### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON, D.C. 20460

OFFICE OF

PREVENTION, PESTICIDES

AND TOXIC SUBSTANCES

PC Code No.: 080302

DP Barcode s : 414489

Date: May 19, 2014

MEMORANDUM

SUBJECT: Estimated Drinking Water Co ncentrations of Fluopyram New Uses on Cotton (in

furrow and seed treatment) , Soybeans (seed treatment) and Peanuts ( in

- furrow and foliar

applications) for the Use in Human Health Risk Assessment.

TO: Marcel Howard , Risk Manager Reviewer,

Fungicide Br anch, Registration Division (7505 P )

AND Christine Olinger

, Branch Chief, RAB 3

Health Effects Division (7509 P )

FROM: Mohammed A. Ruhman , Ph.D

., Senior Agronomist.

Environmental Risk Branch V

, Environmental Fate and Effects Division (7507 P )

THRU: Ma h T. Shamim, Ph.D., Chief

Environmental Risk Branch V

, Environmental Fate and Effects Division (7507 P )



## I. Summary

This memo presents the Estimated Drinking Water Concentrations (EDW Cs) for parent fluopyram

for use in an FQPA human health risk assessmen t.

It is noted that the registrant is seeking registration of fluopyram

, for new use s as a fungicide to

prevent and/or control fungus diseases on cotton ( as a seed treatment and in

- furrow application

during planting), s oybeans ( as seed treatment only ) and Peanuts ( in

- furrow application during

planting and as foliar spray)

.

EDWCs for current and new uses are summarized in Table 1 , below.2



### Table 1 A list of the surface/ground water EDWC values for fluopyram.

Surface Water EDWCs (ppb); 1

- in

- - 10 Years ) ) 1

Ground W ater EDWCs (ppb) 2

Acute Non

- cancer/Chronic Can cer/Chronic Acute Chronic

19.4 4.90 3.487 87.5 76.8

1 Surface water is based on: acute value from STD MScotton scenario and chronic values from MEpotato scenario.

2 Ground water is based o n WISANDS_STD GW Scenario noting that the acute/chronic values obtained for ground

water by SCIGROW modeling did not change from previous assessment (value= 0.319 ppb ; not included in the Table )



### Based on the results above, the surface water acute 1

- in

- 10 years peak EDWC is 19.4 ppb for

parent fluopyram while the surface water non

- cancer/chronic 1

- in

- 10 years annual mean EDWC is

4.90 ppb and the 1

- in

- 10

- years overall mean cancer/chronic is 3.487 ppb . For ground water the

acute EDWCs is 87.5 ppb and the ch ronic 76.8 ppb

.

The above stated values should replace earlier estimates as it represent the upper

- bound estimates of

total concentrations that might be found in surface water and ground water due to the current and

new use of fluopyram as a fungicide. EDWCs for surface water ( Table 1 ) may be considered as

refined due to the fact that foliar decay rate was used in all PRZM/EXAMS modeling runs. This

refinement resulted in only slight reduction in the acute values and much significant reduction in the

non

- cancer and cancer EDWCs. Foliar decay rate was calculated from two studies in which the

residue was determined on and in foliage with no rain or irrigation occurring during the study period.

EDWCs for ground water may be further refined, if needed.



## II. I ntroduction

Previously, t he screening level EDWCs from surface water sources were calculated using Tier II

PRZM (Pesticide Root Zone Model) and EXAMS (Exposure Analysis Modeling System). The

Tier I SCI

- GROW ( S creening C oncentration in Gro und W ater) model was used for calculating

the EDWCs from ground water sources. The se previous estimates are presented in the attached

EDWC Memo ( Attachment 1 : DP Barcodes: 3533

- 19, 3638

- 12/20

- 22 & 24, and 3697

- 73 dated

July 8, 2011)

.

The new use patterns are summarized in Table 2 based on the proposed new label of Fluopyram ST

( EPA Reg. No. 264

- XXX) and the amended label of Luna ® 

### Privilege ( EPA Reg. No. 264

- 1078 )

.3



### Table 2 New and amended use patterns for fluopyram

C rop Form 1 Maximum Rates (lbs a.i/A Minimum

Inte rvals

( days) Application Method (s) and

Timing

Cotton seed treatment 1 0.066 2 0.066 Not Applicable Seed Treatment

Cotton 2 0.222 0.222 Not Applicable In

- Furrow application at

planting; Assume Ground

C otton t otal 1 & 2 0.066 + 0.222 0.288 Not Applicable Assume Ground application

at time of seeding (Seed +

Furrow)

Soybean s eed treatment 1 0.138 3 0.138 Not Applicable Seed Treatment

Peanuts 2 0.222 0.445 14 Assume Ground application

at time of seeding (Furrow) +

another foliar application

post

- emergence ( Ground

, Air Or Chemigation)

1 Form= Formulation: 1= Fluopyram ST: EPA Reg. No. 264

- XXX ( a.i Fluopyram alone); and 2= Luna ® Privilege: EPA

Reg. No. 264

- 1078 ( a. I Fluopyram alone)

2 C alculations of the cotton seeds application rate/A is based on BEAD m axim um seeding rate of 85,000 seeds/A :

Application Rate= 0.07716 X (85,000/100,000)= 0.065586 lbs a.i /A

3 Calculations of soybean seeds application rate/A is based on BEAD m aximum seeding rate of 250,000 seeds/A :

Application Rate= 0.07716 X (250,000 140,00)= 0.137786 lb a.i /A



### In consideration of the new labels and the required use of the new PRZM ground water model

(PRZM

- GW), it was necessary to perform the following:

(1) For surface water EDWCs: execute new PRZM/EXAMS r uns to represent the new crops

of cotton (CAcotton WirrigSTD and MScottonSTD ) ; soybeans ( MSsoybeanSTD ) ; and

peanuts NCpeanutSTD ) ; and

(2) For ground water: execute PRZM

- GW runs for all the crops (new and currently registered

uses)



## III. Estimating Drinking Water Exposure from Surface Water Sources

W ith few exceptions, the exact procedure/parameters used previously in in the attached EDWC

Memo ( Attachment 1 : DP Barcodes: 3533

- 19, 3638

- 12/20

- 22 & 24, and 3697

- 73 dated July 8,

2011) were used in modeling the proposed new uses

. The exceptions include the use of

appropriate application parameters ( Table 2 ), scenarios, chemical application method (CAM=4

for soil incorporation instead of CAM 2 for foliar application ) and seeding depths of 1.27 cm for

cotton, 1.91 cm for soybeans and 3.81 cm for peanuts. Addi tionally, no drift was assumed for

modeling the seed treatment uses.

Tier II PRZM/EXAM results for the new uses are summarized in Table 3 , below.4



### Table 3 A summary of surface water EDWC s (in ppb) for the proposed new uses of fluopyram

Crop: Scenario Acute (Peak) Non

- cancer/Chronic Can cer/Chronic

Cotton: MScotton 19.42 4. 614 2.837

Cotton: CAcotton 4.12 1.725 0.785

Soybeans: MSsoybeans 15.33 3.461 1.212

Peanuts: NCpeanuts 6.43 2.327 1.798



### In comparison with surface water EDWCs for currently registered crops, the peak value of 19.42 for

new use on cotton was higher than the FLcucumber value of 12.97 ppb and therefore it replaces the

peak value assigned previously for fluopyram. Chronic values are lower, therefore these values stay

t he same.5



## IV. Estimating Drinking Water Exposure from Ground Water Sources

As per current EFED policy, ground water exposure was modeled using Tier I PRAZM

- GW and

SCI

- GROW models. Parameters used in modeling runs were as follows:

Scenarios and applica tion rates and associated parameters:

PRZM

- GW calls for using six standard scenarios representing vulnerable ground waters, namely:

(1) DELMARVA_STD GW, (2) FLCITRUS_STD GW, (3) FLPOTATO_STD, (4)

GACOASTAL_STD GW, (5) NCCOASTAL _STD, and (6) WISANDS_STD GW

. Table 4

contains a summary of the maximum active rate (lbs a.i/A) for all crop use patterns categorized

in three application rate categories.

Table 4 Summary of PRZM

- GW and SCI

- GROW input parameters for fluopyram

Parameter Value* Reference (MRID Numb er)

All Crops , including new use on

peanuts and excluding new uses on

cotton and soybeans : Highest

Application Rate; N umber of

Applications/Year and Minimum

intervals between applications Two applications of 0.22 5 lb a.i/A (0.252 kg/h ) with 5

- day inter val

(Current & new labels: the m aximum label rate for all crops including new

uses = 0. 45 lbs a.i/A entered in two applications of 0.225 l bs a.i/A )

Cotton : Highest Application Rate for

seeds+ Furrow) One application of 0.2 88 lb a.i/A (0.323 kg/h ; New la bel)

Soybean : Highest Application Rate

for seeds One applications of 0. 138 lb a.i/A (0.155 kg/h ; New Label )

Aerobic Soil Metabolism t1⁄2 (days) Median: 295

90 th %: 464 Median : of 12 values for SCIGROW run; and

90 th %: 90 th percentile value for PRZ M

- GW runs

(MRID s 473723

- 07 to 09)

Hydrolysis t1⁄2 (days) Stable MRIDs 473723

- 03/07

Koc (L Kg

- 1) Median: 397

Average: 439 Median: of 5 values for SCIGROW run;

Average : of 5 values for PRZM

- GW runs

(MRID 473723

- 01)

* As per current and proposed new l abels for the crops and Guidance for Selecting Input Parameters in Modeling the

Environmental Fate and Transport of Pesticides.



### Due to the fact that application rate is the main driver for expected ground water E DWCs it was

decided to model all scenarios with the highest application rate and minimum interval to

represent all current crops, except the new uses for cotton

, soybeans and peanuts . T hree runs

were executed separately for these three crops using the scenario that gives the highest EDWCs;

that was WISANDS_STD GW. Other PRZM

- GW input parameters are included in Table 4

, above.6



### Results for PRZM

- GW modeling are summarized in Table 5

.

Table 5 PRZM

- GW estimated drinking water concentrations (EDWCs ppb ) in ground water

resulting from current and new us es of fluopyram

Crop Application

Date Scenario Highest

Daily Value Post Breakthrough

Average Average Simulation

Breakthrough Time

April 15 WISANDS_STD 87.5 76.8

May 15 WISANDS_STD 86.5 75.8

June 15 WISANDS_STD 85.2 74 .0 8,250.152 days

April 15 F LCITRUS_STD 64.3 58.8

May 15 FLCITRUS_STD 63.9 58.2

June 15 FLCITRUS_STD 63.5 57.7 5,134.006 days

April 15 NCCOASTAL_STD 63.1 59.0

May 15 NCCOASTAL_STD 63.5 59.3

June 15 NCCOASTAL_STD 64.4 60.0 6,014.616 days

April 15 DELMARVA_STD 57.3 50.0

May 15 DELMARVA_STD 56.1 49.0

June 15 DELMARVA_STD 56.0 48.4 6,241.621 days

April 15 GACOASTAL_STD 20.4 17.2

May 15 GACOASTAL_STD 20.8 17.5

June 15 GACOASTAL_STD 20.8 17.4 8,491.507 days

April 15 FLPOTATO_STD 3.73 3.61

May 15 FLPOTATO_S TD 3.68 3.56

All

Currently

Registered

Crops June 15 FLPOTATO_STD 3.66 3.55 10,182.630 days

Peanuts

(new use) May 01 WISANDS_STD 86.4 75.8

Soybeans

(new Use April 15 WISANDS_STD 26.9 23.6

Cotton

(new use) April 15 WISANDS_STD 56.0 49.1 8,250.152 days



### Data in Table 5 indicated that the highest acute ground water EDWC is 87.5 ppb of parent

fluopyram and the chronic value is 76.8 ppb of parent fluopyram. These values are much higher

than the SCIGROW derived acute/chronic value of 0.319 ppb. Therefore t hese new values should

be replaced by the PRZM

- GW values.