1 OFFICE OF CHEMICAL SAFETY

AND POLLUTION PREVENTION UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460

PC Code : 288202

DP Barcode : D425914

MEMORANDUM

DATE: May 4, 2015

SUBJECT: Estimated Drinking Water Concentrations for Cyprodinil and its Metabolite

CGA

- 249287 for the New Use s of the Chemical on Tree Nuts Crop Group 14

- 12

, I ncluding Filberts (H azelnut) and P ecans

FROM: José L. Meléndez, Chemist

Environmental Risk Branch 5 Environmental Fate and Effects Division (7507P)

THROUGH: Mah T. Shamim, Ph.D., Branch Chief

Environmental Risk Branch 5 Environmental Fate and Effects Division (7507P)

TO: Heather Garvie , Risk Manager Reviewer Hop e Johnson

, Product Manager # 21 Cynthia Giles

- Parker

, Branch Chief Fungicide Branch Registration Division (7505P)

AND: Thurston Morton, Chemist

Elissa Reaves

, Branch Chief

Risk Assessment Branch 4 Health Effects Division (7509P)

This memo presents the Estimated Drinking Water Concentrations (EDWCs) for cyprodinil, an active ingredient of Vangard ® WG, Switch TM 62.5 G , and Inspire Super ® Fungicides, and its

metabolite CGA

- 249287 [ as per t he Metabolism Assessment Review Committee’s decision

document (MARC) ] , for the new uses of the chemical on Tree Nuts Crop Group 14

- 12, including filberts (hazelnut) and pecans. Based on a review of the use information, it was found that the newly proposed crops have a lower application rate than the maximum applicat ion rate of 0.47 lb a.i./A applied three times per year , or 1.4 lb a.i./A/year, previously modeled using the California2 almond and New York grapes scenario (note: the NY grape scenario yielded the highest surface waters EDWCs)

. EDWCs for the new uses shou ld be similar t o those already calculated for grapes

. Since previously modeled crops cover the new proposed crops, the results of the previous drinking waters assessment ( DWA) can be used for the new uses ; a new DWA is not required.

The previous DWA date d January 12, 2015 provides EDWCs from the new model PRZM

- GW

, which ha d not been modeled (DP Barcode D421158 )

. Further, a previous DWA, dated November 8, 2010 (DP Barcode D382086), involved only the products Vangard ® WG and Switch ® 62.5G Fungicides and the request to apply a maximum of two times aerially the product s to most of the

crops , and chemigation application s for several of the crops. Th e DWA provides structures and nomenclature of cyprodinil and its metabolite CGA

- 249287, as well as a summary of

environmental fate for the chemical. In a November 4, 2011 DWA, a number of new uses were

eval uated (DP Barcode D391853 ) , but it referred back to the 2010 DWA for EDWCs

.

T he tier 2 aquatic models PRZM/ EXAMS

, and the model s SCI

- GROW and PRZM

- GW were used

to obtain EDWCs in surface water and groundwater, respectively. The acut e EDWC in surface

water is 34.8 μg/L for the total residues of cyprodinil plus CGA

- 249287. The chronic EDWC in

surface waters is 24.7 μg/L for the tot al residues of cyprodinil and CGA

- 249287. The

cancer/chronic EDWC in surface waters is 16.4 μg/L for the total residues of cyprodinil and CGA

249287. All surface waters EDWCs were obtained using the New York grapes PRZM scenario.

The PRZM

- GW generated E DWC for the use on grapes ( using the FL citrus surrogate scenario ),

were 2.05 μg/L for the total residues of cyprodinil and CGA

- 249287 (acute) and 1.80 μg/L for the total residues (chronic) . For details on methods, characterization of results, uncertainti es, etc.

, please, refer to the previous DWAs. Table 1 provides a summary of the Tier 2 modeled drinking

water concentrations.

Table 1. Maximum Estimated Drinking Water Concentrati ons for the Use of Cyprodinil (e xpressed as total residues of cyprodinil pl us its degradate CGA

- 249287)

DRINKING WATER SOURCE (MODEL USED) USE (rate modeled per year ) MAXIMUM ESTIMATED DRINKING WATER
CONCENTRATION (EDWC) ( ppb )

Groundwater ( PRZM

- GW ) FL citrus 1 (1.4 lb a.i. /season ) Acute 2.05

Chronic 1.80

Surface water (PRZM/ EXAMS) NY grapes (1.4 lb a.i. /season ) Acute 34.8

Chronic 24.7

Cancer/Chronic 16.4

1 Scenario was used as a surrogate and run with the maximum application rate for grapes.

Should it be required, additional refinements may be available. For example, regional PCAs and typical use rates may be options to be used should it be requested by HED.

Identification of specific data gaps :

The environmental fate data base for cyprodinil is considered substantially complete; there are no

new reviewed data for this assessment. There is uncertainty with the aqueous photolysis study (MRID 43908422 ) . It was carried out with natural (unsterilize d) water. Phototransformation of cyprodinil in the irradiated samples followed a biphasic pattern, with slow transformation at the beginning. The possibility of microbial transformation is not ruled out. For modeling purposes, it was assumed that cyprod inil is stable to aqueous photolysis, which is a conservative assumption.3 Since the Problem Formulation for Registration Review was issued in 2012 ( DP Barcode

D393800 ) , soil metabolism studies were submitted, which are currently in review.

Use informatio n:

Th e end

- use products involved in this DWA is Inspire Super ® Fungicide ; however, there are three products that contain cyprodinil , as shown below . One product contains only cyprodinil, while two of the products have another active ingredient :

• Vangard ® WG Fungicide (EPA Reg. No. 100

- 828), containing 75.0% cyprodinil A

. I

. and 25.0% other ingredients

• Switch® 62.5G Fungicide (EPA Reg. No. 100

- 953) containing 37.5% cyprodinil A

. I

. , 25.0% fludioxonil A

. I

. and 37.5% other ingredients

• Inspire Super ® Fungicide (EPA Reg. No. 100

- 1317) contain ing 24.1% cyprodinil A

. I

. , 8.4% difenoconazole A .I. and 67.5% other ingredients

Table 2 provides a summary of the current use information for the pesticide cyprodinil only ( i.e.

, the table does not include the other two active ingredients) , relative to the tree nut crop group
, based on all previously available labels

. It also shows which crop has been modeled in the past. Generally, n o more than two sequential applications are allowed as part of a resistance management strategy (unless otherwise stated for a crop). The label requires a buffer zone to protect lakes, reservoirs, rivers, permanent streams, marshes or natural ponds, estua ries and

commercial fish ponds. For ground applications the buffer zone is 75 ft; mean while

, for aerial applications the buffer zone is 150 ft. A vegetative filter strip should be allowed within 10 ft of aquatic areas. Furthermore, other measures of pre caution are required ( e.g. applications when gusts or sustained winds exceed 10 mph are not allowed). Table 3 provides a summary of the proposed use pattern for Inspire Super ® Fungicide (shaded gray ). Note that almonds and pistachios are previously regis tered uses in this particular label.

Several crops have been modeled in the past, using seasonal rates of 1.4 lb a.i./A /season . These include CA almond, NY grape, CA fruit and MI cherry. Additionally, other crops have been modeled using a seasonal rate of 1.3 lb a.i./A /season , which included OR snap bean, FL strawberry, MO melon, NC sweet potato, GA onion and PA tomato. The new use (nut trees , including filberts and pecans ) involve s a lower rate than previously modeled for CA almond ( Table 3 )

. Since th e previously modeled crop cover s the new proposed crops, the results of the previous DWA can be

used for the new uses.

Table 2. Current Maximum Use Pattern for Cyprodinil B ased on Vangard ® WG (EPA Reg. No. 100

- 828), Switch® 62.5G (EPA Reg. No. 100

- 953) and Inspire Super® (EPA Reg. No. 100

- 1317) Fungicides

Use Max. Single App Rate (lb a.i./A) Number of Apps at

Max Rate Annual App.

Rate (lb a.i./A /yr ) Interval

Between Apps. (days) App

Method Pre

- Harvest

Interval (days) Almond ( CA almond ) 0.47 3 1.4 NS or 14 (1) G, A * 14

Pistachio 0.33 4 1.3 14 G, A * 7

Tree Nuts [ beech nut , Brazil nut, butternut, cashew, chestnut, chinquapin, filbert (hazelnut), hickory nut, macadamia nut,

pecan, walnut (black and English)] 0.47 3 1.4 NS (2) G, A * 14

G = ground; A * = Aerial ( maximum of two aerial applications allowed )4 T he crop that was previously modeled is shaded yellow

. There is one (1) crop cycle for tree nuts per year.

(1) For Vangard ® WG one application at 5

- 10% bloom, 50

- 100% bloom and at petal fall. For Inspire Super ® the minimum retreatment interval is 14 days and the maximum single application rate is 0.33 lb a.i./A.

(2) Apply when conditions are conducive to disease. It is noted that t he supplemental labels for Switch ® 62.5 W G and Inspire Super ® do not have this crop group.

Table 3. Proposed Use Pattern for Inspire Super ® Fungicide (EPA Reg. No. 100

- 1317) (the new uses for Inspire Super ® are shaded gray )

Use Max. Single App Rate (lb a.i./A) Number of Apps at

Max Rate Annual App.

Rate (lb a.i./A /yr ) Interval

Between Apps. (days) App

Method Pre

- Harvest

Interval (days) Almond ( CA almond ) 0.33 4 or 5 1.4 14 G, A * 14

Pistachio 0.33 4 1.3 14 G, A * 7

Tree Nuts Crop Group 14

- 12 [ African

nut

- tree; beechnut; Brazil nut; Brazilian pine; bunya; bur oak; butternut; Cajou nut; candlenut; cashew; chestnut; chinquapin; coconut; coquito nut; dika nut; ginkgo; Guiana chestnut; hazelnut (filbert); heartnut; hickory nut; Japanese horse

- chestn ut; macadamia nut;

mongongo nut; monkey

- pot; monkey puzzle nut; Okari nut; Pachira nut; peach palm nut; pecan; pequi; Pili nut; pine nut; pistachio; Sapucaia nut; tropical almond; walnut, black; walnut, English; yellowhorn; cultivars, varieties, and/or hyb rids of these] 0 .33 4 1.3 14 G, A * 14

Filberts (H azelnut) 0.33 4 1.3 14 G, A * 14

Pecans 0.33 4 1.3 14 G, A * 14 G = ground; A * = Aerial ( maximum of two aerial applications allowed )

T he crop that was modeled is shaded yellow

. There is one (1) crop cycle for tree nuts per year.