UNITED STATES ENVIRONMENTAL PROTECTION AGENC Y

WASHINGTON

, D

. C

. 20460

OFFICE OF CHEMICAL SAFETY

AND POLLUTION PREVENTION



### DP B a r c od es : 0423653 and 423655



### P C Code : 056008



### MEM O RAN D U M

D ATE: June 24

, 2015



### SU B JEC T : Application for Re g istr ation of New Use of Et hyl I- Naphthaleneacetate, on
Pome gra nate in Association with IR-4 petition 4E83 l 0 for the Product Tre-hold Sprout I nhib i tor A 112.



### TO: Driss Benmhend

, Risk Manager Reviewer Shaja Joyner

, Ri s k Manager #20



### F RO M : Cynthia Giles-Parker

, C hi ef Fungicide Bran ch

Laura No llen

, Ri s k Manager Reviewe r
Barbara Madden

, Risk Manager, Risk Manager # 05

Luis Sugu i yama
, Act i ng Chief

Risk Integration

, Minor Use and E mergency**Re~ponse** 

### Branch

R egistration Di visio n (7505 P)

,,.. 

# k4.-

Jose 

### L. Melendez

, Chemist

# ~ .._

# l'**f4e:u!:41.:A.~** Brian Montague

, Fishery

## Biologist**~** A ll en Vau g han

, Ri sk Assessment Proce ss Leader

Env ir onmental Risk Bran ch V

Environmenta l F ate and Effec t s Division (7507P)



### T HRO UG H: Mah T. S hamim

, Ph.D.

, C hief

Env ironmental Ri sk Branch V

# ~~

Env ironm e nta l Fate and Effects Division (750 7P)

The Env ironmental Fate and Effects Divi sion (EFED) has r eviewed the proposed n ew use for the ethyl I -naphthalene acetate (NAA-EE) on pomegranate fo r trunk sprou t and root s ucker control.

The Interregi ona l Research Project No. 4 (I R-4 ). and the**regist~ant ,**  

### AMV AC Chemical

### 2 Corporation, petitioned a tolerance exemption for the above mentioned crop fo r the product Tre

Hold ® 

### Sprout Inhibitor A

- 112. The product would be applied as a spray in a 1% active solution at up to 44 gallons per acre

.

Pomegranates are generally grown in the arid climates of California and a small area of Arizona. They are adaptable to a wide range of soils such as deep loam, sandy soils and adobe clay soils. Generally, between 150

- 200 trees are planted per acre with 18 feet between rows and 12 to 18 feet between trees. Acreage has been increas ing with 35,000 acres planted in California in 2013, up from 15

, 000 acres 6 years earlier. (Western Farm Press May 2013).

EFED evaluated the proposed new use against t he previous assessment of the use s for the

chemical. A previous assessment for the use of the chemical on avocado (D361448) concluded that the proposed use of two applications at 0.22 lb a.e./A (a.e. means acid equivalent) at 45 day

intervals should not pose acute or chronic risk to any non

- target organisms. However

, the new proposed use i s at a much higher rate and

, as a result, EFED has reassessed potential exposure

levels. Table 1 shows a summary of application information proposed for pomegranate along

with label application information for other registered crops.

T able 1. Summary use information for naphthalene acetates, based on the 2007 revision of the RED (USEPA 2007), the sample labels for Rejuvenate Seed Treatment 1 , Fruitone ® L 2 , and the proposed label

for Tre

- Hold ® Sprout Inhibitor A

- 112 3

. The proposed ne w use is in bold type

.

USE SINGLE

APP.

RATE (lb. a.e./A) * N O.

APPS AT

MAX

RATE SEASONAL

APP. RATE (lb . a. e ./A) INTERVAL

BETWEEN

APP S

. (days) APP.

METHOD

* INCORP.

DEPTH (inches) Pomegranate 3.6 2 7.2 60 S pray ** 0 Avocado, mamey sapote, mango 0.11 2 0.22 45 G, A, B 0

CG 11

– 10: P ome fruits: apple

, pears, azarole, crabapple, loquat, mayhaw, medlar, Asian pear, quince, Chinese quince, Japanese quince, Japanese quince, tejocote and cultivars, varieties and/or hybrids of these 0.11 3 0.3 3 5 G, A, SD 0

Citrus (mandarin, oranges, tangelos, tangerines, and non

bearing), cherries, some non

bearing fruit and nut trees, ornamental plants (herbaceous,

non

- flowering trees, woody shrubs and vines), shade trees, and residential fruit, and ornamental

trees 0.11 3 0.33 5 G, A, SD 0

Olives 0.33 1 0.33 N/A AB 0

1 Rejuvenate Seed Treatment (EPA Reg. No. 87320

- 2) contains 6.25% NAA potassium salt or 0.44 lb NAA a.e./gallon.

2 Fruitone L ® (EPA Reg. No. 5481

- 541) contains 3.5% NAA sodium salt or 3.1% NAA a.e.

3 Tre

- Hold ® Sprout Inhibitor A

- 112 (EPA Reg. No. 5481

- 429) contains 15.1% NAA ethyl ester or 1 lb NAA a.e./gallon.

### 3 T able 1. Summary use information for naphthalene acetates, based on the 2007 revision of the RED (USEPA 2007), the sample labels for Rejuvenate Seed Treatment 1 , Fruitone ® L 2 , and the proposed label

for Tre

- Hold ® Sprout Inhibitor A

- 112 3

. The proposed ne w use is in bold type

.

USE SINGLE

APP.

RATE (lb. a.e./A) * N O.

APPS AT

MAX

RATE SEASONAL

APP. RATE (lb . a. e ./A) INTERVAL

BETWEEN

APP S

. (days) APP.

METHOD

* INCORP.

DEPTH (inches) Potato seed pieces 0.0004 1 0.0004 N/A ST 3** *

* a.e. = acid equivalents; N/A = not applicable; G = ground; A = aerial; SD = dip or soil drench; ST = seed treatment; AB = airblast; B = brush, sponge or paint roller (to individual trees); T = t reat rambutan panicles spraying solution to runoff. **Ground applications, diluted in a large volume of water, applied to the lower tree trunks and immediate surrounding area. The PHI is 45 days.

* * * Shallowest depth of plantin g potatoes was obtained from the following source, accessed 08/27/2012: http://www.cals.uidaho.edu/potat oes/Research&Extension/Topic/Seed&Planting/EffectsOfRemovingSeedPieces&PlantingDe pthOnPotatoYield

- 99.pdf (William H. Bohl and Stephen L. Love. 1999. Affects of Removing Seed Pieces and Planting Depth on Potato Yield). Furthermore, the following site stat es that, “Generally the center of the seed piece should be planted 2 to 4 inches below field level and covered with 2 to 3 inches of soil.” (The site was accessed 08/27/2012: http://w ww.ag.ndsu.edu/pubs/plantsci/rowcrops/ae1040w.htm .) ##Even though the label is not clear on what is the application rate per acre, it appears to 0.11 lb a.e./A, similar to other crops.



### Aquatic Organism Exposure and Risk Quotients (see previous Problem Formulation

D421702 , USEPA 2014, for toxicity values used in this assessment)

Preliminary evaluation indicated that using EECs from the Tier 1 model GENEEC2 would yield RQs that exceed the levels of concern for some taxa; therefore, EFED proceeded with Ti er 2

model ing using the SWCC (Surface Water Concentration Calculator)

. The results of GENEEC2

are summarized in Appendix A and not discussed further here. Table 2 shows the EECs

obtained from the Tier 2 SWCC model . For the input parameters used in the m odel s , and model output file s , refer to the Appendices A and B , respectively.

Table 2 . NAA EE Surface Water EECs Based on the SWCC Tier 2
Peak ( m g/L) 21

- day ( m g/L) 60

- day ( m g/L)

0.00839 0.00328 0.00131

Pore Water Peak ( m g/L) Pore Water 21

- day ( m g/L)

0.00103 0.000995



### Risk quotients in Table 3 are based on SWCC exposure estimates and toxicity values from actual submitted study results or ECOSAR estimates for toxicity to aquatic organisms where data has not been submitted. Based on these risk quotie nts no acute or chronic Levels of Concern are exceeded for the proposed Pomegranate use for trunk sprout and root sucker control.

Table 3 . Risk Quotients for Aquatic Species Based on the Tier 2 SWCC and NAA, EE Endpoints

Species Endpoint Toxicity Value (mg/L) RQ

Fish, Acute Exposure

Actual Value Bluegill sunfish

- (MRID 42498101) 96

- hr, LC 50 2.68 <0.01 Fish, Chronic Exposure

Estimated value using ECOSAR 1.11 C hronic Value 0.14 0.01

### 4 Table 3 . Risk Quotients for Aquatic Species Based on the Tier 2 SWCC and NAA, EE Endpoints

Species Endpoint Toxicity Value (mg/L) RQ

Aquati c Invertebrates, Acute Exposure

15.1 % Formulation T est EC50 corrected to 100%

- Daphnia magna (MRID 00042755) 48

- hr, LC 50 3.6 <0.01

Aquatic Invertebrates, Chronic Exposure

Estimated value using ECOSAR 1.11

- Daphnia magna ChV (esters) 1.95 0.02

Estimated value using ECOSAR 1.11

- Daphnia magna C hV (neutral orgs) 0.49 0.01

Marine/Estuarine Aquati c Invertebrates, Acute

Estimated value using ECOSAR 1.11

- Mysid Shrimp 96

- hr, LC 50 1.55 0.01

Marine/Estuarine Aquatic Invertebrates, Chr onic

Estimated value using ECOSAR 1.11

- Mysid Shrimp Chronic Value 3.24 <0.01

Aquatic Plants, Acute Exposure

Estimated value using ECOSAR 1.11 Green Algae 96

- hr, EC 50 1.52 0.01 Aquatic Plants

Estimated value using ECOSAR 1.11 Green Algae Chronic NOEC 0.69 0. 01 (1)

(1) It is a chronic endpoint. However, compared against the peak EEC the RQ is less than 1.0.



### Terrestrial Organism Toxicity and Exposure Considerations

NAA EE has been observed to be practically non

- toxic to birds on an acute dietary basis. The observed dietary value for Bobwhite quail with NAA ethyl ester technical exceeded 5620 ppm (MRID 42584202) with no mortality or adverse effects o bserved at this level . Acute toxicity to laboratory mammal was observed to be 2186 mg a.i./Kg of body weight (practically non

- toxic) for the technical grade NAA ethyl ester. No avian oral acute or chronic avian reproduction studies

are available for NAA ethyl ester, though the NAA salt was observed to be slightly toxic to mallard duck on an oral basis (LD 50 

### 1750 mg a

. i

. /Kg bw). At higher rates for pomegranate use (3.6 lb ai/A) predicted residue levels for exposed short grasses immediately surrounding P omegranate
trees could reach 450 ppm for typical and 864 ppm for maximum residue levels as acid equivalent

values

. Though an actual LC50 has not been established acute hazard to birds is not predicted

from this use.

Chronic avian reproduction data for a similarly structured compound with the same mode of action (quinclorac; NOAEC = 500

- 1000 ppm; MRID 44084501 & 44129201)

, in addition to that for other synthetic auxins (aminopyralid, dicamba; NOAEC = 800

- 2600 ppm)

, suggest low chronic toxicity to birds . However, areas immediately surrounding the bases of treated Pomegranate trees

could reach residue levels within this range of chronic toxicity values if maximum expected

residue values on short grass are assumed. Typical expected residue levels w ould n ot exceed the

Chronic NOAE L observed for similar chemicals

.

Acute toxicity to honeybees has not been determined for the ethyl ester or other NAA salts (data

has been requested for the N apthalene acetic acid ). However, the exposure of pollinator insects t o trunks of sprayed pomegranates following targeted application would be unlikely.

### 5 Currently the Agency has no terrestrial plant data for NAA ethyl ester and only a few studies with

an NAA salt formulations Drift of spray to surrounding vegetation and non

- target plants is possible, but the targeted application to sprouts or cuttings would appear to limit this type of exposure pathway. Label precautions regarding the prevention of spray drift are included. Runoff to adjacent areas would be based on res idues concentrated immediately near the root structures of pomegranate trees and not in the row areas between trees.

Uncertainties

Very little environmental fate data were available for these compounds. Quantitative structure activity relationships (QS AR) and limited available data were used to derive some of the input parameters for the models. The major uncertainties with respect to this assessment are related to the absence of measured values for fate parameters. Furthermore, there is lack of infor mation about possible degradates of NAA.

No toxicological data is available to the Agency regarding chronic effects for aquatic invertebrates, fish or terrestrial wildlife with NAA

- EE or the NAA acid form. In addition, no pollinator insect data has been submitted, though for direct application to trunks or cuttings this

is not determ ined to be an exposure concern. Runoff to non

- target terrestrial plants near pomegranate orchards is potentially possible, but with no actual NAA

- EE or NAA plant toxicity

da ta on this formulation or half

- life data in soils, characterization of the potential risk to non

target plants cannot be made with any certainty.

Environmental Fate and Ecological Effects d ata have been requested in the Registration Review

Problem formula tion for NAA active s that would help to alleviate these uncertainties (see D423581 dated November 18, 2014 for further details).

EFED Label Recommendations

The following label statements are recommended based in part on the OPP Label Review Manual (Chapt er 8, 09/2012 ), available at http://www.epa.gov/oppfead1/labeling/lrm/index.htm (accessed 10/11 /2012).

i. End

- Use Product Environmental Hazards

EFED notes that t he following statements al ready appear in the proposed label:

“ Do not apply directly to water, to areas where surface water is present, or to intertidal areas below the mean high water mark. Do not contaminate water by cleaning of equipment or disposal of wastes . Do not contamina te irrigation ditches or water used for irrigation or domestic

purposes. Do not apply when conditions favor drift from treated areas. Do not use in a greenhouse. Do not store near extreme heat, open flame, or sources of ignition. ”

### 6 EFED suggests replaci ng the sentence, “ Do not contaminate water by cleaning of equipment or disposal of wastes. ” with “Do not contaminate water when disposing of equipment washwater or

rinsate

. ” The recommended sentence complies with the current Label Review Manual.

ii. Labe l Statement for Spray Drift Management



### EFED notes that t he following statements already appear in the proposed label:

Tre

- Hold ® 

### Sprout Inhibitor A

- 112 Label :

SPRAY DRIFT MANAGEMENT : A variety of factors including weather conditions ( e.g. , wind

direction , wind speed, temperature, relative humidity) and method of application can influence pesticide drift. The applicator and grower must evaluate all factors and make appropriate adjustments when applying this product. Do not apply by spray when wind speeds are greater than 10 mph at the application site. Use only medium or coarse spray nozzles or droplets.

. Risk Characterization and Conclusions

Based on SWCC Tier II modeling for Pomegranate uses at a maximum of 3.6 lbs ai/acre and 2 applications, no aqu atic species l evels of concern are exceeded . Predicted environmental concentration are far below any observed or predicted toxicity levels for fish, invertebrates or aquatic plants . It should be noted that this conclusion is based on a very limited data set and extensive chemical structure modeling estimation for missing toxicological endpoints.

Tre

- Hold A112 is applied as a directed spray to lower tree trunks and immediate surrounding root growth areas for control of sprouts and root suckers. The rad ius of this concentrated spray area is not clearly defined on the label, but it is anticipated that residue levels immediately surrounding the trees could be higher than would be expected from this spray concentration if

distributed over an entire acre. There is some uncertainty as to what exposure levels would be expected under current label directions and therefore some uncertainty as to what levels of NAA EE wildlife could be exposed to. Acute toxicity to birds and mammals is low and acute risk is

not expected even with concentrated areas under trees. The levels that would indicate chronic

risk to birds are reached if predictions for chronic toxicity are based on similar structured chemicals such as Quinclorac (NOAEL=500 ppm/LOAEL = 1000 ppm).

As n o honeybee toxicity data has been submitted for NAA salts or the ester there is some uncertainty regarding potential risk. The AMVAC has indicated that data are available in Europe and that results indicate low toxicity to honeybees. EFED does expect that direct application to trunk sprouts or root suckers will provide very limited exposure potential to pollinator insects. Therefore risk to these beneficial pollinators is not expected.

Seedling emergence e ffects to sensitive dicot terrestrial crop plant were observed at 0.011

- 0.015 lb ai/A with ammonium salt formulation. The monocot species showed less sensitivity to this

formulation . With the potassium salt formulation effects to vegetative vigor were observed at

### 7 0.01 to 0.043 lb ai/A for dicots and e ffects to monocots were observed at 0.02

- 0.075 lb ai/A. However, EFED does not expect direct application to tree trunks and root structure to lead to significant off target plant exposure with proper spray drift precautions. Hot arid areas in which

pome granates are grown would offer less potential for runoff events as well. Effects to non

target crops or vegetation is not expected from this usage as proposed on the current label.

References

Crosby, D.G., Tang, C.S. 1969. Photodecomposition of 1

- Na phthaleneacetic Acid. 17(6), 1291

- 1293. USEPA 2007. Reregistration Eligibility Decision (RED) Naphthaleneacetic Acid, Its Salts, Ester,

and Acetamide. OCSPP. OPP. EPA 738

- R

- 07

- 07017. Revised October 2007. USEPA 2009. Guidance for Selecting Input Parame ters in Modeling the Environmental Fate and Transport of Pesticides, Version 2.1 (dated October 22, 2009 and approved November 10, 2009), available at http://www.epa.gov/o ppefed1/models/water/input_parameter_guidance.htm (accessed 04/08/2015). USEPA 2014. Problem Formulation for Registration Review of Napthaleneacetic Acid and Its Sodium, Potassium and Ammonium Salts, Ethyl Ester and Acetamide (Document ID

EPA

‐ HQ

‐ OPP

‐ 2014

‐ 0773

- 0003 in www.regulations.gov , DP Barcode: D423581, dated November 18, 2014).

### 8 

# Appendix A. Aquatic Mode ling for NAA EE

Tier 1 M odeling U sing GENEEC2

GENEEC was designed to mimic a much more sophisticated PR ZM/EXAMS simulation but requires far fewer inputs and much less time and effort to use. The model uses a chemical's label application information, its soil/water partition data and its degradation kinetics to estimate high level exposure values in the same EFED “standard” agricultural field/farm pond scenario as used with PRZM/EXAMS simulations. The program is generic in that it does not consider differences in climate, soils, topography or crop in estimating potential pesticide exposure.

GENEEC is also si mpler than the PRZM and EXAMS models in its treatment of hydrology. The linked PRZM and EXAMS models simulate the impact of daily weather on the treated agricultural field over a period of thirty years. During this time, pesticide is washed

- off of the

fiel d into the water

- body by twenty to forty rainfall/runoff events per year. Each new addition of pesticide to the water

- body adds to the pesticide which has arrived earlier either through previous runoff events or through spray

- drift and begins degrading on the day it reaches the water. GENEEC, on the other hand, is a single event model. It assumes one single large rainfall/runoff event occurs that removes a large quantity of pesticide from the field to the water all at one time. Longer

- term, multiple

- day ave rage concentration values are calculated based on the peak day value and subsequent values considering degradation processes.

GENEEC2 (version 2.0) was developed in response to suggestions for improvements by model users, by the desire to stay current wit h the newer versions of the PRZM (Carsel, 1997) 4 

### and EXAMS (Burns, 1997) 5 

### programs upon which GENEEC is based and by availability of much improved data on spray drift and quantitative methods of estimation of offsite drift developed by the Spray Drift Task Force (SDTF). The main differences between versions 1.0 and 2.0 include: (a) an entirely new binding curve to represent dissolved concentration as a function of K d 

### ; (b) the use of the binding parameter, K d 

### in preference to K
oc 

### to represent pesticide atta chment to soil, to organic matter or to water

- body bottom and suspended sediments; (c) a change in the recommendation for depth of incorporation; (d) a change in the timing of the single event rainstorm for chemicals which receive multiple applications; (e ) addition of a subroutine from the SDTF to estimate spray drift; and (f) a change in the time durations of the output values to better match the durations of relevant toxicity tests.

Table A1 summarizes the input parameters used in GENEEC2. Table A1b su mmarizes output.

4 R.F. Carsel, J.C.Imhoff, P.R.Hummel, J.M.Cheplick and J. S.Donigian, Jr. 1997. PRZM3, A Model for Predicting Pesticide and Nitrogen Fate in Crop Root and Unsaturated Soil Zones: User ’ s Manual for Release 3.0; Environmental Research Laboratory, Office of Research and Development, U.S. Environmental Protection Age ncy, Athens, GA.

5 Burns, L.A. March 1997. Exposure Analysis Modeling System (EXAMSII) Users Guide for Version 2.97.5, Environmental Research Laboratory, Office of Research and Development, U.S. Environmental Protection Agency, Athens, GA.

### 9 Table A1 . Environmental Fate and Other Input Parameters for the Estimation of Naphthalene

- acetic Acid, Ethyl Ester (Expressed in Acid Equivalents) , Using GENEEC2 2

Parameter Value Source

Run Number 1 User Defined Output File Name NAA

- 20 15.txt User Defined

Chemical Name NAA (EE) Product Label 1
Crop Name Pomegranate Product Label 1
Application Method

– diluted in a large volume of water, applied to the lower tree trunks and immediate surrounding area B (Ground) Product Label 1

Applicatio n Rate (lb a.e./A 3 ) 3.6 Product Label 1
Applications Permitted per Season at Max. Rate 2 Product Label 1
Application Interval (days) 60 Product Label 1

Water Solubility (20 ° C) (ppm) (Solubility for the acid. The pH is not specified.) 420 MRID# 40522903

H ydrolysis Half

- Life (pH 7)

Half

- life for NAA ethyl ester at pH 7 is 266 days while there are no hydrolysable groups in the acid (NAA). 0 (stable) MRID# 00129382

Aerobic Soil Metabolism Half

- Life (days) (3x available value = 3 x 10 days = 30 days) 30 HSDB (see USEPA 2014) Aerobic Aquatic Metabolism Half

- life (days) (2x aerobic soil metabolism input value) 60 Per guidelines 2

Aqueous Photolysis Half

- Life (days) 4 Crosby & Tang (1969) Adsorption/Desorption Coefficient (K OC , mL/g OC ) 24.82 EPISUITE v.4.1

Pe sticide is Wetted

- In N (No) Product Label 1
Depth of Incorporation (in) 0 Product Label 1
Droplet Size Distribution (option A is the default value for ground applications) A (Fine) Product Label 1

Nozzle Height (option B is the default; however, for these applications applied to the lower tree trunks and immediate surrounding area, option A is appropriate) A (Low Boom Sprayer) Product Label 1

Width of No

- spray Zone (ft) 0 Product Label 1

1. Proposed label for Tre

- Hold ® Sprout Inhibitor A

- 112.

2. For output from G ENEEC 2 , refer to the Appendix B . Input parameter values were selected based on

the Guidance for Selecting Input Parameters in Modeling the Environmental Fate and Transport of Pesticides version 2.1, dated 10/22/2009 and approved 11/10/2009. URL: http://www.epa.gov/oppefed1/models/water/input_parameter_guidance.htm (accessed 04/08/2015).

3. The abbreviation a.e. means acid equivalent.

Table A1 b NAA EE Surface Water EECs Based on GENEEC2 Tier 1 Output Peak (mg/L) 21

- day (mg/L) 60

- day (mg/L)

0.238 0.222 0.194

### 10 

## Tier 2 modeling using the Surface Water Concentration Calculator 

## ( SWCC )

A brief description of the aquatic models used in this risk assessment follows. Additi onal information about these models is provided in the Agency’s website at http://www.epa.gov/pesticides/science/models_pg.htm#aquatic

. For agricultural and certain non

agric ultural uses, exposure concentrations for surface waters assessments are estimated based on EFED’s Tier II aquatic model PRZM/VVWM. A graphical user interface Surface Water Concentration Calculator (SWCC v.1.10 6 , May 6, 2014), developed by the EPA, was us ed to facilitate inputting chemical and use specific parameters into the appropriate input files and chemical files, replacing the older PE5 shell (November 2006), which used PRZM3 and EXAMS. The SWCC estimates pesticide concentrations in water bodies tha t result from pesticide applications to land. The calculator was designed for regulatory applications as applied in the Office of Pesticide Programs, USEPA, as well as PMRA, Health Canada. The calculator uses the Pesticide Root Zone Model (PRZM v5.0+, M ay 6, 2014) and the Varying Volume Water Body Model (VVWM, May 6, 2014, a replacement for the older EXAMS model). The PRZM field or orchard crop scenario is the basic file which describes the local or regional climatological information, soil hydrology, s oil characteristics, crop characteristics, and the pesticide properties necessary to determine pesticide loadings to surface water. This basic file constitutes the first part of the “exposure scenario.” It simulates the processes in the agricultural

fiel d, such as runoff and erosion, on a daily time step. The runoff and erosion flux output data from PRZM are used as chemical loadings to the VVWM, which simulates surface water, in order to predict the E EC s. The VVWM is conceptually similar to the current EXAMS

- based

model in that both are 2

- compartment models driven by first

- order processes. It simulates the USEPA standard water bodies (i.e., farm pond and/or index reservoir) but with greater efficiency and flexibility for incorporation into a user inter face. The VVWM also allows for variations in water body volume on a daily basis due to runoff, precipitation, and evaporation. Temperature, wind speeds, and pesticide dissipation processes are also allowed to vary daily. E E Cs were determined using the s tandard pond scenario which describes a vulnerable surface water scenario for the VVWM component of the modeling exercise.

To model pomegranate, the CA fruit scenario was chosen. The input parameter values selected were for the acid since presumably the ester degrades to the acid rapidly in the environment.

Table A2 summarizes the input parameters used in the SWCC.

Table A2 . Environmental Fate and Other Input Parameters for the Estimation of Naphthaleneacetic Acid, Ethyl Ester (Expressed in Acid Equival ents) , Using the SWCC 2

Parameter Value Source

Chemical Name NAA, EE Product Label 1
Crop Name Pomegranate Product Label 1

Scenario CA Fruit User selected Dates of Application (per label, apps usually occur between Feb. to May in the San Joaquin Valley; date of first application selected so both apps occur within the labeled range) (dd

- mm) 15

- 03; 14

- 05 Product Label 1

Application Rate (lb a.e./A) 3 3.6 Product Label 1
Application Rate (kg a.e./A) 3 4.03 Product Label 1
Applications Permitted per Season at M ax. Rate 2 Product Label 1

### 11 Table A2 . Environmental Fate and Other Input Parameters for the Estimation of Naphthaleneacetic Acid, Ethyl Ester (Expressed in Acid Equival ents) , Using the SWCC 2

Parameter Value Source Application Interval (days) 60 Product Label 1

Water Solubility ( ppm, 2 0 ° C) (Solubility for the acid. The pH is not specified.) 420 MRID 40522903

Hydrolysis Half

- Life (pH 7)

Half

- life for NAA ethyl ester at pH 7 is 266 days whi le there are no hydrolysable groups in the acid (NAA). 0 (stable) MRID 00129382

Aerobic Soil Metabolism Half

- Life (days) (3 x available value = 3 x 10 days = 3 0 days) 30 HSDB (see USEPA 2014) Reference Temperature (°C) 25 Assumed Aerobic Aquatic Metabol ism Half

- life (days) (2x aerobic soil metabolism input value ) 60 Per guidelines 2

Reference Temperature (°C) 25 Assumed Anaerobic Aquatic Metabolism Half

- life 0 (stable) No data available Reference Temperature (°C) 25 Assumed

Aqueous Photolysis Half

- lif e (days) 4 Crosby & Tang ( 1969 ) Aqueous Photolysis Reference Latitude (°) 40 Assumed Adsorption/Desorption Coefficient (K OC , mL/g OC ) 24.82 EPISUITE v.4.1 Method of Application Ground Product Label 1
Depth of Incorporation (cm) 0 .0 Product Label 1
Appli cation Efficiency (fraction) 0.99 Product Label 1
Spray Drift (fraction for low boom height is appropriate, droplet size ASABE very fine to fine is default, 90 th percentile) 0.027 Product Label 1

Width of No

- spray Zone (ft) 0 Product Label 1
Vapor Pressure (torr) 0.3 MRID 40522903 Foliar Dissipation Half

- life 0 No data available Molecular Weight (g/mol) (for the acid) 186.21 2004 RED 4

1. Proposed label for Tre

- Hold ® Sprout Inhibitor A

- 112.

2. For output from the SWCC , refer to the Appendix B . Input parameter values were selected based on the Guidance for Selecting Input Parameters in Modeling the Environmental Fate and Transport of Pesticides version 2.1, dated 10/22/2009 and approved 11/10/2009. URL: http://www.epa.gov/oppefed1/models/water/input_parameter_guidance.htm (accessed 04/08/2015).

3. The abbreviation a.e. means acid equivalent.

4. USEPA. 2004. Revised EFED Risk Assessment for the Naphthaleneacetic Acid Reregistration

El igibility Decision: Revision Based on Application at Higher Use Rates (DP Barcode: D306433). Memorandum from A. Vaughan and J. Melendez (Environmental Fate and Effects Division) to Michael Goodis (Special Review and Reregistration Division) dated 10/27/200 4. Office of Pesticide Programs.

Table A3 . NAA EE Surface Water EECs Based on GENEEC2
Peak ( m g/L) 21

- day ( m g/L) 60

- day ( m g/L)

0.238 0.222 0.194

Table A4 . NAA EE Surface Water EECs Based on the SWCC
Peak ( m g/L) 21

- day ( m g/L) 60

- day ( m g/L)

0.00839 0. 00328 0.00131

Pore Water Peak ( m g/L) Pore Water 21

- day ( m g/L)

0.00103 0.000995

### 12 

# Appendix B. Example Output Files

GENEEC 2 Output File

RUN No. 1 FOR NAA(EE) ON Pomegranat * INPUT VALUES *

----------------------------------------- ---------------------------

RATE (#/AC) No.APPS & SOIL SOLUBIL APPL TYPE NO

- SPRAY INCORP

ONE(MULT) INTERVAL Koc (PPM ) (%DRIFT) (FT) (IN)

-------------------------------------------------------------------- 3.600( 4.50 0) 2 60 24.8 420.0 GRLOFI( 2.9) 0.0 0.0

FIELD AND STANDARD POND HALFLIFE VALUES (DAYS)

-------------------------------------------------------------------- METABOLIC DAYS UNTIL HYDROLYSIS PHOTOLYSIS METABOLIC COMBINED

(FIELD) RAIN/RUNOFF (POND) (POND

- EFF) (POND) (POND)

-------------------------------------------------------------------- 30.00 2 0.00 4.00

- 496.00 60.00 53.53

GENERIC EECs (IN MICROGRAMS/LITER (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

----------- --------------------------------------------------------- 238.37 235.86 222.03 194.19 175.96



### EPI Suite v.4.11 ’s ECOSAR v.1.11 Output File

ECOSAR Version 1.11 Results Page

SMILES : O=C(OCC)Cc(c(c(ccc1)cc2)c1)c2

CHEM : 1

- Naphthaleneacetic acid, ethyl ester

CAS Num:

ChemID1:

MOL FOR: C14 H14 O2

MOL WT : 214.27 Log Kow: 3.748 (EPISuite Kowwin v1.68 Estimate)
Log Kow: (User Entered)
Log Kow: (PhysProp DB exp value

- for comparison only)

Melt Pt : 88.50 (deg C, User Entered for Wat Sol estimate)
Melt Pt: 88.50 (deg C, PhysProp DB exp value for Wat Sol est) Wat Sol: 14.75 (mg/L, EPISuite WSKowwin v1.43 Estimate)

Wat Sol: (User Entered)
Wat Sol: (PhysProp DB exp value)

-------------------------------------- Values used to Generate ECOSAR Profile

-------------------------------------- Log Kow: 3.748 (EPISuite Kowwin v1.68 Estimate)

### 13 Wat Sol: 14.75 (mg/L, EPISuite WSKowwin v1.43 Estimate)

-------- ------------------------------ ECOSAR v1.11 Class

- specific Estimations

--------------------------------------
Esters
Predicted ECOSAR Class Organism Duration En d Pt mg/L
(ppm)

=========================== ================== ======== ======

========== Esters : Fish 96

- hr LC50 2.730 Esters : Daphnid 48

- hr LC50 4.707

Ester s : Green Algae 96

- hr EC50 1.519

Esters : Fish ChV 0.142 Esters : Daphnid ChV 1.947

Esters : G reen Algae ChV 0.687
Esters : Fish (SW) 96

- hr LC50 3.732 Esters : Mysid 96

- hr LC50 1.551
Esters : Fish (SW) ChV 0.733 Esters : Mysid (SW) ChV 3.238

Esters : Earthworm 14

- day LC50 763.130

*

=========================== ================== ======== ======

======== == Neutral Organic SAR : Fish 96

- hr LC50 4.739 (Baseline Toxicity) : Daphnid 48

- hr LC50 3.162
: Green Algae 96

- hr EC50 4.591

: Fish ChV 0.560 : Daphnid ChV 0.483
: Green Algae ChV 1.722

Note: * = asterisk designates: Chemical may not be soluble enough to measure this predicted effect. If the effect level exceeds the water solubility by 10X, typically no effects at saturation (NES)
are reported.

------------------------------ Class Specific LogKow Cut

- Of fs

------------------------------ If the log Kow of the chemical is greater than the endpoint specific cut

- offs presented below, then no effects at saturation are expected for those endpoints.

Esters:

------ Maximum LogKow: 5.0 (Fish 96

- hr LC50; Daphnid LC50, Mysid LC50) Maximum LogKow: 6.0 (Earthworm LC50) Maximum LogKow: 6.4 (Green Algae EC50) Maximum LogKow: 8.0 (ChV)

### 14 Baseline Toxicity SAR Limitations:

--------------------------------- Maximum LogKow: 5.0 (Fish 96

- hr LC50; Daphnid LC50) Maximum LogKo w: 6.4 (Green Algae EC50) Maximum LogKow: 8.0 (ChV)

### 15 SWCC Output File



# Summary of Water Modeling of NAA, EE and the USEPA Standard Pond

Estimated Environmental Concentrations for NAA, EE are presented in Table 1 for the USEPA standard pond with the CAfru it_WirrigSTD field scenario. A graphical presentation of the year

- to

- year peaks is presented in Figure 1. These values were generated with the Surface Water Concentration Calculator (SWCC Version 1.106). Critical input values for the model are summarized i n Tables 2 and 3. This model estimates that about 0.3% of NAA, EE applied to the field eventually reaches the water body. The main mechanism of transport from the field to the water body is by spray drift (90.8% of the total transport) followed by runoff ( 9.16%).

In the water body, pesticide dissipates with an effective water column half

- life of 6.1 days. (This value
does not include dissipation by transport to the benthic region; it includes only processes that result in removal of pesticide from the comp lete system.) The main source of dissipation in the water column is volatilization (effective average half

- life = 6.7 days) followed by metabolism (90.8 days) and photolysis (383.1 days).

In the benthic region, pesticide is stable. Most of the pesticide in the benthic region (73%) is sorbed to
sediment rather than in the pore water.

Table 1. Estimated Environmental Concentrations (ppb) for NAA, EE.

Peak (1

- in

- 10 yr) 8.39

4

- day Avg (1

- in

- 10 yr) 6.42

21

- day Avg (1

- in

- 10 yr) 3.28

60

- day Avg (1

- in

- 10 yr) 1.31

365

- day Avg (1

- in

- 10 yr) 0.341

Entire Simulation Mean 0.281

Table 2. Summary of Model Inputs for NAA, EE.

Scenario CAfruit_WirrigSTD

Cropped Area Fraction 1

Koc (ml/g) 24.82

Water Half

- Life (days) @ 25 °C 60

Benthic Half

- Life (days) @ 25 °C 0

Photolysis Half

- Life (days) @ 40 °Lat 4

Hydrolysis Half

- Life (days) 0

### 16 Soil Half

- Life (days) @ 25 °C 30

Foliar Half

- Life (days) 0

Molecular Wt 186.21

Vapor Pressure (torr) 0.3

Solubility (mg/l) 420

Table 3. Application Schedule for NAA, EE.

Date (M on/Day) Type Amount (kg/ha) Eff. Drift

03/15 Ground 4.03 0.99 0.027

05/14 Ground 4.03 0.99 0.027

Figure 1. Yearly Peak Concentrations