### Appendix 1 Registrant Proposed Field Adjustment Factors for Methyl Bromide and ChloropicrinAnalysis of Methyl Bromide Emissions in the San Joaquin Valley in 1990 and 2004

Abstract

This report calculates and summarizes the total am ount of methyl bromide emitted from agricultural and non-agricultural usage in the San Joaquin Va lley in 1990 and 2004 during the peak ozone season (May 1 to October 31 of each yea r). All methyl bromide use data were obtained from the CDPR Pesticide Information Portal (CALPIP) – Pestic ide Use Report (PUR) online database. Using the method that CDPR historically has used, which assu mes that 100% of the applied methyl bromide is emitted into the air, approximately 2.56 million pounds of methyl bromide was emitted in the eight counties comprising the San Joaquin Valley in 1990 (6.974 tons/day); and approximately 884,615 pounds of methyl bromide was emitted in 2004. Th e difference between 1990 and 2004 represents a 65.4% reduction in methyl bromide total emissions. An alternative VOC equation, based on mass loss studies and discrete usage data, was developed that takes into account the proportion of methyl bromide that is degraded in the soil (for soil fumiga tions). It is believed that this alternative VOC emission equation more accurately reflects the tota l amount of methyl bromide emitted by each crop or site and method of application. Using this new equation, approximately 1.6 million pounds of methyl bromide was emitted in 1990 (4.387 tons/day), and approximately 423,358 pounds of methyl bromide were emitted in 2004 (1.150 tons/day). The diffe rence between 1990 and 2004, using the corrected VOC equation, represents a 73.8% reduction in methyl bromide total emissions

Data Acquisition and Ov erall Use Statistics

The CALPIP search queries were by Year (“1990” and “2004”) and Chemical Name (“methyl bromide”). In this way, all PUR data for methyl bromide were included, regardless of formulation, product name, crop or site of application, etc. Both Agricultural and Non-Agricultural (under Other

Criteria: Reporting Type ) use reports were included.

The aggregate 1990 and 2004 PUR files for methyl br omide were downloaded and contained all PUR reports for the entire State of California. The 1990 Statewide PUR file c ontained 11,475 records of application that, collectively, totaled 20,139,409.92 pounds of methyl bromide. The 2004 Statewide PUR file contained 5,186 record s of application that, coll ectively, totaled 7,105,109.84 pounds of methyl bromide (Table 1).

The 1990 and 2004 Statewide PUR files were then pr ocessed to include only the 8 counties that comprise the San Joaquin Valley: Fresno, Kern, Kings , Madera, Merced, San Jo aquin, Stanislaus, and Tulare. While only part of Kern County is tec hnically included in the San Joaquin Valley VOC nonattainment area, all PUR records fo r Kern County were included in th ese analyses as a conservative measure, because it was not possible to distinguish between the applications that occurred in the nonattainment area and those that did not.

The 1990 PUR file for the San Joaqui n Valley contained 3,319 records of application that, collectively, totaled 6,381,933.24 pounds of methyl bromide. Th e 2004 PUR file for the San Joaquin Valley contained 1,805 records of a pplication that, collectively, totaled 1,494,252,924 pounds of methyl bromide (Table 1).The 1990 and 2004 San Joaquin Valley PUR files were th en processed to include only the applications that occurred between May 1 and Oc tober 31 of each year, as this period is considered the “peak ozone season”. The 1990 PUR file for the San Joaquin Valley Ozone Season contained 1,125 records of application that, collectively, totaled 2,556,412.799 pounds of methyl bromide. These 1,125 records consisted of 512 records for which the dates of app lication were listed and occurred between May 1 and October 31, and an additional 613 records for which no date of application was listed. As a conservative measure, these 613 no-date records were assumed to have occurred during the peak ozone season. The 2004 PUR file for the San Joaquin Valley Ozone Season contained 735 records of application that, collectively, totaled 884,615.4696 pounds of methyl bromide (Table 1).

The total amount of methyl bromide applied in the San Joaquin Valley during the peak ozone season in 2004 (884,615.4696 lbs.) is approximately 34.6% of what was applied in 1990 (2,556,412.799 lbs.), representing a 65.4% reduction in usage.

Table 1. Cumulative number of records and to tal pounds of methyl bromide applied in California (whole-year) and the San Joaquin Va lley (whole-year and during the “peak ozone season”) for all Agricultural and Non-Ag ricultural applications in 1990 and 2004.

Year Area & Period No. of Records Amount of MeBr Applied (total lbs.)

1990 Statewide, 12-month 11,475 20,139,409.92

San Joaquin Valley, 12-month 3,319 6,381,933.24

San Joaquin Valley, May 1 to

October 31 1,125 2,556,412.799

2004 Statewide, 12-month 5,186 7,105,109.84

San Joaquin Valley, 12-month 1,805 1,494,252.924

San Joaquin Valley, May 1 to

October 31 735 884,615.4696Analysis of VOC Emissions based on CDPR Procedures

CDPR uses the following equation to calculate VOC emissions from pesticide applications, where EP is defined as the Emissions Potential (VOC fraction) of a given pesticide product:

VOC emission (lbs.) = [lbs. of produ ct applied] * [product-specific EP]

For all methyl bromide products, CDPR assigns a default EP value of 100%. This assumes that 100% of the applied amount of methyl bromide is volatized from the soil or other site, such that the total methyl bromide VOC emissions are equal to the am ount of methyl bromide applied during a specific period, location, etc.

Using this equation for the total amounts applied in Ta ble 1, it can be calculated that the average daily VOC emissions in the San Joaquin Valley during the peak ozone season were approximately 6.947 tons/day in 1990 and 2.404 tons/day in 2004 (2000 pounds = 1 ton; 184 days in May 1 to October 31 period) (Table 2). This repr esents a 4.543 tons/day (or 65.4%) reduction in methyl bromide VOC emissions in 2004 compared to 1990.

Alternative Analysis of VOC Emissions based on Mass Loss Studies

While 100% of the applied methyl bromide can theo retically be emitted from a given end-use site,

numerous studies have demonstrated that, at least for soil fumigation, a portion of the methyl bromide is degraded in the soil and is not emitted into the air (i.e., via mass lo ss studies). With respect to this fact, any methyl bromide VOC emission calculation that assumes 100% emission would considerably overestimate methyl bromide’s cont ribution to the VOC burden in the San Joaquin Valley or any other area with significant methyl bromide use in soil fumigation. For non-soil fumi gation sites (commodity fumigation, structural fumigation, etc.), where there is little opportunity for methyl bromide degradation, the 100% emissions is likely accurate.

Yates et al. (1996) provide a detailed review of the techniques and mass loss studies that have determined estimates of methyl bromide emission loss and degradation in the soil from various soil fumigation application methods. These mass loss studies can be used to more accurately estimate total methyl bromide emissions from soil fumi gation activity. Based primarily on Yates et al. (1996) review, an additional component to the VOC emissions calculation was added, where EF = the Emissions Factor, or the proportion of methyl bromide that is emitted from the application field or site.

This alternative calculation is:

VOC emission (lbs.) = [lbs. of product applied] * [product-specific EP] * [application-specific EF]

By example, if methyl bromide wa s applied to 10 acres of almond at 200 lbs. a.i. (active ingredient) per acre, the total amount applied w ould be 2,000 lbs. of methyl bromide. The EP value remains 100% (1.0 by proportion), based on 100% of the product be ing volatile. The EF value would be based on mass loss studies where, in this case, the application is a deep injection (20 + in.) with HDPE tarp, which was estimated to result in 26% emission ( 0.26 by proportion) of the a pplied chemical. So, for this example: VOC emission (lbs.) = [2000 lbs.] * [1.0] * [0.26] = 520 lbs. emitted.

Therefore, based on this approach, only 520 lbs. of the 2,000 lbs. of methyl bromide that was applied, was emitted during this application.Based on Yates et al. (1996), the following EF values were used to calculate total emissions for each crop or site (e.g., soil fumigation vs . structural fumigation), type of fumigation (e.g., almond acres vs. almond nuts prior to packaging), type of application (e.g., shallow vs. de ep shank; tarp or no tarp; hotgas), where the type of applicati on was determined by the “Unit Treate d” field of the PUR records:

Unit Treated:

• A = acres

o Shallow injection (6-15 in.) , bed or broadcast, no tarp= 82% emission (EF = 0.82)

o Shallow injection (6-15 in.), bed or broa dcast, LDPE tarp = 82% emission* (EF = 0.82)

o Shallow injection (6-15 in.) , bed or broadcast, HDPE tarp = 43% emission (EF = 0.43)

o Deep injection (20+ in.), bed or broadcast, no tarp = 38% emission (EF = 0.38)

o Deep injection (20+ in.), bed or broadcast, LDPE tarp = 38% emission* (EF = 0.38)

o Deep injection (20+ in.), bed or broad cast, HDPE tarp = 26% emission (EF = 0.26)

* Note: No studies were found that dete rmined mass loss of methyl bromide through LDPE films, regardless of inj ection depth. However, based on Yates et al. (1996), LDPE film is at least twice as permeable to methyl bromide as HDPE films. Because of this, it is assumed that LDPE film provides virtually no retention properties and, ther efore, the EF values for shallow injection + LDPE tarp and deep injection + LDPE tarp were c onsidered to be equal to the EF values for shallow injection + no tarp (82%) and deep injection + no tarp (38%).

• C = cubic feet (for commodity, potting me dia, etc.; assume 100% loss; EF = 1.0)

• K = thousand cubic feet (for commodity, potting media, etc.; assume 100% loss; EF = 1.0)

• P = pounds (for commodity, potting media, etc.; assume 100% loss; EF = 1.0)

• S = square feet (for greenhouse treatmen ts, etc.; assume 100% loss; EF = 1.0)

• T = tons (for commodity, potting media, etc.; assume 100% loss; EF = 1.0)

• U = miscellaneous unit (for commodity, potting media, etc.; assume 100% loss; EF = 1.0)

• Not Listed = (for commodity, potting me dia, etc.; assume 100% loss; EF = 1.0)

As an aggregate example, the following data for 2004 methyl bromide Almond fumigation is used to illustrate the incorporation of application-specific EF values into the VOC equation:

ALMOND (2004)
Number of Records: 92 Total Pounds of Chemical Applied: 25,789.45151 Units Treated: A (acres), C (cubic feet), K (thousand cubic f eet), T (tons), U (misc. unit) Pounds Applied by Unit Treated: 58 records = A (deep injection + HDPE tarp; EP = 1.0; EF = 0.26) for 19,946.71286 total lbs. 17 records = C (assume 100% loss; EP = 1.0; EF = 1.0) for 1278.769651 lbs. 3 records = K (assume 100% loss; EP = 1.0; EF = 1.0) for 2387.379 lbs. 6 records = T (assume 100% loss; EP = 1.0; EF = 1.0) for 989 lbs. 4 records = U (assume 100% loss; EP = 1.0; EF = 1.0) for 1187.59 lbs. VOC emissions for treated acres of almond = 19,946.71286 x 0.26 = 5,186.14534 lbs. VOC emissions for all other almond applications = 5,842.73865 x 1.0 = 5,842.73865 lbs. Total VOC emissions for Almond = 11,028.884 lbs.This same aggregate analysis was performed for all SITE/CROP listings within both the 1990 and 2004 PUR files. The aggregate analysis and summary table for 1990 applications are provided in Appendix A. The aggregate analysis and summary table for 2004 applic ations are provided in Appendix B. These analyses assume the following:

• Approximately 90% of methyl bromide soil fumi gations in 1990 were non-tarped and 10% were tarped using LDPE film.

• LDPE film is considered to have little gas re tention properties, and therefore, any 1990 applications with LDPE film had EF values that were the same as non-tarped applications.

• LDPE film was only used in 1990 and not in 2004.

• All CDPR-approved HDPE films were assigned the same EF, which was based on mass loss

studies.

• All 2004 soil applications used HDPE film, regardless of injection depth.

• All non-acre applications are assumed to result in 100% emission of product.

Based on the sum values for the EF -corrected VOC emission equations that were applied to each Crop/Site by year, it is calculated that 1,614,281.682 lbs. of methyl bromide were emitted in the eight counties comprising the San Joaquin Valley during the peak ozone season in 1990 (4.387 tons/day), and 423,357.7978 lbs. of methyl bromide were emitted in 2004 (1.150 tons/day). The 2004 VOC total is approximately 26.2% of the 1990 total, which equates to a 73.8% reduction in methyl bromide emissions.

Table 2. Default and Corrected methyl bromide VOC emissions.

Year Default VOC emissions

(tons/day) z VOC emissions corrected using

mass loss data (tons/day) y

1990 6.947 4.387

2004 2.404 1.150

z Values assume 100% emission of applied material.

y Values incorporate empirically-derived mass loss data.

CONCLUSION

When the type of application is not considered and 10 0% of the applied methyl bromide is assumed to be emitted, the total VOC emissions of methyl bromide were reduced from 6.947 tons/day in 1990 to 2.404 tons/day in 2004. When the type of application is considered relative to the proportion of methyl bromide which is degraded in the soil, the total VOC emissions of meth yl bromide were reduced from 4.387 tons/day in 1990 to 1.150 ton/day in 2004. The Product Names listed in the PUR database files are presented in Appendix 3.

Reference Cited:

Yates, S.R., J. Gan, F.F. Ernst, D. Wang, and M. Ya tes. 1996. Emissions of methyl bromide from agricultural

fields: rate estimates and methods of reduction, pp. 116-134. In Seiber et al. 1996, Fumigants: Environmental Fate, Exposure, and Analysis. American Chemical Society, Washington, DC.

### APPENDIX A

1990 Methyl Bromide VOC Emissi ons in the San Joaquin Valley

[since the default EP value is 100% (1.0) for all me thyl bromide applications , this component of the equation was not included in the following calculati ons, as it does not affect the equations’ product]

ALFALFA (FORAGE – FODDER) (ALL OR UNSPEC) -- 1990
Number of Records: 3 Total Pounds Chemical Applied: 16,193.625 Units Treated: A (acres), U (misc. unit) Pounds Applied by Unit Treated: 2 records = A (shallow injection + LDPE or no tarp; EF = 0.82) for 16,019.5 lbs. 1 record = U (assume 100% loss; EF = 1.0) for 174.125 lbs. VOC emissions for treated acres of Alfalfa = 16,019.5 x 0.82 = 13,135.99 lbs.

VOC emissions for all other Alfalf a applications = 174.125 x 1.0 = 174.125 lbs. Total VOC emissions for Alfalfa = 13,210.115 lbs.

ALMOND -- 1990
Number of Records: 120 Total Pounds of Chemical Applied: 97,562.641 Units Treated: A (acres), C (cubic feet), K (t housand cubic feet), P (pounds ), S (square feet), T (tons), U (misc. unit). Pounds Applied by Unit Treated: 26 records = A (deep injection + LDPE or no tarp, EF = 0.38) for 70,709.065 lbs. 19 records = C (assume 100% loss; EF = 1.0) for 3,472.831 lbs. 10 records = K (assume 100% loss; EF = 1.0) for 6,262.7 lbs. 6 records = P (assume 100% loss; EF = 1.0) for 1,316 lbs. 4 records = S (assume 100% loss; EF = 1.0) for 716.125 lbs. 18 records = T (assume 100% loss; EF = 1.0) for 10,159.375 lbs. 37 records = U (assume 100% loss; EF = 1.0) for 4,926.545 lbs. VOC emissions for treated acres of almond = 70,709.065 x 0.38 = 26,869.4447 lbs. VOC emissions for all other almond applications = 26,853.576 x 1.0 = 26,853.576 lbs. Total VOC emissions for Almond = 53,723.0207 lbs.

APPLE -- 1990
Number of Records: 4 Total Pounds Chemical Applied: 11,968.9 Unit Treated: A (acres) EF based on Application Method: 0.38 (deep injection + LDPE or no tarp) VOC emissions for Apple = 11,968.9 x 0.38 = 4,548.182 lbs.APRICOT -- 1990
Number of Records:5 Total Pounds Chemical Applied: 1,529.485 Units Treated: A (acres), U (misc. unit) Pounds Applied by Unit Treated: 2 records = A (deep injection + LDPE or no tarp; EF = 0.38) = 1,395.985lbs. 3 records = U (assume 100% loss; EF = 1.0) = 133.5 lbs. VOC emissions for treated acres of Apricot = 1,395.985 x 0.38 = 530.4743 lbs. VOC emissions for all other Apricot applications = 133.5 x 1.0 = 133.5 lbs. Total VOC emissions for Apricot = 663.9743 lbs.

BEANS (ALL OR UNSPEC) -- 1990
Number of Records: 12 Total Pounds Chemical Applied: 3,207 Units Treated: K (thousand cubic feet), P (pound s), S (square feet), T (tons), U (misc. unit) Pounds Applied by Unit Treated: 1 record = K (assume 100% loss; EF = 1.0) for 76 lbs. 2 records = P (assume 100% loss; EF = 1.0) for 35 lbs. 2 records = S (assume 100% loss; EF = 1.0) for 216 lbs. 6 records = T (assume 100% loss; EF = 1.0) for 2,490 lbs. 1 record = U (assume 100% loss; EF = 1.0) for 390 lbs. VOC emissions for Beans (All or Unspec) = 3,207 x 1.0 = 3,207 lbs.

BEANS, DRIED-TYPE -- 1990
Number of Records: 7 Total Pounds Chemical Applied: 3,349 Units Treated: C (cubic feet), P (pounds), T (tons) Pounds Applied by Unit Treated: 2 records = C (assume 100% loss; EF = 1.0) for 304 lbs. 1 record = P (assume 100% loss; EF = 1.0) for 204 lbs. 4 records = T (assume 100% loss; EF = 1.0) for 2,805 lbs. VOC emissions for Beans, Dried-Type= 3,349 x 1.0 = 3,349 lbs.

BEEHIVES (ALL OR UNSPEC) -- 1990
Number of Records: 4 Total Pounds Chemical Applied: 497.5 Units Treated: A (? Acres of beehives?) EF value based on Application method: 1.0 (assume 100% loss; bee equipment) VOC emissions for Beehives (all or Unspec) = 497.5 x 1.0 = 497.5 lbs.

BEEHIVES, BEE COLONY (DISEA SED, NUISANCE) -- 1990
Number of Records: 2 Total Pounds Chemical Applied: 53.9 Unit Treated: C (cubic feet) EF value based on application method: 1.0 (assume 100% loss) VOC emissions for Beehives, Bee Colony = 53.9 x 1.0 = 53.9 lbs.CARROT, GENERAL -- 1990
Number of Records: 2 Total Pounds Chemical Applied: 398 Unit Treated: A (acres) EF value based on application met hod: 0.82 (shallow injection + no tarp) VOC emissions for Carrots, General = 398 x 0.82 = 326.36 lbs.

CHERRY -- 1990
Number of Records: 53 Total Total Pounds Chemical Applied: 23,246.8726 Units Treated: A (acres), T (tons), U (misc. unit) Pounds Applied by Unit Treated: 40 records = A (deep injection + LDPE or no tarp, EF = 0.38) for 20,653.5776 lbs. 1 record = T (assume 100% loss; EF = 1.0) for 737 lbs. 12 records = U (assume 100% loss, EF = 1.0) for 1,856.295 lbs. VOC emissions for treated acres of Cherry = 20,653.5776 x 0.38 = 7,848.359488 lbs.

VOC emissions for all other Che rry applications = 2,593.295 x 1.0 = 2,593.295 lbs. Total VOC emissions for Cherry = 10,441.654488 lbs.

COMMODITY FUMIGATION -- 1990
Number of Records: 25 Total Pounds Chemical Applied: 5,070.745 Unit Treated: Unknown (assume 100% loss) EF based on application Method: 1.0 VOC emissions for Commodity Fumigation = 5,070.745 x 1.0 = 5,070.745 lbs.

COTTON, GENERAL -- 1990
Number of Records: 2 Total Pounds Chemical Applied: 6,500.335 Unit Treated: A (acres) EF based on Application Method: 0.82 (s hallow injection + LDPE or no tarp) VOC emissions for Cotton = 6,500.335x 0.82 = 5,330.2747 lbs.

FIG -- 1990
Number of Records: 9 Total Pounds Chemical Applied: 1,267.88 Units Treated: A (acres), T (tons) Pounds Chemical Applied by Unit Treated: 2 records = A (deep injection + LDPE or no tarp; EF = 0.38) for 200 lbs. 7 records = T (assume 100% loss; EF = 1.0) for 1,067.88 lbs. VOC emissions for treated acres of Fig = 200 x 0.38 = 76 lbs. VOC emissions for all other Fig applications = 1,067.88 x 1.0 = 1,067.88 lbs. Total VOC emissions for Fig = 1,143.88 lbs.FOREST TREES, FOREST LANDS (ALL OR UNSPEC) -- 1990
Number of Records: 4 Total Pounds Chemical Applied: 32.34 Unit Treated: C (cubic feet) EF value based on application method: 0.82 (shallow injection + LDPE or no tarp) VOC emissions for Forest Trees = 32.34 x 0.82 = 26.5188

FRUITS (ALL OR UNSPEC) -- 1990
Number of Records: 6 Total Pounds Chemical Applied: 2,648.95 Units Treated: C (cubic feet), K (t housand cubic feet), U (misc. unit) Pounds Chemical Applied by Unit Treated: 2 records = C (assume 100% loss; EF = 1.0) for 680 lbs. 1 record = K (assume 100% loss; EF = 1.0) for 1,617 lbs. 3 records = U (assume 100% loss; EF = 1.0) for 351.95 lbs. VOC emissions for Fruits (all or unspec) = 2,648.95 x 1.0 = 2,648.95 lbs.

GRAINS (ALL OR UNSPEC) -- 1990
Number of Records: 1 Total Pounds Chemical Applied: 0.98 Unit Treated: U (misc. unit)

EF value based on A pplication Method: 1.0 VOC emissions for Grains = 0.98 x 1.0 = 0.98 lbs.

GRAPES-- 1990
Number of Records: 34 Total Pounds Chemical Applied: 76,258.236 Units Treated: A (acres), C (cubic feet), K (t housand cubic feet), S (square feet), T (tons), U (misc. unit) Pounds Chemical Applied by Unit Treated: 16 records = A (deep injection + LDPE or no tarp; EF = 0.38) for 61,348.381 lbs. 3 records = C (assume 100% loss; EF = 1.0) for 1,135 lbs. 7 records = K (assume 100% loss; EF = 1.0) for 11,659.105 lbs. 1 record = S (assume 100% loss; EF = 1.0) for 360 lbs. 1 record = T (assume 100% loss; EF = 1.0) for 3 lbs. 6 records = U (assume 1 00% loss; EF = 1.0) = 1,752.75 VOC emissions for treated acres of Grapes = 61,348.381 x 0.38 = 23,312.38478 lbs. VOC emissions for all other Grap e applications = 14,909.855 x 1.0 = 14,909.855 lbs. Total VOC emissions for Grapes = 38,222.23978 lbs.

GRAPES, WINE -- 1990
Number of Records: 13 Total Pounds Chemical Applied: 537,163.545 Units Treated: A (acres) EF value based on application method: 0.38 (deep injection + LDPE or no tarp) VOC emissions for Grapes, Wine = 537,163.545 x 0.38 = 204,122.1471 lbs.KIWIFRUIT -- 1990
Number of Records: 1 Total Pounds Chemical Applied: 2,585.01 Unit Treated: A (acre) EF value based on application method: 0.38 (deep injection + LDPE or no tarp) VOC emissions for Kiwifruit = 2,585.01 x 0.38 = 982.3038 lbs.

LANDSCAPE MAINTENANCE -- 1990
Number of Records: 28 Total Pounds Chemical Applied: 3,802.02

Unit Treated: Unknown EF value based on application method: 0.82 (ass ume shallow injection + LDPR or no tarp) VOC emissions for Landscape Maintenance = 3,802.02 x 0.82 = 3,117.6564 lbs.

NECTARINE -- 1990
Number of Records: 111 Total Pounds Chemical Applied: 192,746.285 Units Treated: A (acres), C (cubi c feet), T (tons), U (misc. unit) Pounds Chemical Applied by Unit Treated: 29 records = A (deep injection + LDPE or no tarp; EF = 0.38) for 163,243.605 lbs. 1 record = C (assume 100% loss; EF = 1.0) for 55.9 lbs. 1 record = T (assume 100% loss; EF = 1.0) for 155 lbs. 80 records = U (assume 100% loss; EF = 1.0) for 29,291.78 lbs.

VOC emission for treated acres of Nectarine = 163,243.605 x 0.38 = 62,032.5699 lbs.

VOC emission for all other Nectarin e applications = 29,502.88 x 1.0 = 29,502.88 lbs. Total VOC emissions for Nectarine = 91,535.4499 lbs.

N-GRNHS GRWN CUT FL WRS OR GREENS -- 1990
Number of Records: 5 Total Pounds Chemical Applied: 103.3099 Units Treated: A (acres), C (cubic feet), S (square feet) Pounds Chemical Applied by Unit Treated: 2 records = A (shallow injection + LDPE tarp or no tarp; EF = 0.82) for 91.54 lbs. 2 records = C (assume 100% loss; EF = 1.0) for 11.76 lbs. 1 record = S (assume 100% loss; EF = 1.0) for 0.0099 lbs.

VOC emissions for treated acres of N-GGCFOG = 91.54 x 0.82 = 75.0628 lbs.

VOC emissions for all other N-GGCFOG = 11.7699 x 1.0 = 11.7699 lbs. Total VOC emissions for N-GGCFOG = 86.8327

N-GRNHS GRWN TRNSPLNT/PRPGTV MTRL -- 1990
Number of Records: 7 Total Pounds Chemical Applied: 86.645 Units Treated: S (square feet), Unknown Pounds Chemical Applied by Unit Treated: 3 records = S (assume 100% loss; EF = 1.0) = 25.95 lbs. 4 records = Unknown (assume 100% loss; EF = 1.0) = 60.695 lbs. VOC emissions for N-GGT/PM = 86.645 x 1.0 = 86.645 lbs.N-OUTDR CONTAINER/FLD GRWN PLANTS -- 1990
Number of Records: 66 Total Pounds Chemical Applied: 794,109.03 Unit Treated: A (acres) EF value based on Applicati on Method: 0.82 (shallow injecti on + LDPE tarp or no tarp) VOC emissions for N-OC/FGP =794,109.03 x 0.82 = 651,169.4046 lbs.

N-OUTDR GRWN TRNSPLNT/PRPGTV MTRL -- 1990
Number of Records: 47 Total Pounds Chemical Applied: 186,321.0915 Units Treated: A (acres ), K (thousand cubic feet), S (square feet); Unknown Pounds Chemical Applied by Unit Treated: 34 records = A (shallow injection + LD PE or no tarp; EF = 0.82) for 184,581.4965 lbs. 1 record = K (assume 100% loss; EF = 1.0) for 1,194 lbs. 2 records = S (assume 100% loss; EF = 1.0) for 464.05 lbs. 10 records = Unknown (assume 100 % loss; EF = 1.0) = 81.545 lbs. VOC emissions for N-OGT/PM = 184,581.4965 x 0.82 = 151,356.82713 lbs. VOC emissions for all other N-OGT/PM = 1,739.595 x 1.0 = 1,739.595 lbs. Total VOC emissions for N-OGT/PM = 153,096.42213 lbs.

NUT CROPS, NUT TREES (ALL OR UNSPEC) -- 1990
Number of Records: 12 Total Pounds Chemical Applied: 4,938.55 Units Treated: C (cubic feet), S (squa re feet), T (tons), U (misc. unit) Pounds Chemical Applied by Unit Treated: 6 records = C (assume 100% loss; EF = 1.0) for 77.61 lbs. 1 record = S (assume 100% loss; EF = 1.0) for 39.8 lbs. 4 records = T (assume 100% loss; EF = 1.0) for 4,817.14 lbs. 1 record = U (assume 100% loss; EF = 1.0) for 4 lbs. VOC emissions for Nut Crops = 4,938.55 x 1.0 = 4,938.55 lbs.

ONION -- 1990
Number of Records: 7 Total Pounds Chemical Applied: 8,648.54 Units Treated: A (acres), S (square feet) Pounds Chemical Applied by Unit Treated: 6 records = A (shallow injection + LD PE or no tarp; EF = 0.82) for 8,529.14 lbs. 1 record = S (assume 100% loss; EF = 1.0) for 119.4 lbs. VOC emissions for treated acres of Onion = 8,529.14 x 0.82 = 6,993.8948 lbs. VOC emissions for all other Onion applications = 119.14 x 1.0 = 119.14 lbs. Total VOC emissions for Onion = 7,113.0348 lbs.ORANGE -- 1990
Number of Records: 3 Total Pounds Chemical Applied: 4,956.865 Unit Treated: A (acres) EF based on Application Method: 0.38 (deep injection + LDPE or no tarp) VOC emissions for Orange = 4,956.865 x 0.38 = 1,883.6087 lbs.

PEACH -- 1990
Number of Records: 77 Total Pounds Chemical Applied: 188,637.64 Units Treated: A (acres), T (tons), U (misc. unit) Pounds Chemical Applied by Unit Treated: 53 records = A (deep injection + LDPE or no; EF = 0.38) for 187,714.41 lbs. 1 record = T (assume 100% loss; EF = 1.0) for 13 lbs. 23 records = U (assume 100% loss; EF = 1.0) for 910.23 lbs. VOC emission for treated acres of Peach = 187,714.41x 0.38 = 71,331.4758 lbs.

VOC emission for all other Peach applications = 923.23 x 1.0 = 923.23 lbs. Total VOC emissions for Peach = 72,254.7058 lbs.

PEAR -- 1990
Number of Records: 1 Total Pound Chemical Applied: 1,333.3 Units Treated: A (acres) EF value based on Appli cation Method: 0.38 (deep inje ction + LDPE or no tarp) VOC emissions for Pear = 1,333.3 x 0.38 = 506.654 lbs.

PEAS, FIELD OR SOUTHERN (BLACKEYED, ETC.) -- 1990
Number of Records: 1 Total Pounds Chemical Applied: 450 Unit Treated: T (tons) EF value based on Applicati on Method: 1.0 (assume 100% loss) VOC emissions for Peas, Field or Southe rn (Blackeyed, etc.) = 450 x 1.0 = 450 lbs.

PEAS, GENERAL -- 1990
Number of Records: 5 Total Pounds Chemical Applied: 706 Units Treated: C (cubic feet), K (thousa nd cubic feet), S (square feet), T (tons) Pounds Chemical Applied by Unit Treated: 1 record = C (assume 100% loss; EF = 1.0) for 171 lbs. 1 record = K (assume 100% loss; EF = 1.0) for 38 lbs. 2 records = S (assume 100% loss; EF = 1.0) for 252 lbs. 1 record = T (assume 100% loss; EF = 1.0) for 245 lbs. Total VOC emissions for Peas, General = 706 x 1.0 = 706 lbs.PEAS, SOUTHERN (COWPEAS, BLACK EYED, CROWDER, ETC.) -- 1990
Number of Records: 2 Total Pounds Chemical Applied: 1,692 Units Treated: C (cubic feet), S (square feet) Pounds Chemical Applied by Unit Treated: 1 record = C (assume 100% loss; EF = 1.0) for 1,008 lbs. 1 record = S (assume 100% loss; EF = 1.0) for 684 lbs. VOC emissions for Peas, Southern (Cowpeas, etc.) = 1,692 x 1.0 = 1,692 lbs.

PETS (ALL OR UNSPEC) -- 1990
Number of Records: 2 Total Pounds Chemical Applied: 9.95 Unit Treated: S (square feet) EF value based on application method: 1.0 (assume 100% loss) VOC emissions for Pets = 9.95 x 1.0 = 9.95 lbs.

PISTACHIO (PISTACHE NUT) -- 1990
Number of Records: 38 Total Pounds Chemical Applied: 10,449.525 Unit Treated: A (acres), C (cubic feet), K (thousand cubic feet), U (misc. unit) Pounds Chemical Applied by Unit Treated: 1 record = A (deep injection + LDPE or no tarp; EF = 0.38) for 721 lbs. 28 records = C (assume 100% loss; EF = 1.0) for 8,619.545 lbs. 1 record = K (assume 100% loss; EF = 1.0) for 731 lbs. 3 records = U (assume 100% loss; EF = 1.0) for 377.98 lbs.
VOC emissions for treated acres of Pistachio = 721 x 0.38 = 273.98 lbs.

VOC emissions for all other Pistach io applications = 9,728.525 x 1.0 = 9728.525 lbs. Total VOC emissions for Pistachio = 10,002.505 lbs.

PLUM (INCLUDES WILD PLUMS FO R HUMAN CONSUMPTION) -- 1990
Number of Records: 16 Total Pounds Chemical Applied: 51,002.88 Unit Treated: A (acres) EF value based on application method: 0.38 (deep injection + LDPE or no tarp) Total VOC emissions for Plum = 51,002.88 x 0.38 = 19,381.0944 lbs.

PUBLIC HEALTH PEST CONTROL -- 1990
Number of Records: 2 Total Pounds Chemical Applied: 405.52

Unit Treated: Unknown EF value based on application method: 1.0 (assume 100% loss) VOC emissions for Public Health Pest Control = 405.52 x 1.0 = 405.52 lbs.RICE -- 1990
Number of Records: 3 Total Pounds Chemical Applied: 14 Units Treated: C (cubic feet), T (tons) Pounds Chemical Applied by Unit Treated: 2 records = C (assume 100% loss; EF = 1.0) for 6 lbs. 1 record = T (assume 100% loss; EF = 1.0) for 8 lbs. VOC emissions for RICE = 14 x 1.0 = 14 lbs.

RIGHTS OF WAY -- 1990
Number of Records: 12 Total Pounds Chemical Applied: 4,228.52 Unit Treated: A (acres), Unknown (assume shallow injection + LDPE or no tarp) Pounds Chemical Applied by Unit Treated: 1 records = A (shallow injection + LDPE or no tarp; EF = 0.82) for 199 lbs. 11 records = Unknown (EF = 0.82) for 4,029.52 lbs. Total VOC emissions for Rights of Way = 4,228.52 x 0.82 = 3,467.3864 lbs.

SOIL APPLICATIONS, (HOUSEPLANT POTTING SOIL) -- 1990
Number of Records = 1 Total Pounds Chemical Applied: 8.9555 Unit Treated: S (square feet) EF value based on application method: 1.0 (assume 100% loss))

VOC emissions for Soil Applications (Hou seplant Potting Soil) = 8.9555 x 1.0 = 8.9555 lbs.

SOIL APPLICATIONS, PREPLANT – OUTDOOR (SEEDBEDS, ETC.) -- 1990
Number of Records: 14 Total Pounds Chemical Applied: 6,214.595 Units Treated: A (acres), C (cubic feet), K (thousand cubic feet), S (square feet) Pounds Chemical Applied by Unit Treated: 5 records = A (shallow injection + LD PE or no tarp; EF = 0.82) for 5,398.675 lbs. 7 records = C (assume 100% loss; EF = 1.0) for 638.795 lbs. 1 record = K (assume 100% loss; EF = 1.0) for 3 lbs. 1 record = S (assume 100% loss; EF= 1.0) for 174.125 lbs.

VOC emissions for treated acres of Soil Applications = 5,398.675 x 0.82 = 4,426.9135 lbs.

VOC emissions for all other Soil Applications = 815.92 x 1.0 = 815.92 lbs. Total VOC emissions for Soil Applications, Preplant = 5,242.8335 lbs.

STRAWBERRY -- 1990
Number of Records: 23 Total Pounds Chemical Applied: 65,198.27616 Unit Treated: A (acres) EF value based on application method: 0.82 (shallow injection + LDPE or no tarp) VOC emissions for Strawberry = 65,198.27616 x 0.82 = 53,462.5864512 lbs.STRUCTURAL PEST CONTROL -- 1990
Number of Records: 189 Total Pounds Chemical Applied: 40,433.14062 Unit Treated: Unknown (assume 100% loss) EF value based on Application method: 1.0 VOC emissions from Structural Pest Control = 40,433.14062 x 1.0 = 40,433.14062 lbs.

TOMATO -- 1990
Number of Records: 7 Total Pounds Chemical Applied: 3,583.58 Units Treated: A (acres), S (square feet) Pounds Chemical Applied by Unit Treated: 3 records = A (shallow injection + LD PE or no tarp; EF = 0.82) for 3,384.58 lbs. 4 records = S (assume 100% loss; EF = 1.0) for 199 lbs. VOC emissions for treated acres of Tomato = 3,384.58 x 0.82 = 2,775.3556 lbs. VOC emissions for all other Tomato applications = 199 x 1.0 = 199 lbs. Total VOC emissions for Tomato = 2,974.3556 lbs.

UNCULTIVATED AGRICULTURAL ARE AS (ALL OR UNSPEC) -- 1990
Number of Records: 21 Total Pounds Chemical Applied: 59,089.7157 Unit Treated: A (acres), S (square feet) Pounds Chemical Applied by Unit Treated: 20 records = A (shallow injection + LD PE or no tarp; EF = 0.82) for 59,077.9557 lbs. 1 record = S (assume 100% loss; EF = 1.0) for 11.76 lbs. VOC emissions for treated acres of Uncult. Ag = 59,077.9557 x 0.82 = 48,443.923674 lbs.
VOC emissions for all other Uncultivated Ag applications = 11.76 x 1.0 = 11.76 lbs. Total VOC emissions from Uncultivated Ag Areas = 48,455.683674 lbs.

UNCULTIVATED NON-AG AREAS (ALL OR UNSPEC) -- 1990
Number of Records: 5 Total Pounds Chemical Applied: 7,229.9 Units Treated: A (acres); C (cubic feet), S (square feet) Pounds Chemical Applied by Unit Treated: 3 records = A (shallow injection + LDPE or no tarp; EF = 0.82) = for 7,210.98 lbs. 1 record = C (assume 100% loss; EF = 1.0) for 15 lbs. 1 record = S (assume 100% loss; EF = 1.0) for 3.92 lbs. VOC emissions for treated acres of Uncult. Non-Ag Areas = 7,210.98 x 0.82 = 5,913.0036 lbs.

VOC emissions for all other Uncult. N on-Ag applications = 18.92 x 1.0 = 18.92 lbs. Total VOC emissions from Uncultivated Non-Ag Areas = 5,921.9236 lbs.

VERTEBRATE PEST CONTROL -- 1990
Number of Records: 1 Total Pounds Chemical Applied: 33.67866 Units Treated: Unknown (assume 100% loss) EF value based on application method: 10. VOC emissions for Vertebrate Pest Control = 33.67866 x 1.0 = 33.67866 lbs.WALNUT -- 1990
Number of Records: 109 Total Pounds Chemical Applied: 130,416.4909 Units Treated: A (acres), C (cubic feet), K (thou sand cubic feet), P (pounds), S (square feet), T (tons), U (misc. unit) Pounds Chemical Applied by Unit Treated: 38 records = A (deep injection + LDPE or no tarp; EF = 0.38) for 68,035.46945 lbs. 14 records = C (assume 100% loss; EF = 1.0) for 2,358.75 lbs. 1 record = K (assume 100% loss; EF = 1.0) for 70 lbs. 9 records = P (assume 100% loss; EF = 1.0) for 2,322.5 lbs. 2 records = S (assume 100% loss; EF = 1.0) for 1,213 lbs. 20 records = T (assume 100% loss; EF = 1.0) for 49,984.99 lbs. 25 records = U (assume 100% loss; EF = 1.0) for 6,431.7815 lbs. VOC emissions for treated acres of Walnut = 68,035.46945 x 0.38 = 25,853.478391 lbs. VOC emissions for all other Walnut applications = 62,381.0215 lbs. Total VOC emissions for Walnut = 88,234.499891 lbs.

WOOD PROTECTION TREATMENTS (ALL OR UNSPEC) -- 1990
Number of Records = 3 Total Pounds Chemical Applied: 27.86 Unit Treated: C (cubic feet) EF value based on application method: 1.0 (assume 100% loss) VOC emissions for Wood Protection Treatments = 27.86 x 1.0 = 27.86 lbs.Summary of 1990 Default and Corrected VOC Emissions Data by Crop/Site

CROP/SITE Default VOC emission (lbs.) Corrected VOC emission (lbs.)

Alfalfa 16,193.625 13,210.115

Almond 97,562.641 53,723.0207 Apple 11,968.9 4,548.182 Apricot 1,529.485 663.9743 Beans (all or unspec) - all beans 6,556 6,556 Beehives (all or unspec) – all beehives 551.2 551.2

Carrots 398 326.36 Cherry 23,246.8726 10,441.654488 Commodity Fumigation 5,070.745 5,070.745

Cotton 6,500.335 5,330.2747 Fig 1,267.88 1,143.88

Forest Trees 32.34 26.5188 Fruits (dried) 2,648.95 2,648.95

Grains 0.98 0.98 Grapes 76,258.236 38,222.23978 Grapes, Wine 537,163.545 204,122.1471

Kiwifruit 2,585.01 982.3038 Landscape Maintenance 3,802.01 3,117.6564

Nectarine 192,746.285 91,535.4499

N-Grnhs Grwn Cut Flwrs or Greens 103.3099 86.8327 N-Grnhs Grwn Trnsplnt/Prpgtv Mtrl 86.645 86.645

N-Outdr Container/Fld Grwn Plants 794,109.3 651,169.4046 N-Outdr Grwn Trnsplnt/Prpgtv Mtrl 186,321.0915 153,096.42213 Nut Crops, Nut Trees 4,938.55 4,938.55

Onion 8,648.54 7,113.0348 Orange 4,956.865 1,883.6087

Peach 188,637.64 72,254.7058

Pear 1,333.3 506.654 Peas – all peas 1,848 1,848

Pets 9.95 9.95

Pistachio 10,449.525 10,002.505

Plum 51,002.88 19,381.0944

Public Health Pest Control 405.52 405.52

Rice 14 14 Rights of Way 4,228.52 3,467.3864 Soil Applications (houseplant soil) 8.9555 8.9555 Soil Applications (preplant) 6,214.595 5,242.8335 Strawberry 65,198.27616 53,462.5864512

Structural Pest Control 40,433.14062 40,433.14062

Tomato 3,583.58 2,974.3556 Uncultivated Ag Areas 59,089.7157 48,455.683674 Uncultivated Non-Ag Areas 7,229.9 5,921.9236

Vertebrate Pest Control 33.67866 33.67866

Walnut 130,416.4909 88,234.49891

Wood Protection treatments 27.86 27.86

TOTAL 2,556,412.779 1,614,281.682

### APPENDIX B

2004 Methyl Bromide VOC Emissi ons in the San Joaquin Valley

[since the default EP value is 100% (1.0) for all me thyl bromide applications , this component of the equation was not included in the following calculati ons, as it does not affect the equations’ product]

ALFALFA (FORAGE – FODDER) (ALL OR UNSPEC) -- 2004
Number of Records: 1 TotalPounds Chemical Applied: 11.76 Unit Treated: A (acres) EF based on Application Method: 0. 43 (shallow injection + HDPE tarp) VOC emissions for Alfalfa = 11.76 x 0.43 = 5.0586 lbs.

ALMOND -- 2004
Number of Records: 92 Total Pounds of Chemical Applied: 25,789.45151 Units Treated: A (acres), C (cubic feet), K (thousand cubic f eet), T (tons), U (misc. unit) Pounds Applied by Unit Treated: 58 records = A (deep injection + HDPE tarp, EF = 0.26) for 19,946.71286 lbs. 17 records = C (assume 100% loss; EF = 1.0) for 1278.769651 lbs. 3 records = K (assume 100% loss; EF = 1.0) for 2387.379 lbs. 6 records = T (assume 100% loss; EF = 1.0) for 989 lbs. 4 records = U (assume 100% loss; EF = 1.0) for 1187.59 lbs. VOC emissions for treated acres of almond = 19,946.71286 x 0.26 = 5,186.14534 lbs. VOC emissions for all other almond applications = 5,842.73865 x 1.0 = 5,842.73865 lbs. Total VOC emissions for Almond = 11,028.884 lbs.

APPLE -- 2004
Number of Records: 1 Total Pounds Chemical Applied: 997.2991 Unit Treated: A (acres) EF based on Application Method: 0.26 (deep injection + HDPE tarp) VOC emissions for Apple = 997.2991 x 0.26 = 259.297766 lbs.

APRICOT -- 2004
Number of Records: 9 Total Pounds Chemical Applied: 784.700504 Units Treated: C (cubic feet), P (pounds), U (misc. unit) Pounds Applied by Unit Treated: 2 records = C (assume 100% loss; EF = 1.0) for 15.70275 lbs. 4 records = P (assume 100% loss; EF = 1.0) for 638.2216 lbs. 3 records = U (assume 100% loss; EF = 1.0) for 130.776154 lbs. Total VOC emissions for Apricot = 784.700504 lbs.CASHEW -- 2004
Number of Records: 1 Total Pounds Chemical Applied: 3 Unit Treated: T (tons; assume 100% loss) EF based on application method: 1.0 VOC emissions for Cashew = 3 x 1.0 = 3.0 lbs.

CHERRY -- 2004
Number of Records: 33 Total Pounds Chemical Applied: 25,753.4966 Units Treated: A (acres), P (pounds), S (square feet) Pounds Applied by Unit Treated: 31 records = A (deep injection + HDPE tarp, EF = 0.26) for 25,214.4966 lbs. 1 record = P (assume 100% loss; EF = 1.0) for 68.6 lbs. 1 record = S (assume 100% loss, EF = 1.0) for 470.4 lbs. VOC emissions for treated acres of cherry = 25,214.4966 x 0.26 = 6,562.78912

VOC emissions for all other che rry applications = 539 x 1.0 = 539 lbs. Total VOC emissions for Cherry = 7,101.78912 lbs.

COMMODITY FUMIGATION -- 2004
Number of Records: 38 Total Pounds Chemical Applied: 16,300.83535

Unit Treated: Unknown EF based on application Me thod: 1.0 (assume 100% loss) VOC emissions for Commodity Fumigation = 16,300.83535 x 1.0 = 16,300.83535 lbs.

COTTON -- 2004
Number of Records: 1 Total Pounds Chemical Applied: 54.1034 Unit Treated: A (acres) EF based on Application Method: 0. 43 (shallow injection + HDPE tarp) VOC emissions for Cotton = 54.1034 x 0.43 = 23.264462 lbs.

CRANBERRY -- 2004
Number of Records: 3 Total Pounds Chemical Applied: 9.1 Unit Treated: T (tons) EF based on Application Method: 1.0 (assume 100% loss) VOC emissions for Cranberry = 9.1 x 1.0 = 9.1 lbs.

EGGPLANT (ORIENTA L EGGPLANT) -- 2004
Number of Records: 1 Total Pounds Chemical Applied: 799.98 Unit Treated: A (acres) EF based on Application Method: 0. 43 (shallow injection + HDPE tarp) VOC emissions for Eggplant = 799.98 x 0.43 = 343.9914 lbs.FIG -- 2004
Number of Records: 9 Total Pounds Chemical Applied: 4,653.4975 Units Treated: C (cubic feet), K (thousand cubic feet) Pounds Chemical Applied by Unit Treated: 8 records = C (assume 100% loss; EF = 1.0) for 64.815 lbs. 1 record = K (assume 100% loss; EF = 1.0) for 4,588.6925 lbs. Total VOC emissions for Fig = 4,653.4975 lbs.

FRUITS (DRIED OR DEHYDRATED) -- 2004
Number of Records: 20 Total Pounds Chemical Applied: 5,967.549 Units Treated: C (cubic feet), T (tons) Pounds Chemical Applied by Unit Treated: 19 records = C (assume 100% loss; EF = 1.0) for 5,409.229 lbs. 1 record = T (assume 100% loss; EF = 1.0) for 558.32 Total VOC emission for Fruits (dried or dehydrated) = 5,967.549 lbs.

FUMIGATION, OTHER -- 2004
Number of Records: 49 Total Pounds Chemical Applied: 14,239.27303

Unit Treated: Unknown EF value based on Applicati on Method: 1.0 (assume 100% loss) VOC emissions for Fumigation, Other = 14,239.27303 x 1.0 = 14,239.27303 lbs.

GRAPES -- 2004
Number of Records: 27 Total Pounds Chemical Applied: 13,182.7389 Units Treated: C (cubic feet), P (pounds), T (tons) Pounds Chemical Applied by Unit Treated: 24 records = C (assume 100% loss; EF = 1.0) for 11,916.1638 lbs. 2 records = P (assume 100% loss; EF = 1.0) for 1,264.576 lbs. 1 record = T (assume 100% loss; EF = 1.0) for 2 lbs. Total VOC emissions for Grapes = 13,182.7389 lbs.

NECTARINE -- 2004
Number of Records: 29 Total Pounds Chemical Applied: 9,771.0202 Units Treated: A (acres), C (cubic feet ), P (pounds), T (tons), U (misc. unit) Pounds Chemical Applied by Unit Treated: 2 records = A (deep injection + HDPE tarp; EF = 0.26) for 6,188.2 lbs. 1 record = C (assume 100% loss; EF = 1.0) for 175.8 lbs. 11 records = P (assume 100% loss; EF = 1.0) for 986.9432 lbs. 5 records = T (assume 100% loss; EF = 1.0) for 1,008.607 lbs. 10 records = U (assume 100% loss; EF = 1.0) for 1,411.47 lbs. VOC emission for treated acres of Nectarine = 6,188.2 x 0.26 = 1,608.932 lbs.

VOC emission for all other Nectarin e applications = 3,582.8202 x 1.0 = 3,582.8020 lbs. Total VOC emissions for Nectarine = 5,191.734 lbs.N-OUTDR CONTAINER/FLD GRWN PLANTS -- 2004
Number of Records: 67 Total Pounds Chemical Applied: 414,159.2887 Unit Treated: A (acres) EF value based on Application Meth od: 0.43 (shallow injection + HDPE tarp) VOC emission for N-Outdr Container Plants = 414,159.2887 x 0.43 = 178,088.494 lbs.

N-OUTDR GRWN TRNSPLNT/PRPGTV MTRL -- 2004
Number of Records: 52 Total Pounds Chemical Applied: 131,928.32 Unit Treated: A (acres) EF value based on Application Meth od: 0.43 (shallow injection + HDPE tarp) VOC emission for N-Outdr Trnsplnt/Prpgtv = 131,928.32 x 0.43 = 56,752.3976 lbs.

NUT CROPS, NUT TREES (ALL OR UNSPEC) -- 2004
Number of Records: 5 Total Pounds Chemical Applied: 79 Unit Treated: T (tons) EF value based on Applicati on Method 1.0 (assume 100% loss) VOC emission for Nut Crops = 79 x 1.0 = 79 lbs.

ONION -- 2004
Number of Records: 4 Total Pounds Chemical Applied: 4,416.64 Unit Treated: A (acres) EF value based on Application Meth od: 0.43 (shallow injection + HDPE tarp) VOC emissions for Onion = 4,416.64 x 0.43 = 1,899.1552

ORANGE -- 2004
Number of Records: 23 Total Pounds Chemical Applied: 4,417.24 Unit Treated: A (acres) EF based on Application Method: 0. 43 (shallow injection + HDPE tarp) VOC emissions for Orange = 4,417.24 x 0.43 = 1,899.4132 lbs.

ORNAMENTAL TURF -- 2004
Number of Records: 7 Total Pounds Chemical Applied: 16,576.7 Unit Treated: A (acres) EF based on Application Method: 0. 43 (shallow injection + HDPE tarp) VOC emissions for Ornamental Turf = 1,576.7 x 0.43 = 7,127.981 lbs.PEACH -- 2004
Number of Records: 31 Total Pounds Chemical Applied: 18,962.44635 Units Treated: A (acres), C (cubic feet ), P (pounds), T (tons), U (misc. unit) Pounds Chemical Applied by Unit Treated: 3 records = A (deep injection + HDPE tarp; EF = 0.26) for 10,492.12325 lbs. 4 records = C (assume 100% loss; EF = 1.0) for 85.215 lbs. 9 records = P (assume 100% loss; EF = 1.0) for 601.8271 lbs. 7 records = T (assume 100% loss; EF = 1.0) for 6,505.4 lbs. 8 records = U (assume 100% loss; EF = 1.0) for 1,277.88 lbs. VOC emission for treated acres of Peach = 10,492.12325 x 0.26 = 2,727.95205 lbs.

VOC emission for all other Peach applications = 8,470.3231 x 1.0 = 8,470.3231 lbs. Total VOC emissions for Peach = 11,198.2751 lbs.

PEAR -- 2004
Number of Records: 3 Total Pounds Chemical Applied: 72.54 Units Treated: A (acres), U (misc. unit) Pounds Chemical Applied by Unit Treated: 2 records = A (acres; deep inje ction + HDPE tarp; EF = 0.26) for 27.44 1 record = U (misc. unit; assume 100% loss; EF = 1.0) for 45.1 lbs.

VOC emissions for treated acres of Pear = 27.44 x 0.26 = 7.1344

VOC emissions for all other Pear applications = 45.1 x 1.0 = 45.1 lbs. Total VOC emissions for Pear = 52.2344 lbs.

PECAN -- 2004
Number of Records: 1 Total Pounds Chemical Applied: 6 Unit Treated: T (tons) EF value based on Applicati on Method: 1.0 (assume 100% loss) VOC emissions for Pecan = 6 x 1.0 = 6 lbs.

PINEAPPLE -- 2004
Number of Records: 1 Total Pounds Chemical Applied: 68.3 Unit Treated: P (pounds) EF value based on Applicati on Method: 1.0 (assume 100% loss) VOC emissions for Pineapple = 68.3 x 1.0 = 68.3 lbs.

PISTACHIO -- 2004
Number of Records: 6 Total Pounds Chemical Applied: 1,155.994 Unit Treated: C (cubic feet), T (tons) Pounds Chemical Applied by Unit Treated: 2 records = C (assume 100% loss; EF = 1.0) for 177 lbs. 4 records = T (assume 100% loss; EF = 1.0) for 987.994 lbs. Total VOC emissions for Pistachio = 1,155.994 x 1.0 = 1,155.994 lbs.PLUM (INCLUDES WILD PLUMS FOR HUMAN CONSUMPTION) -- 2004
Number of Records: 33 Total Pounds Chemical Applied: 3,104.2867 Unit Treated: A (acres), C (cubic feet), P (pounds), T (tons), U (misc. unit) Pounds Chemical Applied by Unit Treated: 2 records = A (deep injection + HDPE tarp; EF = 0.26) for 999.6 lbs. 8 records = C (assume 100% loss; EF = 1.0) for 231.9215 lbs. 12 records = P (assume 100% loss; EF = 1.0) for 661.3392 lbs. 1 record = T (assume 100% loss; EF = 1.0) for 0.026 lbs. 10 records = U (assume 100% lo ss; EF =1.0) for 1,211.4 lbs.

VOC emissions for treated acres of Plum = 999.6 x 0.26 = 259.896 lbs.

VOC emissions for all other Plum applications = 2,104.6867 x 1.0 = 2,104.6867 lbs. Total VOC emissions for Plum = 2364.5827 lbs.

PRUNE -- 2004
Number of Records: 2 Total Pounds Chemical Applied: 555 Unit Treated: C (cubic feet), P (pounds) Pounds Chemical Applied by Unit Treated: 1 record = C (assume 100% loss; EF = 1.0) for 350 lbs. 1 record = P (assume 100% loss; EF = 1.0) for 205 lbs. Total VOC emissions for Prune = 555 x 1.0 = 555 lbs.

RESEARCH COMMODITY -- 2004
Number of Records: Total Pounds Chemical Applied: 2,113.85 Unit Treated: A (acres) EF value based on application met hod: 0.43 (shallow injection + HDPE tarp) VOC emissions for Research Commodity = 2,113.85 x 0.43 = 908.9555 lbs.

RIGHTS OF WAY -- 2004
Number of Records: 2 Total Pounds Chemical Applied: 58.8

Unit Treated: Unknown EF value based on application method: 0.82 (assume shallow in jection, non-tarped) VOC emissions for Rights of Way = 58.8 x 0.82 = 48.216 lbs.

SOIL APPLICATIONS, PREPLANT – OUTDOOR (SEEDBEDS, ETC.) -- 2004
Number of Records: 27 Total Pounds Chemical Applied: 60,945.91 Units Treated: A (acres), C (cubic feet) Pounds Chemical Applied by Unit Treated: 20 records = A (shallow injection + HDPE tarp; EF = 0.43) for 59,671.91 lbs. 7 records = C (assume 100% loss; EF = 1.0) for 1,274 lbs.

VOC emissions for treated acres of Soil Applications = 59,671.91 x 0.43 = 25,658.9213 lbs.

VOC emissions for all other Soil Applications = 1,274 x 1.0 = 1,274 lbs. Total VOC emissions for Soil Applications = 26,932.9213 lbs.STORAGE AREAS & PROCESSING EQUIPMENT (ALL/UNSPEC) -- 2004
Number of Records: 23 Total Pounds Chemical Applied: 2,741.6668 Unit Treated: C (cubic feet) EF value based on application method: 1.0 (assume 100% loss) VOC emissions for Storage Areas = 2,741.6668 x 1.0 = 2,741.6668 lbs.

STRAWBERRY -- 2004
Number of Records: 31 Total Pounds Chemical Applied: 9,644.98 Unit Treated: A (acres) EF value based on application met hod: 0.43 (shallow injection + HDPE tarp) VOC emissions for Strawberry = 9,644.98 x 0.43 = 4,147.3414 lbs,

STRUCTURAL PEST CONTROL -- 2004
Number of Records: 28 Total Pounds Chemical Applied: 4,986.445

Unit Treated: Unknown EF value based on Application method: 1.0 (assume 100% loss) VOC emissions from Structural Pest Control = 4,986.445 x 1.0 = 4,986.445 lbs.

UNCULTIVATED AGRICULTURAL ARE AS (ALL OR UNSPEC) -- 2004
Number of Records: 5 Total Pounds Chemical Applied: 51,265.76 Unit Treated: A (acres) EF value based on Application method: 0.43 (shallow injection + HDPE tarp) VOC emissions from Uncultivated Ag Areas = 51,265.76 x 0.43 = 22,044.2768 lbs.

UNCULTIVATED NON-AGRICULTURAL AREAS (ALL OR UNSPEC) -- 2004
Number of Records: 5 Total Pounds Chemical Applied: 1,657.8918 Unit Treated: A (acres) EF value based on Application method: 0.43 (shallow injection + HDPE tarp) VOC emissions from Uncultivated Ag Areas = 1,657.8918 x 0.43 = 712.893474 lbs.

WALNUT -- 2004
Number of Records: 63 Total Pounds Chemical Applied: 37,380.6043 Units Treated: A (acres), C (cubic feet), S (square feet), T (tons), U (misc. unit) Pounds Chemical Applied by Unit Treated: 22 records = A (acres; deep injec tion + HDPE tarp; EF = 0.26) for 22,450.0859 lbs. 7 records = C (cubic feet; assume 100% loss; EF = 1.0) for 906.5 lbs. 3 records = S (square feet; assume 100% loss; EF = 1.0) for 85.2984 lbs. 20 records = T (tons; assume 100% loss; EF = 1.0) for 8,497.661 lbs. 11 records = U (misc. unit; assume 100% loss; EF = 1.0) for 5,441.059 lbs. VOC emissions for treated acres of Walnut = 22,450.0859 x 0.26 = 5,837.022334 lbs. VOC emissions for all other Walnut applications = 14,930.5184 lbs. Total VOC emissions for Walnut = 20,767.540734 lbs.Summary of 2004 Default and Corrected VOC Emissions Data by Crop/Site

CROP/SITE Default VOC emission (lbs.) Corrected VOC emission (lbs.)

Alfalfa 11.76 5.0586

Almond 25,789.45141 11,028.884 Apple 997.2991 259.297766 Apricot 784.700504 784.700504

Cashew 3 3 Cherry 25,753.4966 7,101.78912 Commodity Fumigation 16,300.83535 16,300.83535

Cotton 54.1034 23.264462 Cranberry 9.1 9.1 Eggplant 799.98 343.9914 Fig 4,653.4975 4,653.4975 Fruits (dried) 5,967.549 5,967.549 Fumigation (other) 14,239.27303 14,239.27303 Grapes 13,182.7389 13,182.7389

Nectarine 9,771.0202 5,191.734

N-Outdr Container/Fld Grwn Plants 414,159.2887 178,088.494 N-Outdr Grwn Trnsplnt/Prpgtv Mtrl 131,928.32 56,752.3976 Nut Crops, Nut Trees 79 79

Onion 4,416.64 1,899.1552 Orange 4,417.24 1,899.4132

Ornamental Turf 16,576.7 7,127.981

Peach 18,962.44635 11,198.2751

Pear 72.54 52.2344

Pecan 6 6 Pineapple 68.3 68.3

Pistachio 1,155.994 1,155.994

Plum 3,104.2867 2,364.5827

Prune 555 555 Research Commodity 2113.85 908.9555 Rights of Way 58.8 48.216 Soil Applications (Preplant) 60,945.91 26,658.9213 Storage Areas & Processing Eq. 2,741.6668 2,741.6668 Strawberry 9,644.98 4,417.3414

Structural Pest Control 4,986.445 4,986.445 Uncultivated Ag Areas 51,265.76 22,044.2768 Uncultivated Non-Ag Areas 1,657.8918 712.893474

Walnut 37,380.6043 20,767.540734

TOTAL 884,615.4696 423,357.7978APPENDIX C

PRODUCT NAMES from PUR database th at are included in the analyses.

1990 2004

75/25 92-2 Contains 2% Chloropicrin Brom-O-Gas (Liquid)

Brom-O-Gas .5%

Brom-O-Gas 2% Brom-O-Gas Contains 1% Chloropicrin DOW Methyl Bromide

Metabrom 100

Meth-O-Gas Meth-O-Gas (Can)

Meth-O-Gas 100 Methyl Bromide 100 Methyl Bromide 98% Methyl Bromide 99.5% Methyl Bromide 99.75% Namco Methyl Bromide

Namco Namfume Shore Chemical Co. Methyl Bromide 100 Shore Chemical Co. Methyl Bromide 99.5%

Terr-O-Gas 57

Terr-O-Gas 75
Tri-Con 57/43

Tri-Con 67/33

Tri-Con 75/25

Tri-Con 80/20 57-43 67-33 Preplant Soil Fumigant 92-2 Contains 2% Chloropicrin Brom-O-Gas (Liquid)

Brom-O-Gas .5% MBC Concentrate Soil Fumigant MBC-33 Soil Fumigant

Metabrom 100 Metabrom Q

Meth-O-Gas Meth-O-Gas (Can)

Meth-O-Gas 100 Methyl Bromide Methyl Bromide 100 Methyl Bromide 98% Methyl Bromide 99.5% Methyl Bromide 99.75% Methyl Bromide Rodent Fumigant

Namco Namfume

Terr-O-Gas 57

Terr-O-Gas 67

Terr-O-Gas 75

Terr-O-Gas 98
Tri-Con 50/50

Tri-Con 57/43

Tri-Con 67/33

Tri-Con 75/25

Tri-Con 80/20Analysis of Chloropicrin Emissions in the San Joaquin Valley in 1990 and 2004

Abstract

This report calculates and summarizes the total am ount of chloropicrin emitted from agricultural and non-agricultural usage in the San Joaquin Valley in 1990 and 2004 during the peak ozone season (May 1 to October 31 of each year). All chloropicrin use data were obtained from the CDPR Pesticide Information Portal (CALPIP) – Pesticide Use Re port (PUR) online database. Using the method that CDPR historically has used, which assumes that 100% of the applied chloropi crin is emitted into the air, approximately 112,646 pounds of chloropicrin were emitted in the eight counties comprising the San Joaquin Valley in 1990 (0.306 tons/day); and approximately 120,808 pounds of chloropicrin were emitted in 2004 (0.328 tons/day). The difference between 1990 and 2004 represents a 7.2% increase in chloropicrin total emissions. An alternative VOC equation, based on mass loss studies and discrete usage data, was developed that takes into account the proportion of chloropicrin that is degraded in the soil (for soil fumigations). It is believed that this alternative VOC emission equation more accurately reflects the total amount of chloropicrin emitted by each crop or site and met hod of application. Using this new equation, approximately 70,931.59 lbs. of chloropicrin was emitted in 1990 (0.193 tons/day), and approximately 41,787.24169 pounds of chloropicrin were emitted in 2004 (0.114 tons/day). The difference between 1990 and 2004, using the corrected VOC equation, represents a 40.9% reduction in chloropicrin total emissions

Data Acquisition and Ov erall Use Statistics

The CALPIP search queries were by Year (“1990” and “2004”) and Chemical Name (“chloropicrin”). In this way, all PUR data for chloropicrin were included, regardless of formulation, product name, crop or site of application, etc. Both Agricultural and Non-Agricultural (under Other Criteria: Reporting Type ) use reports were included.

The aggregate 1990 and 2004 PUR files for chloropicrin were downloaded and contained all PUR reports for the entire State of California. The 1990 Statewide PUR file c ontained 6,418 records of application that, collectively, totaled 2,218,294.898 pounds of chloropicrin. The 2004 Statewide PUR file contained 3,551 records of applicati on that, collectively, totaled 5,132,916.855 pounds of chloropicrin (Table 1).

The 1990 and 2004 Statewide PUR files were then pr ocessed to include only the 8 counties that comprise the San Joaquin Valley: Fresno, Kern, Kings , Madera, Merced, San Jo aquin, Stanislaus, and Tulare. While only part of Kern County is tec hnically included in the San Joaquin Valley VOC nonattainment area, all PUR records fo r Kern County were included in th ese analyses as a conservative measure, because it was not possible to distinguish between the applications that occurred in the nonattainment area and those that did not.

The 1990 PUR file for the San Joaqui n Valley contained 960 records of application that, collectively, totaled 188,762.2068 pounds of chloropicrin. The 2004 PUR file for the San Joaquin Valley contained 439 records of application that , collectively, totaled 328,917.2909 pounds of chloropicrin (Table 1).The 1990 and 2004 San Joaquin Valley PUR files were th en processed to include only the applications that occurred between May 1 and Oc tober 31 of each year, as this period is considered the “peak ozone

season”. The 1990 PUR file for the San Joaquin Valley Ozone Season contained 530 records of application that, collectively, totaled 112,645.6355 pounds of chloropicrin. These 530 records consisted of 228 records for which the dates of app lication were listed and occurred between May 1 and October 31, and an additional 302 records for which no date of application was listed. As a conservative measure, these 530 no-date records were assumed to have occurred during the peak ozone season. The 2004 PUR file for the San Joaquin Valley Ozone Season contained 153 records of application that, collectively, totaled 120,807.6326 pounds of chloropicrin (Table 1).

The total amount of chloropicrin applied in the San Joaquin Valley during the peak ozone season in 2004 (120,807.6326 lbs.) is approximately 107.2% of what was applied in 1990 (112,645.6355 lbs.), representing a 7.2% increase in usage.

Table 1. Cumulative number of records and total pounds of chloropicrin applied in California (whole-year) and the San Joaquin Valley (whole-year and during the “peak ozone season”) for all Agricultural and Non-Agricultural applications in 1990 and 2004.

Year Area & Period No. of Records Amount of Chloropicrin Applied (total lbs.)

1990 Statewide, 12-month 6,418 2,218,294.898

San Joaquin Valley, 12-month 960 188,762.2068

San Joaquin Valley, May 1 to

October 31 530 112,645.6355

2004 Statewide, 12-month 3,551 5,132,916.855

San Joaquin Valley, 12-month 439 328,917.2909

San Joaquin Valley, May 1 to

October 31 153 120,807.6326Analysis of VOC Emissions based on CDPR Procedures

CDPR uses the following equation to calculate VOC emissions from pesticide applications, where EP is defined as the Emissions Potential (VOC fraction) of a given pesticide product:

VOC emission (lbs.) = [lbs. of produ ct applied] * [product-specific EP]

For all chloropicrin products, CD PR assigns a default EP value of 100%. This assumes that 100% of the applied amount of chloropicrin is volatized fr om the soil or other site , such that the total chloropicrin VOC emissions are eq ual to the amount of chloropicrin applied during a specific period, location, etc.

Using this equation for the total amounts applied in Ta ble 1, it can be calculated that the average daily VOC emissions in the San Joaquin Valley during the peak ozone season were approximately 0.306 tons/day in 1990 and 0.328 tons/day in 2004 (2000 pounds = 1 ton; 184 days in May 1 to October 31 period) (Table 2). This represen ts a 0.022 tons/day (or 7.2%) increase in chloropicrin VOC emissions in 2004 compared to 1990.

Alternative Analysis of VOC Emissions based on Mass Loss Studies

While 100% of the applied chloropicrin can theoretic ally be emitted from a given end-use site, studies have demonstrated that, at least for soil fumigation, a portion of the chloropicrin is degraded in the soil and is not emitted into the air (i.e., via mass loss studies ). With respect to this fact, any chloropicrin
VOC emission calculation that assumes 100% emission would considerably overestimate chloropicrin’s contribution to the VOC burden in the San Joaquin Valley or any other area with significant chloropicrin use in so il fumigation. For non- soil fumigation sites (commodity fumigation, structural fumigation, etc.), where there is little opport unity for chloropicrin degradation, the 100% emissions is likely accurate.

Four unpublished studies previously submitted to CDPR provide an array of data on mass loss estimates of chloropicrin during various field fumi gation scenarios. These mass loss studies can be used to more accurately estimate total chloropicrin emissions from soil fumigation activity. Based on these studies, an additional component to the VOC emissions calcu lation was added, where EF = the Emissions Factor, or the proportion of chloropicrin th at is emitted from the application field or site.

This alternative calculation is:

VOC emission (lbs.) = [lbs. of product applied] * [product-specific EP] * [application-specific EF]

By example, if chloropicrin was applied to 10 acres of strawberry at 200 lbs. a.i. (active ingredient) per acre, the total amount applied would be 2,000 lbs. of chloropicrin. The EP value remains 100% (1.0 by proportion), based on 100% of the product being volatile. The EF value would be based on mass loss studies where, in this case, the application is a broadcast shallow (6-15 in.) injection with HDPE tarp, which was estimated to result in 37% emissi on (0.37 by proportion) of th e applied chemical. So, for this example: VOC emission (lbs.) = [2000 lbs.] * [1.0] * [0.37] = 740 lbs. emitted.

Therefore, based on this approach, only 740 lbs. of the 2,000 lbs. of ch loropicrin that was applied, was emitted during this application.Based on the studies, the following EF values were used to calculate total emissions for each crop or site (e.g., soil fumigation vs. stru ctural fumigation), type of fumi gation (e.g., almond acres vs. almond nuts prior to packaging), type of application (e.g., shallow vs. deep shank; tarp or no tarp; dripapplied), where the type of a pplication was determined by the “Unit Treated” and “Product Name”

fields of the PUR records:

Unit Treated:

• A = acres

o Shallow injection (6-15 in .), broadcast, no tarp= 62% emission (EF = 0.62) 1

o Shallow injection (6-15 in.), broadcast, LDPE tarp = 62% emission* (EF = 0.62) 2

o Shallow injection (6-15 in .), broadcast, HDPE tarp = 37% emission (EF = 0.37) 3

o Deep injection (20+ in.), broadcast , no tarp = 62% emission (EF = 0.62) 4

o Deep injection (20+ in.), broadcast, LDPE tarp = 62% emission* (EF = 0.62) 4

o Deep injection (20+ in.), broadcast, HDPE tarp = 37% emission (EF = 0.37) 4

o Drip-application, surface or buried, HDPE tarp = 9% emission (EF = 0.09) 5

1 Cited from: Beard et al. 1996. Monitoring of potential work er exposure, field flux and off-site air concentration during chloropicrin field application. Study # HEH160 (unpublished stud y submitted to CDPR).

2 No studies were found that determined mass loss of chlo ropicrin through LDPE films, regardless of injection depth. However, based on data from other fumigants (e.g., methyl bromide, Yates et al. 1996), LDPE film is assumed to provide virtually no chloropi crin retention properties. Therefore, as a conservative measure, the EF values for all LDPE tarp applications were considered to be equal to the EF values for non-tarped applications.

3 The 37% mass loss estimate was derived as the average from the mass loss measurements from four different sites from which data are available. Using the average mass loss estimate allows for variability in soil type, soil moisture, and other factors that may influence mass loss of chloropicrin from field applications. Study sites and their mass loss estimates from which the average was derived were: Salinas, CA (15% mass loss; Lee et al

. 1994); Yakima, WA (34% mass loss; Beard et al. 1996); Bradenton, FL (37% mass loss; Beard et al. 1996); and Phoenix, AZ (63% mass loss; Beard et al . 1996).

4 No studies were found that determined mass loss of chlo ropicrin at injection depths greater than what is considered shallow (6-15 in.) injection. Therefore, as a conservative measure, all deep injection EF estimates were based on the EF values for shallow injections, even thou gh it is very plausible that deeper injection depths result in lower mass loss values, as was determined for methyl bromide (Yates et al. 1996).

5 The 9% mass loss estimate for drip applications was derived as the average from two mass loss studies because it was not possible to determine, from the PUR database, whether individual applications were buried-drip (3% mass loss; Gillis and Smith 2002) or surf ace-drip (15% mass loss; Rotondaro 2004).

• C = cubic feet (for commodity, potting me dia, etc.; assume 100% loss; EF = 1.0)

• K = thousand cubic feet (for commodity, potting media, etc.; assume 100% loss; EF = 1.0)

• P = pounds (for commodity, potting media, etc.; assume 100% loss; EF = 1.0)

• S = square feet (for greenhouse treatmen ts, etc.; assume 100% loss; EF = 1.0)

• T = tons (for commodity, potting media, etc.; assume 100% loss; EF = 1.0)

• U = miscellaneous unit (for commodity, potting media, etc.; assume 100% loss; EF = 1.0)

• Not Listed = (for commodity, potting me dia, etc.; assume 100% loss; EF = 1.0)As an aggregate example, the following data fo r 2004 chloropicrin applic ations to outdoor grown greenhouse transplant/propagativ e material is used to illustrate the incorporation of a pplication-specific

EF values into the VOC equation:

N-OUTDR GRWN TRNSPLNT/PRPGTV MTRL
Number of Records: 40 Pounds Chemical Applied: 11,357.4905 Unit Treated: A (acres), K (thousand cubic feet), Unknown Pounds Chemical Applied by Unit Treated: 31 records = A (EF = 0.62) for 11,351.1205 lbs. 1 record = K (assume 100% loss; EF = 1.0) for 6 lbs. 8 records = Unknown (assume 100% loss; EF = 1.0) for 0.37 lbs. VOC emissions for shank-injected chloropicrin = 11,351.1205 x 0.62 = 7,037.69471 lbs. VOC emissions for drip-injected chloropicrin = 6.37 x 1.0 = 6.37 lbs. VOC emissions for N-Outdr Trns plnt/Prpgtv Mtrl = 7,044.06471 lbs.

This same aggregate analysis was performed fo r all SITE/CROP listings within both the 1990 and 2004 PUR files. The aggregate analysis and summa ry table for 1990 applications are provided in Appendix A. The aggregate analysis and summ ary table for 2004 applications are provided in Appendix B. These analyses assume the following:

• Approximately 90% of chloropicrin soil fu migations in 1990 were non-tarped and 10% were tarped using LDPE film (primarily as co-formulations with methyl bromide).

• LDPE film is considered to have little ga s retention properties, and therefore, any 1990 applications with LDPE film had EF va lues that were the same as non-tarped applications.

• LDPE film was only used in 1990 and not in 2004.

• All CDPR-approved HDPE films were assigned the same EF, which was based on mass
loss studies.

• All 2004 soil applications where chloropicrin was co-formulated with methyl bromide used HDPE film, regardless of injection depth.

• All 2004 drip-applications of chloropicrin were assumed to be tarped with HDPE.

• All non-acre applications are assumed to result in 100% emission of product.

Based on the sum values for the EF -corrected VOC emission equations that were applied to each Crop/Site by year, it is calculated that 70,931.59 lbs. of chloropicrin were emitted in the eight counties comprising the San Joaquin Valley during the pe ak ozone season in 1990 (0.193 tons/day), and 41,787.24169 lbs. of chloropicrin were emitted in 2004 (0.114 tons/day). The 2004 VOC total is approximately 59.1% of the 1990 total, which equates to a 40.9% reductio n in chloropicrin emissions.Table 2. Default and Corrected Chloropicrin VOC emissions.

Year Default VOC emissions

(tons/day) z VOC emissions corrected using

mass loss data (tons/day) y

1990 0.306 0.193

2004 0.328 0.114

z Values assume 100% emission of applied material.

y Values incorporate empirically-derived mass loss data.

CONCLUSION

When the type of application is not considered and 100% of the applie d chloropicrin is assumed to be emitted, the total VOC emissions of chloropicr in increased from 0.306 tons/day in 1990 to 0.328 tons/day in 2004. When the type of application is considered relative to the proportion of chloropicrin that is degraded in the soil, th e total VOC emissions of chloropicr in were reduced from 0.193 tons/day in 1990 to 0.114 tons/day in 2004.

The Product Names listed in the PUR databa se files are presented in Appendix 3.

References Cited:

Beard, et al. 1996. Monitoring of potential worker expos ure, field flux and off-site air concentration during chloropicrin field application. Study # HEH160. Unpublished study submitted to CDPR.

Gillis, M. and G.S. Smith. 2002. Chloropicrin emissions and offsite drift from tarped and non-tarped fields treated by a drip irri gation application method. Study # TC350. Unpublished study submitted to

CDPR.

Lee, H., K.V. Natta, and M. Gillis. 1994. TC246/ BR707 Chloropicrin workers exposure, flux and offsite monitoring and dispersion modeling for tarped broadcast app lication – pilot study. Unpublished study submitted to CDPR.

Rotondaro, A. 2004. Monitoring of chloropicrin emi ssions from field and gr eenhouse drip irrigation applications, and implied worker inhalation exposur e from applications of chloropicrin by shank injection, drip irrigation systems and at tree re plant sites. Study # PRS02004. Unpublished study

submitted to CDPR.

Yates, S.R., J. Gan, F.F. Ernst, D. Wang, and M. Yates. 1996. Emissions of methyl bromide from agricultural fields: rate estimates and methods of reduction, pp. 116-134. In Seiber et al. 1996, Fumigants: Environmental Fate, Ex posure, and Analysis. American Chemical Society, Washington,

DC.

### APPENDIX A

1990 Chloropicrin VOC Emissions in the San Joaquin Valley

ALFALFA (FORAGE, FODDE R) (ALFALFA HAY)
Number of Records: 4 Pounds of Chemical Applied: 1,863.375 Units Treated: A (acres), T (tons), U (misc. unit) Total Pounds Applied by Unit Treated: 2 records = A (EF = 0.62) for 80.5 lbs. 1 record = T (assume 100% loss; EF = 1.0) for 1,782 lbs. 1 record = U (assume 100% loss; EF = 1.0) for 0.875 lbs. VOC emissions for shank-injected chloropicrin = 80.5 x 0.62 = 49.91 lbs.

VOC emissions for all other Alfalf a applications = 1,782.875 x 1.0 = 1,782.875 lbs. VOC emissions for Alfalfa = 1,832.785 lbs.

ALMOND
Number of Records: 22 Total Pounds of Chemical Applied: 80.076 Units Treated: A (acres), S (square feet), T (tons), U (misc. unit) Total Pounds Applie d by Unit Treated: 6 records = A (EF = 0.62) for 74.316 lbs. 1 record = S (assume 100% loss; EF = 1.0) for 0.875lbs. 1 records = T (assume 100% loss; EF = 1.0) for 0.825 lbs. 14 records = U (assume 100% loss; EF = 1.0) for 7.06 lbs. VOC emissions for shank-injected chloropicrin = 74.316 x 0.62 = 40.07592 lbs. VOC emissions for all other Almond applications = 8.76 x 1.0 = 8.76 lbs. VOC emissions for Almond = 54.83592 lbs.

APRICOT
Number of Records: 2 Pounds Chemical Applied: 7.015 Unit Treated: A (acres) EF based on application method: 0.62 VOC emissions for Apricot = 7.015 x 0.62 = 4.3493 lbs.

BEEHIVES (ALL OR UNSPEC)
Number of Records: 4 Pounds Chemical Applied: 2.5 Unit Treated: A (acres) ? EF based on application method: 1.0 (assume 100% loss)) VOC emissions for Beehives= 2.5 x 1.0 = 2.5 lbs.CHERRY
Number of Records: 7 Total Pounds Chemical Applied: 9.8424 Units Treated: A (acres) EF based on application method: 0.62 VOC emissions for Cherry = 9.8424 x 0.62 = 6.102288 lbs.

COTTON, GENERAL
Number of Records: 1 Pounds Chemical Applied: 7.3 Unit Treated: A (acres) EF based on application Method: 0.62 VOC emissions for Cotton, General = 7.3 x 0.62 = 4.526 lbs.

GRAPES
Number of Records: 6 Pounds Chemical Applied: 186.179 Unit Treated: A (acres), K (thousand cubic feet) EF based on Application Method: 0.62 (shank injecti on) for 177.284 lbs. 1.0 (commodity fumigation) for 8.895 lbs. VOC emissions for shank-injected chloropicrin = 177.284 x 0.62 = 109.91608 lbs. VOC emissions for all other Grape applications = 8.895 x 1.0 = 8.895 lbs. VOC emission Grapes = 118.81108 lbs.

GRAPES, WINE
Number of Records: 10 Pounds Chemical Applied: 2,876.135 Unit Treated: A (acres) EF based on application method: 0.62 VOC emissions for Grapes, Wine = 2,876.135 x 0.62 = 1,783.2037 lbs.

KIWIFRUIT
Number of Records: 1 Pounds Chemical Applied: 12.99 Unit Treated: A (acres) EF based on Application Method: 0.62 VOC emissions for Kiwifruit = 12.99 x 0.62 = 8.0538 lbs.

LANDSCAPE MAINTENANCE
Number of Records: 6 Pounds Chemical Applied: 0.35

Unit Treated: Unknown EF based on Application Method: 1.0 (assume 100% loss) VOC emissions for Landscape Maintenance = 0.35 x 1.0 = 0.35 lbs.NECTARINE
Number of Records: 15 Pounds Chemical Applied: 576.575 Unit Treated: A (acres) EF based on Application Method: 0.62 VOC emissions for Nectarine= 576.575 x 0.62 = 357.4765 lbs.

N-GRNHS GRWN TRNSPLNT/PRPGTV MTRL
Number of Records: 7 Pounds Chemical Applied: 4.139 Units Treated: S (s quare feet); Unknown EF value based on application method: 1.0 (assume 100% loss) VOC emissions for N-Grnhs Grwn Trns plnt/Prpgtv Mtrl = 4.139 x 1.0 = 4.139 lbs.

N-OUTDR CONTAINER/FLD GRWN PLANTS
Number of Records: 31 Pounds Chemical Applied: 57,373.252 Unit Treated: A (acres)

EF value based on A pplication Method: 0.62 VOC emissions for N-Outdr Container Plants = 57,373.252 x 0.62 = 35,571.41624 lbs.

N-OUTDR GRWN TRNSPLNT/PRPGTV MTRL
Number of Records: 40 Pounds Chemical Applied: 11,357.4905 Unit Treated: A (acres), K (thousand cubic feet), Unknown Pounds Chemical Applied by Unit Treated: 31 records = A (EF = 0.62) for 11,351.1205 lbs. 1 record = K (assume 100% loss; EF = 1.0) for 6 lbs. 8 records = Unknown (assume 100% loss; EF = 1.0) for 0.37 lbs. VOC emissions for shank-injected chloropicrin = 11,351.1205 x 0.62 = 7,037.69471 lbs. VOC emissions for drip-injected chloropicrin = 6.37 x 1.0 = 6.37 lbs. VOC emissions for N-Outdr Trns plnt/Prpgtv Mtrl = 7,044.06471 lbs.

NUT CROPS, NUT TREES (ALL OR UNSPEC)
Number of Records: 8 Pounds Chemical Applied: 15.45 Unit Treated: C (cubic feet), S (square feet), T (tons) EF value based on Appli cation Method: 1.0 (assume 100% loss for C, S, T units) VOC emissions for Nut Crops = 15.45 x 1.0 = 15.42 lbs.

ONION
Number of Records: 4 Pounds Chemical Applied: 22.86 Unit Treated: A (acres)

EF value based on A pplication Method: 0.62 VOC emissions for Onion = 22.86 x 0.62 = 14.1732 lbs.ORANGE
Number of Records: 2 Pounds Chemical Applied: 24.835 Unit Treated: A (acres) EF based on Application Method: 0.62 VOC emissions for Orange = 460 x 0.62 = 285.2 lbs.

PEACH
Number of Records: 12 Pounds Chemical Applied: 218.3 Unit Treated: A (acres), U (misc. unit) Pounds Chemical Applied by Unit Treated: 11 records = A (EF = 0.62) for 218.22 lbs. 1 record = U (assume 100% loss; EF = 1.0) for 0.08 lbs. VOC emissions for shank-injected chloropicrin = 218.22 x 0.62 = 135.2964 lbs. VOC emissions for all other Peach applications = 0.08 x 1.0 = 0.08 lbs. VOC emissions for Peach = 135.3764 lbs.

PEAR
Number of Records: 1 Pounds Chemical Applied: 6.7 Unit Treated: A (acres)

EF value based on A pplication Method: 0.62 VOC emissions for Pear = 6.7 x 0.62 = 4.154 lbs.

PETS
Number of Records: 2 Pounds Chemical Applied: 0.05 Unit Treated: S (square feet) EF value based on Applicati on Method: 1.0 (assume 100% loss) VOC emissions for Pets = 0.05 x 1.0 = 0.05 lbs.

PLUM (INCLUDES WILD PLUM FOR HUMAN CONSUMPTION)
Number of Records: 10 Pounds Chemical Applied: 180.765 Unit Treated: A (acres)

EF value based on A pplication Method: 0.62 VOC emissions for Plum = 180.765 x 0.62 = 112.0743 lbs.

RIGHTS OF WAY
Number of Records: 1 Pounds Chemical Applied: 1 Unit Treated: A (acres)

EF value based on A pplication Method: 0.62 VOC emissions for Rights of Way = 1 x 0.62 = 0.62 lbs.SOIL APPLICATIONS, PREPLANT – OUTDOOR (SEEDBEDS, ETC.)
Number of Records: 1 Pounds Chemical Applied: 0.045 Units Treated: S (square feet) EF based on application method: 1.0 (assume 100% loss) VOC emissions for Soil Applications = 0.045 x 1.0 = 0.045 lbs.

STRAWBERRY
Number of Records: 20 Pounds Chemical Applied: 35,693.099 Unit Treated: A (acres) EF value based on application method: 0.62 VOC emissions for Strawberry = 35,693.099 x 0.62 = 22,129.72138 lbs.

STRUCTURAL PEST CONTROL
Number of Records: 265 Pounds Chemical Applied: 967.196405

Unit Treated: Unknown EF value based on Application method: 1.0 (assume 100% loss) VOC emissions from Structural Pest Control = 967.196405 x 1.0 = 967.196405 lbs.

TOMATO
Number of Records: 6 Pounds Chemical Applied: 144.787 Units Treated: A (acres); S (square feet) Pounds Chemical Applied by Unit Treated: 2 records = A (EF = 0.62) for 144.787 lbs. 4 records = S (assume 100% loss; EF = 1.0) for 1 lb.

VOC emissions for treated acres of Tomato = 144.787 x 0.62 = 89.76794 lbs. VOC emissions for all other tomato applications = 1 x 1.0 = 1 lb. Total VOC emissions for Tomato = 90.76794 lbs.

UNCULTIVATED AGRICULTURAL AREAS (ALL OR UNSPEC)
Number of Records: 14 Pounds Chemical Applied: 448.295 Units Treated: A (acres) EP value based on application method: 0.62 VOC emissions for Uncultivated Ag Areas = 448.295 x 0.62 = 277.9429 lbs.

WALNUT
Number of Records: 18 Pounds Chemical Applied: 169.3191505 Units Treated: A (acres), U (misc. unit) Pounds Chemical Applied by Unit Treated: 11 records = A (EF = 0.62) for 166.4606505 lbs. 7 records = U (assume 100% loss; EF = 1.0) for 2.8585 lbs.VOC emissions for treated acres of Walnut = 166.4606505 x 0.62 = 103.20560331 lbs. VOC emissions for all other Walnut applications = 2.8585 x 1.0 = 2.8585 lb. VOC emissions for Walnut = 106.06410331 lbs.

WOOD PROTECTION TREATMENTS
Number of Records: 3 Pounds Chemical Applied: 0.14 Units Treated: C (cubic feet) EP value based on Application method: 1.0 (assume 100% loss) Total VOC emissions for Wood Protectio n Treatments = 0.14 x 1.0 = 0.14 lbs.

Summary of 1990 Default and Corrected VOC Emissions Data by Crop/Site

CROP/SITE Default VOC emission (lbs.) Corrected VOC emission (lbs.)

Alfalfa 1,863.375 1,832.785

Almond 80.076 54.83592 Apricot 7.015 4.3493 Beehives (all or unspec) – all beehives 2.5 2.5 Cherry 9.8424 6.102288

Cotton 7.3 4.526 Grapes 186.179 118.81108 Grapes, Wine 2,876.135 1,783.2037

Kiwifruit 12.99 8.0535 Landscape Maintenance 0.35 0.35

Nectarine 576.575 357.4765 N-Grnhs Grwn Trnsplnt/Prpgtv Mtrl 4.139 4.139

N-Outdr Container/Fld Grwn Plants 57,373.252 35,571.41624 N-Outdr Grwn Trnsplnt/Prpgtv Mtrl 11,357.4905 7,044.06471 Nut Crops, Nut Trees 15.45 15.45

Onion 22.86 14.1732 Orange 24.835 285.2

Peach 218.3 135.375

Pear 6.7 4.154

Pets 0.05 0.05

Plum 180.765 112.0743 Rights of Way 1 0.62 Soil Applications (preplant) 0.045 0.045 Strawberry 35,693.099 22,129.72138

Structural Pest Control 967.196405 967.196405

Tomato 144.787 90.76794 Uncultivated Ag Areas 448.295 277.9429

Walnut 169.3191505 106.06410331

Wood Protection treatments 0.14 0.14

TOTAL 112,645.6355 70.931.59

### APPENDIX B 2004 Chloropicrin VOC Emissions in the San Joaquin Valley

ALMOND
Number of Records: 5 Total Pounds of Chemical Applied: 67.23 Units Treated: C (cubic feet), U (misc. unit) Total Pounds Applie d by Unit Treated: 3 records = C (assume 100% loss; EF = 1.0) for 26.145 lbs. 2 records = U (assume 100% loss; EF = 1.0) for 41.085 lbs. VOC emissions for Almond = 67.23 x 1.0 = 67.23 lbs.

CARROTS
Number of Records: 1 Pounds Chemical Applied: 70 Unit Treated: A (acres) EF based on application method: 0.37 VOC emissions for Carrots = 70 x 0.37 = 25.9 lbs.

CHERRY
Number of Records: 2 Total Pounds Chemical Applied: 0.66 Units Treated: A (acres) EF based on application method: 0.37 VOC emissions for Cherry = 0.66 x 0.37 = 0.2442 lbs.

EGGPLANT
Number of Records: 1 Pounds Chemical Applied: 394.02 Unit Treated: A (acres) EF based on application Method: 0.37 VOC emissions for Eggplant = 394.02 x 0.37 = 145.7874 lbs.

FUMIGATION, OTHER
Number of Records: 4 Pounds Chemical Applied: 12.874

Unit Treated: Unknown EF based on Application Method: 1.0 (assume 100% loss) VOC emission for Fumigation, Other = 12.874 x 1.0 = 12.874 lbs.

MELONS
Number of Records: 1 Pounds Chemical Applied: 674.6642604 Unit Treated: A (acres) EF based on Application Method: 0.09 (drip) VOC emissions for Melons = 674.6642604 x 0.09 = 60.719783436 lbs.NECTARINE
Number of Records: 1 Pounds Chemical Applied: 17.8 Unit Treated: A (acres) EF based on Application Method: 0.37 VOC emissions for Nectarine= 17.8 x 0.37 = 6.586 lbs.

N-OUTDR CONTAINER/FLD GRWN PLANTS
Number of Records: 28 Pounds Chemical Applied: 44,621.52827 Unit Treated: A (acres) EF value based on Application Me thod: 0.37 (shank) and 0.09 (drip) VOC emissions for shank injected chloropicrin = 41,342.75515 x 0.37 = 15,296.8194055 lbs. VOC emissions for drip-injected chloropicrin = 3,278.773123 x 0.09 = 295.08949107lbs. Total VOC emissions for N-Outdr Container Plants = 15,591.90889657 lbs.

N-OUTDR GRWN TRNSPLNT/PRPGTV MTRL
Number of Records: 40 Pounds Chemical Applied: 45,867.845 Unit Treated: A (acres)

EF value based on A pplication Method: 0.37 VOC emissiosn for N-Outdr Trnsplnt/Prpgtv = 45,867.845 x 0.37 = 16,971.10265 lbs.

ONION
Number of Records: 5 Pounds Chemical Applied: 2,595.36 Unit Treated: A (acres)

EF value based on A pplication Method: 0.37 VOC emissions for Onion =2,595.36 x 0.37 = 960.2832

ORANGE
Number of Records: 1 Pounds Chemical Applied: 460 Unit Treated: A (acres) EF based on Application Method: 0.37 VOC emissions for Orange = 460 x 0.37 = 170.2 lbs.

RESEARCH COMMODITY
Number of Records: 2 Pounds Chemical Applied: 1,041.15 Unit Treated: A (acres) EP value based on application method: 0.37 VOC emissions for Research Commodity = 1,041.15 x 0.37 = 385.2255 lbs.SOIL APPLICATIONS, PREPLANT – OUTDOOR (SEEDBEDS, ETC.)
Number of Records: 14 Pounds Chemical Applied: 14,693.47 Units Treated: A (acres) EF based on application method: 0.09 (drip) for 1,142.46 lbs. 0.37 (shank) for 13,551.01 lbs. VOC emissions for shank injected chloropicrin = 13,551.01 x 0.37 = 5,013.8737 lbs. VOC emissions for drip-injected chloropicrin = 1,142.46 x 0.09 = 102.2814 lbs. Total VOC emissions for Soil Applications = 5,116.6951 lbs.

STRAWBERRY
Number of Records: 29 Pounds Chemical Applied: 4,804.89 Unit Treated: A (acres) EF value based on application method: 0.37 VOC emissions for Strawberry = 4,804.89 x 0.37 = 1,777.8093 lbs.

STRUCTURAL PEST CONTROL
Number of Records: 15 Pounds Chemical Applied: 20.02974

Unit Treated: Unknown EF value based on Application method: 1.0 (assume 100% loss) VOC emissions from Structural Pest Control = 20.02974 x 1.0 = 20.02974 lbs.

WALNUT
Number of Records: 1 Pounds Chemical Applied: 0.2 Units Treated: A (acres) EF value based on Application method: 0.37 VOC emissions for Walnut = 0.2 x 0.37 = 0.074 lbs.

WATERMELONS
Number of Records: 3 Pounds Chemical Applied: 5,465.911344 Units Treated: A (acres) EF value based on Application method: 0.09 (drip) for 4,975.911373 lbs. 0.37 (shank) for 490 lbs. VOC emissions for drip injected chloropicrin = 4,975.911373 x 0.09 = 447.83202357 lbs. VOC emissions for shank-injected chloropicrin = 72.27 x 0.37 = 26.7399 lbs. Total VOC emissions for Watermelons = 474.57192357 lbs.Summary of 2004 Default and Corrected VOC Emissions Data by Crop/Site

CROP/SITE Default VOC emission (lbs.) Corrected VOC emission (lbs.)

Almond 67.23 67.23

Carrots 70 25.9 Cherry 0.66 0.2442 Eggplant 394.02 145.7874 Fumigation (other) 12.874 12.874

Melons 674.6642604 60.719783436

Nectarine 17.8 6.586

N-Outdr Container/Fld Grwn Plants 44,621.52827 15,591.90889657 N-Outdr Grwn Trnsplnt/Prpgtv Mtrl 45,867.845 16,971.10265

Onion 2,595.36 960.2832 Orange 460 170.2 Research Commodity 1,041.15 385.2255 Soil Applications (Preplant) 14,693.47 5,116.6951 Strawberry 4,804.89 1,777.8093

Structural Pest Control 20.02974 20.02974

Walnut 0.2 0.074

Watermelons 5,465.91134 474.57192357

TOTAL 120,807.6326 41,787.24169APPENDIX C

PRODUCT NAMES from PUR database th at are included in the analyses.

1990 2004

75/25

Chlor-O-Pic Chloropicrin-100 Chloropicrin 100 Soweco Brand

Larvacide 100 Methyl Bromide 98% Methyl Bromide 99.5% Methyl Bromide Fumigant

Namco Namfume Namco Chloropicrin Shore Chemical Co. Methyl Bromide 99.5% SMCP Chloropicrin Fumigant

Soweco Larvacide 100

Terr-O-Gas 57

Terr-O-Gas 75
Tri-Con 57/43

Tri-Con 67/33

Tri-Con 75/25

Tri-Con 80/20

Tri-Form 40/60 57-43 67-33 Preplant Soil Fumigant

Chlor-O-Pic Chloropicrin-100

InLine MBC-33 Soil Fumigant Metapicrin Methyl Bromide 98% Methyl Bromide 99.5%

Namco Namfume

Telone C-35

Terr-O-Gas 57

Terr-O-Gas 67

Terr-O-Gas 75
Tri-Clor

Tri-Con 50/50

Tri-Con 57/43

Tri-Con 67/33

Tri-Con 75/25

Tri-Con 80/20