### UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D.C. 20460

August 27,2013 OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION



### MEMORANDUM PC Code: 029001 DP Barcode: 410113

SUBJECT:



### FROM

_ :

REVIEWED BY:

THROUGH: 

### Problem Formulation for the Environmental Fate and Ecological Risk, Endangered Species, and Drinking Water Assessments in Support of the Registration Review of 1,3-Dichloropropene (Telone)

Elizabeth Riley, Biologist

# ~**~~ ~**  

# I**~** 

# ) \**~** Andrew Shelby, Environmental

## Scientis**~ ~**  Environmental Risk Branch VI 

# IJ

Environmental Fate and Effects Division (7507P)

William P. Eckel, Senior Science Advisor Mark Corbin, Branch Chief Environmental Risk Branch VI Environmental Fate and Effects Division (7507P)

Mark Corbin, Branch Chief Environmental Risk Branch VI Environmental Fate and Effects Division (7507P)

TO: 

### Margaret Hathaway, Chemical Review Manager

Risk Management and Implementation Branch II Pesticide Re-Evaluation Division (7508P)

Page 1 of 57

### Page 2 of 58 

# Problem Formulation for the Environmental Fate, Ecological Risk, Endangered Species, and Drinking Water Exposure Assessments in Support of the Registration Review of 1,3

- Dichloropropene (Telone)

1,3

- Dichloropropene 

## CAS Registry Number: 542

- 75

- 6 PC C ode: 029001

Prepared by: Elizabeth Riley, Biologist Andrew Shelby, 

### Environmental Scientist U. S. Environmental Protection Agency Office of Pesticide Programs Environmental Fate and Effects Division Environmental Risk Branch VI 1200 Pennsylvania Ave., NW Mail Code 7507P Washington, DC 20460 Reviewed by: William P. Eckel, Senior Science Advisor Mark Corbin, ERB 6 Branch Chief



### May 22, 2013 

## Office of Chemical Safety and Pollution Prevention

### Page 3 of 58 

## Table of Contents
1. Executive summary

................................ ................................ ................................ ................. 4 2. Introduction

................................ ................................ ................................ ............................. 6 3. Use Characterization

................................ ................................ ................................ ............... 8 4. Conclusions from Previous Risk Assessments

................................ ................................ ..... 12 4.1. Ecological Risk Assessment

................................ ................................ ................................ . 12 4.2. Drinking Water Exposure Assessments

................................ ................................ ......... 13 4.3. Clean Water Act Programs

................................ ................................ ............................. 14 5. Environmental Fate and Transport

................................ ................................ ........................ 14 5.1. Transformation Products

................................ ................................ ................................ 18 6. Receptors

................................ ................................ ................................ ............................... 22 6.1. Effects to Aquatic Organisms

................................ ................................ ........................ 22 6.2. Effects to Terrestrial Organisms

................................ ................................ .................... 25 6.3. Ecological Incidents

................................ ................................ ................................ ....... 26 7. Exposure Pathways of Concern

................................ ................................ ............................ 27 8. Analysis Plan

................................ ................................ ................................ ........................ 28 8.1. Stressors o f Concern

................................ ................................ ................................ ....... 28 8.2. Measures of Exposure

................................ ................................ ................................ .... 29 8.3. Measures of Effect

................................ ................................ ................................ ......... 32 9. Endangered Species Assessments

................................ ................................ ...................... 32 10. Endocrine Disruptor Screening Program

................................ ................................ ....... 32 11. Preliminary Identification of Data Gaps

................................ ................................ ........ 32 11.1. Environmental Fate

................................ ................................ ................................ ..... 32 11.2. Ef fects

................................ ................................ ................................ ......................... 38 12. References

................................ ................................ ................................ ............................ 45 Appendix A

- OPPIN Bibliography

................................ ................................ ............................... 48 Appendix B

- SIP and STIR Outputs

................................ ................................ ............................. 56

### Page 4 of 58 

# 1. Executive summary

The Environmental Fate and Effects Division (EFED) has completed the preliminary problem formulation for the ecological risk, environmental fate, endangered species, and drinking water assessments to be conducted as part of the registration review of 1,3

- Dichl oropropene (1,3

- D; Telone) . The problem formulation describes the methods planned to be used during the completion of drinking water and ecological r isk assessments in support of registration review and provide s an ove rview of the environmental fate, ecol ogical effects , and potential risks associated with the use of 1,3

- D as well as uncertain ties unique to the risk assessment of 1,3

- D

. This document also identifies additional studies that would be beneficial to the conduct of an ecological risk assessment

. Major findings include:

The following environmental fate data gaps exist for 1,3

- D:

• Aerobic Soil Metabolism Study for 1,3

- D, 3

- chloroallyl alcohol and 3

- chloroacryllic acid (OCSPP Guideline 835.4100) : An acceptable aerobic soil metabolism study has b een previously submitted for two soils but the half

- life estimates vary greatly, 14 days and 45 days. This results in a high 90 th 

### percentile average of 94 days, the value used as a model input parameter. Aerobic soil metabolism data on CAAL and CAAC are necessary to characterize degradate fate and parameterize models. In the absence of degradate aerobic soil metabolism data, degradate aerobic aquatic metabolism studies can be used for metabolism characterization but does not necessarily accurately reflec t soil metabolism. 1,3

- D aerobic soil metabolism half

- lives are significantly longer than 1,3

- D aerobic aquatic half

- lives and a similar relationship is possible for degradates. Additionally, given the volatility of parent and degradate, the chemical can reside in the vadose zone above the water table and be more affected by soil metabolism rather than aquatic metabolism.

• Anaerobic Aquatic Metabolism Study for 3

- chloroallyl alcohol and 3

- chloroacryllic acid (OCSPP Guideline 835.4 4 00) : 1,3

- D quickly degra des to the highly mobile and potentially persistent residue s of concern, 3

- chloroallyl alcohol (CAAL) and 3

- chloroacryllic acid (CAAC) . Th ese degradate s ha ve the potential to accumulate in groundwater where its only degradation pathways are hydrolysis and anaerobic metabolism. CAAL and CAAC are stable to hydrolysis allowing only for anaerobic metabolism as a possible degradation pathway in anaerobic aquifers

. There is uncertainty relating to the anaerobic metabolism and the persistence or dissipation of th ese residue s of concern depends on the characterization of this pathway.

• Field Volatility Study (OCSPP Guideline 835.8100): A field volatility study for a
t arped application at maximum labeled rate is needed. Tarped field volatility studies have been previously submitted but not at the maximum rate. Due to the high maximum application rate and the multi

- pathway dissipation of 1,3

- D, it is important to fully characterize each use pattern that can result in significantly different dissipation and volatility behavior. In the absence of data, EPA cannot accurately characterize the routes and rates of the various dissipation pathways.

• Envrionmental Chemistry Me thods/Independent Laboratory Validation (OCSPP Guideline 850. 6100) : A study has been submitted that will fulfill this data requirement if found to be acceptable. Pending review of the study, the data gap remains.

### Page 5 of 58 The following ecolo gical data gaps exist for 1,3

- D:

• Estuarine/Marine Invertebrate Chronic Toxicity Study (OCSPP Guideline 850.1350): 1,3

- D has outdoor uses that may result in exposure to estuarine/marine invertebrates. In addition, the aerobic aquatic metabolism half

- life (4.9 days) suggest s tha t 1,3

- D may persist in aqu atic environments long enough for chronic exposure to be a

concern. In the absence of data EPA will use an acute to chronic ratio (ACR) for the freshwater invertebrate to estimate a chronic endpoint for the estuarine/marine invert ebrate.

• Freshwater Fish Early

- Life Stage Toxicity Study (OCSPP Guideline 850.1400): A freshwater fish early life

- stage test (embryo development through a portion of juvenile growth) using the TGAI is required for 1,3

- D because the end

- use product may be
t ransported to surface water from the intended use site. Also, the following conditions are met: (1) the pesticide is intended for use such that its presence in water is likely to be continuous or recurrent regardless of toxicity, (2) the acute LC 50 

### is less than 1 ppm, (3) the EEC in water is equal to or greater than 0.01 of the acute LC 50 

### value or (4) the actual or estimated environmental concentration in water resulting from use is greater than 0.01 of any acute LC 50 

### or EC 50 

### value and 1,3

- D is per sistent in water ( i.e. , half

- life greater than 4 days). The preferred test species is fathead minnow ( Pimephales promelas ). The European Food Safety Authority (EFSA) references a chronic freshwater fish endpoint for the fathead minnow of 0.032 ppm (EFSA 2 009); however, this data would need to be submitted and reviewed by EPA to determine its suitability for use in risk assessment.

• Estuarine/Marine Fish Early

- Life Stage Toxicity Study (OCSPP Guideline 850.1400): An estuarine/marine fish early life

- stage te st using the TGAI has not been submitted, since it was not considered to be necessary based on previous risk assessments for 1,3

- D. However, because 1,3

- D is expected to be applied in coastal counties, it could be transported via runoff to marine/environm ents, and the acute value for sheepshead minnow ( Cyprinodon variegatus ) is < 1.0 mg/L, chronic toxicity data for marine/estuarine fish is needed. If chronic data for a freshwater species become available EPA may be able to use an ACR to estimate a chronic endpoint for the estuarine/marine fish.

• Acute Avian Inhalation Study (Non

- Guideline): Due to the fate properties of fumigants, in particular their high volatility, it is expected that birds will be exposed to fumigants in the vapor phase via inhalation. The standard toxicity studies with birds ( i.e., acute oral and acute dietary) do not account for exposure to vapor phase pesticides. Therefore, to assess risks of 1,3

- D to birds, EFED recommends that the Agency require a

non

- guideline avian inhalation stu dy with the bobwhite quail ( Colinus virginianus ) for 1,3

- D . A protocol should be submitted to the Agency for approval prior to initiating the study

.

• Acute Honey Bee Vapor Exposure Study (Non

- Guideline): Due to the fate properties of fumigants, in particu lar their high volatility, it is expected that honey bees and other insect pollinators will be exposed to fumigants in the vapor phase. Neither of the standard Tier I toxicity studies with honey bees ( i.e., acute contact or acute oral toxicity study for honey bees) account for exposure to vapor phase pesticides. Therefore, to assess risks of 1,3

- D to bees, EFED recommends that the Agency require a non

- guideline acute

### Page 6 of 58 honey bee vapor exposure study for 1,3

- D, to be conducted in lieu of the normally required acute honey bee contact study that would fulfill guideline 850.3020 and the newly proposed requirements for oral toxicity tests including adult and larval honey bees. A protocol should be submitted to the A gency for approval prior to initiating the study

.

• Terrestrial Plant Vapor Exposure Study (Non

- Guideline): Due to the fate properties of fumigants, in particular their high volatility, it is expected that terrestrial plants will be exposed to fumigants in the vapor phase. The standard toxicity studies with terrestrial plants ( i.e., Tier I and II vegetative vigor) do not account for exposure to vapor phase pesticides. Therefore, to assess risks of 1,3

- D to terrestrial plants, EFED recommends that the Age ncy require a non

- guideline terrestrial plant vapor phase exposure study for 1,3

- D, to be conducted in lieu of the normally required Tier II vegetative vigor study that would fulfill guideline 850.4150.

Major uncertainties:

The largest uncertainty in q uantifying aquatic exposure in this assessment will be the impact of tarps, especially bedded tarps, on the likelihood of telone to runoff the field and the concentration of telone in the runoff. Tarps and bedded tarps are thought to reduce or eliminate the potential for aquatic exposure but this is not demonstrated in field data and cannot be quantified. Another uncertainty is the impact of rainfall occurring close to the time of application on the runoff and volatilization rates of telone in the enviro nment.

For terrestrial exposure, estimated environmental concentrations (EECs) in air will conservatively assume that birds and mammals are not transient and are always being exposed to emissions of telone downwind from the treated field. Such an assumpt ion is perhaps more representative for plants since they are not transient. One uncertainty for air EECs is the propensity for large exposures to occur on timescales less than one hour. Such conditions are often associated with temperature inversions whe n light and variable wind speeds and highly stagnant air with limited mixing can occur. Therefore, peak air concentrations may be underestimated. However, it is not expected that these conditions would significantly impact the expected frequency of expos ure events since these conditions may only occur within a few hours of some days after fumigant applications.

Another uncertainty includes the consideration of field size for the quantification of air EECs. Air EECs will be based on emissions occurring from a maximum field size of 80 acres. Eighty acres is considered to be the upper

- bound field size for the maximum area that is typically treated in one day (USEPA, 2013b)

.



# 2. Introduction

1,3

- D is a soil fumigant that exerts toxic action on vital enzym es or enzyme systems in nematodes. Substitution of a sulfhydryl, ammonia, or hydroxyl group with the chlorine in 1,3

- D results in restriction of the enzyme function, leading to paralysis and death (Cox 1992)

. The mechanism of action in other taxa ( e.g., pl ants) is not understood.

### Page 7 of 58 1,3

- D is commonly formulated as a pressurized gas, liquid ready to use, and emulsifiable and flowable concentrate. I t can be applied as a soil fumigant via soil injection or drip irrigation

. The use information presented in th is problem formulation was obtained from the tables in the EFED Label Data Report dated 2 / 28 /201 3 , from BEAD’s Chemical Profile for Registration Review (USEPA 2013 ), and from various evaluated labels. There are currently 16 Section 3 registered products as well as 22 Special Local Needs (SLN) registrations for 1,3

- D.

1,3

- D is registered for preplant use on agricultural crop soils for the following: vegetables, fruit and nut crops, forage crops (grasses, legumes, and other non

- grass forage crops), tobacco, fiber crops, and nursery crops (ornamental, non

- bearing fruit/nut trees and forestry crops). 1,3

- D has no residential uses but is registered for non

- agricultural, preplant use on golf course turf, ornamental and/or shade trees, ornamental herbaceous and non

- flowering plants, and ornamental woody shrubs and vines. The only post

- plant use for which 1,3

- D is registered is in vineyards. This post

- plant use is classified as a food

- use. BEAD provided agricultural information b y state in its 1,3

- D Chemical Profile for Registration Review (USEPA 2013 ) . The BEAD report states: “ The top states in terms of pounds a.i. applied during this period [2007

- 2011] were Washington (20%), Idaho (19%), California (15%), and North Carolina (13% ).”

The following labeling statements appear on all 1,3

- D labels to avoid contamination of aquatic environments and drinking water from use on agricultural products.

ENVIRONMENTAL HAZARD STATEMENTS

o Do not apply directly to water, to areas where surface water is present or to intertidal areas below the mean high water mark. Do not contaminate water by disposal of equipment washwaters.

o Groundwater advisory : 1,3

- dichloropropene is known to move through soil and under certain conditions has the potential to reach groundwater as a result of agricultural use. Application in areas where soils are permeable and groundwater is near the surface could result in groundwat er contamination.

In addition, the Telone II label includes the following restriction for use in karst areas: “ Do not apply this product within 100 feet from the edge of karst topographical features. Karst topography is identified from landscape features that result from the dissolving activity of water in carbonate rock formations (limestone, dolomite and marble). Surface features that are associated with karst topography include sinkholes, caverns, springs, and sinking or disappearing streams. In North Dakota, South Dakota, Wisconsin, Minnesota, New York, Maine, New Hampshire, Vermont, Massachusetts, Utah, and Montana: Where groundwater aquifers exist at a depth of 50 feet or less from the surface, do not apply this product where soils are Hydrologic Gro up A. ”

EFED evaluated the most recent ecological risk assessments for 1,3

- D in association with the update d toxicity, exposure, and usage information to determine if sufficient data are available and if further updates are needed to support registration review. Recent risk assessments include a 20 07 assessment for the use of 1,3

- D on grapes ( DP Barcode 318737 ) , the 2004 analysis of

### Page 8 of 58 risks to endangered and threatened salmon and steelhead (DP Barcode 303297) , the 2008 California Red

- legged Frog assessment ( USEPA, 2008 ), and the 1997 Reregistration Eligibility Decision (RED ) (DP Barcodes 229720, 229725, 235916, and 235834) . In addition, EFED considered the latest Agency science policies and risk assessment methodologies.



# 3. Use Characterization

1,3

- D is a soil fumigant that exerts toxic action on vital enzymes or enzyme systems in nematodes. Substitution of a sulfhydryl, ammonia, or hydroxyl group with the chlorine in 1,3

- D results in restriction of the enzyme function, leading to paralysis and death (Co x 1992)

. It is registered for preplant use on agricultural crop soils for the following: vegetables, fruit and nut crops, forage crops (grasses, legumes, and other non

- grass forage crops), tobacco, fiber
crops, turf, and nursery crops (ornamental, non

- bearing fruit/nut trees and forestry crops). The only post

- plant use for which 1,3

- D is registered is in vineyards . This agricultural post

- plant use is classified as a food

- use

. 1,3

- D is also registered for preplant use on ornamental and/or shade trees, ornamental herbaceous and non

- flowering plants, and or namental woody shrubs and vines. 1,3

- D is commonly formulated as a pressurized gas, liquid ready

- to

- use, and emulsifiable and flowable concentrate. I t can be applied a s a soil fumigant via soil injection or drip irrigation

. The chem ical profile produced by the EPA’s BEAD ( Biological and Economic Analysis Division ) of the Office of Pesticide Programs , located in the docket, lists the use patterns of maxim um exposure s for the current uses of 1,3

- D

. The most dominant uses are on potatoes and tobacco with 11.8 million lbs a.i. and 4.1 million lb a.i. used per year, respectively. Almonds, carrots, cotton, onions, peanuts, and strawberries are also significant use patte rns with more than one million lbs a.i. applied per year for each use. Table 1 lists all use patterns with application information from label extractions provided by the Biological and Economic Analysis Division (BEAD).

On many labels, neither maximum a nnual application rate nor maximum number of applications per year is specified. However, the registrant has submitted characterization of 1,3

- D use patterns with applications that typically occur more than once per year (Dow AgroScience, 2013) . Potatoes in the Pacific Northwest, cotton in the southern states, and tobacco along the east coast may receive a second application to manage perennial weeds, for growing a rotational crop, or to prepare for the following year’s crop. For nursery stock, protocols are in place in states including California that require two 1,3

- D applications. In high value vegetable producing areas including California and Florida, 2 to 2.5 applications of 1,3

- D per year may be made preceding each crop. Uses on corn, ornamentals , recreational lawns, and tree nuts have one or more labels with neither maximum annual application rate nor maximum number of applications per year and no characterization of use was provided from the registrant. For these use patterns, conservative assu mptions will be made regarding number of applications per year. No more than two applications per year are expected but clarification from the registrant would reduce uncertainty.

### Page 9 of 58 Table 1 . Uses Site and Application Information for 1,3

- D

Site Descrip tion Formula tion Type Max Applicatio n Rate (lbs a.i./Acre) Max

. Annual

Rate Max. No. of Apps
per Year Min. App. Interva l Application Method s Restrictions Comments (Relevant data not included in other columns such as applic ation timing, incorporation depth, etc) Agricultu ral crop/soi ls (unspecifi ed) RTU 380 NS NS NS Soil fumigation:
p lowsole or chisels For use in Oregon only Preplant

Alfalfa RTU 247 NS NS NS Soil fumigation: plowsole, chisels, or shank For use in Washington only Preplant (fall); late

summer

Beans; beets RTU 581 581 1 NA Broadcast: plowsole, chisel, or shank Soil fumigation: chisel or drip irrigation Tarp: shank None Preplant

Carrot (includin g tops); cauliflow er; citrus; cole
crops RTU 581 581 1 NA Broadcast: plowsole, chisel, or shank Soil fumigation: chisel or drip irrigation Tarp: shank Certain labels refer to restrictions in Florida Preplant

Corn (unspecifi ed) RTU EC 581 581 1 /NS NA Broadcast: plowsole, chisel, or shank Soil fumigation: chisel or drip irrigation Tarp: shank Certain labels refer to restrictions in Florida Preplant; Preplant (fall); Late summer

Cotton (unspecifi ed) RTU EC 178 178 1 NA Soil band
treatment: plowsole or chisel Soil fumigant: plowsole, chisel or drip irrigation Tarp: chisel or drip irrigation Certain labels restrict use in specific counties in California Preplant, At planting

Deciduou s fruit
trees (unspecifi ed) RTU EC 581 581 1 NA Broadcast: plowsole, chisel or shank Soil fumigant: plowsole, chisel or drip irrigation Tarp: chisel or drip irrigation Certain labels refer to restrictions in Florida Preplant

Forest RTU 544 544 1 NA Soil band Certain labels Preplant

### Page 10 of 58 Site Descrip tion Formula tion Type Max Applicatio n Rate (lbs a.i./Acre) Max

. Annual

Rate Max. No. of Apps
per Year Min. App. Interva l Application Method s Restrictions Comments (Relevant data not included in other columns such as applic ation timing, incorporation depth, etc)
nursery plantings (for transplant ) treatment: chisel Soil fumigation: plowsole or chisel restrict use in specific counties

Fruits (processe d and unspecifi ed) RTU EC 581 581 1 NA Broadcast: plowsole, chisel or shank Soil fumigant: plowsole, chisel or drip irrigation Tarp: chisel or drip irrigation Certain labels restrict use in specific counties in California and Florida Preplant

Golf

course turf RTU 49 49 1 NS Soil fumigation: soil injector equipment Certain labels only allow use in Arkansas and North Carolina Foliar application

Grapes FC 18.5 37 NS NS Soil fumigation: drip irrigation Labels restrict use in certain counties Established plantings; post harvest; postplant

Hops RTU EC 581 581 1 NA Broadcast: plowsole, chisel or shank Soil fumigant: plowsole, chisel or drip irrigation Tarp: chisel or drip irrigation Certain labels restrict use in specific counties in California Preplant

Legume vegetable

s RTU EC 581 581 1 NA Broadcast: plowsole, chisel or shank Soil fumigant: plowsole, chisel or drip irrigation Tarp: chisel or drip irrigation Certain labels restrict use in specific counties in California and Florida Preplant

Lettuce RTU EC 581 581 1 NA Broadcast: plowsole, chisel or shank Soil fumigant: plowsole, chisel or drip irrigation Tarp: chisel or drip irrigation Certain labels restrict use in specific counties in California and Florida Preplant

Melons SC/L EC 85 NS 1 NS Soil fumigation: drip irrigation Only allowed in Texas and Arizona Preplant

Mint RTU 572 572 1 NA Soil Labels restrict Preplant

### Page 11 of 58 Site Descrip tion Formula tion Type Max Applicatio n Rate (lbs a.i./Acre) Max

. Annual

Rate Max. No. of Apps
per Year Min. App. Interva l Application Method s Restrictions Comments (Relevant data not included in other columns such as applic ation timing, incorporation depth, etc) EC fumigation: drip irrigation use in specific counties in California Nursery stock;
ornament al woody shrub and vines EC 572 572 1 NA Tarp: drip irrigation Labels restrict use in specific counties Preplant

Onion EC 572 572 1 NA Soil fumigation: drip irrigation Labels restrict use in specific counties in California Preplant

Ornament al RTU EC 841 NS 1/ NS NS Soil band treatment, soil fumigation, tarp, broadcast Labels restrict use in specific counties in Florida Preplant

Peach RTU 346 NS 1 NS Soil band treatment, soil fumigation, tarp, broadcast Labels restrict use in specific counties Preplant

Peanuts RTU EC 581 NS 1 NS soil fumigation, tarp, broadcast Labels restrict use in specific counties in California Preplant

Pepper EC 80 NS NS NS Chemigation Preplant

Pineapple RTU EC 581 NS 1 NS Soil band treatment, soil fumigation, tarp, broadcast Labels restrict use in specific counties and in Florida Preplant/At planting

Potato RTU EC 581 NS 1/NS 365 d/NS Soil band treatment, soil fumigation, tarp, broadcast Labels restrict use in specific counties and in Florida Preplant

Radish RTU EC 581 NS 1 365 d/NS Soil band treatment, soil fumigation, tarp, broadcast Labels restrict use in specific counties and in Florida Preplant

Recreatio nal area lawn RTU 49 NS 1/NS NS Soil fumigation Foliar

Soybean RTU EC 572 NS 1 365 d soil fumigation, tarp, broadcast Labels restrict use in specific counties and in Florida and California Preplant

Spruce (Forest) RTU 544 NS 1/NS 365 d Soil band treatment, soil fumigation Labels restrict use in specific counties Preplant

Stone Fruit RTU 346 NS 1 Soil band treatment, soil fumigation, tarp, broadcast Labels restrict use in specific counties Preplant

Strawberr
y RTU EC 542 NS 1/NS 14 d with 285 lb a.i./ac applicati

on soil fumigation, tarp, broadcast Labels restrict use in specific counties and in Florida Preplant

### Page 12 of 58 Site Descrip tion Formula tion Type Max Applicatio n Rate (lbs a.i./Acre) Max

. Annual

Rate Max. No. of Apps
per Year Min. App. Interva l Application Method s Restrictions Comments (Relevant data not included in other columns such as applic ation timing, incorporation depth, etc)

Sugar Beet RTU EC 581 NS 1/NS 365 d/NS Soil band treatment, soil fumigation, tarp, broadcast Labels restrict use in specific counties in California Preplant/Pre

renovation

Sweet Potato RTU EC 581 NS 1 NS soil fumigation, tarp, broadcast Labels restrict use in specific counties and in Florida and California Preplant

Tobacco RTU EC 581 NS 1 NS soil fumigation, tarp, broadcast Labels restrict use in specific counties and in Florida and California Preplant

Tomato RTU EC 387 NS 1 NS soil fumigation, tarp, broadcast Labels restrict use in specific counties and in Florida and California Preplant

Tree Nuts RTU EC 581 NS 1/NS NS Soil band treatment, soil fumigation, tarp, broadcast Labels restrict use in specific counties and in Florida and California Preplant

Vegetabl

es RTU EC 581 NS 1/NS 14 d with 285 lb a.i./ac applicati

on Soil band treatment, soil fumigation, tarp, broadcast Labels restrict use in specific counties and in Florida and California Preplant

Wheat RTU 178 NS 1/NS 365 d/NS Soil band treatment, soil fumigation, tarp, broadcast Labels restrict use in specific counties Preplant

RTU

– Ready to use EC

– Emulsifiable Concentrate SC

- Suspended Concentrate LEC

- Liquid Emulsifiable Concentrate NS

– Not Specified



# 4. Conclusions from Previous Risk Assessments

4.1. Ecological Risk Assessment

The Agency has conducted multiple ecological risk assessments on 1,3

- D that serve as a basis for this problem formulation document , including the Reregistration Eligibilit y Decision (RED)

, the 200 8 CRLF assessment, and a new use assessment s from 2007 for use of 1,3

- D on grapes . The primary risk issues have been identified for fish and aquatic invertebrates

.

### Page 13 of 58 The most recent, comprehensive assessment conducted for 1,3

- D is the RED (USEPA, 199 7 )

, which was issued in October 1998. Though the RED provides the most recent, comprehensive assessment, maximum rates assessed do not reflect the current maximum rates for 1,3

- D used today. In addition, the RED did not assess vapor phase exposure ( i.e., the major exposure route) to birds, terrestrial invertebrates, or terrestrial plants due to a lack of data. The major ecological conclusions presented in the RED were as follows:

Table 2 . Summary of Risk Conc erns Identified for Chemical 1,3

- D in Previous Assessments

Birds Mammals Terr

. Plants Terr

. Inverts Fish BCF Aquatic Inverts Aquatic Plants Groundwater Contamination Persistence Degrades of Concern N o a No NA b NA c Yes d No Yes e NA f Yes No 3

- chloroallyl alcohol; 3

- chloroacrylic acid

a No inhalation data were available to allow for an inhalation risk assessment. In addition, no reproduction data were available to allow for a chronic risk assessment , though chronic risks are not anticipated given the relatively short field dissipation half

- life of 1,3

- D. b No terrestrial plant toxicity data were available at the time of the RED. In the 2007 new use assessment for use of 1,3

- D on grapes risks to listed and non

- listed dicotyledonous plants inhabiting semi

- aquatic areas was likely due to runoff from treated fields. Given the relatively low application rate for grapes (18.5 lbs a.i/A versus a maximum application rate of 581 lbs a.i./A on several other crops), it is likely that the RED would have identifi ed risks to plants if terrestrial plant toxicity data were available. Vapor phase exposure was not considered as the corresponding toxicity data were not available.

c Risk to terrestrial invertebrates has not been assessed. Vapor phase exposure was not considered as the corresponding toxicity data were not available. d No data were available to assess chronic risks to fish. e No data were available to assess chronic risks to aquatic invertebrates. f Aquatic plants were not assessed in the RED. In th e 2007 new use assessment for use of 1,3

- D on grapes risks to listed and non

- listed aquatic plants were minimal. However, the maximum application rate assessed for the new use (18.5 lbs a.i./A) is substantially less than the maximum application rate recogn ized on current labels of 1,3

- D (581 lbs a.i./A). Yes = at least one LOC has been exceeded in previous assessments; No = LOCs have not been exceeded in previous
assessments ; NA = RQs have not been calculated previously.



## 4.2. **Drinking Water Exposure Assessments** 

Characterization of drinking water exposure from surface water was addressed in 2008 memorandum (D348051 ; “Characterization of Surface Water Modeling Results for Telone” ). While not providing estimated concentrations, use of EFED’s standard s urface water exposure model, PRZM

- EXAMS, is qualified with a caution to the user for 1,3

- D due to the chemical’s high volatility. The volatilization routines in PRZM have been evaluated however only volatilization at room temperature is modeled. Volatili zation will be faster at summer outdoor temperatures, so this important process is not captured adequately. Thus, PRZM

- EXAMS does not adequately model the major dissipation process for telone. Further, the memorandum reasons that the variable and limited aerobic soil metabolism data, lacking aerobic aquatic metabolism data, and incomplete degradate fate dataset do not allow for a refinement of EDWCs. Finally, the memorandum concludes EFED’s concern about human exposure to telone is via the

### Page 14 of 58 groundwater ex posure route due to being shielded from many of the processes that can contribute to its more rapid dissipation from surface water.

Characterization of drinking water exposure from groundwater was addressed in 2009 (D367253) and 2010 memoranda ( USEPA, 201 0 ). The 2009 memorandum describes 1,3

- D as a

non

- persistent compound that hydrolyzes on the order of days to weeks to the daughter products 3

- chloroallyl alcohol and 3

- chloroacrylic acid, and then to carbon dioxide and chloride ions . The memorandum further describes 1,3

- D as less likely to contaminate ground water than chemically similar but more persisten t compounds such as chlorinated methanes, ethanes, and ethylenes. The memorandum concludes the non

- persistent nature of 1,3

- D makes contamination of aquifers less likely than for similar compounds (chlorinated volatiles) that are more persistent and the presence of other chlorinated volatiles in aquifer studies is a line of evidence, indicating that telone could have reached ground water if it were sufficiently persistent. The 2010 memorandum reports on extensive groundwater monitoring by USGS showing that 1,3

- D is not among the man

- made chemicals found in ground water in karst areas ( i.e. , vulnerable groundwater areas where limestone bedrock is di ssolved by acids in rainwater). Similar but more persistent chemicals (multiple chlorinated two

- and three

- carbon compounds) such as solvents and dry

- cleaning chemicals had been detected. The memorandum concludes that telone is not found as a ground wate r contaminant because of its rapid volatilization from soil, and because any telone that reaches groundwater is degraded by hydrolysis before it can travel far from the application site. The memorandum provides location information on karst regions and US GS monitoring sites, indicating the extensive nature of the USGS monitoring effort.

A drinking water assessment will be needed for registration review. Although surface water and groundwater concentrations of 1,3

- D may be discountable, its degradates, 3

- chloroallyl alcohol and 3

- chloroacryllic acid, are residues of concern and have potential to be present in groundwater or surface water.



## 4.3. **Clean Water Act Programs**

1,3

- D is not identified as a cause of impairment for any water bodies listed as impaired un der section 303(d) of the Clean Water Act

. No Total Maximum Daily Load (TMDL) criteria have been developed for 1,3

- D

. Aquatic benchmarks have been established for 1,3

- D and are available at http://www.epa.gov/oppefed1/ecorisk_ders/aquatic_life_benchmark.htm . Any data submitted or otherwise located as part of the registration review process may be used to update aquatic life benchmarks if applicable.



# 5. Environmental Fate a nd Transport

The cis and trans isomers of 1,3

- dichloropropene (1,3

- D; CAS No. 542

- 75

- 6; PC Code 029001) are highly volatile and mobile under most environmental conditions. The major hydrolysis degradates, 3

- chloroallyl alcohol and 

## 3

- chloroacrylic acid, are both mobile, but are expected to be less volatile. The degradates are stable to hydrolysis in sterile, buffered water, but are quickly

### Page 15 of 58 degraded in aerobic aquatic metabolism studies (3

- chloroallyl alcohol, half

- life 1.2 days at 25°C

, total 3

- chloroacrylic acids, 3.4 days, MRID 44975503).

The primary routes of 1,3

- D dissipation in the field appear to be volatilization, leaching, abiotic hydrolysis, and aerobic soil metabolism. In air, 1,3

- D does not degrade through direct photolysis; however, there can be degradation through free

- radical (OH and ozone) processes. Experimental data for reaction with hydroxyl and ozone, cited in the EPISuite AOP v1.91 program (Kwok, ESC and Atkinson, R., 1994) suggest that the half

- life for telone in a ir is on the order of 1.0 to 1.1 days, with the reaction dominated by hydroxyl addition to the double bond.

In water, hydrolysis is temperature dependent with an increase in stability at lower temperatures. This seems to indicate that in warm climates, de gradation will occur more rapidly than in cooler climates. According to laboratory mobility studies, 1,3

- D is mobile in a variety of soils including loamy sand (Kd= 0.23), sand (Kd= 0.32) and clay (Kd= 0.42 and 1.09. These mobility data, in addition to gro und

- water monitoring information, have clearly demonstrated that 1,3

- D is highly mobile in soil. Mobility data for 3

- chloroallyl alcohol (MRID 44940323) give a Koc rang e of 10 to 55, with a mean of 3 1.

As mentioned above, 1,3

- D is highly volatile (vapor pressure 34 mmHg). The factors influencing the volatility of 1,3

- D from a field plot include, but are not limited to: soil organic matter, wind speed, soil moisture content, depth of incorporation

- injection, soil temperature and soil porosity. Studies indi cate that approximately 25 percent of applied volatilizes within the first two weeks after application. Wind is a major factor in the dispersion of 1,3

- D as higher concentrations are measured in the air at night when winds are often lighter. During the day , an increase in wind velocity also increases vapor dispersion and lowers the measurable amount of material.

1,3

- D has one major degradate, 3

- chloroallyl alcohol, and one minor degradate, 3

- chloroacrylic acid. The 3

- chloroallyl alcohol is the major hydrol ysis degradation product and is formed at 72% of applied. The 3

- chloroacrylic acid is produced through aerobic soil metabolism at lower and variable amounts depending on the soil type. 

## In studies submitted to the Agency, 3

- chloroacrylic acid formed at 1 %

- 

### 6% of applied. The degradation pathway is presumed to be 1,3

- D to 3

- chloroallyl alcohol to 3

- chloroacrylic acid. A selection of environmental fate and transport properties of 1,3

- D is summarized Table 3

.

Table 3

. Chemical Properties and Environmental Fate Parameters of 1,3

- D
Parameter Value Description Source Selected Physical/Chemical Parameters Molecular mass (molecular formula) 110.97 g/mol (C 3 

### H 4 

### Cl 2 

### )

-- (Calculated)

Vapor pressure (2 5 °C) 34 mm Hg Highly volatile 

### Footprint 1 

### : Accessed 5/6/13 Aqueous solubility (20 ° C) 2 .5 g/L Soluble 

### Footprint 1 

### : Accessed 5/6/13

### Page 16 of 58 Parameter Value Description Source Henry’s Law Constant (20°C) 1.7 x10 - 3 

### atm

- m 3 

### /mol Highly volatile 

### Footprint 1 

### : Accessed 5/6/13 Log octanol

- to

- water partition coefficient (log K OW 

### ) 1.82 Moderately hydroph il ic 

### Footprint 1 

### : Accessed 5/6/13

Persistence Hydrolysis half

- life (20 ° C) 13.5 days Degrades to 

### 3

- chloro

- 2

- propen

- 1

- ol. MRID 158442

Air photolysis half

- life (25 ° C) Stable Xenon arc lamp used MRID 40390101

Aerobic soil metabolism half

life (25°C) 12 days (silt loam) 54 days (loamy sand) MRID 42642301

Anaerobic aquatic metabolism half

- life (20

- 29 ° C) -- 1,3

- D degraded 1.4

- 3X more rapidly in soil slurries than in soil free solutions MRID 40727

Aerobic aquatic metabolism half

- life (25 ° C) 4.9 days MRID 44975502

Mobility

Freundlich soil

- water partition coefficients (K F 

### ); organic carbon

- normalized Freundlich coefficients (K FOC 

### ) 0.23, 0.32, 0.42, 1.09 L/kg; 20, 25, 41, 42 L/kg OC 

### Mobile MRID 40538901

Field Dissipation

Terrestrial field dissipation half

life; injection depth; leaching depth 1 day; injected to 13

- 14 inches; leaching up to 90 inches 345 lbs a.i./ac applied to Norfolk loamy sand in North Florida. Volatilization and leaching are both significant dissipation pathways . CAAL was

detected in soil but neither 1,3

- D nor CAAL were detected in

groundwater. MRID 40855501

### Page 17 of 58 Parameter Value Description Source Field Volatility +3 days

– 126 μg/m 2 

### /sec +4

- 6 days

– 29 to 80 μg/m 2 

### /sec +7

- 9 days

– 17 to 63 μg/m 2 

### /sec +10

- 12 days

– 12 to 28 μg/m 2 

### /sec +12

- 14 days

– 5 to 18 μg/m 2 

### /sec 12 to 18 inch direct injection to sandy loam 12.3 gallons/A (Telone II, 96.6% a.i.) MRID 42545101

Drip irrigation application to 5 inches soil depth of 4.33 gallons a.i./A in sandy loam. MRID 44795602

Broadcast +1hr

– 9 μg/m 2 

### /sec +14hr

– 37 μg/m 2 

### /sec +32

- 62hr

– 13

- 23 μg/m 2 

### /sec +68hr

– 30 μg/m 2 

### /sec +73hr

– 12 μg/m 2 

### /sec +86hr

– 6 μg/m 2 

### /sec +217hr

– 2 μg/m 2 

### /sec

Winged row shank +2hr

- 2 , μg/m 2 

### /sec +20hr

- 32 μg/m 2 

### /sec +32hr

- 14 μg/m 2 

### /sec +68hr

- 8 μg/m 2 

### /sec +87hr

- 5 μg/m 2 

### /sec +104

- 188hr

- 1

- 2 μg/m 2 

### /sec Broadcast injection shank to 14 inch soil depth with 12.0 gallons

a.i./A in sandy loam

Winged row shank to 12

inch soil depth at 6.7 gallons a.i./A in sandy loam MRID 45010501

+6hr

- 128 μg/m 2 

### /hr +12hr

- 76 μg/m 2 

### /hr +1day

- 50 μg/m 2 

### /hr +1.5day

- 14μg/m 2 

### /hr +2.5day

- 4 μg/m 2 

### /hr +4day

- <1 μg/m 2 

### /hr 5.19 gallons a.i./A (50.7 lb a.i./A) by direct injection (approximately 5

- inch soil depth) to a turf plot of sand soil MRID 45120701/45222501

+3hr

- 32 μg/m 2 

### /hr +8hr

- 15 μg/m 2 

### /hr +30hr

- <1 μg/m 2 

### /hr 5.12 gallons a.i./A (49.8 lb a.i./A) by direct injection (5

- inch soil depth) to nine golf fairway plots MRID 45120702

### Page 18 of 58 Parameter Value Description Source 

### Prospective Groundwater Onsite well screened at 15

- 20 feet (maximum) : 1,3

- D: 579 ppb CAAL: 2,737 ppb CAAC: 1,092 ppb

303 DAT: 4.2 ppb

Offsite down gradient well (maximum) : 1,3

- D: 84 ppb CAAL: 194 ppb CAAC: 153 ppb

603 DAT: 1.3 ppb 283 lbs a.i./ac were applied to a field in Portage County, Wisconsin with an unconfined aquifer at a depth of 15 to 18 feet below grade. Aquifer materials range from sand to coarse sand with gravel. MRID 44952201

Onsite well screened at 4 feet (maximum): 1,3

- D: 833 ppb CAAL: 360 ppb CAAC: 424 ppb

Onsite well screened at 10 feet (maximum): 1,3

- D: 22 ppb CAAL: <0.01 ppb CAAC: 9 ppb

Offsite down gradient well (maximum): 1,3

- D: 0.23 ppb CAAL: <0.01 ppb CAAC: <0.01 ppb 193 lbs a.i./ ac were applied to a field in South Florida with an unconfined aquifer at a depth of 4 feet below grade. Aquifer materials range from fine sand to fine sandy loam. MRID 

### 44444501

1



### - http://sitem.herts.ac.uk/aeru/footprint/index2.htm



## 5.1. **Transformation Products**

The major organic degradate of 1,3

- D in submitted environmental fate studies is 3

- chloroallyl

a lcohol (in hydrolysis and aerobic soil metabolism) and the minor degradate is 3

- chloroacrylic

a cid (in aerobic aquatic and soil metabolism studies ). Error! Reference source not found. 4 summarizes the transformation products of 1,3

- D and their maximum amounts formed and Tables 5 & 6 summarize submitted data for 3

- chloroallyl a lcohol and 3

- chloroacrylic a cid

.

### Page 19 of 58 3

- chloroallyl a lcohol is highly mobile but metabolizes very rapidly in aerobic soil and aquatic systems (t 1/2 

### = 0.5

- 1.2 days)

. 3

- chloroacrylic a cid is also highly mobile but metabolizes somewhat less readily than 3

- chloroallyl a lcohol (t 1/2 

### = 3.4

- 12.4 days)

.

Table 4

. 1,3

- D and Its Environmental Degradates

Name Chemical Name Chemical Structure Study Type Ref. (MRID) Maximum %AR (day) A Final %AR (study length)

PARENT 1,3

- D 1,3

- dichlor

- 1

- propene CAS No.: 542

- 75

- 6

Formula: C 3 H 4 Cl 2 MW: 110.97 g/mol
MAJOR TRANSFORMATION PRODUCTS
3

- chloroall yl alcohol 3

- chloro

- 2

- propen

- 1

- ol Formula: C 3 H 5 ClO MW: 92.52 g/mol Hydrolysis 158442 72% (22 d) 72% (22 d) Aerobic soil 42642301 22.1% (105 d) 22.1% (105 d) Aerobic aquatic 44975502 6.4% (1 d) 1.2% (21 d)

Terrestrial dissipation 40855501 1.5% (0 d) n.d. (562 d)

3

- chloroac rylic acid 3

- chloro

- 2

- propenoic acid

Formula: C 3 H 3 ClO 2 MW: 106.51 g/mol Aerobic aquatic metabolism 44975502 9.5% (7 d) 1.4% (21 d)

Aerobic soil metabolism 42642301 8.5%( 7 d) 1.7% (105 d)

A Bolded values indicate a major degradate was formed or that a degradate is of toxicological significance
B n.d. means “not detected”.
C Terrestrial field study percentages represent the ratio of degradate concentration to the maximum parent concentration, both in the top layer of soil.



### Table 5

. Chemical Properties and Environmental Fate Parameters of 3

- Chloroallyl Alcohol
Parameter Value Description Source Selected Physical/Chemical Parameters Molecular mass (molecular formula) 92.52 g/mol ( C 3 

### H 5 

### ClO ) (Calculated)

Vapor pressure (25°C) 3.5 mm Hg May volatilize from dry surfaces EpiSuite

Aqueous solubility (25 ° C) 129 g/L Highly Soluble EpiSuite

Henry’s Law Constant (20°C) 2.5 x10 - 6 

### atm

- m 3 

### /mol Semi

- volatile EpiSuite

### Page 20 of 58 Parameter Value Description Source Log octanol

- to

- water partition coefficient (log K OW 

### ) 0.57 Hydrophilic EpiSuite

Persistence Hydrolysis half

- life (25 ° C) Stable MRID 

### 44948601

Aerobic soil metabolism half

life 0.5 days 

### Footprint : Accessed 5/6/13 Aerobic aquatic metabolism half

- life (25 ° C) 1.2 days MRID 44975503

Mobility
Freundlich soil

- water partition coefficients (K F 

### ); organic carbon

- normalized Freundlich coefficients (K FOC 

### ) 0.10, 0.11, 0.09, 0.20, 0.05, 0.10, 0.04, 0.15, 0.17 L/kg; 15, 12, 11, 4, 12, 10, 4, 12, 5 L/kg OC 

### Highly Mobile MRID 44940323



### Table 6

. Chemical Properties and Environmental Fate Parameters of 3

- Chloroacrylic Acid
Parameter Value Description Source Selected Physical/Chemical Parameters Molecular mass (molecular formula) 106.51 g/mol ( C 3 

### H 3 

### ClO 2 

### ) (Calculated)

Vapor pressure (2 5 °C) 0.2 mm Hg May volatilize from dry surfaces EpiSuite

Aqueous solubility (25 ° C) 58 g/L Highly Soluble EpiSuite

Henry’s Law Constant (2 5 °C) 2.1 x10 - 7 

### atm

- m 3 

### /mol Semi

- volatile EpiSuite Log octanol

- to

- water partition coefficient (log K OW 

### ) 0.80 Hydrophil ic EpiSuite

Persistence Hydrolysis half

- life (25 ° C) Stable MRID 

### 44940321

Aerobic soil metabolism half

life (20°C) 12.4 days 

### Footprint : Accessed 5/6/13 Aerobic aquatic metabolism half

- life (25 ° C) 3.4 days MRID 44975504

Mobility

### Page 21 of 58 Parameter Value Description Source

Freundlich soil

- water partition coefficients (K F 

### ); organic carbon

- normalized Freundlich coefficients (K FOC 

### ) 0.02 L/kg; 3.4 L/kg OC 

### Highly Mobile 

### Footprint : Accessed 5/6/13

### Page 22 of 58 

# 6. Receptors

Table and Table provide a summary of the aqua tic and terrestrial taxonomic groups, respectively, and most sensitive surrogate species tested to characterize the potential acute and chronic ecological effects of 1,3

- D

. Table and Error! Reference source not found. provide a summary of the available toxicity data for aquatic taxonomic groups for the degradate s 3

- chloroallyl alcohol and 3

- chloroacrylic alcohol , respectfully

. Information on the toxicity of the degradates to terrestrial taxonomic groups are discussed below

. In addition, the table s provide a preliminary overview of the potential acute toxicity of 1,3

- D by providing the acute toxicity classifications. Based on the available ecotoxicity information, 1,3

- D is particularly toxic to estuarine/marine fish, freshwater and estuarine/marine invertebrates and aquatic plants . However, 1,3

- D is also slightly to moderately toxic to freshwater fish and terrestrial animals . Available data on the major degradate, 3

- chloroallyl alcohol , suggest that it is more toxic than parent 1,3

- D to mammals, aquatic plants and freshwater fish

. Available data on the other major degradate, 3

- chloroacrylic acid, suggest that it is more toxic to mammals and aquatic plants but less toxic to freshwater fish than parent 1,3

- D. Additional detail is included in the following tables.



## 6.1. **Effects to Aquatic Organisms**

Tabl e 7 . Summary of the M ost S ensitive E ndpoints from A quatic T oxicity S tudies for 1,3

- D Taxonomic

Group Study Type Surrogate Species Toxicity Value (all units in

terms of measured

active ingredient ) Acute Toxicity Classification Source

Freshwater fish 1 Acute Walleye (Stizostedion vitreum) LC 50 = 1.08 mg/L Moderately toxic 40098001

Chronic (Early Life

Stage) -- -- -- --

Freshwater invertebrates Acute Water Flea ( Daphnia magna ) EC 50 = 0.09 mg/L Very highly toxic 40098001

Chronic Water Flea NO A EC = 0. 07 mg/L LO A EC = 0.105 mg/L Endpoint: growth (length) and mean
progeny -- 45007501

Estuarine/marine fish Acute Sheepshead minnow ( Cyprinodon variegatus ) LC 50 = 0.87 mg/L Highly toxic 44843901

### Page 23 of 58 Taxonomic

Group Study Type Surrogate Species Toxicity Value (all units in

terms of measured

active ingredient ) Acute Toxicity Classification Source

Estuarine/marine invertebrates Acute Saltwater mysid ( Mysidopsis bahia ) LC 50 = 0.70 mg/L Highly toxic 44843904

Acute Eastern Oyster ( Crassostrea virginica ) EC 50 = 0.64 mg/L Endpoint: s hell growth Highly toxic 44843903

Aquatic plants and algae Vascular Duckweed ( Lemna gibba ) NO A EC = 1.2 mg/L EC 50 = 20 mg/L -- 44843914

Non

vascular Freshwater diatom ( Navicula pelliculosa ) NO A EC = 2.7 mg/L EC 50 = 7.9 mg/L -- 44843909

1 Freshwater fish may be surrogates for aquatic

- phase amphibians.



### Table 8 . Summary of the M ost S ensitive E ndpoints from A quatic T oxicity S tudies for 3

- Chloroallyl alcohol

Taxonomic

Group Study Type Surrogate Species Toxicity Value (all units in terms of measured active ingredient ) Acute Toxicity Classification Source

Freshwater fish 1 Acute Rainbow trout ( Oncorhynchus mykiss ) LC 50 = 0.986 mg/L Highly toxic 44940306

Freshwater invertebrates Acute Water Flea EC 50 = 2.3 mg/L Moderately toxic 44843902

Aquatic plants and algae V ascular Duckweed NO A EC = 0.042 mg/L EC 50 = 1.6994 mg/L -- 44940320

Non

vascular Saltwater diatom ( Skeletonema

costatum ) NOAEC = 0.071 mg/L EC 50 = 0.248 mg/L -- 44940316

1 Freshwater fish may be surrogates for aquatic

- phase amphibians.



### Table 9 . Summary of the M ost S ensitive E ndpoints from A quatic T oxicity S tudies for 3

- Chloroacrylic acid

Taxonomic

Group Study Type Surrogate Species Toxicity Value (all units in terms of measured active ingredient ) Acute Toxicity Classification Source

Freshwater fish 1 Acute Rainbow trout ( Oncorhynchus mykiss ) LC 50 = 69.5 mg/L Slightly toxic 44940307

Freshwater invertebrates Acute Water Flea EC 50 = 55 mg/L Slightly toxic 44940308

### Page 24 of 58 Taxonomic

Group Study Type Surrogate Species Toxicity Value (all units in terms of measured active ingredient ) Acute Toxicity Classification Source

Aquatic plants and algae V ascular Duckweed NO A EC = 0.023 mg/L EC 50 = 0.22 mg/L -- 45007504

Non

vascular Green algae ( Selenastrum capricornutum ) NOAEC = 0.181 mg/L EC 50 = 0. 432 mg/L -- 44940319

1 Freshwater fish may be surrogates for aquatic

- phase amphibians.


### Based on the above toxicity data for the degradates , the 3

- chloroallyl alcohol is more toxic to freshwater fish and invertebrates than the 3

- chloroacrylic acid. The acid is classified as slightly toxic to both taxa while the 3

- chloroallyl alcohol degradate is classified as very highly toxic to freshwater fish and moderately toxic to freshwater invertebrates. The alcohol degradate is also more toxic to r ainbow trout than the parent compound. As a result, this degradate could pose greater risk to freshwater fish than the parent, depending on how much of it is formed in the environment. Since the degradates of 1,3

- D are mobile and persistent in the environment, it is possible that the degradates could reach marine/estuarine environments. The ratio of acute toxicity between the parent and alcohol degradate for rainbow trout is 3.99 (LC 50 

### of 3.94 ppm for 1,3

- D/LC 50 

### of 0.986 ppm for 3

- chloroallyl alcohol). If the ratio of toxicity is the same for marine/estuarine fish, then an approximate LC 50 

### for 3

- chloroallyl alcohol for the sheepshead minnow is 0.218 ppm ( LC 50 

### of 0.87 for 1,3

- D/3.99). Using the peak exposure estimate of 0.039 ppm for 3

- chloroallyl alcohol in the risk assessment for grapes result ed in an estimated RQ of 0.18, which exceeds the listed species and acute restricted use LOCs for aquatic animals

. Therefore, data should be submitted to demonstrate the toxicity of 3

- chloroallyl alcohol to marine/estuarine fish and invertebrates. The 3

- chloroacrylic acid degradate was less toxic than the parent for both the freshwater fish and invertebrate tested ( r ainbow trout and D. magna

, respectively).

Except for the saltwater diatom ( S. costatum ), aquatic plant results for the degradates were the reverse of that for freshwater fish; the acid degradate was more toxic than the alcohol degradate. Except for S. costatum the acid degradate is also more toxic than the parent compound. However, the sensitivity to the alcohol degradate as compared to the parent was mixed, L. gibba and S.

costatum were more sensitive to the alcohol degradate than the parent whereas A . flos

- aquae , N. pelliculosa , and S. capricornutum were more sensitive to the parent than the alcohol degradate. Duckweed ( L. gibba ) was the most sensitive to both degradates, and was more sensitive to both of these than the parent compound.

### Page 25 of 58 

## 6.2. **Effects t o Terrestrial Organisms** 

Table 10 . Summary of the M ost S ensitive E ndpoints from T errestrial T oxicity S tudies for 1,3

- D

Taxonomic

Group Study Type Surrogate Species Toxicity Value (all units in terms of measured active ingredient) Acute Toxicity Classification Source

Birds 1 Acute Bobwhite quail ( Colinus virginianus ) LD 50 = 152 mg/kg

bw Moderately toxic 00118938

Sub

- acute dietary Bobwhite quail LC 50 > 10,000 mg/kg

- diet Practically

non

- toxic 00120907

Chronic

-- -- -- --

Mammals Acute Oral Laboratory rat ( Rattus norvegicus ) LD 50 = 224 mg/kg

bw (females) Moderately toxic 40220901

Acute Inhalation Laboratory rat LC 50 = 3.31 mg/L

-- 42954802

Chronic Dietary Laboratory rat NO A EL = 5 mg/kg/day Endpoint: body weight, hyperkeratosis and/or basal cell -- 42954802

Chronic Inhalation Laboratory rat NOAEL Maternal = 20 ppm NOAEL Developmental = 60
ppm -- 00144715 00152848

Insects Acute
contact Honey bee ( Apis mellifera L. ) LD 50 > 60.43 μg/bee Practically

non

- toxic 00028772 00018842

Terrestrial plants 2 Seedling Emergence Monocot

– onion NOAEC = 11.69 lb/A EC 25 > 11.69 lb/A None -- 45007502

Dicot

– tomato NOAEC = 2.19 lb/A EC 25 = 4.81 lb/A Endpoint: shoot dry weight -- 45007502

Vegetative Vigor Monocot

– onion NOAEC = 2.19 lb/A EC 25 = 3.5 lb/A Endpoint: shoot length 45007502

Dicot

– tomato NOAEC = 4.08 lb/A EC 25 = 6.86 lb/A Endpoint: shoot dry weight 45007502

1 Birds represent surrogates for terrestrial

- phase amphibians and reptiles.

### Page 26 of 58 2 The report provides toxicity levels tested and toxicity values in units of ppm. These were converted to lbs a.i./acre by multiplying the concentration in ppm (mg/L) by the volume of treatment solution used to treat each plant (0.35 L). Mass was divided by the area of each pot (6.5 in diame ter) and the resulting value was converted to pounds/acre.



### Terrestrial toxicity tests do not accurately represent the major route of exposure for 1,3

- D. Vapor phase exposure (e.g., inhalation study for birds) studies are required to accurately describe the risk associated with currently registered uses of 1,3

- D

. An acute avian inhalation LD 50 

### is derived in the STIR model (described in Section 7 ) using avian acute oral, mammalian oral, and mammalian inhalation toxicity data, adjusted for difference in diffusion across the avian lung membrane compared to the mammalian lung membrane. Using this approach, the adjusted acute avian inhalation LD 50 

### for 1,3

- D i s 1.25 mg/kg

- bw for a 0.02 kg bird, which is two orders of magnitude more sensitive than the acute oral LD50 of 109.51 mg/kg

- bw for the same size bird.

Terrestrial plant toxicity of 3

- chloroallyl alcohol and 3

- chloroacrylic acid data were collected simu ltaneously with the 1,3

- D tests on terrestrial plants described above (MRID 45007502). The results of these tests demonstrate no significant effects of the degradates at the concentrations tested, and that the hazard resulting from exposure of non

- target plants to these degradates i s unlikely.

T wo acute oral studies with laboratory rats have been submitted, which indicated an LD 50 

### of 91 mg/kg

- bw for both the alcohol and acid degradates (MRID 44843905 and 44940309), indicating that the degradates are mo re toxic than the parent compound (LD 50 

### of 224 mg/kg

- bw). This value would classify the alcohol and acid degradates of 1,3

- D as moderately toxic.

Data are not available to determine the toxicity of the degradates of 1,3

- D (3

- chloroallyl alcohol and 3

- chloroacrylic acid) to birds, reptiles, and terrestrial phase amphibians. Based on evidence that mammals are more sensitive to the degradates than the parent, it is likely that birds are also more sensitive to the acid and alcohol degradates than to the parent.



## 6.3. **Ecological Incidents**

The ecological incident information system (EIIS) is an OPP database that houses ecological incidents that have been reported to the Agency. When available, EIIS includes date and location of a n incident, type and magnitude of effects observed in various species, use(s) of pesticides known or suspected of contributing to the incident, and results of any chemical residue analysis or other analyses conducted during incident investigation. EIIS in cidents are categorized according to the certainty that the incident resulted from pesticide exposure. The Avian Monitoring System (AIMS) is a database administered by the American Bird Conservancy that contains publicly available data on reported avian i ncidents involving pesticides. Many of the incidents listed in this database are also in the EIIS

.

EIIS returned eight terrestria l plant incidents in Washington, California, Idaho, Florida, Mississippi, and South Carolina attributed to 1,3

- D use with “ possible” to “highly probable” certainty (USEPA, 2007 b )

. Most of the incidents resulted from registered uses of products co

formulated with 1,3

- D and chloropicrin; however, a few resulted from use of 1,3

- D only. Incident

### Page 27 of 58 

### #I 007358

- 001 occurred in January 1 998 when a pple trees were planted on a field previously treated with 1,3

- D and chloropicrin

. Some trees didn’t leaf out fully, were sick, or died. Incident # I012366

- 064 occurred in March 2001 when a registered use of 1,3,

- D and chloropicrin damaged 52 acr es of watermelons

. Incident #I013636

- 048 occurred in April 2001 when 80 acres of grape fields were fumigated with 1,3

- D . Roughly half of the crop died as a result of 1,3

- D phytotoxicity and a settlement was reached. Incident #I014702

- 075 occurred in June 2 002 when a registered use of 1,3

- D damaged 20 acres of potatoes, resulting in poor yield and crop quality. Incident #I014702

- 076 occurred in September 2003 when a registered use of 1,3

- D and chloropicrin damaged 91 acres of watermelon seedlings. Incident # s I014871

- 001 and I016962

- 028 occurred in July 2003 and May 2005, respectively, when golf course s treated with 1,3

- D experienced significant burn shortly after application

. Incident #I017958

- 012 occurred in August 2006 when 1,3

- D applied to peach seedlings several months before killed the entire crop. In addition to the terrestrial plant incident, EIIS reports one aquatic incident (#I016738

- 016) when 1,3

- D and chloropicrin applied to strawberry fields via irrigation accidently spilled into a nearby creek,

r esulting in 1000 fish kill ed . Residues taken from the fish confirmed the exposure.

As of 30 April , 2012, AIMS identified no ecological incidents involving 1,3

- D

.

R egistrants reported 5 minor plant incidents and 1 minor wildlife incident with 1,3

- D bet ween 2000 and 2012 . Unless additional information on these aggregated incidents becomes available, they will be assumed to be representative of registered uses of 1,3

- D in the risk assessment.



# 7. Exposure Pathways of Concern

The environmental fate properti es and use patterns of 1,3

- D indicate that leaching to ground water, atmospheric deposition, and runoff represent potential transport mechanisms of 1,3

- D to aquatic and terrestrial organisms. Drinking water and inhalation exposure pathways were screened using the SIP (Screening Imbibition Program) and STIR (Screening Tool for Inhalation Risk) screening methods and were found to be exposure pathways of concern (LOC exceedances are expected). SIP and STIR are described in detail at: http://www.epa.gov/oppefed1/models/terrestrial/index.htm

. As applied according to the registered labels, 1,3

- D and its degradates will be available in the soil
to non

- target organisms. The degradates are expected to form at the site of application, and are also expected to move to the same environmental compartments as the parent compound via the same pathways. The only exception to this is movement via volatilization, since the degradates are not expected to volatilize to the same degree as 1,3

- D.

The primary exposure route for terres trial animals is expected to be inhalation of volatilized 1,3

- D

. Ingestio n of soil containing 1,3

- D and its degradates at the treatment site is also expected. Applications through above

- ground irrigation lines may result in formation of puddles of treated irrigation water and also contact with the foliage of terrestrial plants , which could expose terrestrial animals via drinking water and on

- field plant food resources. The latter two routes are expected to be minor compared to the greater exposure through inhalation . Runoff and vapor phase drift of 1,3

- D and its degradates co uld also result in exposure to plants that inhabit terrestrial and semi

- aquatic areas off

- site.

### Page 28 of 58 

### Volatilization of 1,3

- D from the application site and subsequent movement via wind is expected to result in deposition into nearby water. Leaching (and to a l esser extent runoff and erosion) is also expected to move 1,3

- D and its degradates to nearby water bodies. Once reaching these environments, some 1,3

- D is expected to volatilize, while the remainder will likely degrade into 3

- chloroallyl alcohol (alcohol degradate) and 3

- chloroacrylic acid (acid degradate). These compounds are expected to remain in the water column.

Exposure to aquatic organisms is likely to occur, and will affect both fish and invertebrates. Exposure may occur via ingestion or uptake through the gills (inhalation pathway) and/or integument (dermal pathway) . Aquatic plants are also expected to be exposed via direct contact or vascular uptake.



# 8. Analysis Plan

**8.1. Stressors of Concern** 

8.1.1. Ecological Risk Assessment

The stressor of concern for terrestrial plants is the 1,3

- D parent rather than the degradates; exposure to the alcohol and acid degradates is not expected to result in hazard. The stressors of ecological concern for terrestrial animals are 1,3

- D and the degradates, 3

- chloroallyl alcohol and 3 chloroacrylic acid

. The degradates are not expected to be as volatile as the parent (vapor pressure = 472 pa for the alcohol and 28.4 pa for the acid degradate) so exposure to terrestrial animals would be l imited to food residues, incidental soil ingestion, and drinking water. Based on acute toxicity studies with the laboratory rat, the degradates, 3

- chloroallyl alcohol and 3

- chloroacrylic acid , are more toxic than the parent (LD 50 

### of 91 mg/kg

- bw for the deg radates versus 224 mg/kg

- bw for the parent)

. D ata on the comparative toxicity of the 1,3

- D parent and its degradates are not available for birds. Although exposure via contaminated drinking water is possible for terrestrial animals, the main route of expo sure to terrestrial animals to 1,3

- D is expected to be through inhalation. For birds, based on 1,3

- D’s vapor pressure and calculations using STIR, the maximum 1

- hour vapor inhalation dose for birds is 17,300 mg/kg. By contrast, based on 1,3

- D’s solubilit y limit and calculations using SIP, the upper bound daily drinking water intake dose for a bird is 1,782 mg/kg bw. Multiplying the STIR estimate of one hour by 12 (to match the daily exposure duration of the SIP estimate) yields 207,600 mg/kg which is 2 o rders of magnitude more than the potential drinking water dose. For 1,3

- D, this suggests that the potential daily inhalation exposure of a bird is substantially greater than the potential daily drinking water
exposure for a bird

, indicating that inhalatio n exposure may be of more concern. Additionally

, acute oral and acute inhalation toxicity data are available for the laboratory rat (MRIDs 40220901 and 40220903 , respectively). The data indicate that for mammals, 1,3

- D is more toxic via inhalation exposu re than via oral exposure (oral LD 50 

### = 224 mg/kg

- bw, acute inhalation LD 50 

### 89.7 mg/kg

- bw [converted in STIR from LC 50 

### 3.31 mg/L]). Therefore, any risks associated with terrestrial animals and exposure to 1,3

- D via inhalation are expected to be protective of other potential routes of exposure (including via drinking water). F or terrestrial animals and 1,3

- D, the risk assessment will therefore focus on risks associated with inhalation.

### Page 29 of 58 

### The stressors of concer n for aquatic organisms are 1,3

- D and the aquatic degradate s 3

- chloroallyl alcohol and 3

- chloroacrylic acid . Submitted data indicate that the alcohol and acid degradates have similar toxicity to that of 1,3

- D (see Section 6 ). More specifically, the alcoh ol degrade is slightly more toxic to freshwater fish and aquatic plants and the acid degradate is slightly less toxic to aquatic animals slightly more toxic to aquatic plants.

8.1.2. Drinking Water

The drinking water assessments conducted to support the regis tration review human health risk assessments of 1,3

- D will incorporate model estimates of 1,3

- D residues of concern, which are the parent compound, 3

- chloroallyl alcohol

, and 3

- chloroacrylic acid ( Personal communication, Ideliz Encarnacion, 2013 ), in surfa ce and ground waters. The 1,3

- D residues of concern may be reevaluated pending receipt and review of additional environmental fate and toxicity data for 1,3

- D and its degradates. 1,3

- D is not likely to be found in groundwater and surface water due to
rap id degradation and volatility. 3

- chloroallyl alcohol and 3

- chloroacrylic acid , however, are more persistent, less volatile

, and highly mobile. These chemical properties indicate substantial risk for drinking water exposure via groundwater.



## 8.2. **Measures of Exposure** 

EFED will use standard available models to evaluate potential exposures to aquatic and terrestrial organisms as described at http://www.epa.go v/pesticides/science/models_db.htm

. Available Monitoring Data

From more than 20,000 groundwater samples testing for 1,3

- D, there are 3 detections in Washington ranging from 0.315 ppb to 0.028 ppb of total 1,3

- D (combined cis and trans isomers). In addi tion, m onitoring for 1,3

- D has included targeted sampling near Tampa, Florida. Thirty public water supply wells were sampled but no telone was found despite its use in the area (USGS, 2006). From more than 5,000 groundwater samples testing for 1,3

- D, CAA C, and CAAL in Europe, there were two detections of 0.12 ppb and 0.4 ppb in the alluvial gravels of the River Tiétar in the Caceres region of Spain (Terry, et al . 2008).

No domestic monitoring data is available for 1,3

- D degradates, 3

- chloroallyl alcohol

, or 3

- chloroacryllic acid. Based on the rapid hydrolysis of 1,3

- D

, the high mobility of CAAL and CAAC, and detections up to 2.7 ppm in prospective groundwater monitoring studies , it may be expected that the degradates would be detected in groundwater.

Aq uatic Exposure Modeling

The models used to predict aquatic estimated environmental concentrations ( EECs ) are the Pesticide Root Zone Model coupled with the Exposure Analysis Model ing System (PRZM/EXAMS) publically available at: http://www.epa.gov/oppefed1/models/water/pe5_user_manual.htm

. The PRZM/EXAMS Standard Pond scenario will be used to estimate the aquatic EECs in surface water. Since both surface chemigation and incorporat ed chemigation and injection application methods for 1,3

- D application exist, two separate runs will be conducted for each crop scenario addressing the

### Page 30 of 58 

### surface and incorporated applications. The PRZM volatilization algorithm will be used to address both 1 ,3

- D’s upward movement in soil to the runoff extraction zone and escape to the atmosphere.

In addition, the degradates of 1,3

- D will be incorporated in the residues of concern modeled for exposure to aquatic organisms because of available toxicity data in dicating they are more toxic than the parent. The alcohol degradate will be included with 1,3

- D in the residues of concern modeled for exposure to aquatic animals, while both the acid and alcohol degradates will be included with 1,3

- D in the residues of co ncern modeled for exposure to aquatic plants

Terrestrial Exposure Modeling

Screening level calculations have suggested that the inhalation exposure pathway may be significant for terrestrial wildlife . This exposure pathway is far more significant than potential exposure via drinking water and will be further considered at the time of the risk assessment. Dietary exposure to terrestrial wildlife is not anticipated.

1,3

- D acute e xposures of the birds, mammals, terrestrial invertebrates, and plants through inhalation and vapor exposure are determined using the EECs from atmospheric dispersion models relying on the input of 1,3

- D atmospheric flux measurements from the collection field volatility (flux) studies. For detailed descriptions of the field volatility studies reviewed for chloropicrin, see Appendix C . Field Volatility Study Summarie s. Consistent with the aquatic exposure assessment, the ecological risk assessment will assess two separate scenarios addressing surface and incorporated applica tion of 1,3

- D. The Agency’s recommended screening dispersion model for the near field, the American Meteorological Society/EPA Regulatory Screening Model (AERSCREEN), will be used to generate Tier I EECs. The Tier I analysis will consider the maximum flu x rate for each application method from the collection of 1,3

- D flux studies and
worst

- case meteorological conditions (light winds and stagnant conditions) to calculate peak air EECs, representing one

- hour average concentrations. Documentation on the AERS CREEN model is available at http://www.epa.gov/scram001/dispersion_screening.htm . The exposure scenario evaluated in the Tier 1 analysis will assume that the terrestrial receptors are dire ctly downwind from the emissions source. This is illustrated in Figure 8 below.

Figure 8 . Schematic showing soil fumigant air exposure scenario due to volatilization and subsequent release from soil evaluated in Tier 1 analysis. Wind, Dispersion, and Accumulation of Vapors or Gas

Volatilization of residues in soil Soil incorporated and chemigation fumigant application

### Page 31 of 58 

### If the Tier 1 EECs for either surface or incorporated applications re sult in an exceedance with the LOC, EECs will be further examined using the Tier 2 model, the Probablistic Exposure and Risk Model for Fumigants (PERFUM). PERFUM is parameterized by a time series of flux data obtained from field volatility studies. PERFU M considers these flux values with a robust statistical sampling of meteorological data from points within rings surrounding a treated field (usually 5 years of hourly meteorological data). The current version of PERFUM processes estimated air concentrati ons from EPA’s previously recommended atmospheric dispersion model in the near field, the Industrial Source Complex Short

- Range Model, Version 3 (ISCST3). ISCST3 has since been replaced by the refined mode of AERSCREEN, the AERMOD model, as the recommende d refined dispersion model in the near field. However, both ISCST3 and AERMOD are similar by that they both use Gaussian plume dispersion principles. The framework for PERFUM is illustrated in Figure 9 below. Estimated air concentrations are calculated and binned by percentile distributions within each ring and averaging time period. First, a peak one

- hour averaging period will be used to calculate ai r EECs. If necessary, a higher averaging period equivalent to the exposure duration in toxicity studies will be used to characterize the RQs resulting from utilizing the one

- hour peak EECs. The highest 90 th 

### percentile estimated air concentration from all averaging periods from the receptor ring closest to the edge of the field will be considered as the upper

- bound EEC to determine the RQ. The PERFUM model is publically available on the web from the follow link: http://www.exponent.com/projectdetail.aspx?project=450 . For this soil fumigant assessment, maximum air exposure will occur at the edge of the field corresponding to the where 1,3

- D mass emissions from the treated field will accum ulate to maximum levels along the fetch of wind blowing over the treated field.

Figure 9 . Illustration of the spatial and temporal aspects of the source to receptor configuration in PERFUM. The wind rose (left) illustrates the frequency distribution of variations in wind speed and wind direction that PERFUM accounts for in the transport of the vapor plume from the treated source to receptors (right).



### All modeling scenarios will be parameterized based on field volatility flux data normalized to an 80 acre field. Receptor Rings

Treated Field

### Page 32 of 58 

### For exposure to plant seedlings, EFED’s standard terrestrial plant exposure model, TerrPlant will be used. Although TerrPlant EECs are base d on runoff, TerrPlant will capture the overall exposure of plant seedlings whether it occurs from diffusion in the gas phase or runoff of dissolved 1,3

- D. The Agency is currently developing a replacement model for TerrPlant. If the replacement has been approved prior to the initiation of the risk assessment, this new model will be used instead.



## 8.3. **Measures of Effect**

Toxicity data presented in Section 6 of this problem formulation will be used to calculate risk quotien ts. Any additional information submitted by the registrant or found in the open literature prior to conduct of the risk assessment will also be considered. The open literature studies are identified using EPA’s ECOTOXicology database ( ECOTOX) ( USEPA, 200 7 c ), which employs a literature search engine for locating chemical toxicity data for aquatic life, terrestrial plants, and wildlife. The evaluation of both sources of data can also provide insight into the direct and indirect effects of pesticides on bio tic communities from loss of species that are sensitive to the chemical s and from changes in structure and functional characteristic s of the affected communities.



## 9. **Endangered Species Assessments**

Consistent with the Agency’s responsibility under the Endang ered Species Act (ESA), the Agency will evaluate risks to species federally listed as threatened and/or endangered from registered uses of pesticides in registration review

. The process for evaluating potential risks to listed species is further described at http://www.epa.gov/oppfead1/endanger/litstatus/riskasses.htm

. Both endangered species
assessment s previously conducted d etermined that 1,3

- D may affect but is not likely to adversely affect the California red

- legged frog, salmon or steelhead

.



## 10. **Endocrine Disruptor Screening Program**

1,3

- D was not included in the first group of 67 chemicals issued an order to conduct Tier 1 EDSP testing. For additional information the EDSP program, visit http://www.epa.gov/endo/

.


## 11. **Preliminary Identification of Data Gaps**

11.1. Environmental Fate

Table and Table 3. Submitted Environmental Fate Data for 1,3

- D

### Page 33 of 58 OCSPP Guideline Data Requirement Submitted Studies (MRID) Study Classifications Are data needed to conduct risk assessment? Justification and Assumptions EPA will Make in Absence of Data

835.2120 Hydrolysis 158442 Acceptable No
835.2370 Air photolysis 117046 Supplemental No 40390101 Acceptable
835.41 00 Aerobic Soil Metabolism 42642301 Acceptable Yes An acceptable aerobic soil metabolism study has been previously submitted for two soils but the half

- life estimates vary greatly, 14 days and 45 days. This results in a high 90 th percentile average of 94 da ys, the value used as a model input parameter. 44630202 In review

835.4200 Anaerobic soil metabolism 40025901 Acceptable No

835.4 4 00 Aerobic aquatic metabolism 44975502 Acceptable No

835.4400 Anaerobic aquatic metabolism 40727 Supplemental No A sufficiently quantitative anaerobic aquatic metabolism study has not been submitted and 1,3

- D will be considered stable to this pathway for the purposes of aquatic and drinking water exposure modeling. However, anaerobic aquatic metabolism is not expected to be a significant degradation pathway for 1,3

- D therefore more data is not expected to affect risk conclusions.
835.1230 835.1240 Adsorption/ desorption and leaching 40538901 Supplemental No 42515501 Acceptable

– Aged Column Leaching 835.6100 Terrestrial field dissipation 40403301 Supplemental No
40855501 Acceptable
45022301 Supplemental

835.7100 Prospective Ground Water 94726 Supplemental No 44939601 Supplemental 835.8100 Field Volatility 119187 Supplemental Yes A field volatility study for a tarped application at maximum labeled rate is needed. Tarped field volatility studies have been previously submitted but not at the maximum rate. Due to the high maximum application rate and the multi

pathway dissipation of 1,3

- D, it is important to fully characterize each use pattern that can result in significantly different dissipation and volatility behavior. 42265701 Supplemental
42545101 Acceptable 42967601 Supplemental 44795602 Acceptable
45010501 Acceptable 45112901 Supplemental 45112902 Supplemental
45120701 45222501 Acceptable

45120702 Acceptable 45296101 Supplemental
94724 Acceptable

### Page 34 of 58 OCSPP Guideline Data Requirement Submitted Studies (MRID) Study Classifications Are data needed to conduct risk assessment? Justification and Assumptions EPA will Make in Absence of Data

41057701 Unacceptable
33253 Supplemental 47813901 In review
48085701 In review
850.6100 Water and Soil Environmental Chemistry Methods 44536511 In review Yes A study has been submitted that will fulfill this data requirement if found to be acceptable. Pending review of the study, the data gap remains.
850.6100 Soil Independent Laboratory Validation 44536508 In review Yes

Water Independent Laboratory Validation 44536509 In review Yes



### identify environmental fate studies by MRID that offer data for each guideline requirement, as well as study classifications and whether or not further data are needed in order to support risk
assessment.

Table 3 . Submitted Environmental Fate Data for 1,3

- D

OCSPP Guideline Data Requirement Submitted Studies (MRID) Study C lassifications Are data needed to conduct risk assessment? Justification and Assumptions EPA will Make in Absence of Data

835.2120 Hydrolysis 158442 Acceptable No
835.2370 Air photolysis 117046 Supplemental No 40390101 Acceptable
835.41 00 Aerobic Soil Metabolism 42642301 Acceptable Yes An acceptable aerobic soil metabolism study has been previously submitted for two soils but the half

- life estimates vary greatly, 14 days and 45 days. This results in a high 90 th percentile average of 94 da ys, the value used as a model input parameter. 44630202 In review

835.4200 Anaerobic soil metabolism 40025901 Acceptable No

835.4 4 00 Aerobic aquatic metabolism 44975502 Acceptable No

835.4400 Anaerobic aquatic metabolism 40727 Supplemental No A sufficiently quantitative anaerobic aquatic metabolism study has not been submitted and 1,3

- D will be considered stable to this pathway for the purposes of aquatic and drinking water exposure modeling. However, anaerobic aquatic metabolism is not expected to be a significant degradation pathway for 1,3

- D therefore more data is not expected to affect risk conclusions.

### Page 35 of 58 OCSPP Guideline Data Requirement Submitted Studies (MRID) Study C lassifications Are data needed to conduct risk assessment? Justification and Assumptions EPA will Make in Absence of Data

835.1230 835.1240 Adsorption/ desorption and leaching 40538901 Supplemental No 42515501 Acceptable

– Aged Column Leaching
835.6100 Terrestrial field dissipation 40403301 Supplemental No
40855501 Acceptable
45022301 Supplemental

835.7100 Prospective Ground Water 94726 Supplemental No 44939601 Supplemental
835.8100 Field Volatility 119187 Supplemental Yes A field volatility study for a tarped application at maximum labeled rate is needed. Tarped field volatility studies have been previously submitted but not at the maximum rate. Due to the high maximum application rate and the multi

pathway dissipation of 1,3

- D, it is important to fully characterize each use pattern that can result in significantly different dissipation and volatility behavior. 42265701 Supplemental 42545101 Acceptable
42967601 Supplemental 44795602 Acceptable 45010501 Acceptable 45112901 Supplemental 45112902 Supplemental 45120701 45222501 Acceptable

45120702 Acceptable 45296101 Supplemental
94724 Acceptable
41057701 Unacceptable 33253 Supplemental
47813901 In review
48085701 In review 850.6100 Water and Soil Environmental Chemistry Methods 44536511 In review Yes A study has been submitted that will fulfill this data requirement if found to be acceptable. Pending review of the study, the data gap remains.
850.6100 Soil Independent Laboratory Validation 44536508 In review Yes

Water Independent Laboratory Validation 44536509 In review Yes

### Page 36 of 58 Table 3 . Submitted Environmental Fate Data for the Chemical 3

- Chloroallyl Alcohol

OCSPP Guideline Data Requireme nt Submitted Studies (MRID) Study Classifications Are data needed to conduct risk assessment? Justification and Assumptions EPA will Make in Absence of Data

835.2120 Hydrolysis 44948601 Acceptable No

835.4100 Aerobic soil metabolism --- --- Yes Aerobic soil metabolism data on CAAL and CAAC are necessary to characterize degradate fate and parameterize models. In the absence of degradate aerobic soil metabolism data, degradate aerobic aquatic metabolism studies can be used for metabolism characterization but does not necessarily accurately reflect soil metabolism. 1,3

- D aerobic soil metabolism half

- lives are significantly longer than 1,3

- D aerobic aquatic half

- lives and a similar relationship is possible for degradates. Ad ditionally, given the volatility of parent and degradate, the chemical can reside in the vadose zone above the water table and be more affected by soil metabolism rather than aquatic metabolism.
835.4300 Aerobic aquatic metabolism 44975503 Acceptable No

835.4400 Anaerobic aquatic metabolism --- --- Yes 1,3

- D quickly degrades to the highly mobile and potentially persistent residues of concern, 3

- chloroallyl alcohol and 3

- chloroacryllic acid. These degradates have the potential to accumulate in groundwater where its only degradation pathways are hydrolysis and anaerobic metabolism. 3

- chloroallyl alcohol and 3

- chloroacryllic acid are stable to hydrolysis allowing only for anaerobic metabolism as a possible degradation pathway in anaerobic aquifer s. There is uncertainty relating to the anaerobic metabolism and the persistence or dissipation of this residue of concern depends on the characterization of this pathway

### Page 37 of 58 OCSPP Guideline Data Requireme nt Submitted Studies (MRID) Study Classifications Are data needed to conduct risk assessment? Justification and Assumptions EPA will Make in Absence of Data

835.1230 Adsorption/ desorption 44940323 Supplemental No

Environmental Chemistry Methods soil 44536501 In review Yes A study has been submitted that will fulfill this data requirement if found to be acceptable. Pending review of the study, the data gap remains. Water 44536505 In review

Independent Laboratory Validation Soil 44536502 In review Yes
Water 44536507 In review

A ND means “not yet determined; studies are in review.”



### Table 4 . Submitted Environmental Fate Data for the Chemical 3

- Chloroacrylic Acid

OCSPP Guideline Data Requireme nt Submitted Studies (MRID) Study Classifications Are data needed to conduct risk assessment? Justification and Assumptions EPA will Make in Absence of Data

835.2120 Hydrolysis 44940321 Acceptable No

835.4100 Aerobic soil metabolism --- --- Yes Aerobic soil metabolism data on CAAL and CAAC are necessary to characterize degradate fate and parameterize models. In the absence of degradate aerobic soil metabolism data, degradate aerobic aquatic metabolism studies can be used for metabolism characterization but does not necessarily accurately reflect soil metabolism. 1,3

- D aerobic soil metabolism half

- lives are significantly longer than 1,3

- D aerobic aquatic half

- lives and a similar relationship is possible for degradates. Additionally, given the volatility of parent and degradate, the chemical can reside in the vadose zone above the water table and be more affected by soil metabolism rather than aquatic metabolism.
835.4300 Aerobic aquatic metabolism (degradate) 44975504 Acceptable No

835.4400 Anaerobic aquatic metabolism --- --- Yes 1,3

- D quickly degrades to the highly mobile and potentially persistent residues of concern, 3

- chloroallyl alcohol and 3

- chloroacryllic acid. These degradates have the potential to accumulate in groundwater where its only deg radation pathways are hydrolysis and anaerobic metabolism. 3

- chloroallyl alcohol and 3

- chloroacryllic acid are stable to hydrolysis allowing only for anaerobic metabolism as a possible degradation

### Page 38 of 58 OCSPP Guideline Data Requireme nt Submitted Studies (MRID) Study Classifications Are data needed to conduct risk assessment? Justification and Assumptions EPA will Make in Absence of Data

pathway in anaerobic aquifers. There is uncertainty relat ing to the anaerobic metabolism and the persistence or dissipation of this residue of concern depends on the characterization of this pathway



### . 835.1230 Adsorption/ desorption 44940322 Supplemental No

Environmental Chemistry Methods Water and Soil 44536504 In review Yes A study has been submitted that will fulfill this data requirement if found to be acceptable. Pending review of the study, the data gap remains. Independent Laboratory Validation Soil 44536503 In review Yes
Water 44536506 In review



## 11.2. Effects

Table 5 and Table 6 identify ecological effects studies by MRID that offer data for each guid eline requirement, as well as study classifications and whether or not further data are needed in order to support risk assessment. Rationale for the additional data requested is presented below the tables.

For the major alcohol and acid degradate s , toxicity data are available for freshwater fish, freshwater invertebrates , vascular and non

- vascular aquatic plants , and terrestrial plants

. Table 7

a nd Table 12 identif y ecological effects studies that are needed for the effects assessment for the degradates

.

Table 5

. Submitted A quatic E cological E ffects D ata for Chemical 1,3

- D

OCSPP Guideline Data Requirement Submitted Studies (MRID) Study Classifications Are data needed to conduct risk assessment? Current Additional Data Need

850.1010 Freshwater invertebrate acute toxicity 40098001 Supplemental No

-- 00117044 Supplemental

850.1025 850.1035 850.1045 850.1055 Saltwater invertebrate acute toxicity 44843904 Acceptable No

--

44843903 Acceptable

850.1075 Freshwater fish acute toxicity 40098001 Supplemental No

-- 40098001 Supplemental

44849101 Acceptable

00039692 Acceptable

40098001 Supplemental

### Page 39 of 58 OCSPP Guideline Data Requirement Submitted Studies (MRID) Study Classifications Are data needed to conduct risk assessment? Current Additional Data Need

STE0DI01 USEPA 1977 Acceptable

00117043 Supplemental

STE0DI02 USEPA 1977 Acceptable

00039692 Acceptable

850.1075 Saltwater fish acute toxicity 44843901 Acceptable No

--

850.1300 Freshwater invertebrate life cycle 45007501 Supplemental No

850.1350 Saltwater invertebrates life cycle (None) (N/A) Yes In the absence of data EPA will use an acute to chronic ratio (ACR) to estimate a chronic endpoint for the saltwater invertebrate.

850.1400 Freshwater fish early

- life stage 45145001 Invalid Yes While environmental fate data suggest that, from a time standpoint, 1,3

- D may be short lived in the water column and not chronically persistent, chronic toxicity data for freshwater invertebrates and fish are essential for capturing any sublethal effects that 1,3

- D may elicit. Sublethal exposures of aquatic species to 1,3

- D at certain points of the life cycle may elicit effects on growth and reproduction. Currently, no data are available with which to assess sublethal effects of 1,3

- D to aquatic species.

### Page 40 of 58 OCSPP Guideline Data Requirement Submitted Studies (MRID) Study Classifications Are data needed to conduct risk assessment? Current Additional Data Need

850.1400 Saltwater fish early

- life stage (None) (N/A) Yes While environmental fate data suggest that, from a time standpoint, 1,3

- D may be short lived in the water column and not chronically persistent, chronic toxicity data for freshwater invertebrates and fish are essential for capturing any sublethal effects t hat 1,3

- D may elicit. Sublethal exposures of aquatic species to 1,3

- D at certain points of the life cycle may elicit effects on growth and reproduction. Currently, no data are available with which to assess sublethal effects of 1,3

- D to aquatic species.

850.1500 Fish life cycle No

-- 850.4400 Aquatic plant Toxicity Test using Lemna
spp. 44843914 Acceptable No

--

850.4500 Algal toxicity 44940314 Acceptable No

-- 44843909 Supplemental

44843910 Acceptable

850.4550 Cyanobacteria 44843911 Acceptable No

--



### Table 6

. Submitted Terrestrial E cological E ffects D ata for 1,3

- D

OCSPP Guideline Data Requirement Submitted Studies (MRID) Study Classifications Are data needed for risk assessment ? Current Additional Data Need

850.2100 Avian oral toxicity 00118938 Acceptable No Though data are not available for a passerine species, oral toxicity studies do not assess the relevant exposure for 1,3

- D. Therefore, this study is not requested at this time.

850.2200 Avian dietary toxicity 00120907 Acceptable No

-- 00120908 Acceptable

850.2300 Avian reproduction (None) (N/A) No

### Page 41 of 58 OCSPP Guideline Data Requirement Submitted Studies (MRID) Study Classifications Are data needed for risk assessment ? Current Additional Data Need

Non

guideline Acute Avian inhalation (None) (N/A) Yes Due to the fate properties of fumigants, in particular their high volatility, it is expected that birds will be exposed to fumigants in the vapor phase via inhalation

. T he standard toxicity studies with birds ( i.e., acute oral and acute dietary) do not account for exposure to vapor phase pesticides. Therefore, to assess risks of 1,3

- D to birds , EFED recommends that the Agency require a non

- guideline avian inhalation study for 1,3

- D. A n a cute avian inhalation stud y on one upland game bird species is need ed to establish LC 50 s.
850.3020 Honey bee
acute contact toxicity 00018842 Acceptable No

--

850.3030 Honey bee residue on foliage (None) (N/A) No

--

850.3040 Field testing for pollinators (None) (N/A) No

--

Non

guideline Honey bee acute vapor phase
exposure (None) (N/A) Yes Due to the fate properties of fumigants, in particular their high volatility, it is expected that honey bees and other insect pollinators will be exposed to fumigants in the vapor phase. Neither of the standard Tier I toxicity studies with honey bees ( i.e., acute contact or acute oral toxicity study for honey bees) account for exposure to vapor phase pesticides. Therefore, to assess risks of 1,3

- D to bees, EFED recommends that the Agency require a

non

- guideline acute honey bee v apor exposure study for 1,3

- D, to be conducted in lieu of the normally required acute honey bee contact study that would fulfill the newly proposed requirements for oral toxicity tests including adult and larval honey bees.

850.4100 S eedling E mergence

a nd Seedling Growth 45007502 Acceptable No

--

850.4150 V egetative V igor 45007502 Acceptable No

--

### Page 42 of 58 OCSPP Guideline Data Requirement Submitted Studies (MRID) Study Classifications Are data needed for risk assessment ? Current Additional Data Need

Non

guideline Terrestrial plant vapor phase
exposure (None) (N/A) Yes Due to the fate properties of fumigants, in particular their high volatility, it is expected that terrestrial plants will be exposed to fumigants in the vapor phase. T he standard toxicity studies with terrestrial plants ( i.e., Tier I and II vegetative vigor ) do not account for exposure to vapor phase pesticides. Therefore, to assess risks of 1,3

- D to terrestrial plants , EFED recommends that the Agency require a non

guideline terrestrial plant vapor exposure study for 1,3

- D.

Table 7

. 

### E cological E ffects D ata for the 1,3

- D Degradate , 3

- chloroallyl alcohol

OCSPP Guideline Data Requirement Submitted Studies (MRID) Study Classifications Are data needed for risk assessment ? Current Additional Data Need

850.1075 Freshwater fish acute toxicity 44940306 Supplemental No

--

850.1010 Freshwater invertebrate acute toxicity 44843902 Supplemental No

--

850.4400 Aquatic plant
g rowth: Tier II vascular plants 44940320 Supplemental No

--

850.4500 Algal toxicity 44843913 Supplemental No

-- 44940315 Supplemental

44940316 Supplemental

850.4550 Cyanobacteria 44843902 Supplemental No

--

Table 8 2. 

### E cological E ffects D ata for the 1,3

- D Degradate , 3

- chloroacrylic acid

OCSPP Guideline Data Requirement Submitted Studies (MRID) Study Classifications Are data needed for risk assessment ? Current Additional Data Need

850.1075 Freshwater fish acute toxicity 44940307 Acceptable No

--

850.1010 Freshwater invertebrate acute toxicity 44940308 Acceptable No

--

### Page 43 of 58 OCSPP Guideline Data Requirement Submitted Studies (MRID) Study Classifications Are data needed for risk assessment ? Current Additional Data Need

850.4400 Aquatic plant
g rowth: Tier II vascular plants 45007504 Supplemental No

--

850.4500 Algal toxicity 44940317 Supplemental No

-- 44940319 Supplemental

45007503 Supplemental

850.4550 Cyanobacteria 44940318 Supplemental No

--



### Guideline Number: N/A (Non

- Guideline Study) Study Title: Acute Avian Inhalation Rationale for Requiring the Data Volatilization is the major route of dissipation for 1,3

- D

. In order to determine toxicological responses associated with vapor exposure to 1,3

- D , an acute avian inhalation study is being requested. Practical Utility of the Data How will the data be used? The acute avian inhalation data are needed to asses potential acute risks to birds associated with the inhalation route of exposure. The data will allow the Agency to better assess the risks to these organisms, including the likelihood of potential risks to endangered species, either by direct effects or by indirect effects such as reducing food sources to listed predators and
scavengers. Results of this study would be used to calculate acute risks to birds from exposure
to 1,3

- D and to identify whether c urrent labeling is appropriate and whether further mitigation is
necessary.

How could the data impact the Agency’s future decision

- making? If the data indicate that 1,3

- D poses a significant acute risk to birds, the Agency may explore additional decision options to minimize the risk of 1,3

- D to these species. If future endangered species risk assessments are performed without these data, the Agency would have to assume that chloropicrin "may affect” birds directly and other endangered species indirectly t hrough loss of prey. The lack of these data will limit the flexibility the Agency and registrants have in complying with the Endangered Species Act and could result in inappropriate mitigation

measures.

Guideline Number: N/A (Non

- Guideline Study) Study Title: Acute Honey Bee Vapor Exposure Study Rationale for Requiring the Data Due to the fate properties of fumigants, in particular their high volatility, it is expected that honey bees and other insect pollinators will be exposed to fumigants in the vapor phase. Neither of the standard Tier I toxicity studies with honey bees ( i.e., acute contact or acute oral toxicity

### Page 44 of 58 

### study for honey bees) account for exposure to vapor phase pesticides. Therefore, to assess risks of 1,3

- D to bees, EFED recommends that the Agency require a non

- guideline acute honey bee vapor exposure study for 1,3

- D, to be conducted in lieu of the newly proposed requirements for oral toxicity tests including adult and larval honey bees. Practical Utility of the Data How will the data be used? Data from an acute honey bee vapor exposure study will be used to determine the potential for 1,3

- D to affect non

- target terrestrial invertebrates in the terrestrial environment. Of particular interest is quantification of a toxicity endp oint, i.e., a 4

- hour LC50, that can be used to derive risk quotients. In the absence of vapor exposure data specific for honey bees, risk to terrestrial invertebrates, including listed species, will be assumed.

How could the data impact the Agency’s futur e decision

- making? If future ecological risk assessments are performed without these data, the Agency would have to presume risk to non

- target terrestrial invertebrates, including honey bees, from use of 1,3

- D. Therefore, use of 1,3

- D and its formulated pr oducts may need to be restricted in areas where terrestrial invertebrates, including honey bees, could be exposed. The lack of these data will limit the flexibility the Agency and registrants have in mitigating potential risks and could result in use restr ictions for 1,3

- D that are unnecessarily severe.

Guideline Number: N/A (Non

- Guideline Study) Study Title: Terrestrial Plant Vapor Exposure Study Rationale for Requiring the Data Due to the fate properties of fumigants, in particular their high volatility, it is expected that terrestrial plants will be exposed to fumigants in the vapor phase. The standard toxicity studies with terrestrial plants ( i.e., Tier I and II vegetative vigor) do not account for exposure to vapor phase pesticides. Therefo re, to assess risks of 1,3

- D to terrestrial plants, EFED recommends that the Agency require a non

- guideline terrestrial plant vapor exposure study for 1,3

- D. Practical Utility of the Data How will the data be used? Data from a terrestrial plant vapor exposure study will be used to determine the potential for 1,3

- D to affect non

- target terrestrial plants in the terrestrial environment. Of particular interest is quantification of a toxicity endpoint, i.e., a 4

- hour IC25 , that can be used to derive risk quotients. In the absence of vapor exposure data specific for plants , risk to plants , including listed species, will be assumed.

How could the data impact the Agency’s future decision

- making? If future ecological risk assessments are performed witho ut these data, the Agency would have to presume risk to non

- target terrestrial plants from use of 1,3

- D. Therefore, use of 1,3

- D and its formulated products may need to be restricted in areas where terrestrial plants could be exposed. The lack of these dat a will limit the flexibility the Agency and registrants have in mitigating potential risks and could result in use restrictions for 1,3

- D that are unnecessarily severe.

Guideline Number: 835.8100 Study Title: Field Volatility Study Rationale for Requiring the Data

### Page 45 of 58 

### A field volatility study for a tarped application at maximum labeled rate is needed. Tarped field volatility studies have been previously submitted but not at the maximum rate. Due to the high maximum application rate and the multi

- pathway dissipation of 1,3

- D, it is important to fully characterize each use pattern that can result in significan tly different dissipation and volatility behavior. Practical Utility of the Data How will the data be used? Data will be used to characterize the environmental fate of 1,3

- D in tarped applications. How much 1,3

- D dissipates through volatilization, leaching, and degradation for tarped applications will be determined from the study.

How could the data impact the Agency’s future decision

- making? Field volatility strongly informs the risk characterization of fumiga nt pesticides. The EFED standard model for aquatic exposure, PRZM

- EXAMS, does not provide as reliable estimates for fumigants as it does for less volatile pesticides. Because of this, field studies are relied upon, quantitatively, which can impact the c alculation of risk quotients and the eventual risk conclusions.



# 12. References

Cox, C. 1992. 1,3

- Dichloropropene: Journal of Pesticide Reform. 12 (1):33

- 37 and references therein. Available at http://www.pesticide.org/dichloropropene.pdf

Dow AgroSciences’ Responses to Information Needs for the Registration Review of 1,3

- D (Telone®) May 30, 2013

Jones, R.D. et al ., 2000. Guidance for use of the Index Reservoir and Percent Crop Area Factor in Drinking Water Assessments (March 21, 2000). Office of Pesticide Programs, Environmental Fate and Effects Division, U.S. Environmental Protection Agency. Arlington, VA.

Terry, A. et al . 2008. An monitoring programme for 1,3

- dichloropropene and metabolite s in groundwater in five EU countries. Pest Management Science. 64: 923

- 932.

EFSA. 2009. Conclusion on the peer review of the pesticide risk assessment of the active substance ( EZ )

- 1,3

- dichloroprone. European Food Safety Authority, Parma, Italy. Availabl e at http://www.efsa.europa.eu/en/efsajournal/doc/1341.pdf

USEPA. 1999. Guidance for Use of the Index Reservoir in Drinking Water Exposure Assessments. Arlington, VA.

USEPA. 2000. Drinki ng Water Screening Level Assessment. Part A: Applying a Percent Crop Area Adjustment to Tier II Surface Water Model Estimates for Pesticide Drinking Water

### Page 46 of 58 

### Exposure Assessments. FQPA Science Policy Document .Public Comment Draft September 1, 2000. Federal Register: October 11, 2000 (volume 65, number 197). Electronic copy available at http://www.epa.gov/pesticides/trac/science/ .

USEPA. 2002a. Guidance for Selecting Input Parameters in Modeling the Environmental Fat e and Transport of Pesticides, Version I I (February 28, 2002). Office of Pesticide Programs, Environmental Fate and Effects Division, U.S. Environmental Protection Agency. Arlington, VA.

U.S. EPA. 2002b. Pesticide Root Zone Model (PRZM) Field and Orchard Crop Scenarios: Standard Procedures for Conducting Quality Control and Quality Assurance. Office of Pesticide Programs, Environmental Fate and Effects Division, U.S. Environmental Protection Agency. Arlington, VA.

U.S. EPA. 2003b. Use of Regional Percent Crop Area Factors in Refined Drinking Water Assessments. US EPA Office of Pesticide Programs (OPP), Environmental Fate and Effects Division (EFED), Water Quality Technical Team (WQTT). Arlington, VA

USEPA, 2003c. SCI

- GROW 2.3: Windows Version of SCI

- GROW. September 30, 2003. Office of Pestici de Programs, Environmental Fate and Effects Division, U.S. Environmental Protection Agency. Arlington, VA.

USEPA. 2004. Overview of the Ecological Risk Assessment Process in the Office of Pesticide Programs . United States Environmental Protection Agency (USEPA). Environmental Fate and Effects Division. Office of Pesticide Programs. Available at http://www.epa.gov/espp/consultation/ecorisk

- overview.pdf

. USEPA. 2004. Analysis of Risks to Endangered and Threatened Salmon and Steelhead. Office of Pesticide Programs, U.S. Environmental Protection Agency, Arlington, VA. Available at http://www.epa.gov/oppfead1 /endanger/litstatus/effects/#1,3

- d

. USEPA. 2007. Environmental Risk Assessment for Proposed Section 3 New Use Registration of 1,3

- Dichloropropene in Drip Irrigation in Grapes. Office of Pesticide Programs, Environmental Fate and Effects Division, U.S. Env ironmental Protection Agency. Arlington, VA.

USEPA. 2008. Risks of Telone Use to the Federally Threatened California Red

- legged Frog. Office of Pesticide Programs, U.S. Environmental Protection Agency, Arlington, VA. Available at http://www.epa.gov/oppfead1/endanger/litstatus/effects/redleg

frog/index.html#telone

.

USEPA. 2010. National

- scale assessment of Telone in karst area ground water. Office of Pesticide Programs, Environmental Fate and Effects Division, U.S. Environmental Protection Agency, Arlington, VA.

USEPA. 2013. BEAD Chemical Profile for Registration Revie w: 1,3

- Dichloropropene (1,3

- D) (029001). Office of Pesticide Programs, Biological and Economic Analysis Division, U.S. Environmental Protection Agency, Arlington, VA.

### Page 47 of 58 

### USEPA. 2013b. Guidance for Conducting Fumigant Exposure Assessments in Ecological Risk Assessments. Draft Interim Divisional Guidance. Environmental Fate and Effects Division. Draft October 10, 2012.

US Geological Survey Scientific Investigations Report 2006

- 526 7, Anthropogenic Organic Compoun ds in Ground Water and Finished Water of Commu nity Water Systems in the Northern Tampa Bay Area, Florida, 2 02

- 04

### Page 48 of 58 

# Appendix A

- OPPIN Bibliography

029001 1,3

- Dichloropropene Eco Effects Bibliography

71

- 1 Avian Single Dose Oral Toxicity

MRID Citation Reference

118938 Fink, R.; Beavers, J.; Joiner, G.; et al. (1982) Acute Oral LD50

-- Bobwhite Quail: Telone II Soil Fumigant: Project No. 103

- 207. Final rept. (Unpublished study received Sep 22, 1982 under 464

- EX

- 63; prepared by Wildlife Inte rnational Ltd., submitted by Dow Chemical U.S.A., Midland, MI; CDL:248415

- C)

119181 Ross, D.; Cameron, M.; Roberts, N. (1977) The Acute Oral Toxicity (LD50) of Vorlex to the Mallard Duck According to E.P.A. Guide

- lines: SHG 135

- WL/77331. (Unpublished study received Nov 29, 1977 under 2139

- 55; prepared by Huntingdon Research Centre, Eng., submitted by Nor

- Am Agricultural Products, Inc., Naper

- ville, IL; CDL:232346

- B)



## 71

- 2 Avian Dietary Toxicity

MRID Citation Reference

52564 or 120908 Fink, R. (1975) Final Report: Eight

- Day Dietary LCI50^

-- Mallard Ducks: Project No. 103

- 150. (Unpublished study received Jul 22, 1980 under 464

- EX

- 63; prepared by Truslow Farms, Inc., submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:099515

- U)

52565 or 120907 Fink, R. (1975) Final Report: Eight

- Day Dietary LCI50^

-- Bobwhite Quail: Project No. 103

- 149. (Unpublished study received Jul 22, 1980 under 464

- EX

- 63; prepared by Truslow Farms, Inc., submitted by Dow Chemical U.S.A., Midland, Mich.; CDL:099515

- V)

119183 Ross, D.; Roberts, N.; Cameron, M. (1977) The Subacute Toxicity (LC50) of Vorlex to the Pheasant: SHG 135

- WL/77647. (Unpub

- lished study received Nov 29, 1977 under 2139

- 55; prepared by Huntingdon Research Centre, Eng., submitted by Nor

- Am Agricul

- tural Products, Inc., Naperville, IL; CDL:232346

- D)

119185 Ross, D.; Roberts, N.; Cameron, M. (1977) The Subacute Toxicity (LC50) of Vorlex to the Mallard Duck: SHG 135

- WL/77637. (Unpub

- lished study received Dec 15, 1977 under 2139

- 55; prepared by Huntingdon Research Centre, Eng.,

### Page 49 of 58 submitted by Nor

- Am Agricul

- tural Products, Inc., Naperville, IL; CDL:232497

- B)



## 72

- 1 Acute Toxicity to Freshwater Fish

MRID Citation Reference

39692 Bentley, R.E. (1975) Acute Toxicity of M

- 3993 to Bluegill (?~Lepomis macrochirus~?) and Rainbow Trout (?~Salmo gaird

- ?~neri~?). (Unpublished study received Jul 22, 1980 under 464

- EX

- 63; prepared by Bionomics, EG&G, submitted by Dow Chemical U.S.A., Midla nd, Mich.; CDL:099515

- T)

109669 Stevenson, D.; Reiff, B. (1975) Soil Fumigant D.D.; Its Toxicity to Fish: GRR

- TLGR.0035.75. (Unpublished study received Sep 5, 1978 under 201

- 119; prepared by Shell Research Ltd., Eng., submitted by Shell Chemical Co., Washington, DC; CDL:235252

- F)

10967 1 Reiff, B.; Thorpe, E.; Rees, H. (1978) The Acute Toxicity of 1,3

- Dichloropropene to the Golden Orfe (Idus idus melanotus): Group Research Report TLGR.0057.78. (Unpublished study received Sep 5, 1978 under 201

- 119; prepared by Shell Research Ltd., Eng., submitted by Shell Chemical Co., Washington, DC; CDL:235252

- H)

117040 see 117044 Dow Chemical U.S.A. (1980) (Telone II Toxicity Data

-- Water Flea and Other Freshwater Species). (Compilation; unpublished study re

- ceived Sep 22, 1982 under 464

- EX

- 63; CDL:2 48415

- A)

117043 Buccafusco, R.; Ells, S.; LeBlanc, G. (1981) Acute toxicity of priority pollutants to bluegill (Lepomis macrochirus). Bull. Environm. Contam . Toxicol. 26:446

- 452. (Also In unpublished submission received Sep 22, 1982 under 464

- EX

- 63; submitted by Dow Chemical U.S.A., Midland, MI; CDL:248415

- E)

119175 Cope, O. (1968) Letter sent to R. Glasser dated Jun 7, 1968 ?Tox

- icity data of D

- D to speci fic fish|. (Unpublished study re

ceived Dec 12, 1975 under 201

- 119; prepared by U.S. Fish and Wildlife Service, Fish Pesticide Research Laboratory, submitted by Shell Chemical Co., Washington, DC; CDL:225436

- B)

119177 Stevenson, D. (1975) Soil Fumigant D.D: Its Toxicity to Fish: GRR

- TLGR.0035.75. (Unpublished study received Dec 12, 1975 under 201

- 111; prepared by Shell Research, Ltd., Eng., submitted by Shell Chemical Co., Washington, DC; CDL:225436

- D)

### Page 50 of 58 159224 Fraser, W.; Pell, I. (1977) The Acute Toxi city of Vorlex to the Bluegill Sunfish, the Mirror Carp, the Rainbow Trout: SHG126FT/77272. Unpublished study prepared by Huntingdon Re

- search Centre. 15 p. Vorlex = mixture with MITC

ACC 230287 MITC study Fraser, W.; Pell, I. (1977) The Acute Toxicity of Methylisothiocyanate to Bluegill Sunfish, the Mirror Carp, the Rainbow Trout: 11p. Submitted by Nor

- Am Core Agricultural, Inc. 2139

- 55, 5/27/77 (230287).

44849101 Kirk, H.; Hugo, J.; Marino, T. (1999) Telone II Soil Fumigant: An Acute Toxicity Study w ith the Bluegill Sunfish Lepomis macrochirus Rafinesque: Lab Project Number: 981185. Unpublished study prepared by Dow AgroSciences, LLC. 39 p.

44940306 Marino, T.; Kirk, H.; Hugo, J. (1999) 3

- Chloroprop

- 2

- EN

- 1

- OL: An Acute Toxicity Study with the Rainbo w Trout, Oncorhynchus mykiss Walbaum: Lab Project Number: 991005. Unpublished study prepared by Dow Chemical Co. 38 p.

44940307 Marino, T.; Kirk, H.; Hugo, J. (1999) 3

- Chloroacrylic Acid: An Acute Toxicity Study with the Rainbow Trout, Oncorhynchus mykiss Walbaum: Lab Project Number: 991041. Unpublished study prepared by Dow Chemical Co. 36 p.

TN 1118 U.S. EPA (1977) Report on th e Toxicology of dichloropropene 92% Active Ingredient to Bluegill. (U.S. EPA, Chemical and Biological Investigations Branch, Beltsville, Maryland, Static Jar, Test No. 1118, 10/4/77, Unpublished Report).

TN 1083 U.S. EPA (1977) Report on the Toxicology of dichloropropene 92% Active Ingredient to Rainbow Trout. (U.S. EPA, Chemical and Biological Investigations Branch, Beltsville, Maryland, Static Jar, Test No. 1083, 10/4/77, Unpublished Report).

40098001 Mayer, F.; Ellersieck, M. (1986) Manual of Acute Tox icity: Inter

pretation and Data Base for 410 Chemicals and 66 Species of Freshwater Animals. US Fish & Wildlife Service, Resource Pub

lication 160. 579 p.



## 72

- 2 Acute Toxicity to Freshwater Invertebrates

MRID Citation Reference

117040

- see 117044 Dow Chemical U.S.A. (1980) (Telone II Toxicity Data

-- Water Flea and Other Freshwater Species). (Compilation; unpublished study re

- ceived Sep 22, 1982 under 464

- EX

- 63; CDL:248415

- A)

117044 LeBlanc, G. (1980) Acute toxicity of priority pollutants to water flea (Daphnia magna). Bull. Environm. Contam. Toxicol. 24:684

- 691. (Also In unpublished submission received Sep 22, 1982 under 464

- EX

- 63; submitted by Dow Chemical U.S.A., Midland, MI; CDL: 248415

- F)

119186 Morrissey, A. (1979) The Acute Toxicity of Vorlex to the Water

### Page 51 of 58 Flea ...: Flow

- through Test: UCES Project No. 11506

- 74. (Unpublished study received Jun 5, 1979 under 2139

- 55; prepared by Union Carbide Corp., submitted by Nor

- Am Agricultur al Products, Inc., Naperville, IL; CDL:238635

- A)

44843902 Marino, T.; Kirk, H.; Hugo, J. (1999) 3

- Chloroprop

- 2

- EN

- 1

- OL: An Acute Toxicity Study with Daphnia, Daphnia magna Straus: Lab Project Number: 991006. Unpublished study prepared by The Dow Chemical Co. 44 p.

44940308 Marino, T.; Kirk, H.; Rick, D. (1999) 3

- Chloroacrylic Acid: An Acute Toxicity Study with the Daphnia, Daphnia magna Straus: Lab Project Number: 991042. Unpublished study prepared by Dow Chemical Co. 47 p.

40098001 Mayer, F.; Ellersi eck, M. (1986) Manual of Acute Toxicity: Inter

pretation and Data Base for 410 Chemicals and 66 Species of Freshwater Animals. US Fish & Wildlife Service, Resource Pub

lication 160. 579 p.



## 72

- 3 Acute Toxicity to Estuarine/Marine Organisms

MRID Citation Reference

117042 Heitmuller, P.; Hollister, T.; Parrish, P. (1981) Acute toxicity of 54 industrial chemicals to sheepshead minnows (Cyprinodon variegatus). Bull. Environm. Contam. Toxicol. 27:596

- 604. (Also In unpublished submission received Sep 22, 1982 under 464

- EX

- 63; submitted by Dow Chemical U.S.A., Midland, MI; CDL: 248415

- D)

44843901 Drottar , K.; Krueger, H. (1999) Telone II: A 96

- Hour Flow

Through Acute Toxicity Test with the Sheepshead Minnow (Cyprinodon variegatus): Final Report: Lab Project Number: 103A

- 110: 103/090198/SHE96H2. Unpublished study prepared by Wildlife International Ltd. 62 p. {OPPTS 850.1075}

44843903 Drottar, K.; Krueger, H. (1999) Telone II: A 96

- Hour Shell Deposition Test with the Eastern Oyster (Crassostrea virginica): Final Report: Lab Project Number: 103A

- 111. Unpublished study prepared by Wildlife International Ltd . 60 p. {OPPTS 850.1025}

44843904 Drottar, K.; Krueger, H. (1999) Telone II: A 96

- Hour Flow

Through Acute Toxicity Test with the Saltwater Mysid (Mysidopsis bahia): Final Report: Lab Project Number: 103A

- 109. Unpublished study prepared by Wildlife Inter national, Ltd. 62 p. {OPPTS 850.1035}



## 72

- 4 Fish Early Life Stage/Aquatic Invertebrate Life Cycle Study

MRID Citation Reference

### Page 52 of 58 39692 Bentley, R.E. (1975) Acute Toxicity of M

- 3993 to Bluegill (?~Lepomis macrochirus~?) and Rainbow Trout (?~Salmo gaird

- ?~neri~?). (Unpublished study received Jul 22, 1980 under 464

- EX

- 63; prepared by Bionomics, EG&G, submitted by Dow Chemical U.S.A., Midla nd, Mich.; CDL:099515

- T)

45007501 Kirk, H.; Gilles, M.; Marino, T.; et al. (1999) Evaluation of the Chronic Toxicity of Telone II Soil Fumigant to the Daphnid, Daphnia magna Straus: Lab Project Number: 981201: 991086. Unpublished study prepared by The Dow Chemical Co. 61 p.

45145001 Mari no, T.; Kirk, H.; Hugo, J. et al. (2000) Telone II Soil Fumigant: Toxicity to the Early Life Stages of the Fathead Minnow, Pimephales promelas Rafinesque: Lab Project Number: 991081. Unpublished study prepared by The Dow Chemical Company. 60 p.



## 122

- 1 Seed Germination/Seedline Emergence and Vegetable Vigor

MRID Citation Reference

45007502 Schwab, D. (1999) Effect of 1,3

- Dichloropropene, 3

- Chloroallyl Alcohol, and 3

- Chloroacrylic Acid on the Emergence and Vegetative Vigor of Non

- Target Terrestrial Plants: Lab Project Number: 45386: 990043. Unpublished study prepared by ABC Labs., Inc. 157 p. {OPPTS 850.4100, 850.4225}



## 122

- 2 Aquatic plant growth

MRID Citation Reference

44588903 van Dijk, A. (1990) W141 Methyl Isothiocyanate : Acute Toxicity of Methyl Isothiocyanate (MITC) to Scenedesmus subspicatus (OECD Algae Growth Inhibition Test): Lab Project Number: TB 88025: RCC 219003. Unpublished study prepared by RCC Umweltchemie AG. 46 p.



## 123

- 1 Seed germination/seedling emer gence and vegitative vigor

MRID Citation Reference

45007502 Schwab, D. (1999) Effect of 1,3

- Dichloropropene, 3

- Chloroallyl Alcohol, and 3

- Chloroacrylic Acid on the Emergence and

### Page 53 of 58 Vegetative Vigor of Non

- Target Terrestrial Plants: Lab Project Number: 45386: 990043. Unpublished study prepared by ABC Labs., Inc. 157 p. {OPPTS 850.4100, 850.4225}



## 123

- 2 Aquatic plant growth

MRID Citation Reference

44843909 Kirk, H.; Gilles, M.; Rick, D. et al. (1999) Phytotoxicological Evaluation of Telone II Soil Fumigant Exposed Freshwater Diatom Navicula pelliculosa: Lab Project Number: 991178. Unpublished study prepared by The Dow Chemical Co. 98118 p.

44843910 Kirk, H .; Gilles, M.; Rick, D. et al. (1999) Phytotoxicological Evaluation of Telone II Soil Fumigant Exposed Saltwater Diatom, Skeletonema costatum: Lab Project Number: 981168. Unpublished study prepared by The Dow Chemical Co. 38 p

44843911 Kirk, H.; Gilles, M.; Rick, D. et al. (1999) Phytotoxicological Evaluation of Telone II Soil Fumigant Exposed Bluegreen Alga, Anabaena flos

- aquae: Lab Project Number: 981177. Unpublished study prepared by The Dow Chemical Co. 39 p.

44843912 Kirk, H.; Gil les, M.; Hugo, J. et al. (1999) Phytotoxicological Evaluation of 3

- Chloroprop

- 2

- EN

- 1

- OL Exposed Bluegreen Alga, Anabaena flos

- aquae: Lab Project Number: 991003. Unpublished study prepared by The Dow Chemical Co. 41 p.

44843913 Kirk, H.; Gilles, M.; Hugo, J. et al. (1999) Phytotoxicological Evaluation of 3

- Chloroprop

- 2

- EN

- 1

- OL Exposed Freshwater Diatom, Navicula pelliculosa: Lab Project Number: 991004. Unpublished study prepared by The Dow Chemical Co. 42 p.

44843914 Kirk, H.; Gilles, M.; Hugo, J. et al. (1999) Phytotoxicological Evaluation of Telone II Soil Fumigant Exposed Aquatic Plant, Duckweed, Lemna gibba L. G

- 3: Lab Project Number: 981165. Unpublished study prepared by The Dow Chemical Co. 42 p.

44940314 Kirk, H.; Hugo, M.; Gilles, M. et al. (1999) Phytotoxicological Evaluation of Telone II Soil Fumigant Exposed Freshwater Green Alga, Selenastrum capricornutum Printz: Lab Project Number: 981159. Unpublished study prepared by Dow Chemical Co. 38 p.

44940315 Kirk, H.; Hu go, M.; Gilles, M. et al. (1999) Phytotoxicological Evaluation of 3

- Chloroprop

- 2

- EN

- 1

- OL Exposed Freshwater Green Alga, Selenastrum capricornutum Printz: Lab Project Number: 991002. Unpublished study prepared by Dow Chemical Co. 44 p.

44940316 Kirk, H.; Hugo, M.; Gilles, M. et al. (1999) Phytotoxicological Evaluation of 3

- Chloroprop

- 2

- EN

- 1

- OL Exposed Saltwater Diatom, Skeletonema costatum: Lab Project Number: 991010. Unpublished study prepared by Dow Chemical Co. 41 p.

44940317 Kirk, H.; Hugo, M.; Gille s, M. et al. (1999) Phytotoxicological Evaluation of 3

- Chloroacrylic Acid Exposed Freshwater Diatom,

### Page 54 of 58 Navicula pelliculosa: Lab Project Number: 991058. Unpublished study prepared by Dow Chemical Co. 44 p.

44940318 Kirk, H.; Hugo, M.; Gilles, M. et al. (19 99) Phytotoxicological Evaluation of 3

- Chloroacrylic Acid Exposed Bluegreen Alga, Anabaena flos

- aquae: Lab Project Number: 991066. Unpublished study prepared by Dow Chemical Co. 40 p.

44940319 Kirk, H.; Hugo, M.; Gilles, M. et al. (1999) Phytotoxicological Evaluation of 3

- Chloroacrylic Acid Exposed Freshwater Green Alga, Selenastrum capricornutum Printz: Lab Project Number: 991065. Unpublished study prepared by Dow Chemical Co. 43 p.

44940320 Kirk, H.; Hugo, M.; Gilles, M. et al. (1999) Phytotoxicological Evaluation of 3

- Chloroprop

- 2

- EN

- 1

- OL Exposed Aquatic Plant, Duckweed, Lemna gibba L. G

- 3: Lab Project Number: 991030. Unpublished study prepared by Dow Chemical Co. 53 p.

45007503 Kirk, H.; Gilles, M.; McClymont, E.; et al. (1999) Phyt otoxicological Evaluation of 3

- Chloroacrylic Acid Exposed Saltwater Diatom, Skeletonema costatum: Lab Project Number: 991067. Unpublished study prepared by The Dow Chemical Co. 40 p.

45007504 Kirk, H.; Gilles, M.; Hugo, J. et al. (1999) Phytotoxicologica l Evaluation of 3

- Chloroacrylic Acid Exposed Aquatic Plant, Duckweed, Lemna gibba L. G

- 3: Lab Project Number: 991059. Unpublished study prepared by The Dow Chemical Co. 53 p.

44901710 Smyth, D.V., S.J. Kent and N. Shillabeer (1997?) MNBA: Toxicity to the Green Alga Selenastrum capricornutum. Brixham Environmental Laboratory, Devon, England. Laboratory ID BL6066/B. Sponsor: Zeneca Ag Products, Wilmington, DE.



# 141

- 1 Acute Toxicity to Honeybees

18842 Atkins, E.L., Jr., L.D. Anderson and E.A. Greywood (1969 ) Effect of Pesticides on Apiculture: Project No. 1499; Research Report CF

- 7501. (Unpublished Study Received May 8, 1971 under 1F1174, Prepared by Univ. of California

– Riverside, Dept. of Entomology, Submitted by Ciba Agrochemical Co., summit, NJ, CDL:090 973

- B).

28772 Atkins, E.L., Jr., E.A. Greywood and R.L. Macdonald (1973) Toxicity of Pesticides and Other Agricultural Chemicals to Honey Bees: laboratory Studies. Rev. by Univ. of California

– Riverside, Dept. of Entomology. Riverside, Calif: UC, Agricultural Extension Service. (Also In Unpublished Submission Received Apr 2, 1980 under 464

- 556, Submitted by Dow Chemical USA, Midland, Mich. CDL:242149

- Z).

66708 Atkins, E.L., Jr., L.D. Anderson and E.A. Greywood (1969) Effect of Pesticides on Apicul ture: Project No. 1499; No. 2177. Annual Report (Unpublished Study Including Submitter Summary Received August 8, 1971 under 1G1055, Prepared by Univ. of California

– Riverside, Dept. of Entomology, Submitted by Thompson Hayward Chemical Co., Atlanta, GA CDL:091888

- H).

### Page 55 of 58 

# Non Guideline Selections

42299400 Washington State Dept. of Health (1992) Submission of a sheep kill incident report for Telone II fumigant. Transmittal of 1 incident.

42299401 Washington State Dept. of Health (1989) Report of Investiga tion by the State of Washington as a Result of a Sheep Kill Where an Area was Fumigated with Telone II. Unpublished study. 32 p.

45106202 Stott, W.; Gollapudi, B. (2000) Mammalian and Environmental Toxicity of 1,3

- Dichloropropene Metabolites: 3

- Chloroall yl Alcohol and Chloroacrylic Acid: Lab Project Number: BAH042600

- 02. Unpublished study prepared by The Dow Chemical Company. 16 p.

117047 U.S. Environmental Protection Agency (1980) Ambient Water Quality Criteria for Dichloropropane and Dichloropropene. By Office of Water Regulations and Standards, Criteria and Standards Div., Office of Research and Development, Environmental Criteria and As sessment Office, Carcinogen Assessment Group, Environmental Research Laboratories. Washington, DC: USEPA. ( EPA 440/5

- 80

- 043 , available from: US Department of Commerce, National Technical Information Service, Springdale, VA 22161, Published Study CDL:24841 7

- B

### Page 56 of 58 

# Appendix B

- SIP and STIR Outputs

STIR



# Input

Application and Chemical Information
Enter Chemical Name 1,3

- D Enter Chemical Use Fumigant Is the Application a Spray? (enter y or n) y If Spray What Type (enter ground or air) ground Enter Chemical Molecular Weight (g/mole) 110.97 Enter Chemical Vapor Pressure (mmHg) 2.30E+01 Enter Application Rate (lb a.i./acre) 774.65

Toxicity Properties
**Bird** Enter Lowest Bird Oral LD 50 (mg/kg bw) 152 Enter Mineau Scaling Factor 1.15 Enter Tested Bird Weight (kg) 0.178 **Mammal** Enter Lowest Rat Oral LD 50 (mg/kg bw) 224 Enter Lowest Rat Inhalation LC 50 (mg/L) 3.31 Duration of Rat Inhalation Study (hrs) 4 Enter Rat Weight (kg) 0.35


# Output Results Avian (0.020 kg ) Maximum Vapor Concentration in Air at Saturation (mg/m 3 ) 1.37E+05 Maximum 1

- hour Vapor Inhalation Dose (mg/kg) 1.73E+04 Adjusted Inhalation LD 50 1.25E+01 Ratio of Vapor Dose to Adjusted Inhalation LD 50 1.38E+03 Proceed to Refinements Maximum Post

- treatment Spray Inhalation Dose (mg/kg) 8.19E+01 Ratio of Droplet Inhalation Dose to Adjusted Inhalation LD 50 6.54E+00 Proceed to Refinements



### Results Mammalian (0.015 kg ) Maximum Vapor Concentration in Air at Saturation (mg/m 3 ) 1.37E+05 Maximum 1

- hour Vapor Inhalation Dose (mg/kg) 2.17E+04 Adjusted Inhalation LD 50 1.97E+02 Ratio of Vapor Dose to Adjusted Inhalation LD 50 1.10E+02 Proceed to Refinements Maximum Post

- treatment Spray Inhalation Dose (mg/kg) 1.03E+02 Ratio of Droplet Inhalation Dose to Adjusted Inhalation LD 50 5.22E

- 01 Proceed to Refinements

### Page 57 of 58 

### SIP

Table 1. Inputs Parameter Value Chemical name 1,3

- D Solubility (in water at 25 o C; mg/L) 2200

Mammalian LD 50 (mg/kg

- bw) 224 Mammalian test species laboratory rat Body weight (g) of "other" mammalian species

Mammalian NOAEL (mg/kg

- bw) 5 Mammalian test species laboratory rat Body weight (g) of "other" mammalian species

Avian LD 50 (mg/kg

- bw) 152 Avian test species northern bobwhite quail Body weight (g) of "other" avian species Mineau scaling factor 1.15

Mallard NOAEC (mg/kg

- diet) 0 Bobwhite quail NOAEC (mg/kg

- diet) 0 NOAEC (mg/kg

- diet) for other bird species Body weight (g) of other avian species NOAEC (mg/kg

- diet) for 2nd other bird species Body weight (g) of 2nd other avian species

Table 2. Mammalian Results Parameter Acute Chronic Upper bound exposure (mg/kg

- bw) 378.4000 378.4000 Adjusted toxicity value (mg/kg

- bw) 172.2920 3.8458 Ratio of exposure to toxicity 2.1963 98.3930

Conclusion* Exposure through drinking water alone is a

potential concern for mammals Exposure through drinking water alone is a

potential concern for mammals

Table 3. Avian Results Parameter Acute Chronic Upper bound exposure (mg/kg

- bw) 1782.0000 1782.0000 Adjusted toxicity value (mg/kg

- bw) 109.5053 0.0000

### Page 58 of 58 Ratio of exposure to acute toxicity 16.2732 0.0000

Conclusion* Exposure through drinking water alone is a

potential concern for birds Due to insufficient data, risk cannot be precluded

*Conclusion is for drinking water exposure alone. This does not combine all routes of exposure. Therefore, when aggregated with other routes ( i.e ., diet, inhalation, dermal), pesticide exposure through drinking water may contribute to a total exposure that has potential for effects to non

- target animals.