0.078 lb a.i./A when used against Pythium spp. The maximum application rate of 0.071 lb a.i./A (for outdoor applications) was used in all instances. For resistance management, not more than 6 spray s of the product are allowed for both fr uiting vegetables and grapes. Also, not more than 3 consecutive applications of cyazofamid are 1 They include o kra , t omato, ground cherry , tomatillo, bell pepper, chili pepper, cooking pepper, pimento, sweet peppers, eggplant and pepino plus okra.

### 21

allowed, and at least 3 applications of other fungicides with different mode of action should be alternated. The interval between applications is 7 - 10 day s for fruiting vegetables, and 10 - 14 day s for grapes. The minimum interval between applications was used in all instances. It is unknown if the maximum application rate with the minimum interval between applications would be ty

pically used. The label instruc ts to use the lowest rate with the longest intervals for preventative applications or for very low disease pressure. There are no usage data readil y available that would indicate the percent crop area treated (PCA) for the new crops. The national default of 87% (used for all “other crops”) was assumed for all runs, all of which adds conservativeness to the assessment. A regional restriction for grapes is the use on the East of the Rocky Mountains. EDWCs for cyazofamid and degradates were calculated for drinking water based on half - lives obtained from supplemental aerobic soil and aerobic/anaerobic water/sediment metabolism studies. In these studies, suspected poor extraction may have underestimated the half - lives of cyazofamid and degradates possibly re sulting in lower model values for the EDWCs. In this respect, it is noted that major identified degradates (CCIM, CCIM - AM and CTCA) may not constitute a significant part of the late accumulated un - characterized bound residue (due to the apparent adequate extraction of these degradates); however, a degree of uncertainty exists in such estimates until new studies with proven extraction procedures are submitted. No data were submitted by

the registrant t o suggest that reasonable attempts were made to extract or anal yz e significant soil or sediment bound radioactivity . Complete characterization of the fate of cyazofamid requires data to prove that no parent or degradates were left as part of the bound residue and to characterize various other components that may be present. As a result, EFED is requiring additional fate information/data be submitted to assess the impact of these residues on the environment. For SCI - GROW, a complete input dataset was available from submitted studies, but the aerobic soil metabo lism half

- lives were from supplemental studies. For CTCA, an aerobic soil metabolism half

- life of 10,000 day s (>27 years) was assumed, since no degradation occurred in the available study (MRID 45409105; three soils, two radiolabels). In this assessment the total residue method (or approach) was not used. Each metabolite of concern was modeled separatel y. The structures of all three relevant degradates are the result of the loss of the sulfonamide moiety . The fate behavior and other characteristics of the degradates may not resemble the one s for the parent. There is uncertainty in the input parameters for the degradates since no aquatic metabolism (aerobic or anaerobic), solubility , vapor pressure and Henry ’s Law Constant were available. Certain assumptions were made. For the parent and for all the degradates (CCIM, CCIM - AM and CTCA), in PRZM/ EXAMS, the vapor pressure, Henry ’s Law Constant and solubility were assumed to be the same. There were 8 half

- lives for aerobic soil metabolism of the parent, and 6 for each of the degradates. The upperbound value (90 th 

### percentile) was used in each case as input for PRZM, as indicated b y the input parameter guidance. The fact that there were multiple aerobic soil halflives reduces the uncertainty in this input parameter considerabl y. Nevertheless, with respect to the aerobic aquatic metabolism input for EXAMS, there were no studies for the degradates, and 2x the aerobic soil metabolism input was used, as per guidance. It was noted that for the parent,

### 22

based on laboratory

data, the aerobic aquatic metabolism input value (16.4 day s) is roughly 3x the aerobic soil metabolism input value (5.5 days). Inthe case of the anaerobic aquatic metabolism input, there was only one half - life for the parent, and it was mul tiplied by a 3x factor to get the input used in the model. The 3x factor is used to account for the uncertainty surrounding the fact that only one half - life was available. For the degradates there was no data, and they were assumed stable to anaerobic aq uatic metabolism. The impact of this assumption is to overestimate the EDWCs if the chemicals are not in fact persistent in anaerobic media. The depth of incorporation selected for the parent, cyazofamid, was 0.0 cm (appropriate for spray or foliar aeria l or ground applications). For the degradates, it was assumed to be 5.08 cm (2 inches) to mimic the formation of the degradates on the top soil layer. For the degradates, a spray drift value of 6.4% or 16% was utilized (for ground or aerial applications, respectivel y). The drift was modeled this way because the degradates may be formed in surface waters. For both the parent and all the degradates, the KOC 

### model was determined to be appropriate (as opposed to the Kd 

### model). Individual mobility data were available for all the degradates. The aqueous photoly sis half

- life for the parent cyazofamid is very short (0.02 day s or around 30 min). Aqueous photoly sis is expected to occur more often in clear shallow waters, where the sunlight is able to penetrate; the process is expected to result in the formation of various degradates. Based on its decline in the parent aqueous photoly sis study , a half - life of 31.5 day s was derived for CCIM and utilized in modeling. For the aqueous photol ys is, the input paramete r guidance does not stipulate the use of a factor ( e.g. 3x) in any case; there may

be uncertainty regarding the use of such a short half - life. Environmental fate data reported in the TOXNET (HSDB) database is generally consistent with the data available directly to the Agency ; no other sources of fate data were identified ( e.g. an EU DAR or a PMRA regulatory note). Of the three fruiting vegetables crop scenarios tested, CA tomato, FL pepper and PA tomato, the FL pepper scenario yi elded the highest peak ED WC (refer to Table 10), while the PA tomato yi elded the highest chronic EDWCs (though lower than for NY grapes). F or the uses on turf and ornamentals , the surface water acute EDWC is 38.2 ppb . The surface water non - cancer chronic value is 133.5 ppb and the cancer chronic EDWC is 77.3 ppb (Table 1) . By comparison, the EDWCs for the uses on fruiting vegetables and grapes were as follows: peak 4.23 ppb; non cancer chronic 3.41 ppb; and cancer chronic 2.67 ppb. These EDWCs correspond to 11.1%, 2.55% and 3.4 5% of the corresponding values for the uses on turf and ornamentals, respectivel y. In this memorandum, the acute EDWCs were obtained from the sum of values of three runs: for the parent, for CCIM, and for CCIM - AM. This means that resultant EDWCs may have been overestimated and are expected to be conservative because of nearl y double counting the application rate (full rate for the parent + estimated rates for CCIM and CCIM - AM). On the other hand, chronic values were obtained from EDWCs for the terminal degradate, CTCA, which was considered persistent to all fate processes, which is unlikely (CTCA would be dissipated only by binding and dilution). In addition, 100% conversion of the parent to the degradate was assumed (also unlikel y). Therefore, the result ant chronic EDWCs are also expected to be highl y conservative.

### 23

Degradates CCTS, HTID, CDTS and p - Toluamide were found as major degradates onl y in aqueous photoly sis studies. Significant amounts of CCIM and CCTS form earl y in the study (peak within a day) , and show decline afterwards. Meanwhile HTID, CDTS and p - Toluamide form/peak late in the studies (within day s), and show only slight or no decline under the conditions of the aqueous photolysis study . Because of their late formation, possibly persistent degradates HTID, CDTS and p - Toluamide are therefore not expected to be important components in natural aquatic sy stems. Previously , the Metabolism Assessment Review Committee ( MARC ) determined that these degradates will not be more toxic than the parent. In addition, based on the use pattern, and the nature of parent, aqueous photoly sis may not be a major route of degradation in most natural environments. Although the MARC recommended to exclude these degradates from drinking wate r assessment, EFED is requesting hydrol ys is/aerobic soil metabolism studies on the degradate CCTS to confirm that degradates HTID, CDTS and p - Toluamide were only photol ytic degradates resulting from long exposure to light energy

in aqueous sy stems. This a ssessment is considered national in scope for fruiting vegetables, but regional for grapes. No regional PCAs were used. Due to the lack of data, the potential impact of drinking water treatment on cyazofamid and its degradates concentrations constitute an uncertainty . CONCLUSIONS The results of this DWA show that the uses that bring the highest exposure to surface and ground drinking waters are turf and ornamentals (reported in a previous review). The new uses on fruiting vegetables and grapes result ed in lower EDWCs. The results reported represent a timeline in which the parent and the degradates CCIM and CCIM - AM are present initially . These chemicals contribute to the surface water peak EDWC. Since the formation of the parent and two degradates are assumed and modeled (full application rate for the parent, plus estimated application rates for the degradates), the peak EDWC is likely an overestimation. For chronic exposure, the most conservative scenario is 100% conversion of the parent to the ter minal degradate CTCA. This scenario of 100% conversion was not observed in the aerobic soil metabolism studies and is also likely an overestimation of the chronic EDWCs. It is noted that the chronic EDWCs are up to three and a half times larger than the peak EDWC. The ground water EDWC was <6% of the peak and chronic surface water EDWCs, which indicates a lower contribution of the chemicals in ground waters. Once again, since 100% conversion was assumed to derive ground water values, the EDWCs are possi bly overestimated. There were limitations in the environmental fate dataset for the degradates, which were assumed to behave similar to the parent ( e.g. lack of vapor pressure, solubility and Henry ’s Law Constant); however, all three degradates are the re sult of the loss of the sulfonamide moiety . It is possible that they

have substantially

different ph ysicochemical properties. An important weakness of this assessment is that it relies mostly on supplemental studies, bringing uncertainty to the EDWCs. A strength of this assessment is the availability of several aerobic soil

### 24

metabolism half

- lives for the parent and degradates ( ≥6). The aerobic soil metabolism data was also used to derive the aerobic aquatic metabolism input values for the degradates (the aerobic aquatic metabolism input value is 2x the aerobic soil metabolism input value, as per guidance). This screening - level assessment is considered conservative. A more definitive assessment may be made, using the same tier 2 surface waters aquatic mo del (PRZM/ EXAMS). The application rates may be refined and possibly

regional PCAs may

be used. REF E RENCES 1. U.S. Environmental Protection Agency (2006). Guidance for Developing a Tier I Drinking Water Exposure Assessment. F: \ USER\ SHARE \

Policies,Effe cts Assessments \d.Water Assessments \ Surface Water\ Drinking Water 2. U.S. Environmental Protection Agency . Guidance on Characterization of Drinking Water Exposure for Dietary

Risk Assessment. Draft EFED Policy . 3. U.S. Environmental Protection Agency ( 1 99 9) Estimating the Drinking Water Component of a Dietary Exposure Assessment . http://www.epa.gov/oppfead1/trac/science/#drinking 4. U.S. Environmental Protection Agency ( 2000 a). Devel opment and Use of Distributions of Pesticide Concentrations in Drinking W ater for FQPA Exposure Assessments. FIFRA SAP Meeting

– February

29

– March 3, 2000. http://www.epa.gov/oscpmo nt/sap/meetings/2000/index.htm . 5. June 2000: Monitoring Strategies for Pesticides in Surface - Derived Drinking W ater. FIFRA SAP Meeting

– http://www.epa.gov/scipol y/ sap/2000/june/f inwateronl y.pdf 6. U.S. Environmental Protection Agency (2000b). Progress Report on Estimating Pesticide Concentrations in Drinking Water and Assessing Water Treatment Effects on Pesticide Removal and Transformation. http://www.epa.gov/oscpmont/sap/meetings/2000/index.htm 7. U . S . E nvironmental P rotection A gency ( 2000c ) Drinking Water Screening Level Assessment. Part A: Guidance for Use of the Index Reservoir in Drinking Water Exposure Assessments. Part B: Appl yi ng a Percent Crop Area Adjustment to Tier 2 Surface Water Model Estimates for Pesticide Drinking Water Exposure Assessments. FIFRA SAP Meeting

– September 1, 2000. http://www.epa.gov/oppfead1/trac/science/reservoi.pdf . 8. SCI GROW: Users Manual (11/01/2001, revised 08/23/2002) 9. Guidance for Selecting Input Parameters in Modeling the Environmental Fate and Transport of Pesticides, Version II (02/28/2002) 10. Food and Agriculture Organization of the United Nations. FAO PESTICIDE DI SPOSAL SERIES 8 . Assessing Soil Contamination: A Reference Manual. Appendix 2. Parameters of

### 25

pesticides that influence processes in the soil. Editorial Group , FAO Informatio n Division : Rome, 2000. http://www.fao.org/DOCREP/003/X2570E/X2570E00.htm

### 26

Appendix A. Structures of Cyazofamid and Relevant Degradation Products Cyazofamid [IKF - 916] IUPAC Name: 4 - Chloro - 2 - cyano -N,N - dimethyl - 5 - p - tol yl imidazole - 1 - sulfonamide. CAS Name: 4 - Chloro - 2 - cyano -N,N - dimethyl - 5 - (4 - methylphenyl) - 1H - imidizole 1 - sulfonamide. CAS Number: 120116 - 88 - 3. SMILES String: Cc1ccc(cc1)c1c(nc(n1S(=O)(=O)N(C)C)C#N)Cl

(I SI S v2.3/Universal SMILES). No EPISuite, v3.12 SMILES String found as of 6/28/06. C H 3



### N N Cl

C N S O O N C H 3 

### C H 3

### 27

CCIM IUPAC Name: 4 - Chloro - 5 - p - tol yl imidazole - 2 - carbonitrile. CAS Name: Not reported. CAS Number: Not reported.

N N H Cl C H 3



### C N 

### CCIM - AM IUPAC Name: 4 - Chloro - 5 - p - tol yl imidazole - 2 - carboxamide. CAS Name: Not reported. CAS Number: Not reported.

N N H Cl C H 3



### C O N H 2

### 28

CTCA IUPAC Name: 4 - Chloro - 5 - p - tol yl imidazole - 2 - carbox yl ic acid. CAS Na me: Not reported. CAS Number: Not reported.

N N H Cl C H 3



### C O O H

### 29

Appendix B. Sample Model Outputs PRZM/EXAMS For the parent cyazofamid, on CA tomato: stored as Cyazofam.out Chemical: Cyazofamid PRZM environment: CAtomato_WirrigSTD.txt modified Tueda y, 29 May 2007 at 11:43:54 EXAMS environment: ir298.exv modified Thuday, 29 August 2002 at 14:34:12 Metfile: w93193.dvf modified Wedday, 3 July 2002 at 08:04:24 Water segment concentrations (ppb) Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1961 0.2597 0.1 595 0.1089 0.07954 0.05394 0.01333 1962 0.2548 0.1638 0.1136 0.07858 0.0532 0.01314 1963 0.3623 0.2325 0.1517 0.1217 0.08242 0.02036 1964 0.2398 0.1533 0.1072 0.07752 0.05258 0.01296 1965 0.7912 0.5077 0.2352 0.1307 0.08796 0.02172 1966 0.2378 0.1505 0.105 0.07467 0.05045 0.01246 1967 0.4721 0.3414 0.2071 0.1394 0.09402 0.02322 1968 0.2626 0.1686 0.1264 0.08822 0.05961 0.01469 1969 0.255 0.1588 0.106 0.0921 0.06205 0.01533 1970 0.2365 0.1489 0.1037 0.07591 0.05123 0.01265 1971 0.3936 0.2458 0.1536 0.09577 0 .06639 0.01642 1972 0.2356 0.1456 0.1012 0.07376 0.05104 0.01298 1973 0.3581 0.2442 0.1602 0.0971 0.06542 0.01616 1974 0.2468 0.1844 0.1273 0.0886 0.0597 0.01474 1975 0.2485 0.1645 0.1185 0.08416 0.05681 0.01403 1976 0.2377 0.1499 0.1045 0.0771 0.05206 0.0 1324 1977 0.2456 0.1556 0.1109 0.07789 0.05401 0.01334 1978 0.3643 0.2393 0.1507 0.1176 0.07923 0.02079 1979 0.2454 0.1712 0.1189 0.08208 0.05536 0.01367 1980 0.2402 0.154 0.1077 0.07898 0.0535 0.01318 1981 0.3639 0.2517 0.1487 0.09662 0.06517 0.01608 1982 0.3559 0.2392 0.1708 0.1103 0.07425 0.01848 1983 1.274 0.791 0.2659 0.1597 0.11 0.02718 1984 0.2361 0.146 0.1015 0.07474 0.05045 0.01244 1985 0.2406 0.1544 0.1089 0.07653 0.05171 0.01303 1986 0.3111 0.2016 0.143 0.09064 0.06113 0.01509 1987 0.2632 0.1699 0.1207 0.08128 0.06504 0.01607 1988 0.3918 0.2684 0.1728 0.09964 0.06736 0.01659 1989 0.6768 0.4383 0.1809 0.1096 0.07697 0.01907 1990 0.3661 0.2416 0.1348 0.0887 0.07097 0.01763 Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.03225806451612 9 1.274 0.791 0.2659 0.1597 0.11 0.02718 0.0645161290322581 0.7912 0.5077 0.2352 0.1394 0.09402 0.02322 0.0967741935483871 0.6768 0.4383 0.2071 0.1307 0.08796 0.02172 0.129032258064516 0.4721 0.3414 0.1809 0.1217 0.08242 0.02079 0.161290322580645 0.3936 0. 2684 0.1728 0.1176 0.07923 0.02036 0.193548387096774 0.3918 0.2517 0.1708 0.1103 0.07697 0.01907 0.225806451612903 0.3661 0.2458 0.1602 0.1096 0.07425 0.01848 0.258064516129032 0.3643 0.2442 0.1536 0.09964 0.07097 0.01763 0.290322580645161 0.3639 0.2416 0. 1517 0.0971 0.06736 0.01659 0.32258064516129 0.3623 0.2393 0.1507 0.09662 0.06639 0.01642 0.354838709677419 0.3581 0.2392 0.1487 0.09577 0.06542 0.01616 0.387096774193548 0.3559 0.2325 0.143 0.0921 0.06517 0.01608 0.419354838709677 0.3111 0.2016 0.1348 0.0 9064 0.06504 0.01607 0.451612903225806 0.2632 0.1844 0.1273 0.0887 0.06205 0.01533 0.483870967741936 0.2626 0.1712 0.1264 0.0886 0.06113 0.01509 0.516129032258065 0.2597 0.1699 0.1207 0.08822 0.0597 0.01474 0.548387096774194 0.255 0.1686 0.1189 0.08416 0.0 5961 0.01469 0.580645161290323 0.2548 0.1645 0.1185 0.08208 0.05681 0.01403 0.612903225806452 0.2485 0.1638 0.1136 0.08128 0.05536 0.01367 0.645161290322581 0.2468 0.1595 0.1109 0.07954 0.05401 0.01334 0.67741935483871 0.2456 0.1588 0.1089 0.07898 0.05394 0.01333

### 30

0.709677419354839 0.2454 0.1556 0.1089 0.07858 0.0535 0.01324 0.741935483870968 0.2406 0.1544 0.1077 0.07789 0.0532 0.01318 0.774193548387097 0.2402 0.154 0.1072 0.07752 0.05258 0.01314 0.806451612903226 0.2398 0.1533 0.106 0.0771 0.05206 0.01303 0 .838709677419355 0.2378 0.1505 0.105 0.07653 0.05171 0.01298 0.870967741935484 0.2377 0.1499 0.1045 0.07591 0.05123 0.01296 0.903225806451613 0.2365 0.1489 0.1037 0.07474 0.05104 0.01265 0.935483870967742 0.2361 0.146 0.1015 0.07467 0.05045 0.01246 0.96774 1935483871 0.2356 0.1456 0.1012 0.07376 0.05045 0.01244 0.1 0.65633 0.42861 0.20448 0.1298 0.087406 0.021627 Average of yearly averages: 0.0160023333333333 Inputs generated by pe5.pl - Novemeber 2006 Data used for this run: Output File: Cyazofam Me tfile: w93193.dvf PRZM scenario: CAtomato_WirrigSTD.txt EXAMS environment file: ir298.exv Chemical Name: Cyazofamid Description Variable Name Value Units Comments Molecular weight mwt 324.79 g/mol Henry's Law Const. henry 4e - 7 atm - m^3/mol Vapor Pressure va pr 1e - 7 torr Solubility sol 1.07 mg/L Kd Kd mg/L Koc Koc 1338 mg/L Photolysis half - life kdp 0.02 days Half - life Aerobic Aquatic Metabolism kbacw 16.4 days Halfife Anaerobic Aquatic Metabolism kbacs 17.7 days Halfife Aerobic Soil Metabolism asm 5.5 days Ha lfife Hydrolysis: pH 7 11.9 days Half - life Method: CAM 2 integer See PRZM manual Incorporation Depth: DEPI 0.0 cm Application Rate: TAPP 0.0850 kg/ha Application Efficiency: APPEFF 0.99 fraction Spray Drift DRFT 0.064 fraction of application rate applied t o pond Application Date Date 11 - 03 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. app. rate 1 apprate 0.0850 kg/ha Interval 2 interval 7 days Set to 0 or delete line for single app. app. rate 2 apprate 0.0850 kg/ha Interval 3 interval 21 days Set to 0 or delete line for single app. app. rate 3 apprate 0.0850 kg/ha Interval 4 interval 7 days Set to 0 or delete line for single app. app. rate 4 apprate 0.0850 kg/ha Interval 5 interval 7 days Set to 0 or de lete line for single app. app. rate 5 apprate 0.0850 kg/ha Record 17: FILTRA

IPSCND 1 UPTKF 0 Record 18: PLVKRT 0

PLDKRT 0 FEXTRC 0.5 Flag for Index Res. Run IR Reservoir Flag for runoff calc. RUNOFF total none, monthly or total(average of entire run)

### 31

SCI - GROW Sample run for CTCA: SCIGROW VERSION 2.3 ENVIRONMENTAL FATE AND EFFECTS DIVISION OFFICE OF PESTICIDE PROGRAMS U.S. ENVIRONMENTAL PROTECTION AGEN CY

SCREENING MODEL FOR AQUATIC PESTICIDE EXPOSURE SciGrow version 2.3 chemical:CTCA_Scenario_3 time is 2/12/2009 8:37:57

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

------------------------------------------------------------------------ 1.137 2.0 2.274 7.08 E+02 10000.0

------------------------------------------------------------------------ groundwater screening cond (ppb) = 2.18E+00 ************************************************************************