### Page 2 of 35

1.0 Introduction

This document serves as an addendum to the April 30, 2009 ( Post

- Phase 6) risk assessment that was completed for metam sodium (Smith ; D 357118 ). Since the completion of that risk assessment, the Agency has received a number of new flux studies from a variety of

stakeholders. These studies include:

MRID 47770001

- Estimating Methyl Isothiocyanate Emission Rates Following Soil Incorporated Shank and Modified Center Pivot Chemigation Metam Sodium Applications (Sponsored by Washington State University )

MRID 47820001

- Monitoring Chloropicrin

, Dimethyldisulfide, and Methyl Isothiocyanate Emissions from Shank Applic ations at Three Sites n ear Tifton, Georgia (Sponsored by USDA

, ARS Area

- Wide Pest Management Program for Methyl Bromide Alternatives and Florida Specialty Crop Foundation)

MRID 47813901

- Monitoring 1,3

- Dichloropropene, Chloropicrin, and Methyl Isothiocyanate Emissions from Shank Applications at Three Sites Near Duette, Florida (Sponsored by USDA

, ARS Area

- Wide Pest Management Program for Methyl Bromide Alternatives and Florida Specialty Crop Foundation)

MRID 48011601

- Monitoring of Meta m Sodi um Airborne Flux for Shan k Injection for Cultural Practice Applicable to Wisconsin (Sponsored by the Wisconsin Potato & Vegetable Growers
Association, Inc)

MRID 48005901

- Monitoring of Metam Sodium Airborne Flux from Shank

I njection/Compaction Based on Cultural Practice Applicable to Michigan (Sponsored by the Michigan Potato Industry Commission)

MRID 48115101

- WA Potato Growers Study

- Monitoring of Metam Sodium Airborne Flux from Shank Injection/Compaction Based on Cultu ral Practice Applicable to Washington State (Sponsored by the Washington State Potato Commission)

MRID 47956901

- A Trial to Evaluate Concentrations and Emission Rates from the Application of Metam Sodium by Shank Injection/Compaction on a Daytime and Nig httime Basis (Sponsored by Amvac Chemical Corporation, Taminco, Inc., and Tessenderlo Kerley, Incorporated)

MRID 47956701

- Flux Evaluation of a Metam Potassium Application (KAPAM

- HL) Applied by the Drench Method (Study SEC

- 2008D) (Sponsored by Amvac Che mical Corporation)

Specifically, this document provides information that should be considered in addition to the discussions, data, and results previously presented related to MITC (from metam sodium/metam potassium applications) flux estimates and PERFUM modeling. Appendix A includes a

### Page 3 of 35

summary of the parameters under which all of the submitted metam sodium/metam potassium emission studies were performed.

2 .0 Study Summary and Flux Calculations

MRID 47770001 Study

- Estimating Methyl Isothiocyanate Emission Rates Following Soil Incorporated Shank and Modified Center Pivot Chemigation Metam Sodium Applications

In MRID 47770001, the study authors monitored for methyl isothiocyanate at near

- field receptor

location after a drizzle boom modified center pivot chemigation and soil

- incorporated shank injection application of Sectagon 42 ® 

### (42% metam sodium ). The test sit e for this study was located near Eltopia, Franklin County, WA in October 2008

. This study was developed to specifically assess emission r ates and total cumulative field loss of metam sodium’s gaseous by

product, methyl isothiocyanate (MITC) during and four days post

- application under conditions typical for Pacific Northwest (PNW) potato pre

- plant fumigation. Metam sodium was applied to

two treatment plots (1.7 acres for drizzle boom and 1.8 acres for shank injection) within a 122

acre field circle to assess near

- field MITC air emissions before, during, and through 4

- days post application (from October 8th through the 13 th 

### , 2008 ). The fumigan t was applied at a rate of 71 gal/acre for drizzle boom and 52 gal/acre for shank injection concurrently on October 9, 2008. This rate of application is higher than the rate of 35

- 40 gal/acre used in Washington State for

control of soil

- borne pathogens in/ on potatoes, but lower than the allowable maximum label rate of 75 gal/acre.

The drizzle boom modified center pivot application was conducted through use of an eight tower center pivot. Center pivot towers 1

- 3 and 8 were capped off and a horizontal boom c onstructed of PVC piping was attached to existing sprinkler heads to allow for application 2

- 3 feet from the soil surface. The drizzle boom application was applied with 1 inch of water to set the product

within the soil. The soil

- incorporated application was conducted through shank injection at a depth of about 9 inches followed by soil compaction. The plot area was “double disk plowed” before application.

Eight receptors were positioned about 15 meters from the treated edge and equidistant from each other. Four additional ambient air receptors were positioned between the two treatment plots, one

near the cent er of the center pivot circle , one near the southwest circle field corner and two near equidist ant between the drizzle boom and s hank injection plot

. MITC was monitored pre

application, during fumigation and at either 4 or 8 hour periods through 4 days post

- application. MITC samples were collected through activated charcoal.

Wind speed and direction, air and soil temperature, soil moisture, and rainfall data were collected throughout the pre

- application, fumigation, and air sampling time period with an Onset HOBO Weather Station data logger ® 

### . Wind speed and direction were recorded at 2 meters height and soil temperature and moisture levels w ere recorded at 6” depth. Average air temperature over the sampling interval was approximately 7.7°C (45.9 °F) with a high of 18.9°C (66 °F) and a low

belo w freezing (

- 1.5°C or 29.3°F ). Average 6” depth soil temperature during the trial was 10.2
°C (50. 4 °F), with a high of 16.2 °C ( 61.2 °F) and a low of 6.2 °C (43.2°F ). The measured soil moisture level (at 6” depth) dropped from 1.41 m3/m3 at the beginning to 0.094 m3/m3 by the

### Page 4 of 35

end of the sampling period. No measurable rainfall was recorded

. Field fo rtification samples were analyzed to ensure proper analysis of air concentration field samples in the study. Field recovery analysis was conducted and subsequent adjustments were made to the air concentration analysis as appropriate.

Flux rates were cal culated via on

- field flux data except during the fumigant application where the primary method to compute flux rates was the back

- calculation method. The flux profiles were calculated based on the field conditions including the application rates used to m ake the applications in the study. For the purposes of completing the PERFUM analyses, these flux profiles were subsequently adjusted to the maximum application rate for metam sodium of 320 lb metam sodium per treated acre (see Table s 1 and 2 ).

Table 1

. Flux Calculations for Field 1 (Broadcast Shank Injection and Compaction) at Franklin County, WA (MRID 47770001)

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est.

Flux Study Reported

Flux

(ug/m2

- s) (ug/m2

- s)

1 10/9/2008 12:00

- 13:00 1 6.560 7.730

2 10/9/2008 13:00

- 14:00 1 12.480 13.310

3 10/9/2008 14:00

- 18:00 4 9.080 9.090

4 10/9/2008 18:00

- 22:00 4 12.210 12.240

5 10/9/2008 22:00

- 02:00 4 11.160 11.490

6 10/10/2008 03:00

- 07:00 4 16.220 21.320

7 10/10/2008 07:00

- 10:00 3 5.070 5.080

8 10/10/2008 10:00

- 14:00 4 6.170 6.790

9 10/10/2008 14:00

- 18:00 4 5.430 5.680

10 10/10/2008 18:00

- 22:00 4 3.880 4.000

11 10/10/2008 22:00

- 02:00 4 3.420 3.680

12 10/11/2008 02:00

- 07:00 5 2.400 2.410

13 10/11/2008 07:00

- 11:00 4 3.490 3.520

14 10/11/2008 11:00

- 15:00 4 3.680 3.940

15 10/11/2008 15:00

- 22:00 7 5.840 5.860

16 10/11/2008 22:00

- 07:00 9 2.780 2.790

17 10/12/2008 07:00

- 14:00 7 0.190 0.200

19 10/12/2008 14:00

- 22:00 8 2.140 2.150

19 10/12/2008 22:00

- 07:00 9 1.390 1.410

20 10/13/2008 07:00

- 11:00 4 2.170 2.160

### Page 5 of 35 Table 2 . Flux Calculations for Field 2 ( Center Pivot Irrigation Using

Drizzle Boom ) at Franklin County, WA (MRID 47770001)

Period No. Sample Interval Times Duration
(Hrs.) Study Reported

Flux

(ug/m2

- s)

1 10/9/2008 12:00

- 13:00 1 172.08

2 10/9/2008 13:00

- 15:00 2 171.80

3 10/9/2008 15:00

– 19:00 4 67.00

4 10/9/2008 19:00

– 23:00 4 40.10

5 10/9/2008 23:00

– 03:00 4 35.32

6 10/10/2008 03:00

- 07:00 4 32.20

7 10/10/2008 07:00

- 12:00 5 26.71

8 10/10/2008 12:00

- 16:00 4 57.15

9 10/10/2008 16:00

– 20:00 4 37.92

10 10/10/2008 20:00

- 24:00 4 26.83

11 10/10/2008 24:00

– 03:00 3 22.60

12 10/11/2008 03:00

- 07:00 4 15.29

13 10/11/2008 07:00

- 11:00 4 15.54

14 10/11/2008 11:00

– 15:00 4 31.90

15 10/11/2008 15:00

– 23:00 8 16.03

16 10/11/2008 23:00

- 07:00 8 9.73

17 10/12/2008 07:00

- 16:00 9 4.40

19 10/12/2008 16:00

- 23:00 7 6.92

19 10/12/2008 23:00

- 07:00 8 3.14

20 10/13/2008 07:00

- 15:00 8 3.28



### Note: The Agency did not verify the flux estimates presented in Table 2 at this time. The presented flux estimates are presented directly as reported in the study. The Agency did not verify the center pivot flux rates a t this time because there is currently no fumigant air model that will accurately model circular fields (i.e., center pivot applications) to the Agency’s specifications. A Beta version of PERFUM is currently in develop ment that will allow the Agency to model circular fields . When this PERFUM version is complete t he Agency will revisit the center pivot portion of this study.

MRID 47820001 Study

- Monitoring Chloropicrin, Dimethyldisulfide, and Methyl Isothiocyanate Emissions from Shank Applications at Three Sites near Tifton, Georgia

In MRID 47820001, the study authors monitored for chloropicrin, dimethyldisulfide, and methyl isothiocyanate during three separate bedded shank injection applications. The test site for this study was located in Tifton, Georgia and the field work was cond ucted in November of 2009.

C hloropicrin and DMDS (pre

- mixed together in a 79% dimethyldisulfide:21% chloropicrin ratio) were applied as a pre

- bed application using 3 swept back shanks spaced 12 inches apart to deliver chloropicrin and DMDS to an 8 inch depth. This application was followed by an application of metam sodium at a 4 inch depth using 12

– inch vertical cultures spaced 4 inches apart. Thirty

- two inch wide by 9 inch high raised beds were pressed immediately after the

### Page 6 of 35

metam sodium application. Field 1 was 0.96 acres in size (treated acreage was 0.41 acre) and

was treated with 299.5 lbs metam sodium per treated acre . The treated beds at field 1 were immediately covered with a virtually impermeable film (Blockade). Field 2 was 0.96 acres in

siz e (treated acreage was 0.43 acre) and was treated with 306.3 lbs metam sodium per treated

acre . The treated beds at field 2 were immediately covered with an LDPE film. Field 3 was 0.99 acres in size (treated acreage was 0.45 acre) and was treated with 29 5.2 lbs metam sodium per

treated acre . The treated beds at field 3 were immediately covered with an LDPE film.

All three fields were in close proximity and displayed comparable surface roughness conditions. On this basis, one centrally located field was selected to represent wind profiles within the treatment zones. Two 2 dimensional sonic anemometer profile wind systems were established at Field 2 with coverage at 0.3, 0.6, 0.9, 1.8, 2.4, and 3.0 m above ground level (for both wind

sensors and thermoco uples). In addition, a 3

- dimensional (3D) sonic anemometer (installed at approximately 3.0 m above ground level) was established on the field after the application at

field 2 to document 3

- dimensional turbulence. The average temperature throughout the st udy ranged from 3.6

- 16.5 oC and wind speeds ranged from approximately calm conditions to 10 m/s.

Soil samples were collected at two points during the study; prior to application and following the completion of the study air sampling. Core samples were co llected at five depths at a minimum
of two locations across each field (0

- 15 cm, 15

- 30 cm, 30

- 46 cm, 46

- 61 cm, and 61

- 76 cm). The preapplication soil samples from each field were analyzed for texture, bulk density, organic
matter, and soil moisture while the post

- study samples were analyzed for soil moisture only. The

soil at Fields 1 and 2 was classified as a loamy sand soil and the soil at Field 3 was classified as a sandy soil. The water content of the soil relative to field capacity was approximately 70% across the 0 to 9” depth. Soil organic content of the soil was 0.7% across the 0 to 12” depth . Soil

tem perature ranged between 10 (50 ° F) and 21 o 

### C (70 ° F) at the 6 to 9” depth throughout the study

duration.

Off

- site air sampling was conducted via eight samplers surrounding the field at 12 meters from the edge of the field. The intake height was approximately 1.5 m above ground level to approximate the human breathing zone. Off

- site sampling was conducted pr ior to the on

- field sampling and during the first period (i.e., during the application). ). On

- site air samples were collected on sampling masts placed at the approximate center of each of the test fields shortly after the passage of the application rig. Air sampling tubes were placed at 0.3, 0.9, 1.8, and 3.0

m above the field on the on

- site air sampling masts. Off

- cite sampling at each field was terminated approximately six hours after the start of the application. A total of 416 Charcoal and

312 XAD

- 4 sorbent tubes were analyzed for the on

- field sampling portion of the study. Field fortification samples were analyzed to ensure proper analysis of air concentration field samples in the study. All fortification sample recoveries were greater than (>) 9 0%, therefore no adjustment to air concentration sample analysis was necessary.

Flux rates were calculated via on

- field flux data except during the fumigant application where the primary method to compute flux rates was the back

- calculation method. The flux profiles were calculated based on the field conditions including the application rates used to make the applications in the study. For the purposes of completing the PERFUM analyses, these flux

### Page 7 of 35

profiles were subsequently adjusted to the maximum appli cation rate for metam sodium of 320 lb metam sodium per treated acre (see Tables 3

- 5 ).

Table 3 . Flux Calculations for Field 1 (Bedded Shank Injection

Blockade VIF Tarp) at Tifton, GA (MRID 47820001)

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est.

Flux Study

Reported Flux

(ug/m2

- s) (ug/m2

- s)

1 1 2/7/2009 16:30

- 21:30 5 1.006 0.940

2 2/7/2009 21:30

- 3:30 6 1.044 1.645

3 2/8/2009 3:30

- 9:30 6 3.132 3.822

4 2/8/2009 9:30

- 15:30 6 4.449 3.352

5 2/8/2009 15:30

- 21:30 6 1.096 1.899

6 2/8/2009 21:30

- 3:30 6 3.947 6.694

7 2/9/2009 3:30

- 9:30 6 10.975 9.290

8 2/9/2009 9:30

- 15:30 6 16.513 10.587

9 2/9/2009 15:30

- 0:30 9 0.414 1.287

10 2/10/2009 0:30

- 12:30 12 11.267 4.601

11 2/10/2009 12:30

- 0:30 12 2.624 4.338

12 2/11/2009 0:30

- 12:30 12 7.097 4.762

13 2/11/2009 12:30

- 0:30 12 1.145 1.266

14 2/12/2009 0:30

- 12:30 12 2.937 5.098

15 2/12/2009 12:30

- 0:30 12 1.934 3.173

16 2/13/2009 0:30

- 12:30 12 1.234 0.594

17 2/13/2009 12:30

- 0:30 12 1.088 1.104

18 2/14/2009 0:30

- 12:30 12 1.453 1.439

19 2/14/2009 12:30

- 0:30 12 1.045 1.299

20 2/15/2009 0:30

- 12:30 12 1.386 2.258

21 2/15/2009 12:30

- 0:30 12 0.652 0.823

22 2/16/2009 0:30

- 12:30 12 1.476 0.775

23 2/16/2009 12:30

- 0:30 12 0.084 0.157

24 2/17/2009 0:30

- 12:30 12 0.469 0.153

25 2/17/2009 12:30

- 0:30 12 0.050 0.086

26 2/18/2009 0:30

- 12:30 12 0.908 0.500

27 2/18/2009 12:30

- 0:30 12 0.268 0.229

28 2/19/2009 0:30

- 6:30 6 1.047 1.257

29 2/19/2009 6:30

- 12:30 6 1.985 2.423

30 2/19/2009 12:30

- 0:30 12 0.130 0.179

31 2/20/2009 0:30

- 12:30 12 0.469 0.460

32 2 2/20/2009 12:30

- 0:30 12 0.027 0.030

1 Indirect flux calculation method was used.

2 Measurement at levels filtered, poor regression fit

### Page 8 of 35 Table 4 . Flux Calculations for Field 2 (Bedded Shank Injection

LDPE Film ) at Tifton, GA (MRID 47820001)

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est.

Flux Study Reported

Flux

(ug/m2

- s) (ug/m2

- s)

1 1 2/7/2009 18:30

-

22:30 5 39.632 40.700

2 2/7/2009 22:30

- 3:30 6 38.739 55.255

3 2/8/2009 3:30

- 9:30 6 35.184 43.213

4 2 2/8/2009 9:30

- 15:30 6 55.159 48.845

5 2/8/2009 15:30

- 21:30 6 10.591 19.291

6 2/8/2009 21:30

- 3:30 6 4.962 7.549

7 2/9/2009 3:30

- 9:30 6 3.772 3.001

8 2/9/2009 9:30

- 15:30 6 8.033 4.401

9 2/9/2009 15:30

- 0:30 9 2.936 9.305

10 2/10/2009 0:30

- 12:30 12 5.110 2.029

11 2/10/2009 12:30

- 0:30 12 2.385 3.993

12 2/11/2009 0:30

- 12:30 12 5.980 3.806

13 2/11/2009 12:30

- 0:30 12 0.519 0.636

14 2/12/2009 0:30

- 12:30 12 1.187 1.842

15 2/12/2009 12:30

- 0:30 12 0.876 1.342

16 2/13/2009 0:30

- 12:30 12 1.154 0.555

17 2/13/2009 12:30

- 0:30 12 0.408 0.416

18 2/14/2009 0:30

- 12:30 12 0.461 0.432

19 2/14/2009 12:30

- 0:30 12 0.182 0.241

20 2/15/2009 0:30

- 12:30 12 0.212 0.295

21 2/15/2009 12:30

- 0:30 12 0.160 0.187

22 2/16/2009 0:30

- 12:30 12 0.212 0.108

23 2/16/2009 12:30

- 0:30 12 0.136 0.245

24 2/17/2009 0:30

- 12:30 12 0.113 0.038

25 2/17/2009 12:30

- 0:30 12 0.057 0.094

26 2/18/2009 0:30

- 12:30 12 0.260 0.132

27 2/18/2009 12:30

- 0:30 12 0.147 0.031

28 2/19/2009 0:30

- 6:30 6 0.071 0.029

29 2/19/2009 6:30

- 12:30 6 0.134 0.030

30 2/19/2009 12:30

- 0:30 12 0.173 0.031

31 2/20/2009 0:30

- 12:30 12 0.309 0.026

32 3 2/20/2009 12:30

- 0:30 12 0.153 0.028

1 Indirect flux calculation method was used.

2 Delta flux calculation method was used.

3 Measurement at levels filtered, poor regression fit

### Page 9 of 35 Table 5 . Flux Calculations for Field 3 (Bedded Shank Injection

LDPE Film) at Tifton, GA (MRID 47820001)

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est.

Flux Study Reported

Flux

(ug/m2

- s) (ug/m2

- s)

1 1 2/7/2009 18:30

-

22:30 5 4.516 6.780

2 1 2/7/2009 22:30

- 3:30 6 8.562 6.780

3 2/8/2009 3:30

- 9:30 6 22.967 27.724

4 2/8/2009 9:30

- 15:30 6 32.866 24.092

5 2/8/2009 15:30

- 21:30 6 9.989 20.440

6 2 2/8/2009 21:30

- 3:30 6 1.851 1.968

7 2 2/9/2009 3:30

- 9:30 6 3.541 1.352

8 2 2/9/2009 9:30

- 15:30 6 13.366 7.461

9 2/9/2009 15:30

- 0:30 9 1.498 4.239

10 2/10/2009 0:30

- 12:30 12 4.126 1.439

11 2/10/2009 12:30

- 0:30 12 1.608 2.683

12 2/11/2009 0:30

- 12:30 12 4.200 2.226

13 2/11/2009 12:30

- 0:30 12 0.784 0.913

14 2/12/2009 0:30

- 12:30 12 0.396 0.609

15 2/12/2009 12:30

- 0:30 12 0.575 0.786

16 2/13/2009 0:30

- 12:30 12 0.710 0.351

17 2/13/2009 12:30

- 0:30 12 0.355 0.369

18 2 2/14/2009 0:30

- 12:30 12 0.755 0.682

19 2/14/2009 12:30

- 0:30 12 0.074 0.100

20 2/15/2009 0:30

- 12:30 12 0.146 0.211

21 2/15/2009 12:30

- 0:30 12 0.109 0.128

22 2/16/2009 0:30

- 12:30 12 0.386 0.188

23 2/16/2009 12:30

- 0:30 12 0.110 0.217

24 2 2/17/2009 0:30

- 12:30 12 0.151 0.051

25 2/17/2009 12:30

- 0:30 12 0.064 0.108

26 2/18/2009 0:30

- 12:30 12 0.369 0.179

27 2/18/2009 12:30

- 0:30 12 0.153 0.026

28 2/19/2009 0:30

- 6:30 6 0.195 0.026

29 2/19/2009 6:30

- 12:30 6 0.205 0.216

30 2/19/2009 12:30

- 0:30 12 0.153 0.028

31 2/20/2009 0:30

- 12:30 12 0.042 0.027

32 3 2/20/2009 12:30

- 0:30 12 0.025 0.028

1 Indirect flux calculation method was used.

2 Delta flux calculation method was used.

3 Measurement at levels filtered, poor regression fit

### Page 10 of 35

MRID 47813901 Study

- Monitoring 1,3

- Dichloropropene, Chloropicrin, and Methyl Isothiocyanate Emissions from Shank Applications at Three Sites Near Duette, Florida (Sponsored by USDA , ARS Area

- Wide Pest Management Program for Methyl Bromide Alternatives and Florida Specialty Crop Foundation)

In MRID 47813901, the study authors monitored for 1,3

- dichloropropene, chloropicrin, and methyl isothiocyanate during three separate bedded shank injection applications. The test site for this study was located in Duette, Florida and the field work was conducted in January of 2009.
At fields 1 and 2, c hloropicrin was co

- applied with 1,3

- dichloropropene as a pre

- bed application using 3 swept back shanks spaced 12 inches apart to deliver chloropicrin and 1,3

- dichloropropene to an 8 inch depth. Separate delivery lines were used to carry each fumigant from their respective cylinder to the shank. On a separate tract or metam potassium was applied into the pressed bed at a 4 inch depth via a 12 inch culture spaced 4 inches apart. The beds were then immediately pressed following the metam potassium application. The application at field 3

did not include 1,3

- dichloroprop ene. Field 1 was approximately 1 acre in size (treated acreage
was 0.357 acre) and was treated with 311.0 lbs metam potassium per treated acre. The treated beds at field 1 were immediately covered with a metalized plastic film (Canslit, 1.25 mil). Field 2 was approximately 1 acre in size (treated acreage was 0.357 acre) and was treated with 300.1 lbs metam potassium per treated acre . The treated beds at field 2 were immediately covered with

a virtually impermeable plastic film (Guardian, Olefinas, 1.2 m il)

. Field 3 was approximately 1 acre in size (treated acreage was 0.357 acre) and was treated with 305.8 lbs metam potassium per

treated acre . The treated beds at field 3 were immediately covered with a metalized plastic film
(Canslit, 1.25 mil)

.

All t hree fields were in close proximity and displayed comparable surface roughness conditions. On this basis, one centrally located field was selected to represent wind profiles within the treatment zones. Two 2 dimensional sonic anemometer profile wind syst ems were established at Field 2 with coverage at 0.3, 0.9, 1.8, and 3.0 m above ground level (for both wind sensors and thermocouples). In addition, a 3

- dimensional (3D) sonic anemometer (installed at approximately 3.0 m above ground level) was establishe d on the field after the application at field 2 to

document 3

- dimensional turbulence. The average temperature throughout the study ranged from

3.6

- 16.5 oC and wind speeds ranged from approximately calm conditions to 9 m/s.

Soil samples were collected at two points during the study; prior to application and following the completion of the study air sampling. Core samples were collected at five depths at a minimum
of two locations across each field (0

- 15 cm, 15

- 30 cm, 30

- 46 c m, 46

- 61 cm, and 61

- 76 cm). The preapplication soil samples from each field were analyzed for texture, bulk density, organic matter, and soil moisture while the post

- study samples were analyzed for soil moisture only. The

water content of the soil relati ve to field capacity was 245% at Field 1, 207% at Field 2, and 228% at Field 3 across the 0 to 6” depth. Soil organic content of the soil was 0.94% at Field 1, 1.38% at Field 2, and 1.26% at Field 3 across the 0 to 6” depth . Soil temperature ranged

betwe en 7 and 22 o 

### C at the 6 to 9” depth throughout the study duration.

Off

- site air sampling was conducted via eight samplers surrounding the field at 12 meters from the edge of the field. The intake height was approximately 1.5 m above ground level to approximate the human breathing zone. Off

- site sampling was conducted pr ior to the on

- field

### Page 11 of 35

sampling and during the first period (i.e., during the application). On

- site air samples were collected on sampling masts placed at the approximate center of each of the test fields shortly after the passage of the application rig. Ai r sampling tubes were placed at 0.3, 0.9, 1.8, and 3.0

m above the field on the on

- site air sampling masts. A total of 342 Charcoal and 342 XAD

- 4 sorbent tubes were analyzed for the study. Field fortification samples were analyzed to ensure proper analysi s of air concentration field samples in the study. Field recovery analysis was conducted and subsequent adjustments were made to the air concentration analysis as appropriate.

Flux rates were calculated via on

- field flux data except during the fumigant application where the primary method to compute flux rates was the back

- calculation method. The flux profiles were calculated based on the field conditions including the application rates used to make the applications in the study. For the purposes of co mpleting the PERFUM analyses, these flux profiles were subsequently adjusted to the maximum application rate for metam potassium of

320 lb metam potassium per treated acre (see Tables 6

- 8 ).

Table 6 . Flux Calculations for Field 1 (Bedded Shank Injection

- C anslit

Metalized Film ) at Duette, FL (MRID 47813901)

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est.

Flux Study Reported

Flux

(ug/m2

- s) (ug/m2

- s)

1 1 1/14/2009 9:30

- 15:30 6 0.870 0.950

2 1/14/2009 15:30

- 21:30 6 0.732 0.534

3 1/14/2009 21:30

- 3:30 6 0.448 0.372

4 1/15/2009 3:30

- 9:30 6 0.381 0.319

5 1/15/2009 9:30

- 15:30 6 0.563 0.334

6 1/15/2009 15:30

- 21:30 6 0.636 0.688

7 1/15/2009 21:30

- 3:30 6 0.483 0.357

8 1/16/2009 3:30

- 13:30 10 0.548 0.350

9 1/16/2009 13:30

- 1:30 12 0.558 0.603

10 1/17/2009 1:30

- 13:30 12 0.434 0.284

11 1/17/2009 13:30

- 1:30 12 0.370 0.579

12 1/18/2009 1:30

- 13:30 12 0.933 0.458

13 1/18/2009 13:30

- 1:30 12 2.068 1.436

14 1/19/2009 1:30

- 13:30 12 1.242 0.942

15 1/19/2009 13:30

- 1:30 12 2.219 1.415

16 1/20/2009 1:30

- 13:30 12 1.037 0.862

17 1/20/2009 13:30

- 1:30 12 0.283 0.309

18 1/21/2009 1:30

- 13:30 12 0.257 0.194

19 1/21/2009 13:30

- 1:30 12 0.118 0.175

20 2 1/22/2009 1:30

- 13:30 12 0.276 0.359

21 1/22/2009 13:30

- 1:30 12 0.433 0.536

22 3 1/23/2009 1:30

- 13:30 12 3.827 0.562

1 ISCST3 flux calculation method was used.

2 Calculated as per registrant as average of flux from period before and period after

3 Registrant used flux value from previous period due to poor regression fit

### Page 12 of 35 Table 7 . Flux Calculations for Field 2 (Bedded Shank Injection

Gaurdian, Oledfinas Film ) at Duette, FL (MRID 47813901)

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est.

Flux Study Reported Flux

(ug/m2

- s) (ug/m2

- s)

1 1 1/14/2009 9:30

- 15:30 6 4.670 3.630

2 2 1/14/2009 15:30

- 21:30 6 10.432 2.102

3 1/14/2009 21:30

- 3:30 6 1.720 1.603

4 1/15/2009 3:30

- 9:30 6 1.182 1.157

5 1/15/2009 9:30

- 15:30 6 2.464 1.544

6 1/15/2009 15:30

- 21:30 6 1.816 2.371

7 1/15/2009 21:30

- 3:30 6 1.117 0.881

8 1/16/2009 3:30

- 13:30 10 1.191 0.759

9 1/16/2009 13:30

- 1:30 12 1.276 1.640

10 1/17/2009 1:30

- 13:30 12 0.973 0.667

11 1/17/2009 13:30

- 1:30 12 1.280 2.119

12 1/18/2009 1:30

- 13:30 12 2.199 1.139

13 1/18/2009 13:30

- 1:30 12 4.275 3.625

14 1/19/2009 1:30

- 13:30 12 2.564 2.015

15 1/19/2009 13:30

- 1:30 12 10.119 6.247

16 1/20/2009 1:30

- 13:30 12 1.032 0.782

17 1/20/2009 13:30

- 1:30 12 0.575 0.658

18 1/21/2009 1:30

- 13:30 12 0.339 0.262

19 1/21/2009 13:30

- 1:30 12 0.187 0.292

20 3 1/22/2009 1:30

- 13:30 12 0.187 0.302

21 3 1/22/2009 13:30

- 1:30 12 0.187 0.302

22 3 1/23/2009 1:30

- 13:30 12 0.187 0.292

1 ISCST3 flux calculation method was used.

2 Calculated as per registrant as average of flux from period before and period after

3 Registrant used flux value from previous period due to poor regression fit

### Page 13 of 35 Table 8 . Flux Calculations for Field 3 (Bedded Shank Injection

- Canslit

Metalized Film) at Duette, FL (MRID 47813901)

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est.

Flux Study Reported Flux

(ug/m2

- s) (ug/m2

- s)

1 1 1/14/2009 9:30

- 15:30 6 15.130 7.190

2 2 1/14/2009 15:30

- 21:30 6 8.890 1.563

3 1/14/2009 21:30

- 3:30 6 2.650 1.725

4 1/15/2009 3:30

- 9:30 6 0.528 0.484

5 1/15/2009 9:30

- 15:30 6 0.655 0.430

6 1/15/2009 15:30

- 21:30 6 0.678 0.819

7 1/15/2009 21:30

- 3:30 6 0.507 0.442

8 1/16/2009 3:30

- 13:30 10 0.333 0.267

9 2 1/16/2009 13:30

- 1:30 12 0.273 0.227

10 1/17/2009 1:30

- 13:30 12 0.213 0.176

11 1/17/2009 13:30

- 1:30 12 0.303 0.583

12 1/18/2009 1:30

- 13:30 12 0.820 0.425

13 2 1/18/2009 13:30

- 1:30 12 0.665 0.436

14 1/19/2009 1:30

- 13:30 12 0.510 0.471

15 1/19/2009 13:30

- 1:30 12 6.233 1.472

16 2 1/20/2009 1:30

- 13:30 12 3.207 0.837

17 1/20/2009 13:30

- 1:30 12 0.181 0.201

18 1/21/2009 1:30

- 13:30 12 0.114 0.127

19 1/21/2009 13:30

- 1:30 12 0.060 0.112

20 2 1/22/2009 1:30

- 13:30 12 0.076 0.123

21 1/22/2009 13:30

- 1:30 12 0.091 0.141

22 3 1/23/2009 1:30

- 13:30 12 0.091 0.139

1 ISCST3 flux calculation method was used.

2 Calculated as per registrant as average of flux from period before and period after

3 Registrant used flux value from previous period due to poor regression fit



### MRID 48011601 Study

- Monitoring of Metam Sodium Airborne Flux for Shank Injection for Cultural Practice Applicable to Wisconsin (Sponsored by the Wisconsin Potato & Vegetable
Growers Association, Inc)

In MRID 48011601, the study authors monitored for m ethyl isothiocyanate in fields 1 and 3 during a broadcast shank injection application of metam sodium

. In field 2, chloropicrin was
monitored during a bedded untarped shank injection application

. ’

The test site for this study was located in Coloma, Wisconsin and the field work was conducted in September of 2009. Metam sodium was applied via shank injection at a depth of 5.5 and 9.5

inches. The treated field was meant to receive a 0.25 inch water seal about 6 hours after application but a p recipitation event occurred resulting in only 0.10 inches of water being applied

to the field. The two metam sodium applications were sealed mechanically because they were broadcast applications. Field 1 was approximately 1 acre in size and was treated wi th 287.0 lbs

### Page 14 of 35

metam sodium per treated acre. Field 3 was approximately 1 acre in size and was treated with

270.1 lbs metam sodium per treated acre.

The three fields in this study were all located in the general vicinity with two of the fields being

part of a common field (Field 1

- metam sodium and Field 2

- chloropicrin). Field 3 (metam sodium) was located approximately 4 miles to the southeast of Fields 1 and 2. Wind speed profile data were collected at all three fields to account for potential wind flow differences between the geographic locations of all three fields and to account for surface roughness differences between the bedded field (Field 2) and the broadcast flat applications on Fields 1 and 3. This was accomplished by placing 2D sonic anemomete r profiles with wind monitoring at
three levels near the center of Field 2 and Field 3. On Field 1, 3D sonic anemometers were placed near the center of the field, with supplementary data available at a third level at a location in close proximity to this flat broadcast treatment plot. The temperature throughout the study ranged from 6

- 25 oC and wind speeds ranged from approximately calm conditions to 11 m/s.

Soil samples were collected several days prior to application and following completion of the

app lication. Core samples were collected at two depths (0

- 15 cm and 15

- 30 cm). The preapplication soil samples from each field were analyzed for texture, bulk density, organic matter, and soil moisture while the post

- application samples were analyzed for so il moisture only. The water content of the soil relative to field capacity was approximated to be between 75

- 80% at Field 1, 50

- 55% at Field 2, and 75

- 80% at Field 3 across the 0 to 6” depth. Soil organic

content of the soil was 0.7% at Field 1, 0.7% at Field 2, and 1.3% at Field 3 across the 0 to 6” depth . Soil temperature ranged between 7 and 24 o 

### C at the 3” depth throughout the study

duration.

Off

- site air sampling was conducted via eight samplers surrounding the field at 12 meters from the edge of th e field. The intake height was approximately 1.5 m above ground level to approximate the human breathing zone. Off

- site sampling was conducted prior to the on

- field sampling and terminated approximately 6 hours after the start of application. On

- site ai r samples were collected on sampling masts placed at the approximate center of each of the test fields shortly after the passage of the application rig. Air sampling tubes were placed at 0.3, 0.9, 1.8,

and 3.0 m above the field on the on

- site air sampling masts. A total of 163 Charcoal and 95

XAD

- 4 sorbent tubes were analyzed for the study. Background samples indicated that no cross

contamination occurred during the monitoring. Analytical recovery values were acceptable (i.e.,
> 90%) and no corrections to measured residue values were warranted. Field fortification samples were analyzed to ensure proper analysis of air concentration field samples in the study. Field recovery analysis was conducted and subsequent adjustments were made to the air

concentr ation analysis as appropriate.

Flux rates were calculated via on

- field flux data except during the fumigant application where the primary method to compute flux rates was the back

- calculation method. The flux profiles were calculated based on the field conditions including the application rates used to make the applications in the study. For the purposes of completing the PERFUM analyses, these flux profiles were subsequently adjusted to the maximum a pplication rate for metam sodium of 320 lb metam sodium per treated acre (see Tables 9

- 10)

.

### Page 15 of 35 Table 9 . Flux Calculations for Field 1 (BroadcastShank Injection

- Water

Seal 0.10 inch ) at Coloma, WI (MRID 48011601)

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est.

Flux Study Reported

Flux

(ug/m2

- s) (ug/m2

- s)

1 1 9/25/2009 10:30

- 11:30 1 1.650 1.648

2 9/25/2009 11:30

- 15:30 4 0.906 0.862

3 2 9/25/2009 15:30

- 19:30 4 0.788 0.631

4 2 9/25/2009 19:30

- 23:30 4 1.435 1.345

5 9/25/2009 23:30

- 03:30 4 2.782 2.632

6 9/26/2009 03:30

- 07:30 4 4.628 3.202

7 9/26/2009 07:30

- 11:30 4 5.743 5.174

8 9/26/2009 11:30

- 15:30 4 9.493 8.684

9 9/26/2009 15:30

- 19:30 4 10.857 9.755

10 9/26/2009 19:30

- 23:30 4 8.745 8.028

11 3 9/26/2009 23:30

- 03:30 4 8.388 7.595

12 9/27/2009 03:30

- 07:30 4 5.818 5.277

13 9/27/2009 7:30

- 19:30 12 9.220 8.246

14 9/27/2009 19:30

- 7:30 12 2.156 2.035

15 9/28/2009 7:30

- 19:30 12 1.637 1.573

16 9/28/2009 19:30

- 7:30 12 0.914 0.859

1 ISCST3 flux calculation method was used.

2 Slope, intercept and R squared values for concentration calculated from 3 values only due to poor regression fit

3 Slope, intercept and R squared values for concentration calculated from 3 values only due to missing data

### Page 16 of 35 Table 10 . Flux Calculations for Field 3 (BroadcastShank Injection

Water Seal 0.10 inch ) at Coloma, WI (MRID 48011601)

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est.

Flux Study Reported

Flux

(ug/m2

- s) (ug/m2

- s)

1 1 9/25/2009 10:30

- 11:30 1 5.930 5.530

2 9/25/2009 11:30

- 15:30 4 1.554 1.492

3 2,3 9/25/2009 15:30

- 19:30 4 2.829 2.227

4 9/25/2009 19:30

- 23:30 4 4.105 3.047

5 9/26/2009 23:30

- 03:30 4 6.107 5.992

6 9/26/2009 03:30

- 07:30 4 4.901 4.395

7 9/26/2009 07:30

- 11:30 4 7.975 7.021

8 9/26/2009 11:30

- 15:30 4 11.684 10.338

9 9/26/2009 15:30

- 19:30 4 9.725 8.676

10 9/26/2009 19:30

- 23:30 4 9.833 10.245

11 9/27/2009 23:30

- 03:30 4 10.476 10.680

12 9/27/2009 03:30

- 07:30 4 7.980 7.479

13 9/27/2009 7:30

- 19:30 12 11.133 10.146

14 9/27/2009 19:30

- 7:30 12 3.351 3.073

15 9/28/2009 7:30

- 19:30 12 2.387 2.204

16 9/28/2009 19:30

- 7:30 12 1.337 1.306

1 ISCST3 flux calculation method was used.

2 Slope, Intercept and R squared values calculated only for 3 heights as the raw data for the uppermost height is missing due to low pressure event at site

3 Calculated as of flux from period before and period after (Interpolation) due to poor regression fit



### MRID 48005901 Study

- Monitoring of Metam Sodium Airborne Flux from Shank Injection/Compaction Based on Cultural Practice Applicable to Michigan

In MRID 48005901, the study authors monitored for methyl isothiocyanate from two different treatments of metam sodium. Both appli cations were conducted as untarped broadcast shank injection and compaction on October 28, 2009

. The two test sites were located in the general vicinity of Howard City, Michiga n. The sites received concurrent air and soil monitoring to

maintain similar met eorological and soil conditions. Both fields were applied metam sodium at

1 2 inch depth . Field 1 was 0.96 acres and applied at a rate of 318.2 lbs per treated acre. Field 2 was 0.95 acres with 321.1 lbs per acre applied followed by a 0.33 inch water seal. Both fields were disked prior to application to obtain the appropriate field moistur e.

Wind speed profile data were collected on both fields in order to account for potential wind flow differences between Fields 1 and 2. 2D sonic anemometer profiles with wind monitoring at three levels were placed near the center of each field. On Field 1, 3D sonic anemometers were placed near the center of the each field as well to provide backup low

- threshold wind monitoring level for each field. A standard electronic weather station also was established adjacent to Field 1 to record precipitation, sol ar radiation, relative humidity, wind direction and wind speed. Average maximum

### Page 17 of 35

temperature during the study was ~8°C and average minimum temperat ures during the study was

~13°C.



### Soil samples were collected at the test sites. The soil type was characteri zed as loamy sand and sand. Samples were collected several days prior to application for gravimetric analysis and soil texture analysis in the range of 0

- 6 in and 6

- 12 in. Each soil sample consisted of approximately 0.5 kg (1.102 pounds) of soil. The soil samples collected for soil texture analysis from each field and depth were analyzed for texture, bulk density, organic matter, pH, percent sand, percent silt, and percent clay . Organic matter was measured at 1.1

- 1.6% and 0.5

- 1.3% for field 1 and field 2

, respectively. Within approximately one hour of each application, soil samples within the layer of

0

- 6 in were collected for final gravimetric analysis. Percent field capacity of both fields were measured to be within acceptable ranges (60

– 80%) and soil temperature ranged from 4 to 15°C (average of 10 °C).

Off

- site air sampling was conducted via eight samplers surrounding each field at 25 meters from the edge and corners of the field. The intake height was approximately 1.5 m above ground level

to ap proximate the human breathing zone. Off

- site sampling was conducted prior to the on

- field sampling and during the first period (i.e., during the application). On

- site air samples were collected on sampling masts placed at the approximate center of each o f the test fields shortly after the passage of the application rig. Air sampling tubes were placed at 1, 3, 6, and 10 feet (approximately 0.3, 0.9, 1.8, and 3.0 m eters) above the field on the on

- site air sampling masts. A

total of 169 C harcoal sorbent tubes were analyzed for the study. Field fortification samples were analyzed to ensure proper analysis of air concentration field samples in the study. All fortification sample recoveries were greater than (>) 90%, therefore no adjustment to air

concentra tion sample analysis was necessary.

Flux rates were calculated via on

- field flux data except during the fumigant application where the primary method to compute flux rates was the back

- calculation method. The flux profiles

were calculated based on the field conditions including the application rates used to make the applications in the study. For the purposes of completing the PERFUM analyses, these flux profiles were subsequently adjusted to the maximum application rate for metam sodium of 3 2 0 lb

meta m sodium per treated acre (see Tables 11

- 1 2 ).

### Page 18 of 35 Table 1 1 . Flux Calculations for Field 1 (BroadcastShank Injection and Compaction) at Howard City, MI (MRID 48005901)

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est.

Flux Study Reported

Flux

(ug/m2

- s) (ug/m2

- s)

1 1 10/28/2009 17:00

- 21:00 4 0.205 0.340

2 10/28/2009 21:00

- 1:00 4 0.237 0.167

3 10/29/2009 1:00

- 5:00 4 0.167 0.118

4 10/29/2009 5:00

- 9:00 4 0.285 0.250

5 10/29/2009 9:00

- 13:00 4 0.486 0.445

6 10/29/2009 13:00

- 17:00 4 1.542 1.111

7 10/29/2009 17:00

- 21:00 4 1.487 1.516

8 10/29/2009 21:00

- 1:00 4 1.692 1.753

9 10/30/2009 1:00

- 5:00 4 3.181 2.788

10 10/30/2009 5:00

- 13:00 8 0.348 0.349

11 10/30/2009 13:00

- 17:00 4 0.000 0.004

12 10/30/2009 17:00

- 1:00 8 0.000 0.000

13 2 10/31/2009 1:00

- 13:00 12 0.085 0.003

14 10/31/2009 13:00

- 1:00 12 0.006 0.002

15 11/1/2009 1:00

- 13:00 12 0.003 0.008

16 11/1/2009 13:00

- 19:00 6 0.000 0.000

1 ISCST3 flux calculation method was used.

2 Use Field 2 wind speed

### Page 19 of 35 Table 1 2 . Flux Calculations for Field 2 (BroadcastShank Injection and Compaction

- 0.33 inch water seal) at Howard City, MI (MRID
48005901)

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est.

Flux Study Reported Flux

(ug/m2

- s) (ug/m2

- s)

1 1 10/28/2009 17:00

- 21:00 4 0.180 0.180

2 2 10/28/2009 21:00

- 1:00 4 0.022 0.021

3 2 10/29/2009 1:00

- 5:00 4 0.011 0.028

4 2 10/29/2009 5:00

- 9:00 4 0.332 0.036

5 2 ,3 10/29/2009 9:00

- 13:00 4 0.010 0.020

6 4 10/29/2009 13:00

- 17:00 4 0.097 0.200

7 10/29/2009 17:00

- 21:00 4 0.126 0.133

8 10/29/2009 21:00

- 1:00 4 0.193 0.202

9 10/30/2009 1:00

- 5:00 4 0.274 0.250

10 5 10/30/2009 5:00

- 13:00 8

- 0.012 0.006

11 2 10/30/2009 13:00

- 17:00 4 0.000 0.000

12 2 10/30/2009 17:00

- 1:00 8 0.000 0.000

13 2 10/31/2009 1:00

- 13:00 12 0.002 0.005

14 5 10/31/2009 13:00

- 1:00 12 0.014 0.003

15 11/1/2009 1:00

- 13:00 12 0.000 0.001

16 11/1/2009 13:00

- 19:00 6 0.000 0.000

1 ISCST3 flux calculation method was used.

2 Slope, Intercept and R squared values for concentration calculated only for 3 heights due to poor regression (based on registrants).

3 Use Field 1 wind speed data

4 Slope, Intercept and R squared values for concentration calculated only for 3 heights due to poor regression (registrants used 4 heig hts).

5 Slope, Intercept and R squared values for concentration calculated only for 3 heights due to poor regression (registrants used only 2 heights).



### MRID 48115101 Study

- Monitoring of Metam Sodium Airborne Flux from Shank Injection/Compaction Based on Cultural Practice Applicable to Washington State

In MRID 48115101

, the study authors monitored for methyl isothiocyanate during a metam sodium application at AgriNorthwest near Kennewick, WA. The study was conducted during
the week of March 21, 2010. Two fields were applied metam sodium via shank injection and compaction however field 2 was also applied a 0.25 inch water seal. The water seal was started 6 hours after the completion of the ap plication to represent the lag time that occurs as a result of

a center

- pivot applied water seal. Field 1 was 1.10 acres in size and was treated with 317 lbs metam sodium per treated acre. Field 2 was 0.87 ac re in size and was treated with 368 lbs

metam sodium per treated acre.

Wind speed profile data were collected on both fields to account for potential wind flow

differences between Fields 1 and 2. Two

- dimensional wind sonic anemometer profiles

### Page 20 of 35

were established approximately at the center of each fi eld. In addition, 3D sonic anemometers

and an electronic weather station (ET

- 106) were established adjacent to Field 1. The sensor heights for the meteorological equipment were set to 0.5, 0.9, 1.8, and 3.0 meters. The maximum and minimum air temperature measured during the day was 17°C and 0°C, respectively and wind speeds ranged from approximately calm conditions to 1 3 m/s.

Soil samples were collected in triplicate on March 10, 2010 fro m 0

- 6” and 6

- 12” ranges. Soil

characterization results demonstrated that both of the fields were uniform across 0

– 12”. Percent organic matter in field 1 ranged from 1.55

- 1.99% and field 2 ranged from 1.05

– 1.43%. Field capacity measured indicated that by March 24, 2010, both fields maintained a field capacity with a range of 70 to 80%. Soil temperature ranged between 4 and 14 o 

### C at the 3 to 9” depth throughout the study duration.

Off

- field air monitoring stations were established in eight directions around each field at

appr oximately 25 m (+/

- .5 m) from the edge of the fields at 0, 45, 90, 135, 180, 225, 270, and 315 degrees from the center point of the field. The north and south off field monitoring stations were established at 35 m from the edge of the field to accommodate for the turning radius of the application rig. The intake heights were set to approximately 1.5 m above ground level. Off

- site monitoring was conducted prior to the on

- field sampling stations coming on

- line following the application. A total of 128 Charc oal sorbent tubes were analyzed for the study.

Flux rates were calculated via on

- field flux data except during the fumigant application where the primary method to compute flux rates was the back

- calculation method. The flux profiles

were calculated base d on the field conditions including the application rates used to make the applications in the study. For the purposes of completing the PERFUM analyses, these flux profiles were subsequently adjusted to the maximum application rate for metam sodium of 32 0 lb metam sodium per treated acre (see Tables 1 3

- 1 4 ).

### Page 21 of 35 Table 1 3 . Flux Calculations for Field 1 (Broadcast Shank Injection and

Compaction) at Kennewick, WA (MRID 48115101 )

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est.

Flux Study Reported

Flux

(ug/m2

- s) (ug/m2

- s)

1 1 3/24/2010 0930

- 1200 2.5 4.776 4.590

2 3/24/2010 1200

- 1600 4 2.549 2.219

3 3/24/2010 1600

- 1900 3 2.409 2.096

4 3/24/2010 1900

- 2330 4.5 2.791 2.432

5 3/24/2010 2330

- 0330 4 4.172 3.639

6 3/25/2010 0330

- 0730 4 2.010 1.727

7 3/25/2010 0730

- 1100 3.5 4.776 4.266

8 3/25/2010 1100

- 1500 4 7.253 6.229

9 3/25/2010 1500

- 1930 4.5 6.695 5.953

10 3/25/2010 1930

- 2300 3.5 5.046 4.411

11 3/25/2010 2300

- 0300 4 6.656 5.818

12 3/26/2010 0300

- 0700 4 6.012 5.295

13 3/26/2010 0700

- 1900 12 8.195 7.073

14 3/26/2010 1900

- 0700 12 2.187 1.945

15 3/27/2010 0700

- 1900 12 5.832 4.930

16 3/27/2010 1900

- 0700 12 4.563 4.043

1 Since there are fewer than three pairs of measured and modeled values greater than 0.1 micrograms/cubic meter for both terms, the emission rate for the period in question is defaulted by weighted interpolation or conservative diurnal matching

. Hence, using the most conservative approach, the flux values for this period is used from Period 7 (diurnal matching)

### Page 22 of 35 Table 1 4 . Flux Calculations for Field 2 (Broadcast Shank Injection and Compaction

- 0.25 inch water seal) at Kennewick, WA (MRID 48115101 )

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est.

Flux Study Reported Flux

(ug/m2

- s) (ug/m2

- s)

1 1 3/24/2010 0830

- 1200 3.5 0.527 1.710

2 2 3/24/2010 1200

- 1500 3 0.527 0.401

3 3/24/2010 1500

- 1930 4.5 0.173 0.176

4 3/24/2010 1930

- 00:00 4.5 0.120 0.123

5 3/25/2010 0000

- 0400 4 0.183 0.175

6 3/25/2010 0400

- 0730 3.5 0.267 0.255

7 3/25/2010 0730

- 1100 3.5 0.308 0.269

8 3/25/2010 1100

- 1530 4.5 0.387 0.336

9 3/25/2010 1530

- 1930 4 0.297 0.258

10 3/25/2010 1930

- 2330 4 0.153 0.133

11 3/25/2010 2330

- 0330 4 0.213 0.186

12 3/26/2010 0330

- 0700 3.5 0.167 0.146

13 3/26/2010 0700

- 1900 12 0.223 0.197

14 2 3/26/2010 1900

- 0730 12.5 0.237 0.143

15 3/27/2010 0730

- 1900 11.5 0.256 0.271

16 2 3/27/2010 1900

– 0700 11.5 0.788 0.170

1 Since there are fewer than three pairs of measured and modeled values greater than 0.1 micrograms/cubic meter for both terms, the emission rate for the period in question is defaulted by weighted interpolation or conservative diurnal matching

. Hence, using the most conservative approach, the flux values for this period is used from Perio d 2

2 Slope, Intercept and R squared values calculated only for 3 heights due to removal of

outlier



### MRID 47956901 Study

- A Trial to Evaluate Concentrations and Emission Rates from the Application of Metam Sodium by Shank Injection/Compaction on a Daytime and Nighttime Basis

In MRID 47813901, the study authors monitored for methyl isothiocyanate following an application of metam sodium by shank injection and compaction on a daytime and nighttime

basis. Th e test site was an agricultural field in San Joaquin Valley of California. The shank injection and compaction application were unbedded and conducted on a bare ground field in good seedbed condition within designated 2.4 acre each subplots . A water seal at the rate of 0.53 cm per hour followed the application. A second water seal was applied over a two hour period at a rate of 0.53 cm per hour from approximately 20:00 to 22:00 after the completion of each application and starting before the first sunset. The metam sodium application was conducted at the maximum label rate (75 gallons per acre) which is higher than the typical rate for each 2.4

acre area

. The daytime application (field 1) was conducted from 06:00 to 07:45 and the nighttime application (fie ld 2) was applied from 00:20 to 01:35. Field 2 was treated approximately 42

hours after field 1. The fields were 1.5 km from each other in a west to east orientation. The plots were typical of commercial agricultural fields in San Joaquin Valley.

### Page 23 of 35

On

- field air sampling was conducted on each of the two fields with sample intakes heights established at approximately 0.30, 0.60, 0.9, 1.8, and 3.0 meters above the soil surface. Each profile sampling mast was centrally located. Off

- field sampling was carri ed out only during the application and water sealing periods at the nighttime application (field 2) and throughout the study for the daytime application. Meteorological monitoring was conducted with a 2D sonic anemometer profile system established on field 1 to monitor wind speed, wind direction, and ambient temperature at 0.5, 0.9, 1.4, 1.8, 2.4, and 3.0 meters above the treated surface. The on

field meteorological profile systems were established approximately 5 meters downwind of the concentration profil e mast. A standard cup and vane system was established adjacent to field 2. Based on flat terrain and near proximity of the two fields, comparable wind speed profiles were expected for the two fields.

Six soil samples were obtained form both fields. Each sample was a composite of three sub

samples collected randomly for percent sand, silt, clay, organic matter, and pH. Soil cores were

taken from the same depths to compute field capacity and bulk densi ty subsequent to the compaction. Soil temperature ranged between 15 and 43 o 

### C at the 0 to 11 ” depth throughout the study duration. Soil temperature and moisture sensors connected to data loggers were buried at depths of approximately 8, 15, 23, and 30 cm in each field. Soil moisture in the upper 15 cm during the metam application was 72.5% and 53.7% field capacity or field 1 and 2, respectively. Field 2 also had lower soil water content. The second water treatment was applied after three periods in field 1 and four periods in field 2.

MITC samples were collected by charcoal sampling tubes. A total of 12 off

- field air sampling stations were established 20, 40, or 60 meters from the edge of field 1 and 8 were established

around field 2. Sampling intake heig ht for the ambient samplers were positioned approximately

1.5 meters above the soil surface. There were in total 289 on

- field samples analyzed and 388

off

- field samples.

Flux rates were calculated via on

- field flux data except during the fumigant application where the primary method to compute flux rates was the back

- calculation method. The flux profiles were calculated based on the field conditions including the applicat ion rates used to make the applications in the study. For the purposes of completing the PERFUM analyses, these flux profiles were subsequently adjusted to the maximum application rate for metam sodium of 320 lb metam sodium per treated acre (see Tables 1 5

- 1 6 ).

### Page 24 of 35 Table 1 5 . Flux Calculations for Field 1 (Broadcast Shank Injection and Compaction) at San Joaquin Valley, CA ( MRID 47956901 )

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est. Flux Study Reported Flux

(ug/m2

- s) (ug/m2

- s)

1 1,3 7/31/2008 9:30

- 11:30 2 6.190 4.380

2 7/31/2008 11:30

- 15:30 4 2.410 2.428

3 7/31/2008 15:30

- 19:30 4 4.543 4.452

4 2,3 7/31/2008 19:30

- 23:30 4 0.350 0.370

5 7/31/2008 23:30

- 3:30 4 0.589 0.607

6 8/1/2008 3:30

- 7:30 4 0.259 0.268

7 8/1/2008 7:30

- 11:30 4 0.198 0.209

8 8/1/2008 11:30

- 15:30 4 0.360 0.369

9 8/1/2008 15:30

- 19:30 4 0.334 0.342

10 4 8/1/2008 19:30

- 23:30 4 0.053 0.149

11 8/1/2008 23:30

- 3:30 4 0.278 0.266

12 5 8/2/2008 3:30

- 7:00 3.5 0.288 0.279

13 4 8/2/2008 7:00

- 11:30 4.5 0.059 0.291

14 6 8/2/2008 11:30

- 15:30 4 0.058 0.050

15 8/2/2008 15:30

- 18:30 3 0.093 0.087

16 4 8/2/2008 18:30

- 23:30 5 0.037 0.050

17 8/2/2008 23:30

- 3:30 4 0.092 0.102

18 4 8/3/2008 3:30

- 7:30 4 0.077 0.412

19 4 8/3/2008 7:30

- 11:30 4 0.702 0.197

20 6 8/3/2008 11:30

- 15:00 3.5 0.063 0.083

21 6 8/3/2008 15:00

- 19:30 4.5 0.052 0.066

22 6 8/3/2008 19:30

- 23:30 4 0.031 0.043

23 4 8/3/2008 23:30

- 3:30 4 0.189 0.322

24 4 8/4/2008 3:30

- 7:30 4 0.161 0.111

25 6 8/4/2008 7:30

- 19:00 11.5 0.016 0.022

26 6 8/4/2008 19:00

- 23:00 4 0.021 0.034

27 6 8/4/2008 23:00

- 7:30 8.5 0.090 0.114

28 6 8/5/2008 7:30

- 19:00 11.5 0.021 0.028

29 6 8/5/2008 19:00

- 23:30 4.5 0.027 0.034

30 4 8/5/2008 23:30

- 7:30 8 0.232 0.103

31 6 8/6/2008 7:30

- 19:00 11.5 0.027 0.034

1 No samples collected, application period

2 No samples collected, irrigation period

3 Flux calculated using ISCST3 Modeling

4 Slope, intercept and R squared values for concentration calculated from 3 values only due to poor regression fit

5 Calculated as average of flux (Delta method) value of Period 11 & 13 due to off

- field application contamination

6 Delta method used due to p oor regression fit (Refer to Field 1 Delta worksheet for
calculation details)

### Page 25 of 35 Table 16 . Flux Calculations for Field 2 (Broadcast Shank Injection and Compaction) at San Joaquin Valley, CA (MRID 47956901)

Period

No. Sample Interval Times Duration
(Hrs.) EPA Est.

Flux Study Reported Flux

(ug/m2

- s) (ug/m2

- s)

1

- 10 No samples collected as these correspond to periods 1

- 10 of the application

performed in field 1 which were prior to application of field 2.

11 1,3 8/2/2008 1:00

- 5:00 4 2.36 2.4

12 5 8/2/2008 5:00

- 7:00 3 39.982812 34.278326

13 8/2/2008 7:00

- 12:00 5 4.9751087 4.8418855

14 8/2/2008 12:00

- 16:00 4 16.814398 16.778182

15 8/2/2008 16:00

- 19:00 3 23.886099 22.910119

16 2,3 8/2/2008 19:00

- 22:30 3.5 2.07 2.7

17 4 8/2/2008 22:30

- 4:00 5.5 0.580 1.412

18 8/3/2008 4:00

- 8:00 4 2.575 2.738

19 8/3/2008 8:00

- 12:00 4 4.902 4.428

20 5 8/3/2008 12:00

- 15:30 3.5 7.209 8.085

21 5 8/3/2008 15:30

- 20:00 4.5 6.461 8.944

22 4 8/3/2008 20:00

- 00:00 4 4.322 7.781

23 5 8/4/2008 00:00

- 4:00 4 4.231 5.872

24 5 8/4/2008 4:00

- 8:00 4 2.514 8.370

25 8/4/2008 8:00

- 20:00 12 3.223 3.633

26 6 * see Note 1 2.129 4.106

27 4 8/4/2008 20:00

- 8:00 12.5 1.036 4.579

28 5 8/5/2008 8:00

- 19:30 11.5 1.198 1.315

29 6 * see Note 1 0.845 1.133

30 8/5/2008 19:30

- 8:00 11.5 0.492 0.950

31 4 8/6/2008 8:00

- 19:00 11 0.145 0.242

1 No samples collected, application period

2 No samples collected, irrigation period

3 Flux calculated using ISCST3 Modeling

4 Slope, intercept and R squared values for concentration calculated from 3 values only due to poor regression fit

5 Slope, intercept and R squared values for concentration calculated from 4 values only due to poor regression fit

6 Flux caculated as average of flux from preceding and following periods (Not shown in graph) *Note 1: The explanation for lack of concentration data for Periods 26 and 29 for Field 2 is provided in Log Sheet Detailed Description.doc Starting after Period 24 on Field 2 the sampling duration time were approximately 12 hours, t herefore, the duration for Periods 27 and 29 were approximately 12 hours for Field 2, but for Field 1 the sum of durations for Periods (26 and 27) and (29 and 30) were approximately 12 hours each.

### Page 26 of 35

MRID 47956701 Study

- Flux Evaluation of a Metam Potassium Application (KAPAM

- H L) Applied by the Drench Method (Study SEC

- 2008D) (Sponsored by Amvac Chemical
Corporation)

In MRID 47956701, the study authors monitored for methyl isothiocyanate (MITC) following the application of metam potassium onto a bedded soil surface using spray mozzles from a tank containing product with mixed with water that is pulled behind a tractor . The test site for this study was located in Modesto

, California and the field work was conducted in August of 2008. This study was conducted to identify the flu x rates of MITC over a six

- day period following the application. The single treated field was 2.35 acres in sized based on GPS coordinates. The metam potassium (KAPAM

- HL) application was applied at a rate o 17.05 gallons per broadcast acre. The applicati on resulted in a total volume of 1,895 gallons of solution per acre. A 0.2 inch water seal was applied immediately following the application. On the first and second evenings, an additional water deal of approximately 0.2 inches of water each was applied

.

Immediately following the application and water seal, air quality and meterological sampling equipment was relocated to the center of the treated field. Six MITC monitors were placed in the field at heights ranging from 0.3 meters to 3.0 meters above ground level. Meteorlogical profile monitoring for wind, temperature, and relative humi dity was conducted on the treated field downwind (south) center of the field based on the steady flow from the northwest and north through the study. Also, a 3D sonic anemometer and standard weather station were positioned to

document additional weather c onditions. The sampling height of the CSAT3 wind speed monitor
was 6.05 meters, the ET106 solar radiation monitor was set to 2.79 meters, the 2D meteorological monitors for wind speed ranged from 0.46 meters to 3.07 meters

, and the HOBO soil temperature se nsor was set to 0.61 meters above ground level

. The 1.6 meter wind sensor was found to produce inconsistent wind data compared to the other 5 wind monitor levels; therefore, wind speed was computed based on the other five levels.

Soil samples were collec ted on a random basis in the treatment zone prior to the application. Three subsamples collected with a shovel to the depth of 6 inches were used for each composite sample. The composite samples were transferred to a zip

- lock bag and numbered 1 through 6, along with the location of each sample through GPS readings. The preapplication soil samples from each field were analyzed for soil type, percent s and, silt, clay, organic matter, and pH. Soil was also continuously monitored by HOBO soil sensors for soil temperat ure and relative soil

moisture data within the treatment zone.

Off

- site air sampling was conducted via eight samplers throughout the active application and two

post

- application irrigation sets established approximately 25 to 50 meters from the edges of the plots around the field. The intake height was approximately 1.5 m above ground level to approximate the human breathing zone. There were 132 on

- field samples plus 27 exposed fortified samples. On

- field profile sampling began after application activities and initial sealing

ceased. There were a total of 24 off

- field samples which began sampling shortly before application and through the application period and two i rrigation periods (Periods 1, 4, and 10). Charcoal tubes were analyzed for the study.

### Page 27 of 35

Flux rates were calculated via on

- field flux data except during the fumigant application where the primary method to compute flux rates was the back

- calculation method. The flux profiles were calculated based on the field conditions including the application rates used to make the applications in the study. For the purposes of completing the PERFUM analyses, these flux profiles were subsequently adjusted to the maximum application rate for metam potassium of 320 lb metam potassium per treated acre (see Table 1 7 ).

Table 1 7 . Flux Calculations for Field 1 (Drench and Water Seal) at Modesto,
CA (MRID 47956701 )

Period

No. Sample Interval Times Duration (Hrs.) Est. Flux Re ported Flux

(ug/m2

- s) (ug/m2

- s)

1 1,3 8/20/2008 7:30

- 11:30 4:00 121.91 128.32

2 8/20/2008 11:30

- 15:30 4:00 12.60 11.62

3 8/20/2008 15:30

- 19:15 3:45 2.79 2.77

4 2,3 No samples collected 4:00 0.32 0.23

5 8/20/2008 23:15

- 3:15 4:00 2.39 0.04

6 8/21/2008 3:15

- 7:15 4:00 0.24 0.04

7 4 8/21/2008 7:15

- 11:15 4:00 0.94 0.06

8 4 8/21/2008 11:15

- 15:30 4:15 1.29 0.14

9 4 8/21/2008 15:30

- 19:15 3:45 1.34 0.06

10 2,3 No samples collected 4:00 0.03 0.09

11 4 8/21/2008 23:15

- 3:15 4:00 0.27 0.02

12 4 8/22/2008 3:15

- 7:15 4:00 0.26 0.03

13 4 8/22/2008 7:15

- 15:30 8:15 0.25 0.04

14 4 8/22/2008 15:30

- 23:30 8:00 0.41 0.02

15 4 8/22/2008 23:30

- 7:30 8:00 0.41 0.03

16 4 8/23/2008 7:30

- 15:30 8:00 0.40 0.02

17 4 8/23/2008 15:30

- 23:30 8:00 0.40 0.02

18 4 8/23/2008 23:30

- 7:30 8:00 0.40 0.02

19 4 8/24/2008 7:30

- 19:30 12:00 0.40 0.02

20 4 8/24/2008 19:30

- 7:30 12:00 0.40 0.01

21 4 8/25/2008 7:30

- 19:30 12:00 0.40 0.01

22 4 8/25/2008 19:30

- 4:30 9:00 0.40 0.01

1 No samples collected, application period

2 No samples collected, sample time too short

3 Flux calculated using ISCST3 Modeling

4 Delta method used due to poor regression fit.

### Page 28 of 35

3.0 PERFUM Modeling

The risk estimates calculated based on the recently submitted monitoring studies are summarized in this section. All risk estimates were calculated using the same hazard inputs and PERFUM modeling approaches as described in the previous risk assessment fo r metam sodium (Smith;

D 357118 ). Tables 1 8

– 2 1 provide a comparison of the PERFUM modeling results for the recently submitted studies to the studies used in the 2009 risk assessment. The results presented

in these tables are based on the Ventura weather station for a 40 acre field at the maximum application rate.

In the 2009 Metam Sodium RED, the re was not specific buffer table developed for shank injection broadcast untarped applications without water seals. Since that time, the Agency has

received three emission studies ( MRID 47770001, 48005901, and 48115101 ) examining

emissions from three fields using the untarped broadcast shank injection without water seals application methodology

. HED recommends that these three studies be utilized to develop a buffer table for this particular application method (see Tabl e 18 and Figure 1)

. Th e field s utilized

in these studies were prepared according to the currently recommended GAPs to ensure compliance with the fumigant labels and regulations and to achieve hi gh quality emissions data.

Table 1 8 : Comparison of 40 Acre PERFUM Whole Field Buffer Analyses Using Ventura Meteorological Data for F ive Metam Sodium Broadcast Shank Injection Flux Studies at the Maximum Application Rate of 320 lbs ai/A without water

seals 1

Percentiles Smith River, CA

–

Spray/Rototill/Roll 2 Mount Vernon, WA

– Roozen Rig 2 Pasco, WA

Broadcast Howard City, MI

Broadcast Injection

12” (field 1) Kennewick, WA

–

Broadcast Injection 9”
(field 1)

50 0 65 0 0 0

75 80 350 65 0 5

90 370 1160 290 0 70

95 685 ≥1440 525 5 150

99 1355 ≥1440 1040 85 355

99.9 ≥1440 ≥1440 ≥ 1440 160 605

1 All buffers measured in meters

. 2 Previously reviewed study

.

### Page 29 of 35

In the 2009 Metam Sodium RED, the buffer tables for shank injection broadcast untarped applications with water seals were developed based on the Bakersfield/Broadcast

Shank/Intermittent Water Seal emission stud y . Since that time, the Agency has received four

emission studies ( MRID 48011601, 48005901, 47956901, and 48115101 ) examining emiss ions

from six fields using the untarped broadcast shank injection with water seals application methodology

. HED recommends that these four studies be utilized to revise the current buffer table for this particular application method (see Table 1 9 and Figu re 2)

. Th e field s utilized in

these studies were prepared according to the currently recommended GAPs to ensure compliance with the fumigant labels and regulations and to achieve high quality emissions data.

Table 1 9 : Comparison of 40 Acre PERFUM Whole Field Buffer Analyses Using Ventura Meteorological Data for Nine Metam Sodium Broadcast Shank Injection Flux Studies at the Maximum Application Rate of 320 lbs ai/A with water seals 1

Percentiles Bakersfield,

CA

Standard

Water Seal 2 Bakersfield,

CA

Intermittent

Water Seal 2 Lost Hills,

CA

Intermittent

Water Seal 2 Coloma, WI

0.1” due to
rain (field 1) Coloma,

WI 0.1”

due to rain
(field 3) Howard

City, MI

0.33” after

app (field 2) San Joaquin

Valley, CA

double

water seal
(field 1) San Joaquin

Valley, CA

double

water seal
(field 2) Kennewick,

WA 0.25” after app
(field 2)

50 15 5 10 0 0 0 0 0 0

75 225 12 5 110 45 45 0 0 30 0

90 ≥1440 315 300 185 240 0 0 235 0

95 ≥1440 450 435 365 475 0 0 555 0

99 ≥1440 890 855 755 970 0 5 1390 0

99.9 ≥1440 ≥1440 1420 1205 ≥1440 0 95 ≥1440 0

1 All buffers measured in meters

. 2 Previously reviewed study

.

### Page 30 of 35

In the 2009 Metam Sodium RED, the re was not specific buffer table developed for shank injection bedded tarped applications. Since that time, the Agency has received two emission
studies ( MRID 47820001 and 47813901 ) examining emissions from six fields using the untarped

broadcast shank injection without water seals application methodology

. HED recommends that

these two studies be utilized to de velop a buffer table for this particular application method (see

Table 20 and Figure 3)

. Th e field s utilized in these studies were prepared according to the currently recommended GAPs to ensure compliance with the fumigant labels and regulations and

to ach ieve high quality emissions data.

Table 20 : Comparison of 40 Acre PERFUM Whole Field Buffer Analyses Using Ventura Meteorological Data

for S even Metam Sodium Bedded Shank Injection Flux Studies at the Maximum Application Rate of 320 lbs

ai /A with Tarps 1

Percentiles Citra, FL

LDPE
Tarp 2 Tifton, GA

Block ade
Tarp
(field 1) Tifton, GA

LDPE Tarp
(field 2) Tifton, GA

LDPE Tarp
(field 3) Duette, FL

Metalized
Tarp
(field 1) Duette, FL

Guardian VIF Tarp (field 2) Duette, FL

Metalized
Tarp (field 3)

50 50 0 25 0 0 0 0

75 360 55 205 60 0 15 5

90 1240 265 810 340 0 85 70

95 ≥1440 530 ≥1440 670 0 160 135

99 ≥1440 1075 ≥1440 1405 0 365 340

99.9 ≥1440 ≥1440 ≥1440 ≥1440 0 680 615

1 All buffers measured in meters

. 2 Previously reviewed study

.

### Page 31 of 35

In the 2009 Metam Sodium RED, the re was not specific buffer table developed for drench applications. Since that time, the Agency has received one emission stud y (MRID 47956701 ) examining emissions from one field using the drench with water seal a pplication methodology

. HED recommends that these two studies be utilized to develop a buffer table for this particular application method (see Table 2 1 ). Th e field utilized in this study was prepared according to the currently recommended GAPs to ensu re compliance with the fumigant labels and regulations and to achieve high quality emissions data

.

Table 2 1 : 40 Acre PERFUM Whole Field Buffer Analys i s Using Ventura Meteorological Data for One Metam Sodium Drench Study at the Maximum Application Rate of 320 lbs ai/A 1

Percentiles Modesto, CA

– triple water seal

50 55

75 270

90 685

95 1100

99 ≥1440

99.9 ≥1440

1 All buffers measured in meters

.

### Page 32 of 35



# Appendix A : Metam Sodium/Metam Potassium

Emission Studies Overview

### Page 33 of 35 Appendix A/Table A 1 : Metam Sodium/Metam Potassium Emission Studies Overview

MRID Location Application Type Application Rate
(lbs ai/treated
acre) Max 1

- hr

flux rate (ug/m2

- s) Max Application

Rate (lbs
ai/treated acre) Max Adjusted

1

- hr flux rate (ug/m2

- s) % Field

Capacity Soil

Temp
(oC) % OM Soil Type Start Time

of Application Completion

Time of Application Time of

highest peak % Mass

Loss

Sprinkler Irrigation Studies

45703701 Bakersfield, CA Solid set sprinkler, standard water seal
(2 water seals for a 1" total

- 0.5" after app and 24 hours after app) 320 358.1 320 358.1 NA NA NA NA NA NA 20

- 24 NA

CSREES #74 Bakersfield, CA Solid set sprinkler, Intermittent water
seal (6 water seals for a 1.5" total

0.25" after app, 4, 11, 24, 30, and 35

hours after app) 320 54.8 320 54.8 NA ~25 NA Sandy

loam NA NA 1 2

- 16 NA

45703702 San Joaquin,

CA Solid set sprinkler, Intermittent water

seal (5 water seals for a 1.5" total

- 0.5" after app; 0.25" at 8, 24, 30, and 48 hours after app) 320 48.0 320 48.0 ~60

- 80 NA NA NA 5:00 11:30 12

- 16 NA

46969601 Mettler, CA Solid set sprinkler, double water seal
(2 water seals for a 0.69" total

- 0.23" after app and 0.46" 8 hours after app) 320 80.7 320 80.7 ~50

- 75 ~20

- 25 0.5

- 0.8 Loamy

Sand 16:00 22:00 0

- 4 NA

Broadcast Shank Injection Studies

45703701 Bakersfield, CA Broadcast, standard water seal (0.5" after app) 320 118.3 320 118.3 NA NA NA NA NA NA 36

- 40 NA

CSREES #74 Bakersfield, CA Broadcast, Intermittent water seal (6

water seals for a 1.5" total

- 0.25" after app, 6, 11, 24, 30, and 35 hours after

app) 320 52.4 320 52.4 NA ~25 NA Sandy

loam NA NA 8

- 12 NA

45703704 Lost Hills, CA Broadcast, Intermittent water seal (5

water seals for a 1.5" total

- 0.5" after app; 0.25" at 8, 12, 30, and 34 hours

after app) 320 36.3 320 36.3 NA ~27 NA Clay

Loam 6:50 14:00 4

- 8 NA

46379201 Mt. Vernon,

WA Broadcast "Roozen Rig" 320 159 320 159.1 NA NA NA NA NA NA 8

- 12

47770001 Pasco, WA Broadcast 219 12 320 18.2 NA 7 to 16 NA NA 12:10 12:50 4

- 8 12.6

48011601 Coloma, WI Broadcast (Dual Injection at 5.5 and
9.5"), water seal (0.1" of rain after

app) 287 9.8 320 10.9 ~75

- 80 ~13 to 16 0.7 Loamy

Sand 10:27 10:38 29

- 33 6.98

48011601 Coloma, WI Broadcast (Dual Injection at 5.5 and
9.5"), water seal (0.1" of rain after

app) 270 10.7 320 12.7 ~75

- 80 ~13 to 16 1.3 Loamy

Sand 8:15 8:35 37

- 41 10.37

### Page 34 of 35 Appendix A/Table A 1 : Metam Sodium/Metam Potassium Emission Studies Overview

MRID Location Application Type Application Rate
(lbs ai/treated
acre) Max 1

- hr

flux rate (ug/m2

- s) Max Application

Rate (lbs
ai/treated acre) Max Adjusted

1

- hr flux rate (ug/m2

- s) % Field

Capacity Soil

Temp
(oC) % OM Soil Type Start Time

of Application Completion

Time of Application Time of

highest peak % Mass

Loss

48005901 Howard City,

MI Broadcast (Injection at 12") 318 2.8 320 2.8 ~60

- 80 ~7 to 12 1.1

- 1.6 Loamy

Sand/Sand 16:10 16:22 28

- 32 0.55

48005901 Howard City,

MI Broadcast (Injection at 12"), water

seal (0.33" after app) 321 0.3 320 0.2 ~60

- 80 ~7 to 12 0.5

- 1.3 Sand 14:34 14:45 28

- 32 0.07

47956901 Bak ersfield,

CA Broadcast (daytime), double water

seal (0.4" after app, 0.4" at sunset) 317 4.4 320 4.4 ~72 ~27 NA NA 6:00 7:45 0

- 4 1.2

47956901 Bakersfield, CA Broadcast (nightime), double water seal (0.4" after app, 0.4" at sunset) 320 34.3 320 34.3 ~54 ~27 NA NA 0:20 1:35 4

- 8 12.87

48115101 Pasco, WA Broadcast (Injection at 9") 317 7.1 320 7.1 72.4 ~8 1.6

- 1.9 NA 9:40 9:55 47

- 59 6.78

48115101 Pasco, WA Broadcast (Injection at 9"), water se al (0.25" after app) 368 1.7 320 1.5 70.9 ~8 1.1

- 1.4 NA 8:30 8:45 0

- 4 0.45

Bedded Shank Injection Studies

47131601 Helms, CA Bedded, untarped 294 18.77 320 20.4 NA ~13 8 Sandy

loam 9:03 10:54 4

- 8 NA

CSREES #74 Citra, FL Bedded, LDPE tarped 320 174.95 320 175.0 NA ~18 NA Sand 9:30 12:30 4

- 8 NA

47820001 Tifton, GA Bedded, Blockade Tarped (Field 1) 299.5 16.5 320 17.6 70 ~10 to 21 0.7 Sandy

loam 12:47 14:20 41

- 47 5

47820001 Tifton, GA Bedded, LDPE tarped (Field 2)

- Bad Soil Prep 306.3 55.2 320 57.7 65 ~10 to 21 0.6 Sandy clay loam 15:19 16:47 17

- 23 13

47820001 Tifton, GA Bedded, LDPE tarped (Field 3) 295.2 32.9 320 35.7 74 ~10 to 21 0.6 Loamy

sand 17:42 19:58 17

- 23 6

47813901 Duette, FL Bedded, Metallized tarped (Field 1) 313.6 2.2 320 2.3 142 ~10 to 21 0.94 NA 10:43 11:51 124

- 136 2.6

47813901 Duette, FL Bedded, Guardian VIF tarped (Field
2) 302.6 10.4 320 11.0 189 ~10 to 21 1.38 NA 13:22 14:38 6

- 12 5.5

47813901 Duette, FL Bedded, Metallized tarped (Field 3) 308.4 15.1 320 15.7 171 ~10 to 21 1.26 NA 16:03 16:52 0

- 6 2.31

Drench Studies

47956701 Modesto, CA Drench, triple water seal (0.2" after app, 0.2" at sunset of Day 1 and 2) 164.7 128.3 320 267.8 ~67 ~24 to 27 ~1.3 Sandy

loam 7:30 9:45 0

- 4 37.56

Drip Irrigation Studies

CSREES #74 Citra, FL Bedded, LDPE tarped 383 46.94 320 39.3 NA ~18 NA Sand 9:30 16:00 32

- 36 NA

45703708 Irvine, CA Bedded, LDPE tarped 320 15 320 14.9 NA NA NA NA 18:20 20:45 0

- 4 NA

### Page 35 of 35 Appendix A/Table A 1 : Metam Sodium/Metam Potassium Emission Studies Overview

MRID Location Application Type Application Rate
(lbs ai/treated
acre) Max 1

- hr

flux rate (ug/m2

- s) Max Application

Rate (lbs
ai/treated acre) Max Adjusted

1

- hr flux rate (ug/m2

- s) % Field

Capacity Soil

Temp
(oC) % OM Soil Type Start Time

of Application Completion

Time of Application Time of

highest peak % Mass

Loss

45703708 Irvine, CA Bedded, untarped (drip lines on soil
surface) 320 9 320 9. 4 NA NA NA NA 18:00 22:00 8

- 12 NA

Center Pivot Irrigation Studies

47770001 Pasco, WA Center Pviot Irrigation

- Drizzle Boom 300 172.1 320 183.8 NA 7 to 16 NA NA 11:35 13:30 0

- 4 47

Flood Irrigation Studies

47314301 Brawley, CA Flood Irrigation 318 68.34 320 68.8 NA NA NA NA NA NA 5

- 9 NA

Rotary Tiller and Spray Blade

47572201 Smith River,

CA Broadcast Spray/Rototill/Roller 320 49 320 49.4 ~30

- 35 ~19 to 21 ~4 Clay loam/Clay NA NA 4

- 8 14.1