&,?ED 4374% 

### IIlWTED STATES 

### ENVWONMENTALPROTECTION AGENCY WASHINGTON, 

### D.C. 20460

OFFICE OFPJEWNEWM9PES~ESE~ TOXIC SUBSTANCES



### Memorandum 

### PC Code 108853 

### DP Barcode D270231 D284046 

### Date September 11,2003
SUBJECT: New Chemical Review 

### - Environmental

### Risk Assessment for the Proposed Uses of

### Flufen~vr Ethyl on Sugarcane and Soybeans. 

### FROM: Steve Carey, Biologist 

### ~huy Wguyen, chemist c$ 

# v-3 Environmental 

### Risk Branch 

### III 

### THRU: 

### Ben SmQ 

### Branch Chief Stephanie Syslo, 

### RAPL Dr. 

### W- Erichn, Biologist Environmental Risk Branch 

### IIIEFED TO: DimeMorgan, Review 

### Manager Joanne 

### Miller, PM 23 Herbicide Branch Registration Division 

### TEsmemorandum

### tmmmrhm 

### theEnvironmental Pate and Effect Division's New Chernical Environmental

### Risk Assessment offlufenpyr ethylherbicide to controlpost emergence broadleaf weeds on sugarcane, soybean, and field corn (excluding popcorn 

### and sweet corn). The purpose ofthis review 

### is to assess the environmental fate, potential ecologicaleffects and potential 

### drhking water concentrations associated 

### with flufenpyr-ethyl. Concerns and suggestions for product labeling7 possible 

### data gaps, and uncertainties are included 

### in thereview. Flufenpyr ethyl is a new herbicide produced by Sumitomo Chemical Company Ltd. and under development in the 

### United Statesby Valent U.S.A. Corporation. As a contact herbicide, 

### flufenpyr ethylcontrol 

### susceptibleweeds though disruption of the cell membrane and also induces 

### the inhibition ofprotoporphyringenoxidase 

### in the chlorophyll biosynthetic pathway and leads to a phytotoxic buildup of intermediates. Valent USA Corporation is seeking registration of S-3 1 

### 53 

### WDG Herbicide 

### (57.6% ai) for 

### use on soybean and sugarcane and 

### S-3153lAtrazke 

### WDG (1 

### -9% a.i) for use sugarcane 

### and andld 

### corn. 

### This is the &st application for a 

### US registrationofproducts containing fhfenpyr ethyL

### The proposed new uses considered for this herbicide are listed in the followiug table:

Since data

### were not submitted onthe formulationwith 

### Akcazine. this risk assessment focusesexclusively onthe effects of

### flufqyr ethyl. Furthermore, althouhboth labels are presented here, this assessment will 

### be 

### based only on the S-3

### 153-WDG formulation. Major 

### Risk Conchsions Laboratory tests show that flufenpyr-ethylis 

### practically non-toxic to birds, mammils, 

### and bees, but is moderately toxic to fieshwaterfish and to estuariudmarineinvertebrates on an 

### acute basis. However, acutetoxicityofflzrfenpyr-ethylto 5-eshwakrinvertebrates and estuarinetmarine iish 

### was not seen 

### atthe solu~ lirnit in aquatic environments. At the chronic level, reproductive effects were identified 

### in birds and 

### fieshwaterinvertebrates vvhile growth effects were identified in fieshwater fish. Nevertheless, at the proposed use rates, the estimated environmental concentrations of 

### flufenpy-ethyl exposure 

### did not

### trigger any Level of Concern exceedance for risks 

### to birds &OC = 

### I), aquatic organisms 

### (LO@ = 0.05), 

### or 

### aquatic

### plants (LOC = 

### 1). Based on the highest proposed single applicationrate (0.027 

### lb ai/A for S-3153-WDG), EFED concludesthat the only concern is for post-emergence terrestrialplants growing in areas adjacentto 

### the treated sitesthat 

### may be 

### exposedby spray 

### drift (based on drift LOC 

### exceedances fi-omground and aerial 

### applications). The 

### results ofEFED9s Tier I 

### TerrPlant model suggest



### . 

## . ground applicationunder conditionsthat mbmize drift 

### is 

### preferable to aerial application. Levels of concern were not exceeded for non target terrestrialplants exposed to 

### m off. The f& and disposition of 

### flufq etby1

### and its major degradatescombined with the 

### EFED water models results indicatethat 

### there 

### is a 

### very low probability for either flupenfyrethyl andlor its degradates to reach ground or sd&ce 

### water at any significantlevel. 

### Data Requirements The environmentalfhte and ecological database 

### for flufi:npyr-ethyl 

### is largely complete for

### an 

### adequate risk assessment. However, note the following: 123-l(a) Seedling 

### Emergenee: The parent iluhpyr--ethyldegradesrapidly in the soil, yet weed controlis 

### provided for a longer duration. Althoughno terratrialplant toxicity data were provided for the degradates, the S-1353-acid degradate, which is 

### shownin laboratory studies to be 

### more toxic to aquatic vascular plants than 

### the parent compound, could also be 

### more toxic to terrestrial plants and the cause ofthis residualei%ct. 

### In addition, literature and past incidences of other herbicidesreported the potential forpossible damage 

### to terrestrialplants fromcontaminated surface waters with phytotoxic compounds. Based onthe above stated reasons, and since the parent RQs border on the LOC for risk 

### to non-targ& or endangered plants fiom combinationof drift 

### and mo@possible 

### riskshm the 

### dewdate may be posed to terrestrialplants and/or irrigated crops 

### via 

### m oE Therefore, 

### EFED recommends Tier I1 Seedling Emergence Toxicity testing for the S-1353-acid degradateto determine the toxicity to terrestrialplants, to better characterize runoffto non-target plants, and to determine risks to irrigated crops from contaminatedsllrf$ce

### waters. The value added 

### of repeating this 

### study 

### is "high". E23-$(b) Vegetative Vigor: 

### Flufenpy-ethyl exhibitsmore 

### toxicity fiom foliaruptake than 

### stem or root uptake. Since spray drift is 

### the major route of surfkce 

### water contamination by parent fluhpyrethy1, 

### and since

### this 

### chemicalwill Begrade 

### rapidly upon contact with 

### soils, 

### terrestrial plants 

### in sites adjacent 

### to treated areas could be 

### exposed to the 

### degradates, which are formed 

### in soils following a spray drift event. For these reasons, additional risks 

### may be 

### posed 

### to non-target plants and irrigated crops. 

### EFED recommends Tier I1 Vegetative Vigor Toxicity Test for the S1353-acid degradateto 

### determinethe toxicityto terrestrialplants, to

### better characterize spray drift

### to non-target plants, and to determinerisks 

### to irrigated crops

### earn contaminated surface waters. The value added ofrepeating this study is 

### '%$hB. Endangered Species 

### The Agency's level of concernfor non-target and endangered terrestrialplants is exceeded for the proposed use offlufenpy-ethyl on sugarcane, soybeans, 

### and field corn. concern to terrestrialplants 

### is based on spray drift

### to adjacent sites. As discussed m

### the summary of the risk assessment, restrictions on spray drii

### practices would help alleviate 

### some ofthose concerns. However, they can not be totally addressed without eliminating aerial application Consequently, it will 

### be important to assess the proximity ofendangered plants to use 

### areas. This 

### requirement may be 

### satisfied m

### one ofthree ways: 1)having 

### membership in 

### the 

### FIFRA Endangered Species 

### Task 

### Force (Pesticide Registration 

### PR] Notice 2000-2); 2) citing FIFRA Endangered Species Task Force data; or 3) independentlyproducing these data, pyovided the information is of sufficient quality to meet FIFRA requirements. The information will be 

### used by 

### the OPP Endangered SpeciesProtectionProgramto 

### develop recommendations to avoid adverse eBccts to listed species.

### Uncertainties There remains 

### a degree ofuncertainty

### in 

### assessing risks posed by 

### fldenpyr 

### ethyl degradates. The toxicity 

### data on 

### the degradatesprovided 

### by the registrant suggest that S-1353- acid is more toxic to aquatic vascularplants thanthe parent compound (parent toxicity = 

### 0.0 

### 13 mg/L; S-1353-acid toxicity =

### 0.0063 

# m). Although no terrestrialplant toxicity data were provided for

### the degadates, 

### the aquatictoxicity data 

### suggestthe degradate 

### could be more toxic to terrestrial

### plants than

### the 

### pasent. Eurthrmoree, 

### EED modeling 

### showsthe 

### S-1353-acid degradate to be more mobile and persistent than parent flufenpyr-ethyl. Since the parent RQs border on the LOC 

### for risk 

### to non-target or endangered plants fkom combination of dritt and run06 C;

### asassumption 

### fiomthe aquatic toxicity

### data suggestspossible risk 

### &omrunoffto terrestrialplants 

### fromthe degadate. Because the 

### degadate (5-1

### 353-acid) degrades slower than 

### the parent compound 

### in the environment, the herbicidal effects could be 

### fiomthe degradate,but 

### this cahnot be verified without additionaltesting. 

### Labeling Recommendations The following statements are to be included on the 

### S-3153 

### WDGherbicide label: 

### For Manukturing-Use Products: "Do not discharge effluent containing this active ingredient into lakes, streams, ponds, estuaries, oceans, or other public waters unless this 

### product is 

### specifically identified and addressed in an 

### NPDES permit. Do not discharge effluent containing th 

### product into sewer systems without previously not$& the swagetreatment plant authority. For 

### guidance, contact your State Water Board or Regional Office of

### EPA." For End-Use Products: "Do not apply directlyto water orto areas where surface water or other sensitive areas may be 

### exposed to spray drift, 

### Do not contaminatewater when disposing ofequipment washwater or rinsate." 

### "Do not apply this 

### product through any type of irrigation system, Do not apply this product within 

### one-half mile upstream of an 

### active irrigation or potable water intake in 

### flowing water (i.e., 

### river, strq 

### etc.) or within 

### one-half* ofan 

### active irrigation or potable water intake in a standii 

### body 

### ofwater?suchas 

### a 

### labe, 

### pond, or

### reservoir. 

### " Spray 

### Drift Advisory The foIIowing label statementsconcerningaerial &@ 

### reductionshouldappear on the label: 

### Because ofthe high 

### toxicity offldenpyr-ethyl to plants, there-.is the potential 

### for nontaget plants

### to be harmed by spray drift 

### fkom treated areas. Potential 

### label language 

### to minimize spray driR 

### could 

### be: For aerial applications: 

### 1)the distance ofthe outermostnozzles on the 

### boom must 

### not exceed 314 

### the length of the wingspan 

### or rotor; 

### 2) applications should only occur 

### in wind speeds between 3 

### and 

### 10mph; 3) 

### the nozzles

### must 

### be directed toward

### the rear of

### the aimrail, at 

### an angle between 0 and. 

### 15 degrees downward, 

### 4) ASAl3 droplet size consistent 

### with 

### those presented should be stated (coarser sprays reduce expected 

### risks), and 5) 

### release height should be 

### 10 feet or less above the 

### surface or tops ofvegetation.

### NEW CHEMICAL
ENVIRONMENTAL FATE AND EFFECTS SCIENCE CHAPTER Environmental Fate and Ecological Risk Assessment For Flufenpyr Ethyl (PC Code No: 108853) and Two End-Use Products : 

### S-3153 WDG Herbicide (57.6% 

### a.i.) and S-3153fAtrazineWDG (1.9% a.i.)

Environmental Fate and Effects Division Team Members Steve Carey, Biologist Thuy Nguyen, Chemist 

### Secondary Reviewer William Erickson, Biologist Stephanie Syslo, 

### RAPL
Branch Chief Ben Smith Date of Approval 

# 9//+3 

# 3

### Table of Contents Environmental Risk Assessment



### ....................................... I

# . Environmental Risk Conclusions 4 

### I1

# . Introduction


### .......................................................6



### ..................................... A


### . Physical and Chemical Properties 

### 6 B

. ModeofAction


### ................................................... 7



### ............................................... C


### . Use Characterization 7



### ........................................ D


### . Approach to Risk Assessment 8



### ....................... I11

# . Integrated Environmental Risk Characterization 10



### .......................................... A


### . TerrestrialEcological Risk 10



### ............................................ B

## . Aquatic Ecological Risk 12



### ...................................... IV

# . Environmental Fate Assessment 12



### ................................... A


### . Integrated Assessment

. Summary 12



### ........................... B


### . Environmental Persistence in Soil and Water 13 

### C


### . Environmental Mobility and Exposure in Soil and Water


### ..................14



### .......................................... V

# . Water Resource Assessment 15 A


### . Models


### ......................................................... 15



### ......................................... B


### . Drinking Water Assessment 15



### ................................................. 1


### . Surface Water 15 2


### . Groundwater


### ................................................. 16



### ....................................... C


### . Aquatic Exposure Assessment 17



### ................................ VI

# . Aquatic Exposure and Risk Assessment 17 Hazardsummary


### ................................................. 17 ExposureSummary


### ............................................... 18



### ..................... Estimated of Risks to Aquatic Organisms and Plants 18



### ......................................... Risk Assessment Summary 19



### ............................. VII

# .Terrestrial Exposure and Risk Assessment 20



### ............................ Assessment of Risks to Terrestrial Animals 20



### ...................................... Assessment of Risks to Insects 21



### .............................. Assessment of Risks to Terrestrial Plants 22



### ....................................... VIII

# . Risk to Endangered Species 23

### APPENDICES I


### . Summary of Results Environmental Fate Studies


### ........................ 24 I1

. 

### Chemical Structuresand Proposed Degradation Pathways


### ................. 34 I11


### . Water Resource Assessment


### ........................................ 43 IV

## . Ecological Effects Toxicity Studies


### ................................... 58 V


### . Ecological Risk Assessment


### ........................................ 66 

### VI


### . Environmental Fate Data Requirements


### ............................... 76 VII


### . Ecological Effects Data Requirements


### ................................ 77



### . VIII EllFate Output


### ................................................... 78 

### IX


### . TerrPlant Output


### ................................................. 80 

### X

. 

### SprayDrifl


### ...................................................... 82

### Environmental Risk Assessment I. 

### Environmental Risk Conclusions A. 

### Proposed Uses Flufenpyr ethylis anew herbicideproducedby SumitomoChemical Company Ltd. andunder development in the United States by Valent U.S.A. Corporation. As a contact pyridazinone herbicide, flufenpyr ethyl could be used to control various broadleaf weed species through the disruptionofthe cell membrane and the inhibition ofprotoporphyringen oxidasein the chlorophyll biosynthetic pathway, which leads to a phytotoxic buildup of the intermediates. Valent USA Corporation is seeking registration of 

### S-3153

### WDG Herbicide (57.6% a.i) for use on soybean and sugarcane; and 

### S-3153fAtrazine

### WDG 

### (1.9 % 

### a.i.) for use in sugarcane and field corn (except popcorn and sweet corn). Different application rates are proposed for each crop and each formulation. Sugarcane (S-3 153WDG) has the highest combined maximum seasonal rate of 0.054 lb aiIA, Both aerial and ground application are allowed for S-3 153 WDG, however only ground application is permitted for S-3 153lAtrazineWDG. Although both labels are discussed in portions of this document, the risk assessment relates solely to the S-3153-WDG formulation as EFED does not have any toxicity data to appropriately assess the risks from the uses of 

### S3 153lAtrazine formulation.


### B. Environmental Risks Summary EFED has considered all available information on the toxicity, the environmental fate properties, the potential use areas for sugarcane and soybean, and the application methods of flufenpyr ethyl in characterizing ecological risks related to the above mentioned uses. Based on the highest use rate, which is for S-3153 WDG on sugarcane, the Level of Concern (LOC) of one is exceeded for non target endangered and non-endangeredterrestrial plants growing near the treated sites that may be exposedto spray drift from ground or aerial application as shown in the following table. The endpoint exceeded is based on plant weight loss. These calculations are based on a

presumption of five percent drift from aerial applications coupled with one percent runoff. Runoff scenarios,which arebased on seedling emergencetests, did not result in any exceedanceof anLOC. 

### Endpoint Non-target plant, ground app.

Non-target plant, aerial app. Endangered plant, ground app Endangered plant, aerial app 

### Maximum RQ 3 15 7 3

4There is a degree of uncertainty for potential risk to terrestrial plants, if exposed to the degradates, since the terrestrial risk assessment is based on the parent flufenpyr-ethyl only. No toxicity data on the degradates were submitted by the registrant to determine if they have any potential to damage or kill terrestrial plants. While not necessarily comparable, tests of aquatic vascular plants suggest that the S-1353-acid is approximately twice as toxic as the parent. 

### In addition, it is more persistent and mobile. As to terrestrial animals, aquatic organisms, and aquatic plants, the proposed uses should present minimal acute or chronicrisks. However, it is importantto note that these lowrisk estimates reflect the use at low proposed application rates. Toxicity testing actually indicates that flufenpyr ethyl ismoderatelytoxic to freshwater fish and estuarine/marine invertebrates. There alsowas high dietarytoxicityto mallard ducks as suggestedby the avian reproductive studies. On the other hand, risks to honeybees from parent flufenpyr ethyl are not expected. The environmental fate dataandthe estimated concentrationsfrom the EFED's water models indicate that flufenpyr ethyl metabolizes rapidly in soils and that under the most conservative scenarios, it will not reach surface and ground water resources at significant levels. As for its major degradates (S-3 153-acid, S-3 153-OH, S-3 153-1 -OCH3), although more persistent and more prone to leaching than the parent, they are also not anticipated to present any major concern to drinking water resources, primarily due to the low use rates. 

### C. Drinking Water Summary Flufenpyr ethyl is a new chemical, for which no monitoring data are available. Therefore, potential human exposure to flufenpyr ethyl and its major soil degradates (S-3153-acid, S-3 153-1- OH, and S-3153-1 -OCH,) fiom ingestion of drinking water was estimated using EFED's aquatic models. The drinking water estimated concentrations (DWEC) for surface and ground water are calculated using Tier 1 screening models FIRST (EQPA index _Reservoir Screening Tool) and SCIGROW (Screening Concentration in Groundwater), respectively. All three crops were modeled, however, forHED's humanhealthrisk assessment,EFED recommendsthe DWECsfi-omsugarcane scenario as it represents most conservative estimates. The DWECs from sugarcane use are listed below:

DWECs for Human Health Assessment based on sugarcane use

Surface Water: Peak (acute) Annual Average (chronic) Ground Water: Acute and Chronic Flufenpyr ethyl 0.16 ppb 0.004 ppb S-3153-1- OCH, 1.5 ppb 0.5 ppb S-3153-acid

3.6 ppb 1.5ppb <0.O 1ppb S-3153-OH

0.35 ppb 0.04 ppb <0.01 ppb 0.04 ppb <0.01 ppb

### D. Endangered Species The Agency's levels ofconcern fornon-target and endangeredterrestrial plants are exceeded fortheproposed use offlufenpyr-ethylon sugarcaneand soybeans.Thisconcern for terrestrial plants is based on spray drift to adjacent sites. As indicated in Appendix 

### X, the Tier 1 Aerial Assessment Model predicts relatively high end (90th percentile) drift deposition values. Nevertheless, because there is a relatively flat slopefor the toxicity endpoints,a large no spray zone would be required for plants with responses analogous to the three most sensitive dicots. Numbers would be reduced if extremely coarse spray was used. Nevertheless, at it currently stands,the applicantmust provide information on the proximity of Federally listed endangered and threatened terrestrial plants to the proposed use sites. This requirement may be satisfiedin one ofthree ways: 

### 1)having membership in the FIFRA Endangered Species Task Force (Pesticide Registration [PR] Notice 2000-2); 2) citing FIFRA Endangered Species Task Force data; or 

### 3) independently producing these data, provided the information is of sufficient quality to meet FIFRA requirements. The information will be used by the OPP Endangered Species Protection Program to develop recommendations to avoid adverse effects to listed species. 

### 11. Introduction A 

### Physical / 

### Chemical Properties Common name: Flufenpyr ethyl (IS0 pending) Synonyms: S-3 153,V-3 153 Chemical Name: Acetic acid, 12-chloro-4-fluoro-5-(5-methyl-6-oxo-4- (trifluoromethy1)- 1 (6H)-pyridazinyl)phenoxyl-,ethyl ester CAS Registry No. 188489-07-8 Molecular formula: C,,H,,N,O,F,Cl Molecular weight: 408.7 Physical state: Odorless, Off-white powder Vapor pressure: 3.8 x Pa at 20 "C Solubility (@ 20 "C): 4.1 mg/L in water 

### B. Mode of Action Flufenpyr ethyl is a new herbicide produced by Sumitomo Chemical Company Ltd. and under development in the United States by Valent U.S.A. Corporation. As a contact herbicide, flufenpyr ethyl isproposed for use to controlpost emergence broadleafweed species through disruption of the cell membrane. It also induces the inhibition of protoporphyringen oxidase in the chlorophyll biosynthetic pathway that leadsto a phytotoxic buildup ofintermediates. The later process requires the presence of both light and oxygen.C. Use Characterization Flufenpyr ethyl technical will be formulated as a water dispersable granule, S-3 153 WDG herbicide, containing 57.6% flufenpyr ethyl as the active ingredient. Additionally, a water dispersable granule premix formulation,S-3 153lAtrazineWDG, containingflufenpyr ethyl (1.9%) and atrazine (75%) as active ingredients will also be manufactured. This is the first application for a United States registration of products containing flufenpyr ethyl. Table 1 summarizes the proposed uses for flufenpyr ethyl. Note that althoughboth labels are presented here, this document will be solely based on the S-3153-WDG formulation, since no toxicity data were submitted on the formulation with Atrazine.

The label for S-3 153 WDG recommends broadcast application for soybean and ground drop nozzle application for sugarcane. However, it does not specificallyprohibit the use ofaerial or band application. Each crop couldbe treated up to two applications per a season, 10to 14days apart, and at a maximum rate of 0.027 lb ai1A per application. Table 1. Uses

Field Corn Sugarcane Soybeans

The label for S-3153WDGIAtrazineonly allows ground drop nozzle application for field corn and sugarcane. Aerial application and application through any type of irrigation system are prohibited by this label. Also, although that the label allows a maximum single application rate of 0.019 lb ai/A for field corn, twice a season, it limits the maximum seasonal application to 0.0323 lb ai1A. Similarly, for sugarcane, 0.0355 lb ailA is permitted per application,but only up to 0.0532 1b ailacre is allowed per season. Based only on USDA information (htt~://www.usda.gov) on states in which the these crops are commonly grown, flufenpyr ethyl will be used on approximately 74 million acres of soybeans predominantly in Iowa, Illinois, Minnesota, Indiana, and Nebraska (Figure 1); and 1 million acres of sugarcane predominantly in Florida, Louisiana, Hawaii, and Texas (Figure 2). Pro3osed Use Information for Flufenqyr Product/ Formulation S-3 153/ Atrazine WDG S-3 153WDG S-3 1 53 / Atrazine WDG S-3 153WDG Ethyl Max Application Rate (lb ai/acre) 0.019 0.027 0.0355 0.027 No. AppVyea r 2 2 2 2 Max Appl Rate per year ( lb ai/acre)

0.0323 0.054 0.0532 0.054 Application

Interval

(days)

10 10 -14

10 10 

### - 14 PHI (days)

not specified 90 90 45Figure 

### 1 

## - Soybeans Acreage in the U.S.A.

100,000 to 149,999 CitattdBy: USDA National A-hural 15!3,000+ Statistics Sake
Figure 

### 2 

## - Sugarcane Acreage in the U.S.A., except Hawaii

ested Acres byCounty

Not Estimatzd <5,000 5,000 to 9,999 10,000 to24,999 25,000 to49,999 C] 50,000to 99,999 Crcaabd By: 100,OOO+ USDA National Agdcuhural StatisticsScsvicx

### D. Approach to Risk Assessment EFED's approach to this risk assessment is based on exposure (chemistry, use, fate, etc.) and effects data (acute and chronic toxicity studies for terrestrial animals and aquatic organisms and plants). The initial evaluation is focused on the development of a deterministic point estimate approach, which is the ratio ofmodel derived estimated environmental concentration (based on the maximum applicationrate) of a compound to a protective toxicity effects value (acute [e.g., LC,,, LD,,, or EC,,] and chronic [NOAEC]). The resulting Risk Quotients (RQ = exposure estimate [EECIltoxicity)are then compared to the Agency's Levels of Concern (LOC), which address the following risk presumption categories: 

### Risk Presumption Categories I I 1 

## I Risk Presum~tion for Terrestrial Animals 

## I LOc 

## I

Acute Endangered Species: endangered species may be adversely affectedby use 

# j 0.1 Acute: Potential for acute risk for all non-target organisms Acute Restricted Use: Potential for acute risk for all non-target organisms, but may be mitigated through restricted use classification

Chronic Risk: potential for chronic risk may warrant regulatory action 1 

# I 0.5 0.2

Risk Presumption for Aquatic Organisms 

# I Acute Restricted Use: Potential for acute risk for all non-target organisms, but may be

mitigated through restricted use classification 

# I LOC

Acute: Potential for acute risk for all non-target organisms I 0.5 I

Acute Endangered Species: endangered species may be adversely affected by use 0.05 Chronic Risk: potential for chronicrisk may warrant regulatory action

Giventheminor risk concerns to terrestrial animals and aquaticorganismsfromflufenpyrethyl based on a screening evaluation, this risk assessment focuses on non target terrestrial plants that grow adjacent to the treated areas. I 1

Risk Presumption for Terrestrial and Aquatic Plants

Although flufenpyr ethyl metabolizes rapidly in soils and forms a series ofmore persistent and more mobile degradates, the terrestrial risk assessment can only be based on the parent, since no toxicity data were submitted for the degradates for terrestrial plants and animals. The aquaticrisk assessment is based on parent flufenpyr-ethyl for aquatic organisms and plants, and on parent and its degradates for aquatic vascular plants. I LOC = 1

For terrestrial animals, EFED used the ELLFATE model to calculate the EECs on potential bird and mammal food items (grasses, other green vegetation, seeds, insects). EECs are based on two direct applicationsofflufenpyr-ethylat themaximum allowed single rate of 0.027 lb aiIA. Since no foliar dissipationhalflifewas available for flufenpyr-ethyl, EFED alsoassumed a default half-life value of 

### 35 days. This default half-life of 

### 35 days is based on foliar dissipation data for pesticides for which such data are available, and is designed to be conservative (Willis and McDowell, 1987).Forterrestrialplants inhabiting dry (i.e.,adjacentto treatment site)and semi-aquatic (i.e, areas receiving channelized runoff) areas, RQs are estimated based on the amount of pesticides present on the soil surface due to runoff or spray drift. EFED's scenario for runoff from one treated acre to an adjacent area (sheet runoff) and 10 treated acres to a distant low-lying area (channelized runoff) is based on: 1) solubilityand the amount ofpesticide present on the soil surface and its top one inch and 2) the percent of runoff values of 0.01,0.02, and 0.05 for water solubility of 40 ppm, 10-100 ppm, and >lo0 ppm, respectively. Spray drift exposure from ground application is assumed to be 1

% ofthe applicationrate. Spray drift fiom aerial, airblast,forced-air, and chemigation applications is assumed to be 5% of the application rate. EECs are calculated for the following application methods: (1)unincorporated ground applications and (2) aerial, airblast, forced-air,and chemigation applications. For detailed information regardingthe estimationof spray drift, refer to Appendix 

### X. For acute exposure to aquatic organisms and aquatic plants, EFED relied on the maximum Estimated Environmental Concentration (EEC) values generated through GENEEC2. For chronic exposure to fish and invertebrates, the 60-day and 21-day GENEEC2 averages were used, respectively. Exposure is based on the highest allowable seasonal rate of 0.054 lb ai/A, equally divided among two aerial applications at 10 days apart.


### 111.Integrated Environmental Risk Characterization A. Terrestrial Ecological risk Plants: The results of this risk assessment indicate that terrestrial vascular plants may potentially be at risk if exposed to the proposed uses of parent flufenpyr-ethyl on sugarcane and soybeans. Based on the most sensitive species selected from the seedling emergence (lettuce) and vegetative vigor (tomato) toxicity tests, flufenpyr ethyl poses significantly greater threat to postemergenceplants (RQsof0.05 

### - 0.3 1 forpre-emergence plants vs. 

### 3 

### - 34 for post-emergence plants). The RQYs for flufenpyr ethyl as shown in Appendix 

### IX, paragraphs 1 and 2, exceed the LOC for potential risk to non-endangered and endangered plant fiom spray drift alone for both methods of application(ground or aerial).With a tomato EC2,of 0.00009 lb ai/Afor non-endangered plants and a NOAEC of 0.00004 lb ai/A for endangered plants, the drift LOCs are exceeded with a RO range of 3 (non-endan~ered species) to 7 (endangered species) for ground applicationsand a RO range of 15 (non-endangered species) to 34 (endangered species)for aerial applications when terrestrial plants in areas adjacent to the treated sites are exposed to parent flufenpyr-ethyl. However, based on seedling emergencetoxicityvalues, the same use pattern results in no LOC exceedance (RQ 4) for terrestrial plants fiom runoff alone. Althoughthe above assessment reflectsrisk to terrestrial plants fiom the most sensitivespecies tested in the vegetative vigor study (tomato), there is considerable variability in sensitivity to flufenpyr-ethyl. For vegetative vigortesting,flufenpyr-ethyl was sprayedontoten species (corn, oat, onion, ryegrass, soybean, lettuce, radish, cucumber, cabbage, and tomato) at levels up to 0.029 lb ai/A. Becausethe risk quotient is a linear function of threshold,one can project which specieswould have LOC exceedancesby simple proportional analysis. In the case on non-target plants (tomato based RQ of 7 corresponding to 0.00009 lb ai/A), one post-emergence application at 0.027 lb ailA would trigger LOC exceedances for non-target plants for only lettuce, tomato, and cucumbers dueto spray drift from treated sites (i.e. less than 0.00063 lb ai/A). For endangered plants, a toxicity value calculated at 0.00136 lb ai/A results in a risk quotient of 1 and toxicity values (NOAEC for endangered plants) of 0.001l,0.0011, 0.00012, and 0.00004 lb ai/A for radish, cabbage, cucumber, and lettuce, respectively, are below the calculated value resulting in higher risk quotients. The seedling emergence and vegetative vigor studies suggest this chemical exhibits considerable toxic selectivity. It can be assumed that there may also be similar variation in the general non-target plant population. However, there are uncertainties in having ten tested species represent the universe ofnon-target plant species. In addition,measurable endpoints were based on growth effects (shoot weight, shoot height) and observed physical injury. Currently, EPA does not measure reproduction effects in plants and therefore is not able to adeptly characterize herbicidal effects. Additional uncertainty is introduced because environmental fate data suggest that flufenpyr ethyl will degrade rapidly in soils to form a series ofmore persistent metabolites. The toxicity data on the degradates provided by the registrant suggest that S-1353-acid is more toxic to aquatic vascular plants than the parent compound (parent toxicity = 0.013 mg/L; S-1353-acid toxicity = 0.0063 mg/L). Although no terrestrialplant toxicity data were provided for the degradates, based on the aquatic toxicity data, this degradate could also be more toxic to terrestrial plants than the parent. The environmental fate data also show S-1353-acid to be more persistent and likely to accumulate athigher concentrationsin ground and surface waters than parent flufenpyr-ethyl. Since the parent RQs border on the LOC for risk to non-target or endangeredplants from combination of drift and runoff, the assumptionfrom the aquatic toxicity data suggestspossiblerisk from runoff to terrestrial plants from the degradate. Furthermore, with the degradate (S-1353-acid) degrading slower inthe environmentthan theparent, the herbicidal effects couldbe greater fromthe degradate than from the parent. Because the degradates are mobile and persistent, yet another pathway of potential concern exists withrespectto flufenpyr-ethyl. Literature andpast incidents with otherherbicides suggestthe potential for possible damage to terrestrial plants from surface or ground waters contaminated with phytotoxic compounds.The inadvertentuse of waters contaminated with flufenpyr-ethyl degradates in irrigation systems could pose a potential risk to the irrigated crops through this pathway. This concern is multipliedby the fact that flufenpyr-ethyl exhibitsmore toxicity from foliar uptake than stem or root uptake. Based on the above reasons and uncertainties, EFED recommends Tier I1 terrestrial plant toxicity tests (SeedlingEmergence and Vegetative Vigor) with the S-1353-acid degradate in order to determinethe degradate's toxicity to terrestrial plants, to better characterize runoff and spray drift to non-target plants, and to determine risks to irrigated crops from contaminated surface waters. Animals: The proposed use sites of flufenpyr-ethyl are not likely to pose any potential acute or chronic risk to birds or mammals since toxicity tests indicate that they are not sensitive to exposure to the active ingredient. In the toxicity tests, no acute effects are observed after exposure to the highest concentrationtested according to testing guidelines. While there were chronic avian effects at the 164 ppm level, this is considerably higher than the peak modeled concentration of flufenpyr-ethyl on short grass of 12ppm.

### Honey bees: Toxicityresults for the honeybee test indicatedthat flufenpyr-ethylispractically non-toxic to honeybees (LD,, >25 ug/bee) on an acute contact basis. It is therefore expected that potential risks to honeybees are minimal. 

### B. Aquatic Ecological Risk The proposed uses of flufenpyr-ethyl are likely to pose minimal potential acute or chronic risk to fish or invertebrates (freshwater or estuarinelmarine), primarily because of the low application rates. For freshwater fish, effects were observed in the ppm range with an acute LC,, of 

### 3 ppm for bluegill and a chronicNOAEC of 0.4 ppm for trout. Interestingly, Daphnia did not have an LC,, at the highest level tested, but an analogous chronic value to the trout, while Mysid Shrimp had a similar acute value to bluegill. Mysid were not tested for chronic effects. Regardless, the estimated Tier 

### I surface water screening model (GENEEC2) peak, 21-day, and 60-day concentrations of flufenpyr-ethylof0.3,0.2, and 0.1 ppb, respectively, will not result in any LOC exceedance for acute or chronic risks of aquatic organisms. Results from this risk assessment indicate that aquatic plants (vascular and non-vascular) are not likely to be exposed to flufenpyr-ethyl or its degradates at levels of concern. No LOCs were exceeded for aquatic plants and potential risk is expected to be minimal.


### IV. EnvironmentalFate Assessment A. Integrated Assessment 

## - Summary Flufenpyr ethyl is an odorless off-white powder. Based on a solubility in water of 

### 4.1 mg/L at 20 "C, a vapor pressure of 

### 3.8 x Pa at 20 OC, and a melting point of 100 

### - 101 OC, EFED predicts that volatilizationmay not be a significant dissipative pathway for flufenpyr ethyl. 

### A Log 

### Po, of 2.99 % 0.05 also indicates the bioaccumulation potential of this chemical in fish could be negligible. Flufenfyr ethyl is not expected to persist in the environment, nor in soil or water. In water, it degradesquickly via direct sunlight. Hydrolysis in neutral and alkalinewater is also fast. On soils, flufenpyr ethyl biodegrades within hours under aerobic soil and anaerobic aquatic conditions, but remains stable to photolysis. Flufenpyr ethyl and its degradates are potentially mobile in soil, according to laboratory adsorption data. However, field dissipation studies shows that leaching for parent and degradates does not occur below the 3" soil depth. Table 2 summarizesthe degradateslmetabolites reported in the environmental fate studies.Table 2 Routes of degradation for degradateslmetabolites of Flufenpyr ethyl 1 I I I Degradates Hydrolysis Photolysis (water, pH 5)

rnax 8.7% at day 30 (pH 5) max 92% at day 30 (pH 7) max 99% at Photolysis (soil) Aerobic Soil

rnax 84% at day 1

day 30 (pH 7) max51%at

rnax 41% at day 15 S-3 153-DHPY S-3 153-acid-2,4-(OH)2 TFPYR max 23% at day 7
max 13% at day 32
max 11% at day 20 S-3153-1-OCH3 *

S-3153-1-OH max 53% at day 177
max 14% at

day 91 S-3 153-1-OCH3-5'- CH20H S-3153-f formate Anaerobi cAquatic

rnax 82% at day 1

max 19% at

day 365

Unknown 1 max 84% at day 185

max 14% at

day 365 Terrestrial Field

' Included in DWEC calculations,based on MARC decision max 33% at 7 hour

rnax 8% at day 2
rnax 15% at day 1

rnax 18%at day 13 max7%at day 2

rnax 1%at day 300
rnax 11%atday2

The suggested degradation pathways and the chemical names and structures ofthe degradates are listed in Appendix 

### 11. Based on EFED's laboratory and field data and the decision of the HED's Metabolism Assessment Review Committee (MARC), EFED determines that the degradates of importance to drinking water resources are S-3 153-acid, S-3153-1-OH, and S-3 153-1-OCH3. Only these degradates will be evaluated in this report. 

### B. Environmental Persistence in Soil and Water Based on a solubility in water of

### 4.1 mg/L at 20 OC, a vapor pressure of 3.8 x 10-7 Pa at 20 OC, and a melting point of 100 

## - 101 OC, EFED predicts that volatilization may not be a significant dissipativepathway for flufenpyr ethyl. A Log 

### Po, of2.99

# * 0.05 also indicates thebioaccumulation potential of this chemical in fish could be negligible. In the laboratory studies, flufenpyr ethyl does not persist in water nor in soil systems. In water, photolysis in acidic environment is fairly rapid (t ?4 < 5 days), while the rate of hydrolysis is dependent on the pH of the water. Flufenpyr ethyl remains quite stable in acidic water (t ?4=: 300 days), but degrades within weeks in neutral water (t !4 

### = 8 days) and within hours in alkalinewater(t ?4 

### = 3 hours), forming mostly S-3153-acid. Due to brief duration of the studies, no obvious formationand decline pattern of this degradatewas observed 

## . On soils,flufenpyr ethyl metabolizes quickly (t ?4<2 hours) to S-3 153-acid. Three other major metabolitesare also subsequentlyformed, S-3153-1-OH, S-3153-1 -OCH, and S-3 1 53-1-OCH,-5'-CH,OH, along with some minor amounts of CO,, S-3 153-1-OCH,-5'-COH and bound residues. The calculated half lives are 38 days for S3 153-acid, 7 days for S-3153- 1 OH, and 

### 47 days for S-3 153-1 OCH,. In a sediment-water system, rapid degradation offlufenpyr ethyl (t ?4 <2hours) to S-3 153-acidis alsonoted. S-3153-acidin turn degrades (t % 

# - 3 days) to S-3153-1-OH, which seems to be more persistent under anaerobic conditions(t ?4 = 866 days)than under aerobic conditions (t ?4 = 108 days). Both S-3 153-acidand S-3153- 1 -OH are major metabolites in the sediment-water system. In field studies, flufenpyr-ethyl degrades within hours to S-3 153-acid. S-3153-acid degrades with an estimated half life of approximately four days to two weeks to form S-3 153-1-OH and S3 153-1-OCH,. The later two metabolites seem to be more persistent than the parent as they were still detected one year after treatment, albeit at low levels (<lo% ofparent). 

### C. 

### Environmental Mobility and Exposure in Soil and Water The estimated 

### KO, value fi-omthe Leaching and AdsorptiodDesorption studies indicates that flufenpyr ethyl has some leaching potential. However, since other dissipation routes such as degradation andmineralizationare more important and much more rapid, the likelihood offlufenpyr ethyl leaching into ground water is greatly reduced. In contrast, two of its major metabolites, S3 153-acid and S-3 153-1 -OH, seem to be more mobile and could have more ability to reach ground water than the parent. SCI-GROW model results show that S-3153-acid could reach ground water at a higher level than the parent. However, in the field studies, neither flufenpyr ethyl nor the degradates were detected below the 6" soil depth. The environmental fate data, physical-chemicalproperties,and surface water modeling results suggest that driftimmediately after application, if any, maybe the most importantroute for transport of flufenpyrto surface water. However, once in water, flufenpyr ethyl isprone to hydrolysis,except in acidic aquatic environment, and should not present a major concern to surface water resources. As for the degradates, results fi-om the 

### EFED water models predict higher surface water concentrations than for the parent. It should be noted that there are several levels of uncertainty when modeling the degradates which could lead to a high bias in results. Because there was an incomplete database, several default assumptions were made, including stability of degradates to hydrolysis and photolysis. These assumptions may be erroneous since their molecular formulae, especiallyfor 

### S-3 153-acid,suggest higher solubilityinwater and higher susceptibility to hydrolysis. A detailed assessment and characterization of Drinking Water Estimated Concentrations can be found in Appendix 111. Appendix I summarizes the findings from all of the environmental fate studies, the MRID number associated with each study, and the status of the studies.V. Water Resources Assessment A. Models Flufenpyr ethyl is a new chemical, for which no monitoring data are available. Exposure concentrations for drinking water and aquatic ecosystems assessments were estimated based on EFED's aquaticmodels listedbelow. Detailed description and documentation for thesemodels can be found at: htt~://www.e~a. ~zovlo~pefed 1 /models/water/index.htm. A detailed Tier 1 Screening Level aquatic exposure assessment for human health and ecological risk assessment is attached in Appendix 111. Table 3 Models Used to Estimate Exposure Concentrations for Drinking Water and Aquatic and Ecosystem Assessments 

## I Exposure Estimates 

### 1Models 

## I
I Drinking water, 

### I FIRST @QPA Index geservoir Screening Tool) (version 1.O, 

### I Surface water l~u~ust 1,2001) 

### I
Drinking water Ground water SCIGROW (Screening Concentration In Ground

- Water).(version 2.1; November 1, 2001)* (Tier 1) Aquatic ecosystems Surface water

*Whileuse of this version is provisional, it is expected to produce more accurate estimatedvalues for compounds with - GENEEC2 (GENeric Estimated Environmental Concentration) (version 1.O, August 1, 2001) (Tier 1) Terrestrial ecosvstems Groundwater as a source of irrigation (Tier 11 longerhalf-lives. Inmost cases, a majority oftheuse areawill have groundwaterthat is less vulnerable to contamination than the areas used to drive the SCIGROW estimates. SCIGROW (Screening Concentration In Ground mter).(version 2.1; November 1,2001)*

The input parameters used in this assessment were selected from the environmental fate data submitted by the registrant and in accordance with US EPA-OPP EFED water model parameter selectionguidelines, 

### Guidance for Selecting Input Parameters inModeling the Environmental Fate and Transport ofPesticides, Version 11, February 28,2002 The general input values used in the model runs are presented in Table 111-6 of Appendix 111. 

### B. Drinking Water Assessment The HED MetabolismAssessment Review Committee (MARC) recommend the inclusion of four major degradates offlufenpyr ethyl (S-3 153-acid, S-3 153-1-OH,S-3 153-1-OCH,, and S-3 153- 1

-OCH,-5'-CH,OH ) into the drinking water assessment ofparent flufenpyr ethyl


### . However, at this time, the drinking water concentrationestimation for S-3153-1 -OCH,-5'-CH,OH is not possible due to insufficient fate data for this degradate. 

### Surface Water TheDrinking WaterEstimated Concentrations (DWEC) for surface waterused inhuman health assessment were determined using the Tier 1 model FIRST, version 1, August 1,2001. FIRSTis a screening model designedby EPA-OPPIEFEDto estimate the concentrationsfoundin vulnerable drinking water sources (a reservoir adjacent to fields treated with the pesticide in question. FIRST accounts for Percent Cropped Area (PCA). The PCA factor is 41% for soybean. No PCA was developed for sugarcane and a default value of 87% was used for this crop. The PCA is a generic adjustment which represents the maximum percent of any watershed that is planted to the cropbeing modeled and, thus,may potentiallybe treated with thepesticide in question. PCA factors are generated from Geographic Information System (GIs) overlays of cropping area and watershed delineations. EFED believes that the default value of 87% is probably high for sugarcane and the results reported for that crop could be overestimated. The DWECs, reported in Table 

### 4 for flufenpyr ethyl and in Table 5 for the degradates, were based on the input parameters listed in Appendix 111. All three cropswere modeled for theparent and as expected, the results for sugarcane are the highest due to the high PCA value (87%). Only the most conservative estimates, which are for sugarcane, were reported for the degradates. Table 4- Flufenpyr ethyl DWECs Sugarcane 0.027 lb ai/A, 2 appl at 1 0-day interval Aerial application 

## ' PCA = 0.87

Ground Water: Acute and Chronic 

# I <0.01 ppb 

# I <0.01 ppb 

# I ' PCA = Percent Cropped Area. See "Description of Model Inputs and Results" section for more information Soybean 0.027 lb ai/A, 2 appl at 1 0-day interval Aerial application 'PCA = 0.41 Surface Water: Peak (acute) Annual Average (chronic)



### Ground Water SCI-GROW model was used to estimate the level of flufenpyr ethyl residues in ground water. Based on the highest application rate and the most conservative selection of environmental fate parameters (see Appendix 111), ground water contamination, as a result offlufenpyr ethyl use on the proposed crops, was estimated to be below 

### 0.01 ppb. This is in agreement with the terrestrial field 0.161 ppb 0.004 ppb

Table 

### 5 

### - Flufenpyr ethyl degradates DWECs- based on Sugarcane crop (PCA 

# ' = 87%) 0.076 ppb 0.002 ppb

SurfaceWater: Peak (acute) Annual Average (chronic) Ground Water: Acute and Chronic 

### ' PCA = Percent Cropped Area. See "Description of Model Inputs and Results" section for more information The single application rate of each degradatewas adjusted from the proposed rate of sugarcane proportionally to the degradate's maximum detected concentration, relative to the total amount applied and to their molecular weight. S-3153-acid

0.021 lb ai/A, 2 appl at 1 0-day interval 3.6 ppb 1.5 ppb 0.04 ppb S-3153-1-OH 0.003 lb ai/A, 2 appl at 10-day interval 0.3 ppb 0.04 ppb
<0.01 ppb S-3153-1-OCH, 0.012 lb ai/A, 2 appl at 10-day interval 1.5 ppb 0.5 ppb
<0.01 ppbdissipation study results where no flufenpyr ethyl was detected in the deep soil layers at above the study detection limit (2 ppb). 

### C. Aquatic Exposure Assessment For surface water contamination, the estimated environmental concentrations (EEC) were calculated using GENEEC2 (meric Estimated Environmental Concentration). Resultsfor use of flufenpyr ethyl on sugarcane are reported in Table 

### 6, since it has the highest application rate among the proposed crops (2 applicationsper year at 0.027 lb ai/A each, with a 10-day interval between application). Aerial applicationwas also assumed, since it gives the highest level of surface water contamination. The single application rate of each degradate was adjusted from the proposed rate of sugarcane proportionallyto the maximum detected concentration ofeach degradate relative to the total amount applied and to their molecular weight. No driftwas assumed for the degradates asthey were formed aftertheparent reachedthe soilsand no PCA adjustment was required for these surface water EECs. Table 6 

### - Surface Watel 

# I Flufenpyr Ethyl

0.027 lb ai/A, 2 appl at 1 0-day interval S-3153-acid 0.02 1 lb ai/A, 2 appl at 1 0-day interval S-3153-1-OH 0.003 lb aUA, 2 appl at 1 0-day interval 2.19 ppb 

# 1 2.19 ppb 

# 1 2.15 ppb 

# 1 2.08 ppb 

# 1 2.03 ppb ZECs for Ecological Risk Assessment Peak 0.279 ppb

For ground water contamination, as reported above in the Drinking Water Assessment sectionV. B, SCI-GROW estimated that flufenpyr ethyl residue concentration will be less than 0.01 PP~. 0.215 ppb



### VI. Aquatic Exposure and Risk Assessment Average

4-day 0.270 ppb

Hazard Summary: 0.212 ppb

Flufenpyr-ethyl was shown to be moderately toxic to freshwater fish (LC,, = 2.5 

### - 3.75 ppm) and estuarinelmarine invertebrates (EC,, = 2.08 ppm) on an acute basis. However, the toxicity of flufenpyr-ethyl to freshwater invertebrates and estuarinelmarine fish was not seen at the solubility limit in aquatic environments (4.1 pprn in water). Based on the Tier I1 duckweed toxicity testing, the EC,,values of the parent flufenpyr-ethyl and its degradates S-3 153acid and S-3 153-4-OH were 0.013,0.006, and >0.03 ppm, respectively. The Tier I1 non-vascular aquaticplants toxicity testing with the parent compound shows freshwater green alga (Selenastrum capricornutum) as the most sensitive non-vascular plant, with an EC,, of 0.009 ppm. Although chronic values were not Average 21-day 0.191 ppb

0.196 ppb Average 60-day 0.101 ppb Average 90-day 0.070 ppb

0.165 ppb 0.145 ppbdetermined for estuarinelmarine fish; freshwater early life stage and invertebrate life cycle values (NOAECILOAEC)were showntobe 0.4410.92ppm and 0.4611.2ppm, respectively, with significant reductionsoccurringin fish growth and invertebrate reproduction.In addition, the toxicity tests with aquaticorganisms andplants, the solvent was used to maximize the chemical dissolution,exceeding EFED's guideline recommended range by 1 -fold. None of the aquatic organisms and plants were adversely affected by the solvent in these tests.

Surface water modeling results for the crops considered in this assessment were based on the Tier 1 modeling using GENEEC2. The surface water concentrations used to estimate acute risks from exposures of aquatic fish and invertebrates to flufenpyr-ethyl are based on estimated peak values. Surface water concentrations used to estimate chronic risksto aquaticinvertebrates arebased on estimated 21 -day average values. Concentrations in surface water used to estimate chronicrisks to aquatic fish are based on estimated 60-day average values. Sugarcane was modeled as the most conservative case scenario for aquatic exposure. Tier 

### 1 screening level exposure estimates with GENEEC2 are tabulated in 

### Table 7 and detailed in Appendix 111:

Estimates of Risks to Aauatic Organisms and Plants Table 7. EECs (ppb) of Flufenpyr-ethyl and its Degradates Residues in Surface Water Using GENEEC2 model

A means of integrating the results of exposure (EEC) and toxicity data is called the quotient method. For this method, risk quotients (RQs) are calculated by dividing exposure estimates by toxicity values, both acute and chronic. RQ = EXPOSUREITOXICITY 60-day 0.101 2.08 0.164

The toxicity test values (i.e., measurement endpoints) used in the acute and chronic risk quotients are derived fromthe results ofrequired studies.The EEC,toxicity,andrisk quotient values are provided below in Table 

### 8. 21-day 0.191 2.15 0.196 4-day 0.270 2.19 0.212 Compound Parent Flufenpyr-ethyl S- 13 53-acid degradate S- 1353-4-OH degradate Peak 0.279 2.19 0.215Table 8 

### - Toxicity, Exposure, and Risk Quotient Values of Flufenpyr-ethyl (based on two aerial application of 0.027 lb ai/A, 10 days interval)

Risk Assessment Summary: Species
Rainbow trout-Acute Daphnia magna-Acute Daphnia magna-Chronic Rainbow trout--Early Life Stage Estuarineimarinefish- Acute Shrimp-Acute Eastern Oyster--Shell deposition Aquatic Plants-Duckweed (parent) Aquatic Plants-Duckweed (S 13 53 acid) Aquatic Plants-Duckweed (S 135340H) Aquatic Plants- Selenastrum capricornutum Aquatic Plants- Naviculapelliculosa Aquatic Plants- Skeletonema costatum Aquatic Plants- Anabaenaflos-aquae 

## ' surface water concentrations (EECs) are shown

As shown in 

### table 8, no LOCs were exceeded for aquatic organisms exposed to parent flufenpyr-ethyl and for aquatic plants exposed to parent flufenpyr-ethyl and its degradates. Therefore, risks to fish, invertebrates, and aquatic plants are believed to be negligible. Also, since flufenpyr-ethyl is not persistent (half life 

# - 7 days) in aquatic environments, exposure fiom this scenariobased on GENEEC2 modeling with peak (acute) values of 0.3,2.2,0.2 ppb for parent, 

### S3 153-acid,and S-3 153-1 -OH, respectively, should not present a concern for any aquatic organisms or plants from the proposed use sites of sugarcane and soybean since the toxicity values are at or greater than 440 ppb. At the chronic level, reproductive effects and growth effects were identified in fieshwater invertebrates and fish respectively. However, since the flow-through test maintains a constant concentration, it is not an accurate representation of what is expected to occur in the environment. The simulated aquatic exposure profile for each proposed use of flufenpyr-ethyl differs from the constant exposure in the flow-through test because of rapid degradation of parent flufenpyr-ethyl. The significance ofthe unrealistic constant concentration in the flow-throughtest isnot completely clear. Since chronic effects to invertebrates and fish are not studied throughout the flow-through test, one cannot determinewhether 21 or 60 days of exposure at the EC,,/LC,, concentration were necessary to cause the effects, or if a shorter exposure at that parent concentration would suffice. Regardless, risk quotients did not exceed levels of concern. Toxicity

(ppm)

2.5 >3 1.2 0.92 >2.7 2.08 >2 0.013 0.006 >0.03 0.009 0.16 0.012 B0.05 in ppm. Exposure1 (ppm) 0.00028 0.00028 0.00019 0.0001 0.00028 0.00028 0.00028 0.00028 0.0022 0.0002 0.00028 0.00028 0.00028 0.00028 Risk Quotient (RQ) <O.O 1 <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 0.02 0.36 <0.01 0.03 <0.01 0.02 <0.01

### VII. Terrestrial Exposure and Risk Assessment Summary Assessment of Risks to TerrestrialAnimals Toxicityto TerrestrialAnimals: Data submitted to and reviewed by the Agency (D268736) show that flufenpyr-ethyl is practically non toxic to non-target terrestrial animals. Flufenpyr-ethylisnontoxictobirds on both an acute (LD,, >2250mgkg)and subacute dietary basis (LC,, >5620 mg/kg of diet). However, significant adverse reproductive effects (reduction in 14-day-old survivor/normalhatchlings and final weight of female mallard ducks) were reported at a concentrationof 164ppm flufenpyr-ethyl in the diet. Flufenpyr-ethyl is practically nontoxic to mammals on 

### an acute exposurebasis 

### (LD,, >5000 mgkg) and on a chronic exposurebasis (NOAEC = 1463 ppm). Flufenpyr-ethylis also practically nontoxic to bees on an acute exposurebasis (LC,, >25 uglbee). Estimated Environmental Concentrations for Birds and Mammals: Terrestrial estimated environmental concentrations (EECs) offlufenpyr-ethylinpotentialbird and mammal food items from single or multipleapplications were determined using the ELL-FATE model. The EECs from the ELL-FATE model are based on predicted day-0 maximum residues following a single applicationof 1 lb ai/A. These initial concentrations are based on work done by Hoerger and Kenaga (1972) as modified by Fletcher et al. 

### (1994). The ELL-FATE model adjusts thesepredicted maximum residue valuesby the application rate and annual frequencyofapplication for the use sites being modeled and assumes exponential decay following each application of pesticide at a rate based on the half-life dataprovided for the pesticidebeing modeled. These initial adjusted values were based on two maximum single application rates of 0.027 lbs offlufenpyr-ethyl per acre and aretabulated in the exposure column of 

### Table 

### 9. The ELL-FATE model and EECs are detailed in Appendix 

### VIII.

Table 9. Initial EECs on Avian and Mammalian Food Items Following Two Applications of Flufenpyrethyl at 0.027 lb ai/A Food Items Short grass Tall grass
Fruits, pods, seeds, and large insects 

# I 0.74 Predicted Maximum Flufenpyr-ethylEECs (ppm) 11.8 5.41 Broadleaflforageplants and insects

Estimates of Risks to Birds and Mammals The toxicity test values (i.e., measurement endpoints) used in the acute and chronic risk 20 6.64 Iquotients are derived fromtheresults ofrequired studies. TheEEC,toxicity,andrisk quotient values are provided below in 

### Table 10. Table 10

### - Toxicity, Exposure, andRisk Quotient Values ofFlufenpyr-ethyl(2applications of 0.027lb ai/A,

A - - . 10 days interval, 35 day half-life)

Mammals-Oral and Reproduction 

# 11 >5000 mgikg I 1463 ppm 

# I 11.8 

# I cO.01 1<0.01 

# I ' Based on ELLFATE model (Detailed in appendix VIII)

Species
Northern bobwhite1Mallard duck-Oral BobwhiteIMallard-Dietary Northern bobwhite-Reproduction

Bird and Mammal Risk Assessment Summary No acute or chronicLOCs were exceeded for birds and mammals; the risks are believed to be negligible. Toxicity Exposure (ppm) 

# - >2250 mglkg 11.8 >5620 ppm 11.8

II I 

# I - - 164ppm



### Assessment of Risks to Insects Risk Quotients (RQ) <0.01 <O.O 1

Toxicity results for the honeybee are used for recommending appropriate label precautions. Because flufenpyr-ethylis practically non-toxic to honeybees 

### (LD,, >25 uglbee) on an acute contact basis, precautionary labeling is not required. --- 11.8



### Assessment of Risks to TerrestrialPlants 0.07

Toxicit, to Terrestrial Plants In toxicity tests, post-emergence plants showed more sensitivity to flufenpyr-ethylthan preemergent plants. With ten plant species (corn, oat, onion, ryegrass, soybean, lettuce, radish, cucumber, cabbage, andtomato) applied up to 0.029 lb ai/A, seedling emergenceEC2,values ranged from >0.029 (corn, oat, ryegrass, soybean, cucumber, and tomato) to 0.012 1bs ai/A (lettuce, shoot weight). Seedling emergence NOAEC values ranged from 0.029 (corn, oat, ryegrass, soybean, cucumber, and tomato) to 0.0032 lbs ai/A (radish, shoot weight). Vegetative vigor EC2,values ranged from>0.029 (corn, oat,ryegrass, and soybean)to 0.00009 lbs ai/A (tomato, shoot weight), while NOAEC values ranged from 0.029 (corn, oat, ryegrass, and soybean) to 0.00004 lbs ai/A (lettuce and tomato, shoot weight). The lettuce and tomato EC2, and NOAEC toxicity values are used in the terrestrial plant risk assessment since lettuce and tomato were the most sensitive species in the seedling emergence and vegetative vigor tests, respectively.Estimated Environmental Concentrations for Terrestrial Plants Terrestrial plant EECs offlufenpyr-ethyl from single or multiple applicationswere determined using the TerrPlantmodel 

### (V. 1.0).Details of the TerrPlant model and EECs arepresented in 

### Table 11 and Appendix 

### IX. The EECs from the model are based on the highest single application rate of 0.027 lb ai/A on sugarcane, the solubility of the pesticide in water 

### (4.1 ppm), and the drift characteristics, which vary depending on whether it is a ground or aerial application. The amount of flufenpyr-ethyl that runs off is a proportion ofthe application rate and is assumed to be 1 %, 2%, or 

### 5% for water solubility values of 40 ppm, 10-100 ppm, and >I00 ppm, respectively. For flufenpyr-ethyl, a runoff value of 1 % is assumed, based on its water solubility limit of 4.1 ppm in water. Drift from ground and aerial applications are assumed to be 

### 1 % and 

### 5%, respectively, of the application rate. 

### An applicationefficiency of 60% is assumed for aerial application. In addition to considering where plants grow, exposuremust be estimated to compare with results from two kinds of plant tests 

### - a seedling emergence study and a vegetative vigor study. The seedling emergence study involve treating the soil in which seedlings grow, thus exposing the growing plant to the pesticide. The vegetative vigor study involves exposing only the foliage of actively growing plants off-site to spray drift Both spray drift and runoff are assumed to move off the treated sites


### .

Estimates of Risks to Terrestrial Plants Table 11. Estimated Environmental Concentrations(EECs in lb ai1A) for NON-GRANULAR formulation applications (based on 1 application of 0.027 lbs a.i./acre)

The toxicity test values (i.e., measurement endpoints) used in the acute and chronic risk quotients are derived fi-omthe results ofrequired studies.TheEEC, toxicity, and risk quotient values are provided below in 

### Table 12 for potential runoff, and in 

### Table 13 for potential drift to adjacent sites.

Application

Ground Unincorporated Aerial Total Loading to Adjacent Areas (EEC = Sheet Runoff 

### + Drift)
0.0005 0.0015 Total Loading to Semiaquatic Area (EEC = Channelized Runoff 

### + Drift) 0.003 0.003

Table 12 - Toxicity, Exposure, and Risk Quotient Values of Flufenpyr ethyl fiom Potential Runoff Drift EEC (for ground: application rate x 0.01); (for aerial: application rate x 0.05) 0.0003 0.0014

Species

Non-Endangered Terrestrial plants Endangered Terrestrial plants Seedling Emergence

Toxicity (lbs ai/A)

0.012
0.0097 Exposure (lbs ai/A)

see Table 11 see Table 11 Risk Quotients for Runoff (RQ) To Adjacent Area To Adjacent Semi-Aquatic Area aerial

0.13
0.16 ground 0.05
0.06 aerial 0.25
0.3 1 ground 0.25
0.3 1Table 13 

### - Toxicity,Ex osure, ar Species 

# , I Non-EndangeredTerrestrial

plants 

## I Endangered Terrestrial plants 

### * exceeds the LOC for risk to ten 1 Risk Quotient Values of Flufenp. I

0.00009 see Table 11 Vegetative Vigor Toxicity (lbs ai/A)

0.00004 

# 1 see Table 11 :strial or aquatic plants (RQ 3 1) Exposure (Ibs ai/A) r-ethyl from Potential Drift Risk Quotients for Drift (RQ) To Adjacent Area from Application Area aerial ground

Terrestrial Plant Risk Assessment Summaw Consideringtheproposed uses offlufenpyr-ethyl,theLOC forpotential riskto non-endangered and endangeredterrestrial plants (LOC = 1)is exceeded for both ground and aerial application when drift alone is occurring. The EECs do not exceedthe seedling emergenceEC,, (RQsrange from 0.05 to 0.25 for non-endangered plants) or NOAEC values (RQs range from 0.06 to 0.3 1for endangered plants) from a combination of drift and runoff to dry or semi-aquatic areas. The EECs exceed the vegetative vigor EC,, (RQsrange from 3 to 15 for non-endangered plants) andNOAEC values (RQs range from 7 to 

### 34 for endangered species) from drift to non-target areas. Thus, the proposed use offlufenpyr-ethylon sugarcane and soybean could pose apotential risk to terrestrial plantsfiom drift alone. Currently, EFED does not perform chronic risk assessmentsfor terrestrialplants. Therefore no chronic RQ values for terrestrial plants are presented.


### VIII. Risk to 

### Endangered Species The Agency's levels of concern for non-target and endangered terrestrial plants are exceeded fortheproposed use offlufenpyr-ethylon sugarcaneand soybeans.Thisconcern for terrestrialplants is based on spray drift to adjacent sites. As indicated in Appendix 

### X, the Tier 1Aerial Assessment Model predicts relatively high end (90th percentile) drift deposition values. Nevertheless, because there is a relatively flat slope for the toxicity endpoints, a large no spray zone would be required for plants with responses analogous to the three most sensitive dicots. Numbers would be reduced if extremely coarse spray was used. Nevertheless, at it currently stands, the applicant must provide information on the proximity of Federally listed endangered and threatened terrestrial plants to the proposed use sites. This requirement may be satisfied in one ofthree ways: 1) having membership in the FIFRA Endangered Species Task Force (Pesticide Registration [PR] Notice 2000-2); 2) citing FIFRA Endangered Species Task Force data; or 3) independently producing these data, provided the information is of sufficient quality to meet FIFRA requirements. The information will be used by the OPP Endangered Species Protection Program to develop recommendations to avoid adverse effects to listed species.APPENDIX I - SUMMARY OF ENVIRONMENTAL FATE STUDIES 

### HYDROLYSIS (161-1) 

### MRID 451 190-19 Thehydrolysis of 

### [pyrida~in~l-6-'~C]flufenpyr-ethyl 

### [V- or S-3153;ethyl 

### 2-[2-chloro-4-fluoro-5-[5- methyl-6-oxo-4-(trifluoromethy1)-

### 1,6-dihydropyridazin-1 -yl]phenoxylacetate; radiochemical purity >98%], at 0.93-1.13 pg/mL, was studied in sterile aqueous 0.01 

### M buffer solutions adjusted to pH 5, 7 and 9. Test solutions were incubated in the dark at 25 

# * 1°C for up to 30 days, then were analyzed for total radioactivity using LSC and for parent compound and its degradatesby reversephase HPLC; identifications of [14C]compoundswere confirmed using norrnal-phase twodimensional TLC. Degradationof [14C]flufenpyr-ethyl increased rapidlywith increasing pH. [14C]Flufenpyr-ethyl was relatively stable at pH 5 (calculated half-lives of 299-301 days, 

### ? = 

### 0.69), but degraded with halflives of 8.5 days 

### (? =

### 0.999) at pH 7 and 2.7 hours 

### (? =

### 0.998) atpH 9. One degradate, S-3153-acid 

### [2-[2-chloro-4-fluoro-5-[5-methyl-6-oxo-4-(trifluoromethyl)- 1,6-dihydropyridazin-1 -yl] phenoxylaceticacid],was detected at all threepHs,while a second degradate, S-3 153-acid-4'-COOH 

### [2-[2-chloro-4-fluoro-5-[5-methyl-6-oxo-4-(carboxylic acid)-l,6-dihydropyridazin- 1 -yl] phenoxylacetic acid], was detected only in the pH 7 and 9 test solutions. In the pH 5 solution, [l4C]flufenpyr-ethylgradually decreased from 92.6-96.5% of the applied radioactivity at day 0 posttreatment to 87.9-88.2% at 30 days, while the degradate S-3 153-acid increased from 0.5% of the applied at day 0 to 8.247% at 30 days. InthepH 7 solution, [14C]flufenpyr-ethyl decreased from 93.5-95.1%ofthe applied at day 0to 49.7- 50.1% at 7 

### days, 29.7-29.8% at 14 days, 16.9-17.0% at 21 days and was 8.0-8.2% at 30 days. S3 153-acidin the pH 7 solutionincreased from 0.6-0.7%ofthe applied at day O to 9.1-9.2%at 1day, 22.4-23.1% at 3 days, 41.6-42.2% at 7 days, 79.5-8 1.7%at 21 days, and was 90.0-92.3% at 30 days; the degradate S-3153-acid-4'-COOHwas detected at a maximum of 1.4%ofthe applied at 30 days. In thepH 9 solution, [l4C]flufenpyr-ethyl rapidly decreasedfrom 95.2-96.0% ofthe applied at 0hour to 53.9-55.8% at 2 hours, 3 1.6-32.02%at 4 hours, 17.2-17.7%at 6.5hours, and was 10.4%at 1 day. S-3 1 53-acid in the pH 9 solution increased from 1.2-1.5% ofthe applied at 0 hour to 42.8-43.3% at 2 hours and 98.6-98.7% at 1 day, then gradually decreased to 83.1-84.9% at 7 days, 67.2-72.2% at 14days, and was 48.0-5 1.O% at 30 days. S-3153-acid-4'-COOHin thepH 9 solution increased from 50.3% ofthe applied at 4 hours to 6.7-6.8% at 3 days, 15.0-15.1% at 7 days, 24.8-27.3% at 14 days, and was 49.8-51.4% at 30 days. In all three test solutions (pH 5,7and 9), unidentified [14C]residues were detected at 14.4%of the applied at any sampling interval. Material balances averaged 97.1

# * 1.7%(range 93.7-99.7%) ofthe applied at pH 5,97.5 

# * 2.6% (range 92.4-102.4%) at pH 7, and 

### 99.7 k 

### 2.3% (range 93.4-103.4%) at pH 9. The phenyl ring was not labeled. However, the chemical structure shows that hydrolysis of the phenyl ring is unlikely. Degradation pattern of parent and formation and degradation pattern ofdegradates

### PHOTOLYSIS INWATER (161-2) 

### MRID 451190-20 The photolysis of 

### [pyrida~inyl-6-'~C]-labeled and [phenyl-14C]-labeledflufenpyr-ethyl [V- or S3 153;ethyl 

### 2-[2-chloro-4-fluoro-5-[5-methyl-6-oxo-4-(trifluoromethyl)- 1,6-dihydropyridazin- 1

-yl] phenoxylacetate;radiochemical purities >97%], at a nominal concentration of 1 ppm, was studied in sterile aqueous 0.01 M pH 5 buffer solutions both in the presence and in the absence of a photosensitizer (0.6-0.7 ppm humic acids). Test solutions were maintained at 25 k 1°C outdoors under natural sunlight in Richmond, California (latitude 37.45" N, longitude 122.26" W), for up to 1 month. Maximum light intensity ranged from 3,487 to 28,679 pW/cm2and average daily light energy was 11.49 W-minute/cm2for the 

### [pyridazinyl-6-14C]1abel-treated solutions(July24to August 25, 1997), and 2,603-27,852 pW/cm2 and 10.53 W-minute/cm2, respectively, for the [phenyl14C]label-treated solutions(September 10to October 10,1997). Dark controlswere also maintained for up to 1 month. All samples were analyzed for total radioactivity using LSC and for parent compound and its degradates by reverse-phase HPLC; identifications of [14C]compounds were confirmed using normal-phase two-dimensional TLC. Innon-photosensitized solutions, 

### [pyrida~in~l-6-'~C]-labeled and [phenyl-14C]-labeledflufenpyrethyl degraded rapidly under natural sunlipht, with calculated half-lives of 3 and 5 days 

## (8 values

= 0.98), respectively. Two major degradates, S-3 1 53-4-OH and S-3 1 53-DHPY, and one minor degradate, S-3 153-acid-2,4-(OH),, were identified in the irradiated solutions (both labels). One additional minordegradate, TFPYR, was identifiedonly in irradiated 

### [pyrida~inyl-6-'~C]label-treated solutions. In contrast, in the dark, [14C]flufenpyr-ethyl only slightly degraded in similar solutions incubated


### . Two minor degradates, S-3153-acid 

### [2-[2-chloro-4-fluoro-5-[5-methyl-6-oxo-4- (trifluoromethy1)- l,6-dihydropyridazin-1 -yl]phenoxylaceticacid] and S-3 1 53

### - 1 -OH,were identified in the dark control solutions (both labels). In non-photosensitized irradiated 

### [pyridazinyl-6-14C]1abel-treated solutions, [14C]flufenpyr-ethyl decreased from 97.6-97.8% of the applied radioactivity at day 0 posttreatment to 58.4-61.5% at 2 days, 16.5-21.2% at 7 days, 3.4-4.0% at 11 days, and was 11.0%by 20 days. S-3153-4-OH was detected at a maximum 40.3% ofthe applied at 1 1daysposttreatment and was 19.1-24.6%at 32 days (final sampling interval). S-3 153-DHPY was detected at a maximum 22.7% of the applied at 7 days and was 6.8-14.5% at 32 days. 

### S-3153-acid-2,4-(OH),was detected at amaximum 12.6%at 32 days and TFPYR was detected at a maximum 1 1.2%at 20 days. Unidentified [14C]residues eluting at the solvent front (3-5 minutes)and combined random peaks were detected at maximums of 14.8%of the applied at 20 days and 35.7% of the applied at 32 days, respectively; individual components were each 4% of the applied. At 32 days posttreatment, 14C02 and [14C]organic volatilestotaled 4.4 and 2.2% of the applied, respectively. Innon-photosensitized irradiated 

### [phenyl-14C]label-treated solutions, [14C]flufenpyr-ethyl decreased from 93.0-94.3% of the applied at day 0 posttreatment to 68.7-69.4% at 2 days, 40.5-41.1% at 5 days, 18.8-22.5%at 9 days, 4.7-10.5% at 15days, and was 1.4-1.5% at 30 days. S-3153-4-OHwas detected at a maximum 40.8% oftheapplied at 15daysposttreatment and was 3 1.6-34.3'76 at 30 days (final sampling interval). S-3 153-DHPY was detected at a maximum 21.2% of the applied at 15 days and was 1 1.6-1 5.3% at 30 days. S-3 153-acid-2,4-(OH), was detected at a maximum 8.8% at 30 days. Unidentified [14C]residues eluting at the solvent front (3-5minutes) and combined random peaks were detected at maximums of 10.7%ofthe applied at 15days and 22.9% ofthe applied at 30

### days, respectively; individualcomponents were each 27% ofthe applied. At 30 days posttreatment, 14C0,and [14C]organicvolatiles totaled 14.2 and 0.2% of the applied, respectively. In non-photosensitized dark control solutions at 1 month posttreatment, [14C]flufenpyr-ethy1 comprised 79.5-84.3% of the applied in 

### [pyridazinyl-6-14C]1abel-treated solutions and 80.9-89.8% in 

### [phenyl-14C]label-treated solutions. At 1 month posttreatment for both labels, the degradates 

### S3 153-acid,S-3153-1-OH, and S-3153-4-OH were detected at 4.2-5.6%, ~6.2%~ and <7.8% of the applied, respectively, and 14C0, and organic volatiles were 

### <0.9% and 20.1%, 

### respectively. Material balances ranged from 93.1 

### - 102.2 % 

### for the irradiated solutions and 93.6 

### - 101.3% for the dark control solutions, both labels. 

### In photosensitized solutions, 

### [pyrida~in~l-6-'~C]-labeled and [phenyl-14C]-labeled flufenpyr-ethyl degraded under sunlight in a similar manner as the non-photosensitized solutions,with calculated half-lives of 3 and 4 

### days (I? 

### values = 

### 0.99). [14C]Flufenpyr-ethylonly slightly degraded in photosensitized solutionsincubated in the dark. Degradateprofiles in the irradiated and dark control photosensitized solutions (bothlabels) were similartothe non-photosensitized solutions. However, there was an approximate 2-fold increase in volatilized 14C0, in the irradiated photosensitized solutions; 14C0, totaled 1 1.2 and 24.9%ofthe applied radioactivity forthe irradiated Ipyridazinyl-6- 14C]label- and 

### [phenyl-14C]1abel-treatedphotosensitized solutions, respectively, at 1 month posttreatment. Material balances ranged from 95.0 

### - 106.9 % 

### for the irradiated solutionsand 97.5 

### - 106.7% for the dark control solutions,both labels. Calculated quantum yields for non-photosensitized 

### [pyrida~inyl-6-'~C]-labeled and [phenyl-'4C]- labeled flufenpyr-ethylinpH 5 buffer were 1.4 1

### x 1 

### O4 and 9.80 x lo-', respectively. Quantumyields for photosensitized 

### [pyridazinyl-6-14C]-labeled and [phenyl-14C]-labeledflufenpyr-ethyl in pH 5 buffer were 1.36x loe4 and 1.12x respectively. Based on the average quantum yield of 1.20 

### x (both labels), the predicted half-life of flufenpyr-ethyl in pH 5 buffer at 40°N latitude during winter was calculated as 4.8 days.

### PHOTOLYSIS 

### IN SOIL (161-3) 

### MRID 451 190-21 The photolysis of 

### [pyridazinyl-6-'4C]-labeled and [phenyl-'4C]-labeled flufenpyr-ethyl ( radiochemical purities 296%) was studied on sandy loam and loamy sand soils, respectively, at a nominal concentrationof 0.4 ppm. Sampleswere maintained at 25

# * 1"C and 75% of field moisture capacity outdoors under natural sunlight in Richmond, California (latitude 37.45" 

### N, longitude 122.26" W), for up to 30 days. Maximum light intensities ranged from 4,643-27,575 and 4,188- 28,472 pW/cm2 and average daily light energies were 11.37 and 9.45 W-minute/cm2 for the 

### [pyrida~inyl-6-'~C]flufenpyr-eth~l-treated soil samples (August 19-22,1997and April 27to May 27, 1998, respectively), and 24,036-25,692 pW/cm2 and 10.75 W-minute/cm2, respectively, for the 

### [phenyl-14C]flufenpyr-ethyl-treated soil samples (August 10 to September 9, 1998). Dark controls were maintained alongside irradiated soils for up to 30 days. All samples were analyzed for total radioactivity using LSC and for parent compound and its degradates by reverse-phase HPLC; identifications of ['4C]compounds were confirmed using normal-phase two-dimensional TLC. Volatiles were collected at all sampling intervals after time 0. All data, reported as percentages of the applied, represent percentages of the actual application. 

### [Pyridazinyl-6-'4C]-labeled and [phenyl-'4C]-labeled flufenpyr-ethyl degraded rapidly on both irradiated and dark control soils, with observed half-lives of 4-7 hours. The degradation of ['4C]flufenpyr-ethyl on irradiated soils was bi-phasic with initial half-lives of 5.5-6.7 hours 

## (3= 0.91-0.97; 0- to 7-hour data) and secondary half-lives of 32-40 days 

### (? = 0.23-0.80; 1- to 30-day data). Two major degradates, S-3 153-acid and S-3 153-1 -OH, and one minor degradate, S-3 153-1- OCH,, were identified in irradiated soil extracts (both labels). One additional degradate, TFPYR, was identified only in irradiated 

### [pyrida~inyl-6-'~CIlabel-treated soil extracts. In dark control soil extracts, S-3153-acidwas themajor degradate detected (bothlabels),and S-3153-1 -OHwas detected as a minor degradate onlyin 

### [phenyl-'4C]label-treated soil extracts. Volatilized 14C02 averaged 3.5% and 23.5% of the applied radioactivity for the irradiated 

### [pyridazinyl-6-'4C]label-and [phenyl14C]label-treated soil samples, respectively, at 30 days posttreatment. Inthe dark controls,volatilized I4Co2 was 4% at 30 days posttreatment. Material balances (irradiated and dark controls, both labels) averaged 97.3

# * 4.4% (range 87.3-105.9%, n = 86) of the applied radioactivity. In extracts from irradiated soil, [14C]flufenpyr-ethyl decreased from 90.9-97.0% of the applied radioactivity at time 0 posttreatment to 48.3-55.5% at 4 hours, and was 9.3-10.7% at 30 days. S3 153-acid was detected at a maximum at 1 day posttreatment for both labels at 50.1-77.9% of the applied and degraded quickly to 5.4-19.9% at 30 days. S-3153-1-OH, formed by hydrolysis of S3 153-acid in both labels, was detected at a maximum 15.8-1 8.1% of the applied at 9 days and was 8.0-14.1% at 30 days. S-3153-1-OCH, was 15.4%at any sampling interval. TFPYR, the cleavage product in the 

### [pyrida~iny1-6-'~C]label-treated soil extractswas detected at a maximum 22.8-28.3% of the applied at 30 days. Unidentified [14C]residues comprised a maximum 21.5-25.3% of the applied at 30 days and consistedofnumerous components, each<6.3%of the applied. Unextractable [14C]residues were 8.2-1 1.2%ofthe applied at 30 days; 3.5-10.4% ofthe applied was associated with the fulvic acid fraction, 1.2-2.1 % was humic acid, and 13.6%was humin. In extracts fiom dark control soil, [14C]flufenpyr-ethyl decreased to 50.6-53.6% at 4 hours and was 12.2-14.3%at 30 days. S-3 153-acid increasedto 85.7-95.4%ofthe appliedby 9 days then gradually decreasedto 80.4-8 1.4% at 30 daysin 

### [pyridazinyl-6-'4C]1abel-treated samples, while itwas detectedat a maximum 71.7-78.7% at 3-30 days in 

### [phenyl-14C]label-treated samples. S-3153-1-OH was detected only in 

### [phenyl-14C]label-treated samples at 11.4% of the applied. Unidentified [14C]residues comprised 14.8% of the applied. Unextractable [14C]residues were 4.3-7.3% of the applied at 30 days posttreatment. Due to the rapid microbial degradation of S-3153 on soil (t '/z 

### < 7 hours), it is not certain if photolysis contributes to the degradation of flufenpyr-ethyl on soils. However the results indicate that photolysis is an important dissipationroute for the primary degradate, S-3153-acid,under the conditions tested. The half-life of S-3153-acidin irradiated samples was calculated as 16.3days and 10.5 days, in pyridazinyl and phenyl samples, respectively, by assigning the concentrations of S3 153-acid detected at day 1 posttreatment as time zero values.


### AEROBIC SOIL METABOLISM (161-4) 

### MRID 451190-22 

### [Pyrida~in~1-6-'~C]flufen~yr-ethyl (radiochemical purity 98.8%), at 0.06 ppm, degradedwith an halflive of approximately 1hour in sandyloam soilmoistenedto 75% of the fieldmoisture capacity and incubated in the dark at 25OC for 365 days. The degradation of S-3153 in sandy loam soil was observed to be biphasic; flufenpyr-ethyl comprised 4% of the applied at 1day posttreatment, then declined slowly to 0.9-1.2% at 365 days. Using linear regression oflog transformed concentrations, the half-life in the entire system was calculated to be 1.5hours 

### (? = ) in the entire system,based on 0-4 hours data; and 97.4 days 

### (9 = 0.4170) based on 0-365 days data


### . Using a non linear regression of non transformed data, the half-life is 1.2hours 

### (? = 0.9778) in the entire system. Four degradates were identified: S-3153-acid (maximum 83.5% at day 1 posttreatment), S-3 153-1 

### - OH (maximum 14.1% at day 91), S-3153-1-OCH, (maximum 53.2% at day 177), and S-3153-1- OCH,-5'-CH,OH (maximum 17.7% at day 365). It was proposed that flufenpyr-ethyl degrades rapidly in soil to S-3 153-acid,which was formed by hydrolysis of the ester moiety. S-3153-acid subsequently degraded to S-3 153- 1 -OH via oxidative cleavage of the acid group to phenol, which in turn methylated to form S-3 153-1-OCH,. S-3 153-1 

### - OCH,-5'-CH,OH was formedby hydroxylationof the methyl group in the 5'position ofthe pyridine ring of S-3 153-1 -OCH,. The half-life of S-3 153-acid ( t ?4 = 38.5 days) was calculated assuming that the concentration of S-3153-acid detected at day 1 posttreatment as the time zero value. Likewise,the half-life of S-3153-1 -OH (t ?4 =7.1 days) was calculated using day 59 as the time zero value. The half-life of S-3 153-1-OCH, (t ?4=47.6 days) was calculated using day 177 as the time zero value. The half-life calculationswere based on non linear regression of non transformed data. Flufenpyr-ethyl was 95.0-96.5% ofthe applied at time 0,50.2-50.3% at 1hour posttreatment, 16.1- 19.7%at 4 hours, 5.4-6.0% at 1day, and 0.9- 1.4%at 365 days. Using linear regression calculations with log-converted data, the half-life is 97.6 days 

### (? = 0.417) for 0 

### - 365 days data, 210 days 

### (9 = 0.8151) for 1 

### - 365 days, and 1.7hours 

## (3 = 0.9566) for 0 

### - 4 hours. None of these calculations accurately reflect the curvilinear nature of the whole data set; S-3 153-acidplus S-31 53-1-OCH,-5'-CH,OH, which were not differentiated by HPLC, averaged a maximum of 83.5%ofthe applied at 1dayposttreatment, 57.5-58.9% at 29 days, and varied between15.7 and 30.9% at 59 through 365 days. TLC analysis indicated that S-3 153-acid decreased fkom 30.9% of the applied at 59 days posttreatment to 6.4% at 365 days (fkom 100.0%to 26.2% of the mixture), and S-3153-1-OCH,-5'-CH20H increased from 0% of the applied at 59 days to 18.7% at 365 days. S-3153-1-OCH, averaged a maximum of 53.2% ofthe applied at 177days posttreatment and decreased to 24.1% at 269 days and 11.2%at 365 days. S-3153-1-OH averaged a maximum of 14.1% of the applied at 91 days posttreatment, 4.4-5.2% at 91-177 days, and 2.5% at 365 days. Unknown 1(R,approximately 14minutes),which was thoughtto be derivedby oxidation of S-3 153- 1

-OCH,-5'-CH,OH, was initially detected at 177 days posttreatment and averaged a maximum of 13.9%ofthe applied at 365 days. Unidentified [14C]residues, each present at <4.2% ofthe applied, increasedto 20.6%ofthe applied at 365days posttreatment. At 365 days posttreatment, unextracted ['4C]residues totaled amaximum 20.7-21.3%ofthe applied, organic ['4C]volatiles totaled 0.1%, and I4CO2 totaled 6.7-8.1%. Material balances ranged from 93.1

### - 1 02.9% of the applied throughout the study with no pattern of decline. 

### ANAEROBIC AQUATIC METABOLISM (161-4) 

### MRID 451190-23 

### [Pyrida~in~l-6-'~C]flufen~yr-ethyl (radiochemical purity 99.I%), at 0.06 ppm, degraded with an observed initial half-life of less than 1 hour in anaerobic (flooded plus nitrogen atmosphere) clay loam sediment that was incubated in the dark at 25OC for 365 days. Approximately 90% had dissipatedby 4 hours posttreatment and <99% by 1 day. Two major degradates were identified: S3 153-acid (maximum 81.5% at day 1 posttreatment) and S-3 153-1-OH (maximum 84.4% at day 185). It was proposed that flufenpyr-ethyl degrades rapidly to S-3 153-acid, which in turn degrades to S3 153- 1 -OH. S-3 153-1 -OH isrelatively persistent under anaerobic conditions. Sincethe conversion of flufenpyr-ethylto the acid form was nearly complete by day 1, the half-life of 

### S-3153-acid (t 

### ?4
2 3 days) was calculated assuming that the concentration of S-3153-acid detected at day 1 posttreatment as time zero values. The half-life of S-3153-OH (extrapolated t% = 866 days) was calculated using the time point where the highest percent ofthis degradate was observed (185 days) as the time zero. In the total sediment/water system, flufenpyr-ethyl was 70.5-82.1% of the applied at time 0,27.2- 36.7% at 1 hour posttreatment, 10.0-11.4% at 4 hours, 0.5-0.8% at 1 day, and 0.0% at and after 3 days. S-3 153-acidwas 5.5-1 8.4%ofthe applied attime 0,46.6-61.1% at 1 hour posttreatment, 75.8- 81.5% at 1 day, 52.1-53.7% at 3 days, 19.8-24.2% at 7 days, and was not detected at and after 30 days. S-3 153-1 -OH was 3 1.1-34.2%of the applied at 3 days posttreatment, 78.5-79.3% at 30 days, a maximum 84.0-84.4% at 185 days, and 67.7-77.5% at 365 days. At 365 days posttreatment, an HPLC peak at 14-17 minutes and "others" contained 2.1-7.0 and 4.5-7.8% of the applied, respectively. At 3 65 daysposttreatment,unextracted [14C]residues totaled a maximum 15.1 

### - 15.5% ofthe applied, organic [14C]volatiles were below detection levels, and 14C0, totaled 0.4-0.7%. The distributionratio of [14C]residues between the water and sediment phases was approximately 7:2 at time 0,6:4 at 1 day posttreatment, 3:7 at 7 days, and 1:4 at and after 30 days.Material balances ranged from 93.7-100.1% of the applied (mean 96.6 h 1.8%) with no pattern of decline.


### SOIL ADSORPTION/DESORPTION(163-1) MRID 451191-01 Three degradates of flufenpyr-ethyl, S-3 153 Acid, S-3153-1-OH and S-3153-1-OCH, were determinedtobe mobile in Ockley sandy loam (1.1 

### %OC; 6.6 pH), Cecil sandy clay (0.81 %OC; 5.1 pH), Bosket sandy loam (0.35 %OC; 6.4 pH); and Drummer-Flanagan loam soil (1.8 %OC; 5.6pH). The soils were equilibrated with water or aqueous 0.01M calcium chloride solution slurries in the dark at room temperature for 24 hours. The study was conducted at nominal concentrations of 1.0, 0.2,0.04, and 0.008ppm. The soil:solution ratios were l:l, 1:3,or 1:5,depending on test substance and soil type. The Organic Carbon Normalized soillwater partitioning coefficients for adsorption (KO,-,,,)ranged fi-om 19

### - 73 mL/g for S-3 153Acid, 149

### - 216 mL/g for S-3153-1-OH,and 210 

### - 284 mL/g for S-3 153-1 -OCH,. Based on HPLC adsorptionbehavior, it was predicted that flufenpyr-ethyl would have a KO, of 415 mL/g; the mobility could not be determined experimentally because flufenpyr-ethyl was unstable in solution. This indicated that flufenpyr-ethyl may be less mobile than its major degradates. 

### [14C]S-3153Acid 

### [2-chloro-4-fluoro-5-(5-methyl-6-oxo-4-trifluoromethyl- 1,6-dihydropyridazin- 1 -yl) phenoxy)acetic acid; radiochemical, purity >97%]: Freundlich adsorption K,,,, values were 0.21 mLlg for the Ockley sandy loam soil, 0.59 mL/g for the Cecil sandy clay soil, and 0.74 mL1g forthe Drummer-Flanagan loam soil. The Organic Carbon Normalized soillwaterpartitioning coefficients for adsorption(KO,-,) were 19(Ockley sandy loam), 73 (Cecil sandy clay), 41 (Drummer-Flanagan loam soil), and 24 (Bosket sandy loam; preliminary test); lln values ranged from 0.92-0.96. The coefficient of determination 

## (8) values for K, vs. percent organic matter, Kdvs. pH, and K, vs. percent clay content were 0.91, 0.46, and 0.29 respectively. Following two 24-hour desorption periods, K,,,, values were 2.91 for sandy loam soil, 0.67 for sandy clay soil, and 0.8 1 for loam soil; values were 264 for the sandy loam soil, 83 for the sandy clay soil, and 45 for the loam soil; l/n values ranged from 0.89- 1.04. Material balances ranged from 102-1 16% of the applied. Due to the low adsorption to the Bosket sandy loam (0.6 

### %OM), this soil was not used in the definitive study; the adsorption Kdand KO, values estimated from the preliminary study were 0.08 mL/g and 24 mLlg, respectively. 

### [14C]S-3153-1-OH, 

### [2-(4-chloro-2-fluoro-5-hydroxy)phenyl-4-methyl-5-trifluoromethyl-2,3- dihydropyridazin-3-one; radiochemical, purity 97%]: Freundlich adsorptionK, valueswere 0.75 for the Bosket sandy loam soil, 1.64 for the Ockley sandy loam soil, 1.29 for the Cecil sandy clay soil, and 3.65 for the Drummer-Flanagan loam soil. The respective KO, values were 216, 149, 159, and 203 mL/g, with l/n values ranging fi-om0.78-0.90. The coefficient of determination 

### (?) values for K, vs. percent organic matter, K, vs. pH, and K, vs. percent clay content were 0.46,O. 13, and 0.10 respectively. Following two 24-hour desorption periods, K, values were 3.84-3.87 for the sandy loam soils, 1.86 for the sandy clay soil, and 6.94 mLlg for the loam soil; KO, values were 349-1 111 for the sandy loam soils, 230 for the sandy clay soil, and 386 mLlg for the loam soil; l/n values ranged from 0.83 

### - 0.89. Material balances ranged fi-om 103-1 14% of the applied.[14C]S-3153-1-OCH3 

### [2-(4-chloro-2-fluoro-5-methoxy)phenyl-4-methyl-5-trifluoromethyl-2,3- dihydropyridazin-3-one; radiochemical, purity >99%]: Freundlich adsorption K, values were 0.99 for the Bosket sandy loam soil, 2.3 1 for the Ockley sandy loam soil, 1.83 for the Cecil sandy clay soil, and 4.47mL/g for the Drummer-Flanagan loam soil;Respective KO, values were 284,210,226, and 248 mL/g with l/n values ranged from 0.92-0.90. Reviewer-calculated coefficient of determination (r2) values for K, vs. percent organic matter, K, vs. pH, and K, vs. percent clay content were 0.38,O. 15, and 0.10respectively. Following two 24-hour desorptionperiods, K, values were 5.46-7.94 for sandy loam soils, 8.57 for sandy clay soil, and 9.61 mL/g for loam soil; KO, values were 72 1 

### - 1 570 for the sandyloam soils, 1055for the sandy clay soil, and 535 mL/g for the loam soil; l/n values ranged from 0.89-1.08. Material balances ranged from 96-107% of the applied.
TERRESTRIAL FIELD DISSIPATION (164-1) MRID 451191-02 The terrestrial field dissipation of phenyl ring-labeled flufenpyr-ethyl, formulated as a wettable powder, was conducted on lysimeter-enclosed plots in Kilbourne, Franklin County, Ohio at a rate equivalent to 28.82 g ai/A. Test soils were labeled flufenpyr-ethyl was used because of the low application rate and alsot\ofacilitate the detection and monitoring of anticipatedlow level residues. Followingone application,flufenpyr-ethyl dissipated with ahalf-lifeof<2 hours. Soil sampleswere analyzed for flufenpyr-ethyl and twelve potential degradates, of which the following seven were detected: S-3153Acid 

### [[2-chloro-4-fluoro-5-(5-methyl-6-oxo-4-trifluoromethyl-1,6-dihydropyridazin-1- yl)phenoxy]acetic acid)],

S-3 1 53-DHPY [ethyl 

### [2-chloro-4-fluoro-5-[(2-hydroxy-4-methyl-5-oxo-3-~fluoromethyl-2,5- dihydro- 1 H-pyrrol- 1 

### -yl)amino]phenoxy]acetate],

S-3 153-4-OH 

### [ethyl[2-chloro-4-hydroxy-5-(5-methyl-6-oxo-4-trifluoromethy1- 1,6- dihydropyridazin-1 -yl)phenoxy]acetate], and

Residue data are the means of duplicates. Flufenpyr-ethyl was initially present in the 0- to 3-inch depth at 0.090 ppm, was 0.0 10-0.014ppm from 2 hoursto 2 days, and was detected at ~0.00 1ppm following 2 days posttreatment. S-3153Acidwas present in the 0- to 3-inch depth at a maximum of0.030 pprn at 7 hours, was 0.0 12-0.016pprn from 1 to 5 days, decreased to 0.007 pprn by 13 days, and was last detected at 0.001pprn at 124days posttreatment. Maximum and final detections of S3 153 Acid and the other six degradates in the 

### O- to 3-inch depth were as follows:

No res Degradate 

# I Calculated half-life1 I S-3 153-Acid 1 day S-3 153-1-OCH, 250 days
I S-3 153-DHPY 1 day

S-3 153-4-OH Not determined S-3 153-1-OCH,- Not determined 5'CH,OH lues were detected in the 3- to 6-inch ( Maximum detection (pprn) 

# I Final detection (pprn)

0.017 (13 days) 0.006 (363 days; last

0.0 10 (7 hours and 2 days) 0.0 10 (2 days) 0.006 (2 hours and 1-2 0.001 (170 days) days) 0.007 (2 days) 0.007 (2 days) 0.001 (91 and 170-300 0.001 (300 days) days) epth at >0.002 pprn with the exceptionof S-3 153-1 

### - OCH,, which was detected at 0.003-0.004

# ppm at 13, 58, 9lYand170 days posttreatment. Total [14C]residues were <0.0011 pprn at all sampling intervals below the 3- to 6-inch depth. Radioactivity in the leachate and run-off water was not reported. Test soil is classified by the National Resources Conservation Service (NRCS) as an Ockley silt loam, and has a slope of less than 1%. 

### MRID 451191-03 & 451191-21 Flufenpyr-ethyl, as the formulationS-3 15350 

### WP),was broadcast once at anominal application rate of 24.6 g a.i./Aonto a baregroundplot ofGrangeville loamy sand soil in Madera County, California. Followingthe application, the calculatedDT,, was 0.9days for flufenpyr-ethyl and 4 days for S-3 153 Acid. Data are reported as the averages of three replicates unless otherwise stated. Soil samples were analyzed for flufenpyr-ethyl and the degradates, S-3153 Acid 

### [[2-chloro-4-fluoro-5-(5-methyl-6-oxo-4-~fluoromethyl- 1,6-dihydropyridazin-1 

### - y1)phenoxylacetic acid], S-3 153-1 

### -OH 

### [2-(4-chloro-2-fluoro-5-hydroxy)-phenyl-4-methyl-5-trifluoromethyl-2,3- dihydropyridazin-3-one], and

Residue data were not corrected for soil moisture content or method recovery. In the 0- to 3-inch soil depth, flufenpyr-ethyl was present at a maximum of 0.008 pprn immediately posttreatment, decreased to 0.005 pprn by 1 day, and was last detected at 0.003 pprn at 3 days posttreatment. 

### S3153 Acid was present in the 

### O- to 3-inch soil depth at a maximum of 0.027 pprn immediately

### posttreatment,decreased to 0.012 pprn by 3 days and 0.008 pprn by 

### 7 days, and was last detected at 0.002pprn (1 of 3replicates) at 14days posttreatment. S-3153-1-OCH, was detected at 50.004 pprn (29 days), and S-3153-1-OH was not detected at any sampling interval. Flufenpyr-ethyl and the degradates analyzed for were not detected below the 3-inch soil depth. 

### MRID 451191-04 & 451191-21 

### Flufenpyr-ethyl,as the formulation S-3 15350 

### WP) was broadcast once at a nominal applicationrate of 24.5 g a.i./A onto a bareground plot of Drummer silt loam soil in Champaign County, Illinois. Following the application, the registrant-calculated 

### DT,, was 2.0 days for flufenpyr-ethyl and 14.4 days for S-3 153 Acid. The data are reported as the averages of three replicates unless otherwise stated. Soil sampleswere analyzed for flufenpyr-ethyl and the degradates, S-3 1 53Acid 

### [[2-chloro-4-fluoro-5-(5-methyl-6-oxo-4-trifluoromethyl- 1,6-dihydropyridazin- 1



### - y1)phenoxylacetic acid], S-3 153-1 -OH 

### [2-(4-chloro-2-fluoro-5-hydroxy)-phenyl-4-methyl-5-trifluoromethyl-2,3- dihydropyridazin-3 -one], and

Residue data were not corrected for soil moisture content or method recovery. In the 0- to 3-inch soil depth, flufenpyr-ethyl was present at a maximum of 0.028 pprn immediately posttreatment, decreased to 0.016 pprn by 1 day, and was last detected at 0.014 pprn at 3 days posttreatment. S3 153Acid was present in the O- 

### to 3-inch soil depth at 0.008-0.01 8pprn from O to 14 days, decreased to 0.005 pprn by 28 days, and was last detected at 0.003 pprn at 43 days posttreatment. S-3 153-1- OCH, was detected at 0.009-0.012pprn from 43 to 367 days and decreased to 0.006 pprn by 445 days posttreatment. S-3153-1-OH was detected at 10.005 pprn (9 and 14 days) at all sampling intervals. Flufenpyr-ethyl and the degradates analyzed for were generally not detected below the 3- inch soil depth.Appendix 

### I1 

### - Chemical Structures and Proposed Degradation Pathways Flufenpyr-ethyl Chemical Name: (ethyl 2-[2-chloro-4-fluoro-5-[5-methyl-6-oxo-4-(trifluoromethyl)- 1,6-dihydropyridazin-1- yllphenoxylacetate Synonyms: [Phenyl-14C]S-3 135,V-3 153

Degradates [Phenyl-14C]S-3153Acid Chemical Name: [2-chloro-4-fluoro-5-(5-methyl-6-oxo-4-~1- 1,6-dihydropyridazin-1 -yl)phenoxy]acetic acid Synonyms: S-3 153Acid,M-1[Phenyl-14C]S-3153-1-OH Chemical Name:2-(4-chloro-2-fluoro-5-hy&oxy)phenyl-4-methyl-5-ifluoromethyl-2,3-dihy&opyridazin-3-one Synonvms:S-3153-1-OH, M-5

[Phenyl-14C]S-3153-1-OCH, Chemical Name:2-(4-chloro-2-fluoro-5-methoxy)phenyl-4-methyl-5-@ifluoromethyl-2,3-dihy&op~idazh-3-one Synonyms:S-3153-1-OCH,, M-9S-3153-DHPY Chemical Name: Ethyl [2-chloro-4-fluoro-5[(2-hydroxy-4-methyl-5-oxo-3-trifluoromethyl-2,5-dyo-lH-pyrrol-lyl)amino]phenoxy]acetateS-3153-4-OH Chemical Name: Ethyl[2-chloro-4-hydroxy-5-(5-methyl-6-oxo-4-trifluoromethyl-1,6-dihydropyridazin-1- y1)phenoxylacetateS-3153-acid-4'-COOH ChemicalName:[2-[2-chloro-4-fluoro-5-[5-methyl-6-oxo-4-(carboxylic acid)-l,6-dihydropyridazin-1-yl]phenoxy]acetic acid]

TFPYRProposed Hydrolysis PathwayProposed Aqueous Photolysis PathwayProposed Metabolic Pathway in Aerobic SoilProposed Metabolic Pathway in Anaerobic Aquatic SoilAPPENDIX I11 

### - Aquatic Exposure Assessment

U. S. ENVIRONMENTALPROTECTION AGENCY WASHINGTON, DC 20460 OFFICE OF PREVENTION, PESTICIDES AND TOXIC SUBSTANCES 

### Date: August 08,2003 

### PC Code 108853 

### DP Barcode: D268736 

### MEMORANDUM
SUBJECT: Tier 1 Water Resources Assessment of Flufenfyr ethyl and its degradates 

### PROM: Thuy 

### L. Nguyen, Chemist ERB 111, Environmental Fate and Effects Division (7507C) 

### THRU: Ben Smith, Branch Chief Stephanie Syslo,RAPL ERB 111, Environmental Fate and Effects Division (7507C) 

### TO: Joanne Miller Registration Division (7505C) 

### CC: Jennifer-R Tyler Health Effects Division (7509C) The Environmental Fate andEffectsDivisionhas reviewedtheproposed newuses for flufenpyr ethyl on soybean, sugarcane, and field corn. This memo presents the Tier 1 Water Resources Assessment for flufenpyr ethyl and for three offlufenpyrethyl's major soildegradates, S-3153-acid, S-3153-1-OH, and S-3153-1-OCH,. For human health exposureassessment, drinking water estimated concentrations (DWEC) for surface and ground water are calculatedusing FIRST (EQPA index Reservoir Screening Tool) and SCI-GROW (Screening Concentrationin &und_water), respectively. Results forparent flufenpyr ethyl are reported in 

### Table 

### 1, for all three crops. Results for the degradates are reported in 

### Table 2, for sugarcane crop only, since with the high Percent Cropped Area (PCA) factor and the high maximum annual application rate, the DWECs for sugarcane representthemost conservative values amongst those of the proposed uses. For ecolonical risk assessment, estimated environmental concentrations (EEC) for surface water are calculated using GENEEC2 (GENericEstimated Environmental Concentration). Results are reported in 

### Table 3 on sugarcane for parent and its 2 major degradates. These results represent the most conservative EEC values amongst those of the proposed uses.

# I Annual Average (chronic) 0.004 ppb 

# I 0.002 ppb 

# I 0.001 ppb 

# I Table 

### 1 

### - Flufenpw ethyl DWECs for Human Health Assessment

Ground Water: Acute and Chronic 

# I <0.01 ppb 

# I <0.01 ppb 

# I <0.01 ppb 

# I Surface Water: Peak (acute)

Table 2 

### - Flufenpw ethyl degradates DWECs- based on Sugarcane crop S-3153-acid S-3153-OH S-3153-1-OCH, Surface Water: Peak (acute) 3.6 ppb 0.35 ppb 1.5 ppb 

# I 

# I I Annual Average (chronic) 

## I 1.5ppb 

## I 0.04 ppb 

## I 0.49 ppb 

# I Field corn 0.024 ppb Sugarcane 0.161ppb



## I Ground Water: Acute and Chronic 

## 1 0.04~~b 

## 1 <0.01 DD~ 

## 1 <0.01 ppb 

## I Soybean 0.076 ppb

For flufenpyr ethyl, the water concentrations were based on sugarcane and soybean (2 applicationsper year at 0.027 lb ai/A each, with a 10-dayretreatment interval between application) and on field corn (2 applicationsper year at 0.0 19 lb ai/A each, with a 10-day retreatment interval between application. For sugarcane and soybean, although both aerial and ground application are permitted, aerial application was simulated to derive at the highest level of surface water contamination. For field corn, only ground application is permitted. Note that, even though sugarcane and soybean have the same maximum annual application rate, sugarcane has much higher surface DWEC values partially due to its high default PCA value. For the degradates, only the sugarcane values were reported, as they arethe most conservative estimates, also due to the high PCA value. Table 3 - Surface Water EECs for Eco1og;ical Risk Assessment, based on Sugarcane b I I I I i

The EECs listed in Table 3 were based on sugarcane, since it has the highest maximum allowable rate (2 applications per year at 0.027 lb ai/A each, with a 10-day retreatment interval between application). Aerial application was also assumed for parent flufenpyr ethyl in order to predict the highest level of surface water contamination. For the degradates, although aerial application was used, no drift was assigned since those degradates were formed on soils. Furthermore, no PCA adjustmentwas required for these surface water EECs. Flufenpyr Ethyl

S-3153-acid S-3153-1-OH Peak
0.279ppb 2.19 ppb 0.215 ppb Average 4-day 0.270ppb 2.19 ppb 0.212 ppb Average 21-day 

# ----- 0.191 ppb 2.15 ppb 0.196 ppb Average 60-day 0.101 ppb 2.08 ppb 0.165 ppb Average 90-day 0.070 ppb 2.03 ppb 0.145 ppb
aTable 

### 4 lists the proposed use patterns associated with this surface and ground water resource assessment.

PhysicaYChemicalProperties and EnvironmentalFate Summary Table 4 

### - Uses

F~eld corn
Sugarcane
Soybeans

Flufenpyr ethyl is an odorless off-white powder. Based on a solubility in water of 4.1 mg/L at 20 "C, a vapor pressure of 3.8 x Pa at 20°C, and a melting point of 100 

### - 10l°C, EFED predicts that volatilizationmay not be a significant dissipativepathway for flufenpyr ethyl. A Log Po, of 2.99 h 0.05 also indicates the bioaccumulation potential of this chemical in fish could be negligible. Laboratory studies show that flufenpyr ethyl does not persist in the environment, neither in water nor in soil systems. Photolysis in water is fairly rapid (t ?h <5 days) and the rate ofhydrolysis is dependent on the pH of the water. While flufenpyr ethyl could degrade within days in neutral water (t ?4

### = 8 days) and within hours in alkaline water (t ?4

### = 3 hours), it remains quite stable in acidicwater (t ?h 

### = 300 days). On soils, flufenpyr ethyl quickly biodegrades (t ?h 

### <2 hours) into S3 153-acid. Three other major metabolites are also subsequently formed, S-3 153-1 -OH, S-3 153-1- OCH, and S-3153-1-OCH,-5'-CH20H,along with some minor level of CO,, S-3153-1-OCH,-5'- COH, and some bound residues. In a sediment-water system, rapid degradation of flufenpyr ethyl (t ?4 < 2 hours) to S-3153-acid is also noted. S-3153-acidin turn degrades to S-3153-1 -OH, which seems to be more persistent under anaerobic conditions (t ?4 = 866 days) than under aerobic conditions (t ?4 = 108 days). Both S-3 153-acid and S-3153-1-OH are major metabolites in the sediment-water system. Major and minor metabolites of flufenpyr ethyl are listed in Table 5. The estimated 

### KO, value from the leaching and Adsorption/Desorption studies indicates that flufenpyr ethyl has some leaching potential. However, since other dissipation routes such as degradation and mineralizationare more important and more rapid, the likelihood offlufenpyr ethyl leaching into ground water could be greatly reduced. In contrast, two of its major metabolites, S3 153-acid and S-3 153- 1 -OH, seemto be more mobile and could have greater abilityto reach ground water than the parent. SCI-GROW model results show that S-3153-acid could reach ground water at a higher level than the parent. Nevertheless, in the field studies, neither flufenpyr ethyl nor these degradateswere detected below the 3" soil depth at above the study detection limit (2 ppb). The environmental fate data, physical-chemical properties, and surfacewater modeling results suggest that drift, if any, may be the most important route of potential exposure for flufenpyr in surface water. However, even if it reaches ground water, flufenpyr ethyl is prone to hydrolysis (except in acidic aquatic environment) and should not present a major concern to surface water resources. Modelingresults from FIRSTestimatea peak value ofless than 0.1 ppb offlufenpyrethyl Proyosed Uses for Flufenpvr ethyl Method of Appl. broadcast aerial / broadcast broadcast aerial / broadcast Max Appllyear (Ib ailacre)

0 0323
0.054
0 0532 0.054 PCA value
0 46

0 87

0 41 Application

Interval (days)

10
10 -14

10 10- 14 No. Appl/year
2
2
2 2 Product/ Formulation S-3153/ Atrazine WDG S-3153 WDG S-3153/ Atraz~ne WDG S-3153 WDG PHI (days)

not spec~fied 90
90 45 Application Rate (Ib ailacre)

0,019
0 027

0355 0.027residue in surface water under the most conservative scenario. As for the degradates, predicted surface water concentrations are higher than that of the parent. However, it should be noted that there are uncertaintieswhen modelingthe degradates, due to an incompletedatabase. Consequently, severalassumptions were made, includingdegradate stability tohydrolysis and photolysis. Thismay be a conservative assumptionbased on an analysis of their molecular formulae, especially with 

### S3153-acid, where the chemical structure suggests a higher solubility in water and a higher susceptibility to hydrolysis. A detailed assessment and characterization ofthese uncertainties could be found in the "Description of Modeling Inputs and Results" paragraph. Table 5 - Flufenpyr ethyl Deeradates

1 I Degradates Hydrolysis pH 7 

# I S-3153-acid * 

# I rnax 92% at day 30
rnax 1.4% at

day 30

S-3 153-acid-2,4-(OH)2
TFPYR
S-3 153-1-OCH3* Photolysis Photolysis (water) (soil)

rnax 41% at

day 15 

# I

rnax 23% at day 7 

# I

rnax 13% at

day 32
rnax 11%at

day 20 

# + Aerobic Soil

rnax 84% at day 1

rnax 53% at

day 177
rnax 14% at

day 91
rnax 19% at

day 365

rnax 14% at

day 365 Anaerobic Terrestrial

hours

rnax 8% at 

# 7

rnax 15% at 

# p

rnax 18% at

day 13 day 185
rnax 1%at day 300
rnax 11% at 

# --t

### Description of Modeling Inputs and Results: Flufenpvr ethvl The drinking water estimated concentrations reported in 

### Table 1 were based on the input parameters listed in 

### Table 

### 6. Background information on the models and the model outputs are attached in Appendix 

### 1 for FIRST, Appendix 2 for SCI-GROW, and Appendix 

### 3 for GENEEC2. FIRST accounts for Percent Cropped Area (PCA). The PCA factor is 41% for soybean. No PCA was developed for sugarcane and a default value of 87% was used for this crop. The PCA is a generic adjustment which represents the maximum percent of any watershed that isplanted to the cropbeing modeled and, thus, maypotentially be treated with thepesticide in question. PCA factors are generated from Geographic Information System (GIs) overlays of cropping area and watershed delineations. EFED believes that the default value of 87% is probably high for sugarcane and the resultsreported forthat crop couldbe overestimated. No PCA adjustmentisrequired for GENEEC2 or for SCI-GROW. rable 

### 6. Input Parameters for Drinking

Application rate 

### Parameter Solubility (water) Hydrolysist,, (pH 7) Aq. Photolysist,, (pH 7) Aerobic Soil Metabolismt,,2 Aerobic Aquatic Metabolismt,,2

PCA value 

### Range 4.lmgIL

- - --

8.5 days 2.8,2.9,4.4, and 4.9 days 0.0496 days
no data

0.027 Ib ai/A, 2 app, 10-day interval Yater Concentrations I I

4.9 days (maximum) (FIRSTIGENNECZ) 

# I MRTD 45 1190-20

# 1 Value Used in Model 4.1 mg/L (FIRSTlGENNEC2)
8.5 days (FIRSTlGENEEC2) 

### Source Product Chemistry MRID451190-19

0.0271b ai1A 2 appl, 10-day interval (FIRSTlGENEEC2lSCI-GROW) 0.0496 x 3 = 0.15 days (FIRSTlGENEEC2) 0.0496 days (SCI-GROW) 0 day (stable). Hydrolysis will be the ratedetermining process (FIRSTlGENEEC2) 4 15mL1g (one estimated value) (FIRSTlGENEEC2lSCI-GROW) Label information MRID 45 1190-22

MRID 451 191-01

field corn: 46% (FIRST) 

## I I sugarcane: 87% (default) (FIRST) soybean: 41% (FIRST) Since,only one half life was reported for aerobic soil metabolism, EFED uses three times that value to account for the uncertainty associated with a single laboratory study. The maximum allowable rate of 

### 0.054 lb ai/A/year and the slowest photolysis rate were also simulated to achieve the most conservative surface water contamination scenario. EFED Policy



### Flufen~vr ethvl degradates:Four major degradateswerereportedin the fate laboratory studies,S-3 153-acid, S-3 153-1-OH, S-3153-1-OCH3, and S-3 153-1-OCH3-5'-CH20Hand were identified as degradates ofimportance to the human health effect assessment by the MARC meeting of June 26,2003. The DWECs were estimated for all these degradates, except S-3153-1-OCH3-5'-CH20H for which there are insufficientenvironmental fate data. The input parametersused in thewater models are listed below. 

### 3-3153 Acid Parameter Range Value Used in Model assume solubility of parent:

4.1 mg/L (FIRST)
assume stable - 0 day (FIRST)
assume stable - 0 day (FIRST) 38.5 x 3 = 115.5 days (FIRST) Solubility (water) 

### Source Product Chemistry MRID 451 190-19 MRID 45 1 190-20 MRID 45 1 190-22 no data Hydrolysist,, (pH 7) no data no data Aq. Photolysis t,,(pH 7) 38.5 days Aerobic Soil Metabolismt,,
use 2xaerobic soil metabolism t,, 115.5x 2 = 231 days (FIRST) Aerobic Aquatic Metabolismt,, no data
19mL/g (lowestnon sand) (FIRSTlGENEEC2) 19mL1g (lowest value) (SCI-GROW) 0.027*0.835*380.7/408.7= 0.021 1b ai/A 2 appl, 10-day interval, aerial application, no drift (FIRST & SCI-GROW) Application rate per label: 0.027 lb ai/A, 2 app, 10-day interval max 83.5% of applied formedMW = 380.7 Label information

PCA value no data default = 87% (FIRST) EFED Policy

Solubility (water) no data assume solubility of parent: 

# I 4.1 mg/L (FIRST) 

### 3-3153-1-OH

Product Chemistry Source Parameter

Hydrolysist,, (pH 7) Aq. Photolysis t,, (pH 7) Range

Aerobic Soil Metabolism t,, Aerobic Aquatic Metabolismt,, KO,

0.027*0.141*336.7/408.7= 0.003 lb ai/A 2 appl, 10-day interval, aerial application, no drift (FIRST & SCI-GROW) default = 87% (FIRST) Value Used in Model

no data no data

Application rate per label: 0.027 lb ai/A, 2 app, 10-day interval Label information 7.1 days no data 149, 159,203, and 2 16mL/g

max 14.1% ofapplied formedMW = 336.7 assume stable 

### - 0 day (FIRST)
assume stable 

### - 0 day (FIRST)

EFED Policy MRID 451 190-19 MRID 45 1 190-20 7.1 x 3 = 21.3 days (FIRST)
use 2xaerobic soil metabolism t,, 21.3 x2=42.6 days (FIRST) 149 mL/g (lowestnon sand) (FIRSTlGENEEC2) 149 mL/g (lowest value) (SCI-GROW)

PCA value for sugarcane MRID 45 1190-22

MRID 451 191-01

no dataParameter Solubility (water) Hydrolysis t,, (pH 7) Aq. Photolysist,, (pH 7) Aerobic Soil Metabolismt,, 

# 1 210,226,249, 

# 1 2 10 mL/g (lowest non sand) (FIRST) and 284 mL/g 238 mC/g (median value) (SCI-GROW) Range no data
no data no data
Aerobic Aquatic Metabolismt,, 47.6 days



# I PCA value for sugarcane 

# I no data 

# I default = 87% (FIRST) 

# I EFED policy 

# I Value Used in Model assume solubility of parent:

4.1 mg/L (FIRST)
assume stable 

### - 0 day (FIRST)
assume stable 

### - 0 day (FIRST)

no data

-- -- Application rate per label: 0.027 lb aiIA, 2 app, 10-day interval
As note above, the DWECs reported for the degradates have high degree of uncertainty and should be considered for screening purpose only. Among the assumptionsused for estimating the DWECs for the degradates are: 1. Single applicationrate of each degradate was adjusted from the proposed rate listed in

Table 4 proportionally to their maximum detected concentration relative to the total amount applied and to their molecular weight. 

### 2. Although aerial application was simulated, no drift was assumed for the degradates as they were formed in soils, after application. This assumptiongives lower surface water values, however non significant, since the application rates are low. 3. No solubility data exist for the degradates and their solubility was assumed equal to the parent's. No major impact on the data is expected, as these Tier 1 screening models are not very sensitiveto the change in solubility data. 

### 4. No hydrolysis or photolysis data were received for the degradates. Although their

chemical formulae indicate higher susceptibility to hydrolysis and photolysis than parent,

stability was assumed for all of the modeled degradates, according to the current EFED policies. This assumption would not impact the peak (acute) surface water concentrations, however does result in higher annual average (chronic) values. 5. Insufficient data were submitted for S-3153-1-OCH3-5'-CH,OH to estimate its DWECs.

Although a major degradate in the aerobic soil metabolism study (maximum 13.9% of applied), this degradate was only found in the top soil layer of one out of three field studies

at the analytical method detection limit level. Therefore EFED expects the risk of this degradate to the drinking water resources to be negligible compared to that of the parent and the other three degradates. Despite alltheseuncertainties, EFED is confidentthat thereported DWECs provide an upper bound estimate ofpotential contamination offlufenpyr ethyl degradatesin surfaceand ground water. Source Product Chemistry L MRID 451 190-19 MRID 45 1 190-20 47.6 x 3 = 142.8 days (FIRST)
use 2xaerobic soil metabolism t,, 142.8 x 2 = 285.6 days (FIRST) MRID 45 1 190-22

max 53.2% ofapplied formedMW = 350.7 0.027*0.532*350.7/408.7= 0.012 lb ai/A 2 appl, 10-day interval, aerial application, no drift (FIRST & SCI-GROW) Label information

### Appendix 1. 

### FIRST ( 

### FQPA Index Reservoir Screening xool) Model. 

### BackgroundIn formation on 

### FIRST: FIRST is a screening tool designedto estimatethe pesticide concentrationsfound in surface water for use in drinking water assessments. It provides high-end values of the concentrationsthat might be found in a small drinking water reservoir due to the use of pesticide. FIRST is a singleevent model (one run-off event), but can account for spray drift from multiple applications. The FIRST scenario includes a 427-acre field immediately adjacent to a 130-acre reservoir, 

### 9 feet deep, with continuous flow (two turnovers per year). The reservoir receives off-target spray drift event from each application plus one runoff event. The runoff event moves a maximum of 

### 8% of the applied pesticide into the reservoir. This amount can be reduced due to degradation on the field and the effect of binding to soil. Spray drift is equal to 6.4% of the applied concentration &om ground spray application and 16% for aerial applications. FIRST also makes adjustmentsfor the percent cropped area (PCA). While FIRST assumes that the entirewatershed would not be treated, the use ofa PCA default value of 0.87, is still a screen because it represents the highest percentage of crop cover of any large watershed in the United States, and it assumesthat the entire crop isbeing treated. Various other conservative assumptions of FIRST include the use of a small drinking water reservoir surrounded by a runoff-prone watershed, the use of the maximum use rate, no buffer zone, and a single large rainfall.

First Output for Flufenpyr ethyl on Sugarcane - 

### * INPUT VALUES 

### * RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE %CROPPED INCORP ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) AREA (IN)

FIELD AND RESERVOIR HALFLIFE VALUES (DAYS)



### .................................................................................................................................... METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAINIRUNOFF (RESERVOIR) (RES.-EFF) (RESER.) (RESER.)

UNTREATED WATER CONC (NANOGRAMSLITER (PPTr)) Ver 1.0AUG 1,200I PEAK DAY (ACUTE) ANNUAL AVERAGE (CHRONIC)

CONCENTRATION CONCENTRATIONFirst Output for Flufenpyr ethyl on Soybean 

### - * INPUT VALUES 

### *

....................................................................................................................................

RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE %CROPPED INCORP ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) AREA (IN)



### .................................................................................................................................... .027( .027) 2 10 415.0 4.1 AERIAL(16.0) 41.0 .O FIELD AND RESERVOIR HALFLIFE VALUES (DAYS) METABOLIC DAYSUNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAIN/RUNOFF (RESERVOIR) (RES.-EFF) (RESER.) (RESER.)

UNTREATED WATER CONC (NANOGRAMSLITER (PPTr)) Ver 1.0 AUG 1,2001 PEAK DAY (ACUTE) ANNUAL AVERAGE (CHRONIC)

CONCENTRATION CONCENTRATION

First Output for Flufenpyr ethyl on Field Corn

## - * INPUT VALUES 

### *

RATE (WAC) No.APPS & SOIL SOLUBIL APPL TYPE %CROPPED INCORP ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) AREA (IN)

FIELD AND RESERVOIR HALFLIFE VALUES (DAYS)

.................................................................................................................................... METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAINRUNOFF (RESERVOIR) (RES.-EFF) (RESER.) (RESER.) .15 2 8.50 4.90- 607.60 .OO 8.38
UNTREATED WATER CONC (NANOGRAMSLITER (PPTr)) Ver 1.0 AUG 1,2001 PEAK DAY (ACUTE) ANNUAL AVERAGE (CHRONIC)

CONCENTRATION CONCENTRATIONFirst Output for S-3153-Acid on Sugarcane 

### -* INPUT VALUES 

### * RATE (#lAC) No.APPS & SOIL SOLUBIL APPL TYPE %CROPPED INCORP ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) AREA (IN) .021( .041) 2 10 19.0 4.1 AERIAL( .O) 87.0 .O FIELD AND RESERVOIR HALFLIFE VALUES (DAYS) METABOLIC DAYSUNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) MINIRUNOFF (RESERVOIR) (RES.-EFF) (RESER.) (RESER.)

115.50 2 NIA .OO- .OO 23 1.OO 23 1 .OO UNTREATED WATER CONC (MICROGRAMSILITER (PPB)) Ver 1.0AUG 1,2001 PEAK DAY (ACUTE) ANNUAL AVERAGE (CHRONIC)

CONCENTRATION CONCENTRATION

First Output for S-3153-1-OH on Sugarcane 

### - * INPUT VALUES 

### *

.................................................................................................................................... RATE (WAC) No.APPS & SOIL SOLUBIL APPL TYPE %CROPPED INCORP ONE(MULT) INTERVAL Koc (PPM (%DRIFT) AREA (IN)

FIELD AND RESERVOIR HALFLIFE VALUES (DAYS)

.................................................................................................................................... METABOLIC DAYSUNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAINIRUNOFF (RESERVOIR) (RES.-EFF) (RESER.) (RESER.)



### ....................................................................................................................................

21.30 2 NIA .OO- .OO 42.60 42.60 UNTREATED WATER CONC (NANOGRAMSILITER (PPTr)) Ver 1.0AUG 1,2001

..................................................................................... PEAK DAY (ACUTE) ANNUAL AVERAGE (CHRONIC)

CONCENTRATION CONCENTRATIONFirst Output for S-3153--1-OCH, on Sugarcane - 

### * INPUT VALUES 

### * RATE (WAC) No.APPS & SOIL SOLUBIL APPL TYPE %CROPPED INCORP ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) AREA (IN)

.................................................................................................................................... .012( .023) 2 10 210.0 4.1 AERIAL( .O) 87.0 .O FIELD AND RESERVOIR HALFLIFE VALUES (DAYS) METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAINIRUNOFF (RESERVOIR) (RES.-EFF) (RESER.) (RESER.)

UNTREATED WATER CONC (MICROGRAMSILITER (PPB)) Ver 1.0AUG 1,2001 PEAK DAY (ACUTE) ANNUAL AVERAGE (CHRONIC)

CONCENTRATION CONCENTRATION

### Appendix 2. 

### SCI-GROW (

### Screening Concentration 

### in Ground~ater) Model. Background Information on SCI-GRO W: SCI-GROW is a regression-based, Tier 

### 1 screening model that provides a groundwater screeningexposurevalue to be used in determiningthepotential risk to human health from drinking water contaminatedwith pesticide. Sincethe SCI-GROW concentrations arelikelytobe approached in only a very small percentage of drinking water sources, i.e., highly vulnerable aquifers, it is not appropriate to use SCI-GROW for national or regional exposure estimates. SCI-GROW estimates likely groundwater concentrations if the pesticide is used at the maximum allowable rate in areaswhere groundwateris exceptionally vulnerable to contamination. In most cases, a large majority of the use area will have groundwater that is less vulnerable to contamination than the areas used to derive the SCI-GROW estimate.

SCI-GROWOutputforfIrcfenpyr ethyl 

### ** INPUT VALUES 

### **

.............................................................................................................................. APP RATE APPSI TOTAL1 SOIL AEROBIC SOIL METAB (LBSIAC) YEAR SEASON KOC HALFLIFE (DAYS)



### .............................................................................................................................. .027 2 .054 415.0 .05 GROUND-WATER SCREENING CONCENTRATION (IN UGL

### - PPB)

........................................................ .000000 

### ** See Note Below 

### ** VERSION 2.2: NOVEMBER 1,2001 -----------*-------------------------------------------- 

### ** Values below 0.006 ppb (6 ng/L) are beyond the scope ofthe regression data in SCI-GROW 2.2 and have not been verified. If concerns are raised by exposures of less than 0.006 ppb, a higher-tier ground-water exposure assessment should be considered,regardless of how low a screening concentration is returnedby SCI-GROW.

SCI-GRO W Outputfor S-3153-Acid 

### *

### * INPUT VALUES 

### **

................................................................................................................................ APP RATE APPSI TOTAL1 SOIL AEROBIC SOIL METAB (LBSIAC) YEAR SEASON KOC HALFLIFE (DAYS)



### ................................................................................................................................ .021 2 .042 19.0 38.50 GROUND-WATER SCREENING CONCENTRATION (IN UGL

### - PPB)



### ........................................................ ,035931 VERSION 2.2: NOVEMBER 1,2001



### ........................................................SCI-GROW Output for S-3153-1-OH 

### ** INPUT VALUES 

### ** APP RATE APPSI TOTAL1 SOIL AEROBIC SOIL METAB (LBSIAC) YEAR SEASON KOC HALFLIFE (DAYS)

GROUND-WATER SCREENING CONCENTRATION (IN UG/L - PPB) .000078 

### ** See Note Below 

### ** VERSION 2.2: NOVEMBER 1,2001



### ........................................................ 

### ** Values below 0.006 ppb (6 ng/L) are beyond the scope of the regression data in SCI-GROW 2.2 and have not been verified. If concerns are raised by exposures of less than 0.006 ppb, a higher-tier ground-water exposure assessment should be considered, regardless ofhow low a screening concentrationis returned by SCI-GROW.

SCI-GROW Output for S-3153-1-OCH, 

### ** INPUT VALUES 

### ** APP RATE APPSI TOTAL1 SOIL AEROBIC SOIL METAB (LBSIAC) YEAR SEASON KOC HALFLIFE (DAYS)

GROUND-WATER SCREENING CONCENTRATION (IN UGIL 

### - PPB)

........................................................ .005505 

### ** See Note Below 

### ** VERSION 2.2: NOVEMBER 1,2001



### ........................................................ 

### ** Values below 0.006 ppb (6 ngL) are beyond the scope of the regression data in SCI-GROW 2.2 and have not been verified. If concerns are raised by exposures of less than 0.006 ppb, a higher-tier ground-water exposure assessment should be considered, regardless of how low a screening concentrationis returned by SCI-GROW.Appendix 3. GENEECZ ( GENeric Estimated Environmental Concentration)Model. Background Information on 

### GENEEC: The GENEEC2 (GENeric Estimated Environmental Concentration) model, the tier one computer program, uses the soillwaterpartition coefficient and degradationkineticdata to estimate runofffrom a ten hectare field into a one hectare by two meter deep "standard" pond. This first tier is designed as a coarse screen and estimates conservative pesticide concentrations in surface water from a few basic chemical parameters and pesticide label use and application information. Tier 1 is used to screen chemicals to determine which ones potentially pose sufficient risk to warrant higher level modeling. GENEEC2 Output forflufenpyr ethyl on sugarcane withground application 

### - * INPUT VALUES 

### * RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE NO-SPRAY INCORP ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) (FT) (IN)

FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAINIRUNOFF (POND) (POND-EFF) (POND) (POND)

GENERIC EECs (IN NANOGRAMSLITER (PPTr)) Version 2.0 Aug 1,2001



### ...............................................................................................................

PEAK MAX4DAY MAX21DAY MAX60DAY MAX90DAY GEEC AVG GEEC AVG GEEC AVG GEEC AVG GEEC



### ................................................................................................................ 142.04 137.28 96.94 51.19 35.82 GENEEC2 Output forflufenpyr ethyl on sugarcane with aerial application 

### - * INPUT VALUES 

### * RATE (MAC) No.APPS & SOIL SOLUBIL APPL TYPE NO-SPRAY INCORP ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) (FT) .027( .027) 2 10 415.0 4.1 AERL-B(13.6) .O .O FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAINRUNOFF (POND) (POND-EFF) (POND) (POND)

GENERIC EECs (IN NANOGRAMSLITER (PPTr)) Version 2.0 Aug 1,2001
---------------------------------------------------------------------*-----------------------------------------

PEAK MAX 4 DAY MAX 21 DAY MAX 60 DAY MAX 90 DAY GEEC AVG GEEC AVG GEEC AVG GEEC AVG GEECGENEEC2 Output for S-3153-acid on sugarcane 

### * INPUT VALUES 

### *

.................................................................................................................................... RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE NO-SPRAY INCORP ONE(MSJLT) INTERVAL Koc (PPM) (%DRIFT) (FT) (IN)



### .................................................................................................................................... .021( .041) 2 10 19.0 4.1 AERIAL( .O) .O .O

FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAINIRUNOFF (POND) (POND-EFF) (POND) (POND)

GENERIC EECs (IN MICROGRAMSLITER (PPB)) Version 2.0 Aug 1,2001

...............................................................................................................

PEAK MAX 4 DAY MAX 21 DAY MAX 60 DAY MAX 90 DAY GEEC AVG GEEC AVG GEEC AVG GEEC AVG GEEC



### ................................................................................................................ 2.19 2.19 2.15 2.08 2.03
GENEEC2 Output for S-3153-1-OH on sugarcane 

### * INPUT VALUES 

### * RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE NO-SPRAY INCORP ONE(WLT) INTERVAL Koc (PPM ) (%DRIFT) (FT) (IN)

FIELD AND STANDARD POND HALFLIFE VALUES (DAYS)



### .......................................................................................................................................... METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED (FIELD) RAINRUNOFF (POND) (POND-EFF) (POND) (POND) 21.30 2 NIA .OO- .OO 42.60 42.60
GENERIC EECs (IN NANOGRAMSILITER (PPTr)) Version 2.0 Aug 1,2001

PEAK MAX 4 DAY MAX 21 DAY MAX 60 DAY MAX 90 DAY GEEC AVG GEEC AVG GEEC AVG GEEC AVG GEEC --------------------------------------------------------------------------------------------------------*-------

215.47 212.39 196.05 164.58 145.01Appendix 

### IV 

## - Ecological Effects Toxicity Studies Toxicity to Terrestrial Animals 

### I. Birds, Acute and Subacute dietary One acute oral toxicity study using the technical grade of the active ingredient (TGAI) is required to establish the toxicity of flufenpyr-ethylto birds. The preferred test species are the mallard duck (Anasplatyrhynchos)and/or bobwhite quail (Colinus virginianus). Since the 

### LD50 is greater than 2000 mg/kg (Table 

### I), flufenpyr-ethyl is categorized aspractically nontoxicto avian species on an acute exposurebasis. The guideline (71-1) is fulfilled (MRID 45 118815). Table 1. Acute Toxicitv of Flufen~vr-ethvl to Northern bobwhite. Avian Acute Oral Toxicity Species % ai Toxicity value Toxicity category MRID no. Study classification Northern bobwhite quail 97 LD50 22250' mglkg practically nontoxic 45118815 core1 (Colinus virginianus) 

### ' Core (study satisfies guideline). Supplemental (study is scientifically sound, but does not satisfy guideline)

no mortality reported Two subacute dietary toxicity studies using the TGAI are required to establish the toxicity of flufenpyr-ethyl to birds. The preferred test species are the mallard duck (Anasplatyrhynchos) and bobwhite quail (Colinus virginianus). Since the LC5Os are greater than 5000 ppm (Table 

### 2), flufenpyr-ethyl is categorized aspractically nontoxicto avian species on a subacute exposure basis. The guideline (71-2a,b) is fulfilled (MRID 451 18816 and 451 18817). Table 2. Subacute Dietary Toxicity of Flufenpyr-ethyl to Northern bobwhite and Mallard ducks.

Avian Subacute Dietary Toxicity Species % ai Toxicity value Toxicity category MRID no. Study Classification Northern bobwhite quail 97 LC50 >56201ppm practically nontoxic 45118817 core (Colinus virginianus) Mallard duck LC50 >56201 ppm practically nontoxic 45118816 core (Anasplatyrhynchos) 

### ' no mortality reported 

### 11. Birds, Reproductive Avian reproduction studies using the TGAI are required for flufenpyr-ethyl because multiple applicationsmay subjectbirds to repeated or continuous exposure during orpreceding the breeding season. The preferred test species are the mallard duck and northern bobwhite. Results indicate an NOAEC of 164ppm and an LOAEC of 

### 424 ppm, based on the 14D survivorlnormalhatchling and final weight of mallard ducks (Table 3). The guideline (7 1-4) is fulfilled (MRID 45 118818, -1

### 9).Table 3. Chronic Toxicity of Flufenpyr-ethyl to Bobwhite quail and Mallard ducks. Avian Reproduction Species % ai NOAEC (ppm) LOAEC Affected endpoints MRID no. Study classification
Northern bobwhite 97 1040 >1040 none 451188-19 core 

### ' Mallard 97 164 424 14D survivor/normal 451188-18 core 

### ' hatchling and female body weight 

### ' Core (study satisfies guideline). Supplemental (studyis scientifically sound, but does not satisfy guideline). Invalid (studyis scientifically unsound and does not satisfy guideline). 

### 111. Mammals, Acute and Reproductive Wild mammal testing is required on a case-by-case basis, depending on the results of lower tier laboratory mammalian studies,intended use pattern and pertinent environmental fatecharacteristics. In most cases, rat or mouse toxicity values obtained from the Agency's Health Effects Division (HED) substitute for wild mammal testing. Sincethe LD50 value exceeded 5,000 mgkg (Table 4), flufenpyr-ethyl is categorized as practically non-toxic to small mammals on an acute oral basis. Results from the 2-generation reproduction study indicate 

### an NOAEC of 1463 ppm (Table 

### 5) to small mammals on a chronic exposurebasis. Table 4. Acute Toxicity of Flufenpyr-ethyl to Mammals.

Mammalian Acute Oral Toxicity Species % ai Test type Toxicity value MRU> no. Laboratory rat 57 6 acute oral LD50 r5000 m&g 45118902
Table 5. Chronic Toxicity of Flufenpyr-ethyl to Mammals.

Mammalian Reproduction Species % ai Test type Toxicitv value MRID no. Laboratory rat 57.6 2-generation NOAEC= 1463ppm 45 1 190-01 & -02 reproduction LOAEC =Not Identified
IV. Beneficial Insects A honey bee (Apis 

### mellfera) acute contact study using the TGAI is required for flufenpyr-ethyl, because its use may result in honey bee exposure. Since the LD50 is greater than 25 ughee (Table 6), flufenpyr-ethyl is practically non-toxic to bees on an acute contact basis. The guideline (141-1) is fulfilled (MRID No. 45 119018).Table 6.Acute Contact Toxicity of Flufenpyr-ethylto Honeybees. Nontarget Insect Acute Contact Toxicity Species % ai LD50 Toxicity category MRID no. Study classification Honey bee tech >25 pglbee' practically nontoxic 45119018 core

I 33% mortality in some treatment levels were reported Toxicity to Freshwater Aquatic Organisms V. Freshwater Fish, Acute Two freshwater fish toxicity studies using the TGAI are required to establish the toxicity of flufenpyr-ethyl to fish. The preferred test species are rainbow trout (a coldwater fish) and bluegill sunfish (a warmwater fish). Since the LC5Os fall within the range between 1 

### - 10mg/L (Table 7), flufenpyr-ethyl is categorized asmoderatelytoxicto freshwaterfish on an acute exposure basis. The guideline (72-1) is fulfilled 

### (MRID 45 1 188-21 and 45 1 188-20). Table 7. Acute Toxicity of Flufenpyr-ethyl to Freshwater Fish.

Freshwater Fish Acute Toxicity Species % ai LC50 Toxicity category MRID no. Study classification Rainbow trout 96.8 3.75 mg/L moderatelytoxic 451188-21 core Bluegill sunfish 97 2.537 mg/L moderatelytoxic 451 188-20 core



### VI. Freshwater Fish, Chronic A freshwater fish early life-stagetest using the TGAIisrequired for flufenpyr-ethyl becausethe enduse product may be applied directlyto water or could be transported to water from the intended use site, and the following conditionsare 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) any aquatic acute LC50 or EC50 is less than 1 mg/L, 

### (3) the EEC in water is equal to or greater than 0.01 of any acute LC50 or EC50 value, or, (4) the actual or estimated environmental concentration in water resulting from use is less than 0.0 1of any acute LC50 or EC50 value and any one of the followingconditions exist: studies of other organisms indicate the reproductive physiology of fish may be affected, physicochemical properties indicate cumulative effects, or the pesticide is persistent in water (i.e., half-lifegreaterthan 4 days). Thepreferred test species is rainbow trout. Resultsfromthe early lifestage study indicate adverse growth effects at 0.44 

### - 0.92 mg/L (Table 8) on a chronic exposure basis. The guideline (72-4) is fulfilled. 

### (MRID 451 188-27).Table 8. Chronic Toxicity of Flufenpyr-ethylto Freshwater Fish. Freshwater Fish Early Life-Stage Toxicity Under Flow-through Conditions. Species % ai NOAEC LOAEC Affected Endpoints MRID No. Study Classification Rainbow trout 96.8 0.44 mg/L 0.92 mg/L growth 451 188-27 supplemental' test concentrations were below detectable limits for approximately 20 hours on Day 22-23.
VII. Freshwater Invertebrate, Acute A freshwater aquatic invertebrate toxicity test using the TGAI is required to establish the toxicity of flufenpyr-ethyl to aquatic invertebrates. The preferred test species is Daphnia magna. Since the EC50 is >3 m@ (Table 

### 9), the value is greater than the maximum water solubility of flufenpyrethyl. Thus, the toxicity of flufenpyr-ethyl to freshwater invertebrates could not be characterized on an acute exposure basis. The guideline (72-2) is fulfilled (MRID 45 1 188-23). Table 9. Acute Toxicity of Flufenpyr-ethylto Freshwater Invertebrates.

Freshwater Invertebrate Acute Toxicity Under Flow-through Conditions Species % ai EC50 Toxicity category MRIDNo. Study Classification Water flea 96.8 >3 mg!L nla 45 1 18823 supplemental' 

### ' environmental test conditions were higher than the guideline recommendations.
VIII. Freshwater Invertebrates, Chronic A freshwater aquatic invertebratelife-cycletest using the TGAI is required because flufenpyr-ethyl could be transported to water from the intended use sites. The preferred test species is Daphnia magna. Results from the life cycle study indicate adverse reproduction effects at 0.46 

### - 1.2 mg/L (Table 

### 10). The guideline (72-4) is fulfilled (MRID 45 1188-26). Table 10. Chronic Toxicity of Flufenpyr-ethyl to Freshwater Invertebrates.

Freshwater Invertebrate Life-Cycle Toxicity Under Flow-through Conditions Species %ai NOAEC LOAEC Affected endpoints MRID no. Study classification Water flea 96.8 0.46 mg/L 1.2mg/L reproduction 45 1 18826 core Toxicity to EstuarineNarineAquatic Organisms IX. EstuarineMarine Fish, Acute Acute toxicity testing with estuarinelmarine fish is required for flufenpyr-ethyl since the end-use product may be applied directly to water, could be transported to water from the intended use site or the herbicide is persistent in water (i.e., half-life greater than 4 days) and may contaminate the estuarinelmarine environment.The preferred test species are the sheepshead minnow (Cyprinodonvariegatus) or the Silverside (Menidia sp.). Since the ~650 value is greater than 2.7 mg/L (Table ll),the value is greater than the maximum water solubility of flufenpyr-ethyl.Thus, the toxicity of flufenpyr-ethylto estuarinelrnarine fish could not be characterized on an acute exposurebasis. The guideline (72-3a) is fulfilled (MRID 451 188-22). Table 11.Acute Toxicity of Flufenpyr-ethylto EstuarineIMarineFish

EstuarineMarine Fish Acute Toxicity Under Flow-through Condition Species % ai LC50 Toxicity category MRID no. Study classification Sheepshead minnow 97 >2.7 mgiL n/a 451 188-22 core


### X. EstuarineIMarine Invertebrates, Acute Acute toxicity testing with estuarinelmarine invertebrates is required for since the end-use product may be applied directly to water or could be transported to water from the intended use site or the herbicide is persistent in water (i.e., half-life greater than 4 days) and may contaminate the estuarinelmarine environment. The preferred test species are the mysid shrimp (Mysidopsis bahia) and Eastern oyster (Crassostrea virginica). Since the EC5Os fall within the range of 1 

### - 10mgL (Table 12), flufenpyr-ethyl is categorized as moderately toxic to estuarinelmarine invertebrates on an acute exposure basis. The guideline (72-3b and c) are fulfilled (MRID 451 188-24 and 45 1188- 25). Table 12.Acute Toxicity of Flufenpyr-ethyl to EstuarineIMarine Invertebrates

EstuarineMarine InvertebrateAcute Toxicity Under Flow-through Conditions Species % ai EC50 Toxicity category MRID no. Study Classification Mysid shrimp 97 2.08 mgiL moderately toxic 45 1188-25 core Eastern oyster (shell deposition) 97 >2 mg/L nla 45 11 88-24 core



### XI. EstuarineIMarine Fish and Invertebrates, Chronic Estuarinelmarine chronic testing using the TGAI is not required because chronic exposure to flufenpyr-ethyl is not expected. Toxicity to Terrestrial and Aquatic Plants 

### XII. Terrestrial Plants Terrestrial plant testing (seedling emergence and vegetative vigor) is a standard requirement only for herbicides that have terrestrial non-residential outdoor use patterns and that may move off the application site through drift (aerial) andlor that may have endangered or threatened plant species associated with the application site. For seedling emergence and vegetative vigor testing thefollowingplant species and groups should be tested: (1) six species of at least four dicotyledonous families, one species of which is soybean (Glycine max) and the second is a root crop, and (2) four species of at least two monocotyledonous families, one of which is corn 

### (Zeamays). Normally, tier I testing with the herbicide is conducted at thehighest use rate onthe label.Then, Tier I1 testing is required if any species in tier I is inhibited 25% or more. In this case, the registrant conceded a 25% inhibitionand proceeded directly to tier I1 seedling emergence and vegetative vigor studies instead of tier I studies. Based on an application rate of 0.029 lb ai/A, lettuce (0.012 lb/A) is the most sensitivedicot while onion (0.018 lb/A) is the most sensitive monocot (Table 13) in the seedling emergence tier 

### I1 toxicity test. The guideline (123-la) is fulfilled (MRID 

### 45 1190-1 

### 6) for the seedling emergencetest. Thetier I1 seedling emergencetoxicity test measuresthe response ofplants, relativeto a control, and five or more test concentrations of a pesticide. This simulates the response of non-target plants subjectedto runoff from adjacenttreated areas. Results oftier I1toxicity testingonthe TEP material are tabulated below. Table 13. Toxicity of Flufenpyr-ethyl To Terrestrial Plantsusing Tier I1 SeedlingEmergence.

Nontarget Terrestrial Plant Seedling Emergence Toxicity (Tier 11) Species % ai EC25 (Ibs ai/A) NOAEC Endpoint Affected1 MRID No. Study Classification
50.0 451190-16 Monocot- Corn >0.029 0.029 none core Monocot- Oat >0.029 0.029 none core Monocot- Onion 0.018 0.0097 weight core Monocot- Ryegrass >0.029 0.029 none core Dicot-Soybean >0.029 0.029 none core Dicot- Lettuce Dicot- Radish Dicot-Cucumber Dicot- Cabbage 0.012 0.0097 weight 0.016 0.0032 weight >0.029 0.029 none 0.016 0.0097 weight core
core
core
core Dicot- Tomato >0.029 0.029 none core 

### 'only the most sensitive endpoint is tabulated Tier I1 vegetative vigor studiesindicate that at an application rate of 0.029 lb ai/A,tomato (0.00009 1bIA)isthe most sensitivedicotwhile onion (0.0056lb/A)is the most sensitivemonocot (Table 14). The guideline (123- 1 b) is fulfilled (MRID 

### 45 1190-17)for the vegetative vigor test. The vegetative vigor toxicity test measures the response of plants, relative to a control, and five or more test concentrations that simulate the effects of drift to non-target plants in adjacent areas. Results of Tier I1 toxicity testing on the TEP material are tabulated below.Table 14. Toxicity of Flufenpyr-ethyl To Terrestrial Plants using Tier I1 Vegetative Vigor. Nontarget TerrestrialPlant Vegetative Vigor Toxicity (Tier 11) Species % ai EC25 (Ibs ai/A) NOAEC Endpoint Affected1 MRID No. Study Classification

Monocot- Corn Monocot- Oat Monocot- Onion Monocot- Ryegrass Dicot-Soybean Dicot- Lettuce Dicot- Radish Dicot-Cucumber Dicot- Cabbage none
none height
none
none weight weight weight weight core
core
core
core
core
core
core
core
core Dicot- Tomato 0.00009 0.00004 weight core 'only the most sensitive endpoint is tabulated 

### XIV. 

### Toxicity to Aquatic Plants Aquatic plant testing is required for any herbicide that has outdoor non-residential terrestrial uses and that may move off-site by runoff (solubility >10 ppm in water), and/or by drift (aerial) or that is applied directly to aquatic use sites (except residential). Normally, tier I testing with the TGAI is conducted on duckweed (Lemna gibba), a vascular species, and a green algae (Skeletonema costatum), anonvascular species. Then,tierI1testing isrequired if either speciesin Tier I is inhibited 50% ormore, and also includesSelenastrumcapricornutum, Anabaenaflos-aquae, and a freshwater diatom. In this case, the registrant chose to conduct Tier I1 testing even though it may not have been triggered. Results of Tier I1 toxicity testing with the vascular aquatic plant, duckweed, and the most sensitivenon-vascular aquaticplant, the EC5Os were 0.0 12and 0.009mg/L respectively 

### (Table 15). The guideline (1 23-2) is fulfilled with all five species tested 

### (MRID 45 1 1 90- 1 1,

### - 12, 

### - 1 3, 

### - 14, - 1 5). Table 15. Toxicity of Flufenpyr-ethylto Aquatic Plants using Tier 11. Nontarget Aquatic Plant Toxicity (Tier 11)

Species % ai EC50 NOAEC MRID no. Study classification Vascular species:

Duckweed 99.1 0.013mg/L1 0 003 m&' 451190-11 core Nonvascular species:

AnabaenaJlos-aquae 99.1 >0.5 mg/L1 0.031 rng/L1 451 190-14 core Skeletonema costatum 97 0.012 mg/L 0.00081 mg/L 451 190-12 core Selenastrum capricornutum 99.1 0.009 mg/L1 <0.0063 rng/L1.' 451 190-15 core Naviculapelliculosa 97 0.16 mg/L 0.032 mg/L 451190-13 core 

### ' nominal concentrationthe NOAEC is below the lowest tested concentration


### Additional duckweed toxicity studies were also submitted by the registrant on flufenpyr-ethyl's degradates, S-3 153-acid and S-3 153-4-OH. Results 

### of Tier 

### I1 toxicity testing indicate the EC5Os were 0.0063 and B0.03 mg ae/L, respectively (Table 

### 16) The studies were determined to be core 

### (MRID 452423-03, -04). Table 16. Toxicity of Degradates to Duckweed.

Nontarget Aquatic Plant Toxicity (Tier 11) Species % ai Degradation EC50 (mg a.e./L) NOAEC MRID no. Study classification Identification Duckweed 98.7 S-3153 acid 0.0063 0.003 452423-04 core Duckweed 97.5 S-3 153-4-OH >0.03 0.03 452423-03 coreAppendix V: Ecological Risk Assessment of Flufenpyr-ethyl A means ofintegratingthe results ofexposure and ecotoxicitydata is calledthe quotientmethod. For this method, risk quotients (RQs) are calculated by dividing exposure estimates by ecotoxicity values, both acute and chronic.

RQs are then compared to OPP's levels of concern (LOCs). These LOCs are criteria used by OPP to indicate potential risk to nontarget organisms and the need to consider regulatory action. The criteria indicate that a pesticide used as directed has the potential to cause adverse effects on nontarget organisms.LOCs currently address the following risk presumptioncategories: (1) acute 

### - potential for acute risk is high, regulatory action may be warranted in addition to restricted use classification, (2) acuterestricted use 

### - thepotential for acuterisk ishigh, but this may be mitigated through restricted use classification, (3) acute endangered species 

### - the potential for acute risk to endangered species is high, regulatory action may be warranted, and (4) chronic risk 

### - the potential for chronic risk is high, regulatory action may be warranted. Currently, EFED does not perform assessment for chronicrisk to plants, acute or chronicrisks to nontarget insects,or chronic risk from granularhait formulations to mammalian or avian species. The ecotoxicitytest values (i.e., measurement endpoints) used in the acute and chronicrisk quotients are derived from the results of required studies. Example of ecotoxicity values derived from the results of short-term laboratory studies that assess acute effects are: 

### (1) LC,, (fish and birds), (2) LD50 (birds and mammals), (3) EC50 (aquatic plants and aquatic invertebrates), and (4) EC25 (terrestrial plants). Examples of toxicity test effect levels derived from the results of long-term laboratory studiesthat assess chroniceffects are: (1) LOAEC (birds, fish, and aquaticinvertebrates) and (2) NOAEC (birds, fish and aquatic invertebrates). For birds, mammals, and all aquatic organisms,theNOAEC is the ecotoxicitytestvalue used in assessing chronicrisk. Other values may be used when justified. Risk presumptions, along with the corresponding RQs and LOCs are summarized in Tables 1 through 3.
Table 1. Risk presumptions for terrestrial animals (birds and wild mammals) Risk Presumption RQ LOC Acute Risk EEC1/LC,, or LD,,/ft2 or LD,dday3 0.5 Acute Restricted Use EEC/LC,, or LD,dftZ or LD,,/day (or LD,, < 50 mgikg) 0.2

, Acute Endangered Species EECILC,, or LD,dft2or LD,,/day 0.1

Chronic Risk EEC/NOAEC 1 

### ' abbreviation for Estimated Environmental Concentration (ppm) on avian/mammalianfood items

mg/P me of toxicant consumed/day LD,, * wt. of bird LD,, * wt. of birdTable 2. Risk presumptionsfor aquatic animals Risk Presumption RQ LOC Acute Risk EEC1/LC5, or EC,, 0.5 Acute Restricted Use EECILC,, or EC,, 0.1 Acute Endangered Species EECILC,, or EC,, 0.05 Chronic Risk EECINOAEC 1 

### ' EEC = (ppm or ppb) in water Table 3. Risk presumptions for plants Risk Presumption RQ LOC Terrestrial and Semi-Aquatic Plants Acute Risk EEC1/EC2, 1 Acute Endangered Species EECEC,, or NOAEC 1 Aquatic Plants Acute Risk EEC2/EC5, 1 Acute Endangered Species EECEC,, or NOAEC 1 I EEC = lbs ai/A

EEC = (ppb or ppm) in water Exposure and Risk to Nontarget Terrestrial Animals For pesticides applied as a nongranular product (e.g., liquid and dust), the estimated environmental concentrations (EECs) on food items followingproduct application are compared to LC,, values to assess risk. The ELL-FATE model predicted 0-day maximum residues of a pesticide that may be expected to occur on selected avian or mammalian food items immediately following two applications at 0.027 lb ailA of flufenpyr-ethyl at 10-day intervals is presented in Table 4.
Table 4. Estimated environmental concentrations on avian and mammalian food items (ppm) following2 applications at0.027 Ib ai/A.

-- -

Application Rate Food Items EEC (PP~) Predicted Maximum Residue1 0.027 Ib a.i./A Short grass Tall grass Broadleavforage plants and small insects Fruits, pods, seeds, and large insects 0.74 I ELL-FATE predicted maximum residues and adjusted based on Hoerger and Kenaga (1972) as modified by Fletcheret al. (1994). Predicted residues (EECs) resulting fiom 2 applications are calculated using the first order linear regression model. Uncertainties in the terrestrial EECs are primarily associated with a lack of data oninterception and subsequentdissipationfiom foliar surfaces.EFED assumes the foliar dissipation rate is based on a number ofroutes which include photolysis, hydrolysis and volatilization.It could also include uptake in plants as well as wash off ifthose datawere available. When data are absent, as in this case,EFED assumes a 35-day foliar dissipationhalf life for chemicals that are not volatileand which are stable to photolysis and hydrolysis. This 35-day half-life assumption is based on the work of Willis and McDowell(1987). I. Birds Acute Since flufenpyr-ethyl is classified as practically nontoxic to birds (LD,, >2150 mg/kg, LC,, >5620 pprn). Acute risks to bird arepresumed to be negligible (Table 

### 5) from any of theproposed newuses (soybean, sugarcane, and field corn). The acute risk quotients for single broadcast applications of non-granular products are tabulated below.
Table 5. Avian Acute Risk Quotients for Two Application of Nongranular (broadcast) based on a Bobwhite quail LC,, of 25000 ppm. SiteIApp.Method App FOO~ ltems Maximum Toxicity Value Acute RQ (Ibs ai/A EEC (ppm) LC,, (ppm) (EECLC,,) 0.027 Short grass 11.80 >5000 n/a sugarcane (aerial) Tall grass 5.41 >5000 n/a Broadleaf 6.64 plants / Insects >5000

" exceeds acute high, acute restricted and acute endangered species LOCs.

exceeds acute restricted and acute endangered species LOCs. exceeds acute endangered species LOCs exceeds chronic LOC nla - when information is not available or when a greater than toxicity value which minimal risk (RQ <0.01) is presumed for the species. No acute LOCs are exceeded, even assuming no degradation between applications, the maximum EEC on short grass would not be expected to exceed 11.8pprn from 2 applications of 0.027 lb ai/A at 10-dayintervals for birds. Chronic Chronic risks were evaluated using maximum estimated environmental concentrationsbased on a Mallard duck NOAEC of 164pprn (Table

### 6).Even assuming no degradation between applications, chronicrisk to bird is believed to be negligible. The chronicrisk quotient for abroadcast application of non-granular products are tabulated below. Table 6. Avian Chronic Risk Quotients for Two Application (maximum residue) of Flufenpyr-ethyl (broadcast) based on a Mallard duck NOAEC of 164 ppm. SiteIApp. App. Rate Maximum Food Items Toxicity value Method (Ibs ai1A) EEC (ppm) (NOAEC) Chronic RQ Short grass sugarcane 0.027 (aerial) Tall grass Broadleaf plants I Insects 6.64 164 0.04The results indicate that for a broadcast application of flufenpyr-ethyl, there are no chronic LOC exceedancesfor birds. 11. Mammals Acute Estimating the potential for adverse effects to wild mammals is based upon EFED' s draft 1995SOP of mammalian risk assessments and methods used by Hoerger and Kenaga (1972) as modified by Fletcher et 

### al. (1 994). The concentration of flufenpyr-ethylin the diet that is expected to be acutely lethal to 50% of the test population (LC,,) is determined by dividing the LD,, value (usually rat 

### LD,,) by thepercent body weight consumed.A risk quotient is then determinedby dividing the EEC by the derived LC,, value. Risk quotients are calculated for three separate weight classes of mammals (15, 35, and 1000 g), each presumed to consume four different kinds of food (grass, forage, insects, and seeds). The acute risk quotients for broadcast application of non-granular products are tabulated below.

Table 7: Mammalian Acute Risk Quotients for Multiple Applications of Nongranular Products (Broadcast) Based on a Rat LD,, of >5000 mglkg. Site1App. Meth.1 Body Weight (g) % Body Weight Rat LD,, Maximum Residue (ppm) Acute RQ Rate in Ibs ai/A Consumed (mgfkg) on short grass (No. of Apps.) sugarcane I aerial 1 15 95 0.027 (2) 35 66

n/a - when information is not available or when a greater than toxicity value which minimal risk (RQ <0.01) is presumed for the species. Since flufenpyr-ethyl is classified as practically nontoxic to mammals (LD50 >5,000 mglkg), the acute risk to mammals is believed to be negligible. Chronic The chronic risk quotients for single (Table 

### 8) broadcast application of non-granular products to mammals are tabulated below.

Table 8: Mammalian Chronic Risk Quotients for Two Applications of Nongranular Products (Broadcast) Based on a laboratory rat NOAEC of 1463 ppm in a 2-Generation Reproduction Study. SiteIApplication Appl. Rate Food Items Maximum EEC (ppm) NOAEC (ppm) Chronic RQ Method (No. Apps.) (EECNOAEC) sugarcane 0.027 Ib ai./A Short Grass (aerial) (2) Tall grass Broadleaf plantsAnsectsThe results indicatethat fortwo applications ofnongranular products at theproposed label rate, there are no LOC exceedances for mammals.
111. Insects Currently, EFED doesnot assess riskto nontarget insects. However,toxicityresults forthe honeybee are used only for recommending appropriate label precautions. Flufenpyr-ethyl is practically non toxic to honeybees (LD,, >25 pglbee) on an acute contact basis, precautionary labeling is not required.

IV. Terrestrial Plants Risks to terrestrial plants inhabiting dry and semi-aquatic areas are determinedbased on the amount ofpesticides present onthe soil surface due to runoff, spray drift, or volatilization.EFED's scenario for runoff fi-om one treated acre to an adjacent area (sheet runoff) and 10 treated acres to a distant low-lying area (channelized runoff) is based on: 1) solubilityand the amount ofpesticide present on the soil surface and its top one inch and 2) the percent of runoff values of 0.01,0.02, and 0.05 for water solubility of40 ppm, 1 0- 100 ppm, and 

### >100ppm, respectively. Since the water solubility is 40 ppm for flufenpyr-ethyl, the runoff value of 1% will be used for calculation. Formulas for determining EECs for terrestrialplants as a result ofrunoffand spraydrift are presented in Appendix 

### IV. Spraydrift exposurefrom ground application is assumedto be 1 %ofthe application rate. Spraydrift from aerial, airblast,forced-air, and chemigation applications is assumedto be 

### 5% ofthe application rate. EECs are calculated for the following application methods: (1) unincorporated ground applications and (2) aerial, airblast, forced-air, and chemigation applications. In addition to considering where plants grow, exposure must be estimated to compare with results fromtwo kinds of plant tests 

### - a seedling emergence study (Table 

### 9) and a vegetative vigor study (Table 

### 10). Seedling emergence studies involve treating the soil in which seedlings grow, thus exposing the growing plant to the pesticide. The vegetative vigor study involves exposing only the foliage of actively growing plants off-siteto spray drift. Both runoff and spray drift are assumed to reach offsite soil. No method is currently available for estimating chronic exposuresto terrestrial plants.Table 9. Runoff Risk Quotients from a Single Application for Non-Endangered Terrestrial Plants Based On a Lettuce Seedling Emergence EC25 of 0.012 Ib ai/A and for Endangered Terrestrial Plants Based On a Lettuce Seedling Emergence NOAEC of 0.0097 Ib ai/A. Total Loading (Ib ai/A) Non-Endangered RQ Endangered RQ Site A Application Drift (Total LoadindEC25) Total LoadindNOAEC) Rate (Ib ai/A) (Ibs ai/A) Adjacent Semi-aquatic Dry Semi-aquatic Dry Area Semi-aquatic Dw Area1 Area2 Area Area area unincorp. 0.027 0.0003 0.0005 0.003 0.03 0.17 0.06 0.3 1 ground aerial 0.027 0.0014 0.0015 0.003 0.08 0.17 0.16 0.31

A includes all uses except field corn

Sheet Runoff + Drift 

### 'Channelized Runoff+ Drift 'exceeds the LOC (RQFl) for non-endangered terrestrial plants " exceeds the LOC (RQk 1)for endangered terrestrial plants Based on results of the seedling emergence study tested up to 0.029 lb ai per acre tested, risks to terrestrialnon-targetplantsfiomrunoff areexpectedto be minimal. For aerial or ground application, the non-endangered and endangered species LOCs are not exceeded (RQ 

### <1) for pre-emerged terrestrial plants in dry and semi-aquatic areas at the registered maximum single application rate of 0.027 lb ai per acre. Drift risk quotients for endangered and non-endangered terrestrial plants inhabiting dry and semi-aquatic areas are presented in the following table.

Table 10. Drift Risk Quotients from a Single Application for Non-Endangered Terrestrial Plants Based On a Tomato Vegetative Vigor EC25 of 0.00009 lb ai/A and for Endangered Terrestrial Plants Based On a Tomato Vegetative Vigor NOAEC of 0.00004 lb ai/A. Non-Endan~eredRQ SiteA Appl. Rate Drift EEC (Total LoadingEC25) (single appl.) (Ib ai/A) Drift Endangered RQ Total LoadinpJNOAEC) Drift unincorporated 0.027 0.0003 ground aerial 0.027 0.0014 15* 34**

A includes all uses except field corn 

### ' Sheet Runoff + Drift Channelized Runoff+ Drift 'exceeds the LOC (RQ1)for non-endangered terrestrial plants " exceeds the LOC (RQ> 1) for endangered terrestrial plants Based on the vegetative vigor study, exposure from drift to nontarget plants is expected. With a toxicity value of 0.00009 lb ai/A for non-endangered plants and 0.00004 lb ai/A for endangered plants, the drift LOCs are exceeded with a RO range of 3 to 7 for ground applications and a RO range of 15to 34 for aerial applications when terrestrial plants in offsite areas are exposed to flufenpyr-ethyl. However, the LOCs are exceeded based on a single application, EFED assumes a greater adverse effect to terrestrial plants with multiple applications.Exposure and Risk to Nontarget Aquatic Organisms The Tier 

### I EEC values for estimating acute risk are the maximum (peak) values calculated for flufenpyr-ethyl applied to field corn, sugarcane and soybean using GENEEC2 (GENeric Expected Environmental Concentration model, Version 2; details in Appendix 111). For chronic risk, 60-day EECs are used for fish and 21-day EECs are used for invertebrates. EFED believes that the proposed use and method of application (aerial), because of their proximity to aquaticenvironments,mayresultinthe direct application offlufenpyr-ethylto aquaticenvironments. For this use pattern, EFED assumes simple dilutionofthe amount applied to a surface acre of water at depths varying from 

### 6 inches to 

### 6 feet. V. Freshwater Fish Acute Acute risk quotientsfor multiplebroadcast applications offlufenpyr-ethylto freshwaterfish (Table 

### 11) are tabulated below.

Table 11. Acute Risk Quotients for Freshwater Fish Based on a Bluegill Sunfish LC,, of 2.537 mg/L. Appl. rate No. EEC model LC,, (mg/L) Peak EEC Acute RQ Site (Ib ai/A) ~PPI. (EEC1LC50) sugarcane 0.027 2 GENEEC2 2.537 0.0003 <0.01 *** exceeds the LOCs for acute risk (RQ 2 0.5), restricted use (RQ 20.1) and endangered species (RQ 10.05) ** exceeds the LOCs for restricted use (RQ 20.1) and endangered species (RQ 20.05) * exceeds the LOC for endangered species (RQ 30.05) nla - when information is not available or when a greater than toxicity value which minimal risk (RQ <O.Ol)is presumed for the species. Acute risk to freshwater fish are presumed to be negligible for field corn, sugarcane, and soybean uses. There are no LOC exceedances for fi-eshwaterfish. Chronic Chronic risks were evaluated using both maximum and 60-day mean (average) estimated environmental concentrations offlufenpyr-ethylresidues (Table 12)to freshwater fish.Based on an fish early life-stage toxicity test with flufenpyr-ethyl; the rainbow trout NOAEC is 0.44 mg/L. Chronic risk quotients for two aerial broadcast application to fieshwater fish are tabulated below.

Table 12. Chronic Risk Quotients for Freshwater Fish Based on a Rainbow Trout NOAEC of 0.44 mg/L. Appl. rate No. EEC Toxicity value Peak EEC Site (Ib aiIA) appl. model sugarcane 0.027 2 GENEEC 2 + exceeds the LOC for chronic risk (RQ r 1).Based on the early life-stage toxicity test, the flufenpyr-ethyl residue does not exceed the chronic LOC for risk to freshwater fish. Minimal risk is presumed for freshwater fish fiom short-term and long-term exposures.
VI. Freshwater Invertebrates Acute Acute risk quotientsfor multiplebroadcast applicationsofflufenpyr-ethyl to freshwater invertebrates (Table 13) are tabulated below.

Table 13. Acute Risk Quotients for Freshwater Invertebrates Based on a Daphnid EC,, of >3 mg/L for Flufenpyr-ethyl. Appl. rate No. EEC EC,, (mg/L) Peak EEC RQ (EEC/Ec50) Site (lb ai/A) appl. model (mgk) sugarcane 0.027 2 GENEEC2 >3 0.0003 <0.01 *** exceeds the LOCs for acute risk (RQ 20.5), restricted use (RQ 20.1) and endangered species (RQ 20.05) ** exceeds the LOCs for restricted use (RQ 20.1) and endangered species (RQ 20.05) * exceeds the LOC for endangered species (RQ 10.05) n/a - when information is not available or when a greater than toxicity value which minimal risk (RQ <O.Ol)is presumed for the species Acute risk to freshwater invertebrates is presumed to be negligible for field corn, sugarcane and soybeanuses. There are no LOC exceedances since the toxicity offlufenpyr-ethylis abovethe water solubility limit 

### (>3 mg/L).
Chronic Chronic risks were evaluated using both maximum and 21-day mean (average) estimated environmental concentrations of flufenpyr-ethyl residues (Table 

### 14) to freshwater invertebrates. Based on an invertebrate life cycle toxicity test with flufenpyr-ethyl; the daphnid NOAEC is 

### 0.46 mg/L. Chronic risk quotients for multiple broadcast applications to freshwater invertebrates are tabulated below to examine instantaneous and long-term exposures.

Table 14. Chronic Risk Quotients for Freshwater Invertebrates Based on a Daphnid NOAEC of 0.46 mg/L for Flufenpyr-ethyl. Appl. rate No. EEC Site (lb ai/A) appl model sugarcane 0.027 2 GENEEC2 + exceeds the LOC for chronic risk (RQ 2 1). Minimal risk is presumed for freshwater invertebrates from short-termand long-term exposures.

### VII. EstuarineIMarine Fish Acute risk quotients for multiple broadcast applications to estuarinelmarine fish 

### (Table 

### 15) are tabulated below for use sites from which runoff and drift might contaminate the estuarinelrnarine environment.

Table 15. Acute Risk Quotients for Estuarinelmarine Fish Based on a Sheepshead Minnow LC,, of >2.7 mglL.

- - Appl. rate Number of EEC ToxicityLC,, Peak EEC Fish RQ Site (Ib aUA) applications model (mg/L) (mg/L) (EEC/LC,o) sugarcane 0.027 2 GENEEC2 >2.7 mgiL 0.0003 <0.01 *** exceeds the LOCs for acute risk (RQ 2 0.5), restricted use (RQ 20.1) and endangered species (RQ 20.05) Acute risk to estuarinelrnarinefish ispresumed to be negligible for sugarcane,field corn and soybean uses. There arenoLOC exceedances sincethe toxicityofflufenpyr-ethylis abovethe water solubility limit 

### (>2.7 mg1L).


### VIII. Estuarine/Marine Invertebrates Acute risk quotients for single and multiplebroadcast application to estuarinelmarine invertebrates 

### (Table 

### 16) are tabulated below for use sites from which runoff and drift might contaminate the estuarinelrnarine environment.

Table 16. Acute Risk Quotients for Estuarinelmarine Invertebrates Based on a Shrimp EC,, of 2.08 mgL. Appl. rate No. EEC Toxicity EC,, Peak EEC Shrimp RQ Site (lb ai/A) appl. model (mg/L) (mg/L) (EEC/EC,o) sugarcane 0.027 2 GENEEC2 2.08 0.0003 <0.01 Acute risk to estuarinelrnarine invertebrates is presumed to be negligible for sugarcane, field corn and soybean uses. There are no LOC exceedances since flufenpyr-ethyl is moderately toxic 

### (2.08 mg/L) to estuarinelmarineinvertebrates.


### IX. Aquatic Plants Risk quotients for aquatic plants 

### (Table 17) are addressed below. The assessment for nonendangered and endangered vascular aquaticplants is based on the toxicity ofparent flufenpyr-ethyl and its degradates to duckweed. The assessment for nonvascular, non-endangered plants uses the parent toxicity to the most sensitivealgal or diatom species. Currently,there are no Federally listed endangered nonvascular aquatic plants.Table 17. Acute Risk Quotients for Aquatic Plants based upon Parent and Degradate Compounds. A Duckweed (Lemna gibba) EC50 of 0.013,0.006, and 10.03 ppm from Parent Flufenpyr-Ethyl and its Degradates, respectively and a Nonvascular Plant (Skeletonema capricornutum) EC50 of 0.009 ppm from the Parent Compound. For Endangered Species, the L. gibba NOEC of 0.003,0.0036, and 0.03 ppm from Parent Flufenpyr-Ethyl and its Degradates, Respectively. Site/ Application Method1 Rate of Application Species Endangered EEC NOAEC SpeciesRQ Non-target plant ECso (PP~) (PP~) (PP~) 'FECmOAEC) RQ (EECIECso) (lbs ai/A) sugarcanel aerial I duckweed (parent) 0.013 0.0003 0.003 0.10 0.02 0.027 duckweed (S1353 acid) 0.006 0.0022 0.003 0.73 0.37 duckweed (S135340H) >0.03 0.00022 0.03 <0.01 <0.01 algae or diatom 0.009 0.0003 nla n/a <0.01 * exceeds the plant LOC for non-target or endangered plants (RQ 21) n/a - when information is not available or when a greater than toxicity value which minimal risk is presumed for the species. The endangered and non-target aquaticplants LOCs are not exceeded for vascular or non-vascular plants with the parent compound. However, for testing with the S1353 acid and S1353-4-OH degradates, the non-target and endangered aquatic plants LOCs are not exceeded for the proposed label uses on sugarcane, soybean, and field corn.

### Appendix 

### VI Environmental Fate Data requirements

162- 1 162-2
162-3
162-4
163-1
163-1 163-2and 163-3

!64-1
164-2 165-4 Aerobic Soil Metabolism Anaerobic Soil Metabolism Anaerobic Aquatic Metabolism Aerobic Aquatic Metabolism Mobility in SoilISediments Mobility in Soil Columns Volatility from Soil (Laboratory and Field, respectively) Terrestrial Field Dissipation (Short Term) Aquatic Field Dissipation Bioaccumulationin Fish Yes for S-3 153-acid Yes NA
Yes
NA
Yes
NA NA

Yes
NA NA 45 1 190-22 NA
45 1 190-23
NA
451191-01
NA NA

451191-02,03, 04, & 21

NA NA acceptable NA acceptable
NA acceptable
NA NA
acceptable
NA NA

### Appendix VII 

### Ecological Effects Date Requirements

Are Data Study Guideline Date Requirements Requirements MRID Classification Satisfied? 71-l(a)(b) Acute Avian LD,, 7 1

-2(a) Avian DietaryYQuail 7 1

-2(b) Avian DietaryDuck 71-3 Wild Mammal Toxicity Yes Yes Yes Yes Core Core Core Acceptable
Avian ReproductivefQuail Yes Yes NA Core Core NA Avian Reproductive/Duck Actual Field Testing (Residue monitoring) Fish Toxicity Bluegill Sunfish LC50 Yes Core Fish Toxicity Rainbow Trout LC50 Yes Yes Core Supplemental Invertebrate Toxicity Daphnid EC50 EstuarineMarine Toxicity Fish LC50 Yes Core
EstuarineIMarineToxicity Mollusk Yes Yes Yes Core Core Core EstuarineJMarine Toxicity Mysid Freshwater Aquatic Invertebrate Life Cycle 72-4(c) 122-1 (a) 122-1 (b) 122-2 Freshwater Fish Early Life Stage Yes NA NA Yes Supplemental NA NA Core Tier I Seed Emergence Tier I Vegetative Vigor Tier I Aquatic Plant Growth (Algae) 123-l(a) Tier I1 Seedling Emergence Yes 123-l(b) Tier I1 Vegetative Vigor Yes 141-1 Honey Bee Acute Contact Yes 141-2 Honey Bee Residue on Foliage NA Core Core Core

### 4ppendix 

### VIII 

### - EllPate Output Chemical Name: 

### gi@e&eyr-q@$i: Use Formulation Terresterial Application Residues 

# I Grass

# I

Short Grass Tall Grass Broadleaf plantshm Insects Fruitslpodsllg insects Inputs L I0 8 '9 Application Rate E 6 

# .- Half-life 4 2 ,+- Fruitslpodsll Frequency of 0 Application Maximum #

Avian Apps.Near Outputs Maximum 56 day Average Concentration Concentration (PPM) IPPM) Days

\- - ---, ,- - ---3 11.80 7.48 5.41 3.43 # days 6.64 4.21 Exceeded 0.74 0.47 on short grass (in first 56) Acute LC50 5000 0 (PP~) Chronic NOAEC 1 64 0 (PP~) Acute RQ Chronic RQ (Max. res. mult. apps.) Short Grass 0.00 0.07 Tall Grass 0.00 0.03 # days Broadleaf plantslsm 0.00 0.04 Exceeded Insects Fruitslpodsllg 0.00 0.00 on short grass insects Max Single Application which does NOT exceed Avian Acute Avian Chronic Ib a.i.)
Mammalian Acute Mammalian Chronic (in first 56)Mammalian Acute LD50 5000 0 

### Rat Calcgllated LC-% (ppm) ,w 100(100 , (mglkg bwld) I RChronic NOAEL 1463 0 Rat Calculated NOAEL (ppm) (mglkg diet) 15 g mammal
Acute RQ 35 g mammal 1000 g mammal Rat Acute Rat Chronic Acute RQ Acute RQ Dietary Dietary

### Qppendix

### IX 

## - Terr Plant Output