1 OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION **UNITED ST AT**  **ES ENVIRONMENT AL**  **PROTECTION A GENCY** 

WA SHINGTON, D.C. 20460

**MEMORANDUM DATE:**  July

19 , 2012 **SUBJECT:** Tier I Estimated Drinking Waters Concentrations (EDWCs) of Spirotetramat and

its Transformation Products for the Use in the Human Health Risk Assessment for the Section 3 New Uses on Several New Crops ( **PC Code 392201; DP Barcode D398507**  ) **FROM:** José L
. Meléndez, Chemist

Environmental Risk Branch V Environmental Fate and Effects Division **THROUGH:** Mah T. Shamim, Ph.D., Branch Chief

Environmental Risk Branch V Environmental Fate and Effects Division (7507P) **TO:** Laura Nollen , Biologist

Barbara Madden , Minor Use Officer Luis Sugui yam a , Branch Chief Risk Integration, Minor Use and Emergency Response Branch Registration Division (7505P) **AND:** Julie VanAlstine, Environmental Health Scientist

David Hrdy , Acting Branch Chief Registration Action Branch I Health Effects Division (7509P) This memo randum presents the Environmental Fate and Effects Division’s (EFED’s) Tier I Estimated Drinking Water Concentrations (EDWC s ) for spirotetramat (CAS No. 203313
- 25
- 1 ) 1 , and for two of its m ajor transformation products spirotetramat
- enol 2 and spirotetramat
ketohydroxy 3 , for use in the human health risk assessment by the Health Effects Division (HED)
. The registrant has applied for several new uses for spirotetramat under Section 3 registration , including the following crops , crop groups or crop subgroups : b ananas and plantains, bushberry and low growing berry

subgroup s (Crop Subgroups 13
- 07B and 13
- 07H , includes cranberries ),

1 CAS Name: cis
- 3
- (2,5
- dimethylphenyl)
- 8
- methoxy
- 2
- oxo - 1
- azaspiro[4.5]dec
- 3
- en - 4
- yl ethyl carbonate 2 CAS Name : cis
- 3
- (2,5
- Dimethylphenyl)
- 4
- hydroxy
- 8
- methoxy
- 1
- azaspiro[4.5]dec
- 3
- en - 2
- one 3 CAS Name : cis
- 3
- (2,5
- Dimethylphenyl)
- 3
- hydroxy
- 8
- methoxy
- 1
- azaspiro[4.5]decan
- 2, 4
- dione2

various additional citrus fruits (to conform the Crop Group 10
- 10 ) , coffee, pineapple, various additional pome fruits (to conform the Crop Group 11
- 10 ) , pomegranate, bulb vegetables (Crop Subgroups 3
- 07A and 3
- 07B), various additional fruiting vegetables (to conform the Crop Group 8
- 10), globe artichoke, taro leaves (under the leafy vegetables group), and watercress ( refer to the **Appendix III** ). Using the Tier 1 aquatic models SCI
- GROW v.2.3 (groundwater , for the use on bananas and plantains ) and the Tier 1 Rice Model v.1.0 (surface water , surrogate model for the use on watercress ) , i t was found that watercress at an application rate of 0. 4 lb a.i./A/season (surface water) 4 and bananas and plantains at 1.25 lb a.i./A/season (groundwater) , were the uses involving the highest potential exposure . The highest seas onal application rate is now different than from previous drinking waters assessment s (DWA s ); therefore, both the surface water and the groundwater EDWCs are different from the previous DWA s . For the total toxic residues (spirotetramat + spirotetramat
- eno l + spirotetramat
- ketohydroxy), the acute and chronic EDWC in surface water is 395 ppb and the EDWC in groundwater is 0.00124 ppb ( **Table 1 -**  **1** ). These are dealt with in **Appendix I** for surface water and **Appendix II** for groundwater. This DWA focuses on changes in EDWCs relative to previously reported values (refer to DP Barcode D345275 , dated 01/22/2008 ; this is the DWA issued for the “new chemical,” covering multiple crops )
. Thus , th is DWA relies heavil y on the previous assessment in that the summary o f the environmental fate properties and c haracteri zation , chemical structures, approaches, and several other details about spirotetramat were previously provided
. Spirotetramat is a sy stemic broad spectrum tetramic acid insecticide (ketoenol class) that i s applied as a preventative treatment during an early threshold of developing chewing insect population when sufficient leaf tissue is present for uptake and translocation to occur within agricultural crops
. The mode of action for s pirotetramat is lipid b iosy nthesis inhibition (LBI); it belongs in the Group 23 Insecticides. Residue exposure to surface water is ty picall y possible through surface water runoff, soil erosion and/or off
- target spray

drift. The mobility

of spirotetramat is moderate ly high ( Kd range 3.58
- 5.52 L/Kg, KOC range 184
- 437 L/Kg OC , moderatel y mobile , FAO 2000) . S pirotetramat is labile , especially under aerobic soil metabolism conditions. Nonetheless, its total residues are relativel y persistent. The Tier 1 EDWCs for spirotetramat and for its major transformation products spirotetramat
- enol and spirotetramat
- ketoh ydroxy (per HED ’s request ; DP Barcodes D 333437 & D 345276, dated 05/14/2008 ), were calculated using the Tier 1 Rice Model v.1.0 (surface water, as a surrogate for applications to watercress) and SCI
- GROW v.2.3 (groundwater, applications to bananas and plantains ) for use in the human health risk assessment. **Table 1 -**  **1** provides a summary of the Tier I modeled drinking water concentrations. This DWA pre sents screening level EDWCs for the use of spirotetramat. A more definitive assessment and refinements are possible if needed b y

4 The new

use pattern on cranberries indicated a potential for higher EDWCs for th is use relative to watercress; however, EFED evaluated the pattern using the tier 1 Provisional Cranberry Model (which is similarly based on the Tier 1 Rice Model v.1 .0) , that the Division has used in past assessments. The EDWCs were lower than for watercress, despite the fact that the application rate is somewhat higher. The reasons include that all spirotetramat applications on cranberry occur before flooding the f ield, and the depth of the water column is higher than for watercress. A peak EDWC for the cranberry use of ~ 114 ppb was obtained assuming applications up to 1 day pre
flood and incorporating the aerobic soil metabolism of the total residues of ~ 12 day s.3

HED (see also notes below for further characterization of results) . Should any questions arise, contact EFED (melendez.jose@epa.gov )
.
**Table 1 -**  **1 . Maxim**  **um Tier I Estimated Drinking Water Concentrations (EDWCs) for drinking water**  **risk assessment based on**  **ground or aerial application of spirotetram**  **at on plantains and bana**  **nas (for**  **groundwater) at 1.25**  **lb a.i./A/season, and ground , aerial**  **or chem igation applications on watercress**  **( for surface water) at**  **0. 4**  **lb a.i./A/season .**  **Drinking Water Source**  **(M ODEL)**  **Estimated Drinking Water Concentration (EDWC)**

**Chemical: Parent** 

**Spirotetram at**  **Spirotetram at**  ****

**enol Spirotetram**  **at**  

** ketohydroxy** **Total Toxic**

**Residues (TTR) 1**  **Risk \**  **Units (ppb)**  **(ppb) (ppb)**  **(ppb) Ground**  **- water**  **(SCI -**  **GROW) Acute &** 

**Chronic 2**  7.06 x 10 - 5 5.15 x 10 - 5 1.12 x 10 - 3 1.24 x 10 - 3 **Surface Water (Tier 1**  **Rice Model v.1.0)**  **Acute &**

**Chronic 2**  N/A N/A N/A 395

1 TTR = Total Toxic Residues (sum of spirotetramat + spirotetramat
- enol + spirotetramat
- ketohydroxy) 2 Surface
- water concentrations calculated by the Tier I Rice Model v1.0 and ground water concentrations calculated by SCI
- GROW do not distinguish between peak and chronic concentrations.
**Use Characterization Table**  **III .**  **A** of **Appendix III** is a summary of all agricultural use patterns for spirotetramat in the l abels for BY I 8330 150 OD Insecticide (oil dispersion) , MOVENTO ® SC (suspension concentrate) , and the ULTOR ® (suspension concentrate)
. The use s shaded yellow are proposed new crops while the uses **bold and underlined** are the modeled ones
. In comparing the crops in **Table III**  **. A**  against crops that were assessed in the 2010 DWA (DP Barcode D370675 , dated 11/08/2010 ) , it was noted that some previously assessed crops are not included in the labels available in Pesticide Product Label Sy stem (PPLS ; at http://iaspub.epa.gov/apex/pesticides/f?p=PPL S:1 ) . These crops are cucurbit vegetables , cotton and various additional tropical fruits. The Section 3 crop s are at a range of application rates up to a s easonal rate of 1.25 lb a.i. /A; foliar applications by ground , aerial , airblast, or chemigation methods ( **Table III.A**  )
. **Identification of specific data gaps** The environmental fate database for spirotetramat is substantially complete. At this time, no additional data has been required.4

**References** Food and Agriculture Organization of the United Nations. FAO PESTICIDE DI SPOSAL SERIES 8. Assessing Soil Contamination: A Reference Manual. Appendix 2. Parameters of pesticides that influence processes in the soil. Editorial Group, FAO Information Division: Rome, 2000. http://www.fao.org/DOCREP/003/X2570E/X2570E00.htm (accessed 0 7/17 /2012). U.S. Environmental Protection Agency 2007. Guidance for Tier I Esti mation of Aqueous Pesticide Concentrations in Rice Paddies (dated 05/08/2007) . Available at http://www.epa.gov/oppefed1/models/water/rice_tier_i.htm (accessed 0 7/17 /2012 ).5 **Appendix I Surface Water EDWCs of Spirotetramat Total Residues on Watercress**  Watercress is typicall y grown in clean, flowing water, 2 to 3 inches deep
. 5 The Agency does not currentl y have a methodology for exposure assessment for crops cultivated in flowing water , such as watercress . The T ier 1 Rice model v.1.0 was , therefore , used as the basis of the assessment of surface waters (refer also to Section 18 for the use on watercress in Florida, DP Barcode D399575 , dated 0 4/05 /2012 ) , and the results were characterized to reflect differences between the capabilities of this model and the watercress cultivation practices
. Watercress is a very minor use (<700 acres were harvested in 2002 and 2007 across the U.S. and there were <65 farms, according to the U. S. Census of Agriculture, National Agricultural Statistics Service , U .S. Department of Agriculture )
. Based on the previous review, and according to information provided b y the registrant and IR
- 4 , it appears that according to agricultural practices, water cress is grown in a bed of water which drains to a ditch which is constantly recirculated. (In Florida, as per the Florida Department of Agriculture and Consumer Services Section 18 request, f ield plots are 4
- acres sized each and laser leveled
. ) The circ ulation of water is stopped 24 hours before and is turned on 24 hour s after chemical applications. EFED is concerned primarily about the total toxic residues (TTR), as opposed to individual metabolites (spirotetramat, spirotetramat
- enol and spirotetramat
- ketoh ydroxy), from discharge towards adjacent bodies of water likel y to occur at the end of the season . EFED does not have a standard model for applications on watercress. Inorder to represent the proposed use on watercress, the Tier 1 Rice model v.1.0 was provisionally used (USEPA 2007). Individual metabolites were not modeled because this would double count mass of pesticide and transformation product s in this particular model. The simplified equation for the Tier 1 Rice Model v.1.0 is as follows:

= 0
. 00105 + 0
. 00013 Where: C

w = EDWC = water concentration [μg/L or ppb ] m ai ' = mass applied per unit area [kg/ha] ( i.e. , the seasonal application rate) K d = water - sediment partitioning coefficient [L/kg] For the applications of spirotetramat on watercress, the EDWC expression is based on spirotetramat
- ketoh ydroxy, which is the last and persistent metabolite of the degradation pathway : S pirotetramat  S pirotetramat
- enol  S pirotetramat
- ketohydroxy For spirotetramat, the calculation is therefore :

5 http://www.naturesherbal.com/Watercress.htm ; see also http://www.bwqualitygrowers.com/ourfarms.aspx (accessed 07/12/2012)6 = 0
. 44832 0
. 00105 + ( 0
. 00013 ) ( 0
. 6532 ) / = 395 / Where the input parameters selected for the model and their justification and sources are specified in **Table I**  **. A** 
. **Table I**  **. A**  **. Tier I Rice M**  **odel v1.0 input parameters for spirotetramat use on watercress**  **Input Parameter Value**  **Justification Source**  Application Rate ( m ai ' ) 0.44832 0. 20 lb a.i./A/application x 2 applications = 0.4 lb a.i./A ( x 1.1208 Kg·A/ha·lb ) = 0.44832 kg a.i./ha Proposed spirotetramat labels (see Table 9) Soil
- to - Water Partition Coefficient (Kd) 0.6532 Kd = Mean KOC 1 (65.32 L/Kg oc ) x 1% organic carbon content = 0.6532 L/kg for the total spirotetramat residues OECD Monograph Annex B. Spirotetramat. B.8 Fate and Behaviour 1. The representative partition coefficient used is the one for spirotetramat
- ketohydroxy, which is the last metabolite in the degradation sequence and for which the KOC mo del is more suitable than the Kd mo del ( i.e. , the coefficient of variation is smaller).
**A .**  **Assumptions of the Tier 1 Rice Model v.1.0 (Provisional for**  **Watercress Use**  **)** Most of the assumptions used in th e Tier 1 Rice Model v.1.0 model help ensure that the outputs are protective of most environments ass ociated with rice agriculture (noted though, that it is provisionally

being used to represent the uses on watercress). Rice cultivation differs from watercress in that for the latt er the water is constantly flowing while for rice, the field is flooded. The model assumptions include the following (see USEPA 2007 for parameterization information and further details) : 1. Movement of pesticide on suspended sediment is not considered (while for this use, water is constantly

circulated except when pesticides are applied ; the water circulation may promote pesticide movement)
. 2. Degradation does not occur (notwithstanding, the TTR are relativel y persistent to aerobic aquatic metabolism and moderatel y persistent to aerobic soil metabolism)
. 3. Volatilization and other dissipation processes are not considered (for spirotetramat, the vapor pressure and Henry’s Law Constant are low , indicating a low potential for volatilization, but other dissipation processes like degradation and metabolism are not considered)
. 4. The partitioning to sediment is instantaneous. 5. Water is available for human exposure instantaneously (because the chemical is likely circulated, it appears that the water would be discharge d into adjacent bodies of water and would be of concern primarily at the end of the season)
. 6. Water column depth is 10 cm . (Based upon unofficial data, it appears that actual depth is in the range of 1 to 3 inches or around 2.5 to ~ 8 cm )
. As per the regis trant , c hemical applications occur 24 hours after water circulation is stopped and water circulation is restarted 24 hours after application.) 7. Sediment depth is 1 cm.7

8. All pore space is saturated with water. 9. Organic carbon fraction is 0.01 ( i.e. , 1% OC)
. 10. Bu lk density

is 1300 kg/m 3

. 11. Grain density is 2650 kg/m 3

. The a erobic soil half

- life for the TTR is on the order of 2 03.7 day s and their partitioning is not too strong with a KOC of 65.32 L/Kg OC (mobile according to FAO 2000 , using the ketohydroxy

as the representative chemical ). The aerobic soil metabolism half
- life for spirotetramat
- ketoh ydroxy, the last degradate in the degradation pathway is 12.38 days , and the rate determining step . It is noted that neither the degradation of the pesticide nor the m ass transfer from the aqueous phase to the sediment are considered in this conceptualization, which greatl y simplifies the model. The absence of degradation adds conservatism to the model ( i.e. , estimated concentrations should be higher than those usually found in rice paddies , considered representative of use on watercress ) . The absence of mass transfer processes can either add or reduce conservatism depending on numerous conditions such as whether the pesticide is soil or water applied and whether actual degradation occurs preferentiall y in the sediment or the water compartment (refer to uncertainties below) ; however, consideration of this parameter is a refinement beyond a Tier 1 conceptualization. Spirotetramat is actually foliarly applied and the che micals (spirotetramat, spirotetramat
- enol and spirotetramat
- ketoh ydroxy) do not readil y bind to bottom sediment.
**B . Uncertainties of the Tier 1 Rice Model v.1.0 (Provisional**  **ly used for Watercress)**  T he T ier 1 Rice M odel v.1.0 provides screening
- level estimates and as such, are expected to exceed peak values found in the environment in most cases. They represent paddy

discharge water that has not degraded , and has not diluted with uncontaminated water outside the paddy
. T he aerobic aquatic metabolism is ~ 204 days for the TTR and the overall anaerobic aquatic metabolism, hydrol ys is and aqueous photoly sis processes are considered relatively persistent
. It is noted that the aqueous photoly sis of the parent spirotetramat is 14.4 Phoenix, AZ days. In sterile water, the only

species observed is spirotetramat ( i.e. , the enol and ketohydrox y are not observed) , while in natural water, spirotetramat
- enol is observed peaking at 3 day s and declining to <20% AR after 10 days and the ketoh ydrox y is not observed
. The model does not account for crop interception which appears to be a very important component for this particular chemical. Furthermore, it does not account for dilution occurring in the receiving body of water. Direct discharge water is generall y not expected to be used as a drinking water source. It was noted that the EDWCs obtained by the Tier 1 Rice Model v.1.0 were substantially higher than the acute EDWC for the TTR obtained in the previous assessment ; therefore, various parameters were explored in order to assess the impact of certain variables and characterize the reported results
. For DWA, e valuation of the Tier I Rice Model v
. 1.0 indicate d that modeled within
- paddy estimates are conservative, exceeding peak m easured concentrations of pesticides in water bodies8

well downstream of rice paddies in five evaluated studies by less than one order of magnitude to multiple orders of magnitude . The five studies assessed were conducted in Louisiana and California using four different pesticides (USEPA 2007)
. Itappears that the range of modeled estimate exceedances over measured concentrations is most likely in response to chemical, environmental, and study - specific factors. Estimates from the Tier I model generall y do not represent ty

pical concentrations found in human drinking water, as they represent direct paddy discharge water. **1. Crop Interception**  According to the label s ( e.g. , MOVENTO ® SC) spirotetramat must be applied (tank mixed) with a spray

adjuvant or additiv e having spreading and penetrating properties to maximize leaf uptake and sy stemicity of the active i ngredient within treated plants
. The Section 3 label further say s that “Sufficient leaf tissue must be present for uptake and translocation of this product...” Later it say s that, “Following application to plant foliage, MOVENTO is full y sy stemic, moving through phloem and xylem to new sh oot, leaf and root tissues...” This chemical is primaril y active against immature insect life stages ( i.e
. , aphids) that ingest plant tissue, and fertility

of adult female insects may be reduced. Spirotetramat has limited contact activity ; it is a sy stemic lipid biosy nthesis inhibitor, is ambimobile ( i.e. , it moves up and down through the plant tissue), and must be taken up b y foliage in order to be effective against sucking insects. Therefore, under actual conditions of watercress cultivation, most of the applied pesticide should be taken up b y the treated foliage ( i.e. , leaf tissue) of the watercress to be effective against aphids. Th e fraction remaining on the leaves (expressed as a percentage) , is referred to here as the crop interception ( or efficienc y of application) 6

. A crop interception of 100% is the goal ( i.e. , that is, as much as possible of the chemical is intercepted b y the foliage and not lost in the soil)
. The re is a fraction on the leaves that will also degrade (referred to as foliar decay), and a portion of it may be washed off of the leaves b y rainfall or irrigation into the stream water below the foliage
. T he impact of crop interception on the initial concentration in the rice paddy water is potentially signi ficant
. If the crop interception is, f or example 8 0%, the acute concentration c ould be reduced potentially by 8 0%
. **2. Pesticide Degradation**  Under field conditions , the aerobic soil metabolism is likely to be the main dissipation process when the pesticide is applied. The reason is that spirotetramat is applied on dried field via foliar ground, aerial or chemigation methods. The aerobic soil metabolism half
- lives for spirotetramat and for spirotetramat
- enol are <1 day . The aerobic soil metabolism half
- lif e of spirotetramat
- ketoh ydroxy is 12.38 days. Once the field is flooded , for the total toxic residues ( i.e. , spirotetramat, spirotetramat
- enol and spirotetramat
- ketoh ydrox y) , th e concentration will be reduced onl y slowl y through degradation b y aerobic aqu atic metabolism (aerobic aquatic

6 The hereby named crop interception (or efficiency of application), should not be confused with other variables which are input values in PRZM, such as the application efficiency (lb a.i./A), PLDKRT, which is the pesticide decay on plant foliage (day- 1 ), and FEXTRC, which is the foliar extraction coefficient for pesticide wash off per centimeter of rainfall (cm - 1 ).9

metabolism is ~ 1 day

for the parent, ~ 8 1 days for spirotetramat
- enol, and could not be evaluated for spirotetramat
- ketoh ydrox y and is thus, considered persistent) , and by aquatic photoly sis in clear, shallow water (aqueous photoly sis is 14.4 day for the parent, but no data on degradation for the TTR , spirotetramat
- ketoh ydrox y could be persistent to that route). Assuming that the field remains dry for one day

and that aerob ic soil metabolism takes place during that time, the peak ( acute ) EDWCs for spirotetramat w ould be reduced potentiall y from 395 ppb to around 373 ppb , and will decrease thereafter slowl y through aerobic aquatic metabolism . The annual average would be ~ 214 ppb
. If the field remains dry for two day s pre flood and aerobic soil metabolism takes place during that time, the peak (acute) EDWCs for spirotetramat would be reduced potentiall y from 395 ppb to around 353 ppb, and will decrease thereafter slowl y throu gh aerobic aquatic metabolism. The annual average would be ~2 02 ppb. In the aqueous photol ys is study , using sterile water , spirotetramat
- ketohydroxy was not an observed d egradate . If one assumes that the half
- life for the enol and the ketohydrox y are similar to the one for the parent (with a half
- life of the order of 14.4 Phoenix, AZ day s), the 1 ye ar mean value would be of the order of 2 2 ppb. See the **Figure 1**
.

**Figure 1 .**  **Spirotetramat Concentration v**  **s . Time for Watercress Use**  **Taking Into Account**

**Aqueous Photolysis of the Parent Compound**
**3. Dilution and**  **Flow of Receiving Waters from**  **Cultivated Area s**  T he amount of pesticide which reaches a moving body of water will be removed in the field under actual conditions of watercress cultivation. This would be expected to occur likel y at the end of the season, downstream from the site at which it is applied by advection in the flowing water. The rate of removal depends on the rate of flow through the site. River/stream velocity varies from day

to day based on the volume of flow and changing cross
- sectional area. Ty pical10

ranges of velocity

vary from zero (at the time of tidal flow direction change) to 7 miles per hour 7

. The pesticide in the flowing water will also spread from the center of mass during the flow. **Table I**  **. B**  presents the distance downstream of the center of mass of the applied spirotetramat after a period of one day

for flow rates up to 3 mph. **Figure 2**  show s a conceptualization of a receiving flowing water body of water getting effluents from a watercress field. It is also noted that some receiving bodies of water might not be flowing, such as in the case of ponds and reservoirs . In such instances, dilutio n would be the primary process occurring
. **Table I**  **. B**  **. Downstream Movement from Site of Application of Spirotetramat**  **in Flowing Water in One Day Flow Rate**  **(ft/sec) Flow Rate (**  **mph )**  **Downstream D**  **istance (mi)**  0.1 0.1 3.5 0.2 0.3 7.0 0.6 0.9 21.1 1.0 1.5 35.2 1.4 2.1 49.3 1.8 2.6 63.4 2.2 3.2 77.4

**Figure 2 .**  **Conceptual Model of a Flowing Water Body of Water**  **Receiving Effluent from a Treated Watercress Field**

7 http://hypertextbook.com/facts/2006/NervanaGaballa.shtml ; see also e. g. the following, http://www.pitt.edu/~jdnorton/sail/Speed/index.html and http://www.nps.gov/miss/riverfacts.htm all accessed 07/17/2 012. For example, the Ohio River at Pittsburg appears to flow at up to 1.2 mph and the Mississippi River ranges from 1.2 to 3 m

ph depending on the amount of flow and the reach in which it is measured. See also NOAA Technical Report NOS CO
- OPS 025, “Curre nts of the St. John River, Florida Spring and Summer of 1998” September 1999 ( http://tidesandcurrents.noaa.gov/publications/techrpt25.pdf ; accessed 07/17/2012).11

**4. Modeling Spirotetramat**  **- ketohydroxy Only**  Besides degradation, one could assume that the only species occurring in the field would be spirotetramat
- ketohydroxy . The reason is the relatively short aerobic half

- lives of the parent compound and of spirotetramat
- enol. If that is the case, the EDWCs will be smaller because spirotetramat
- ketoh ydroxy molecular weight is smaller than for the parent compound. As a result, the predicted EDWCs would be proportionally reduced. If the transformation of spirotetramat to spirotetramat
- ketoh ydrox y is quantitative, the seasonal equivalent “ application rate ” would be as follows: Rate = (0. 40 lb parent/A) (317.39 g spirotetramat
- ketohydroxy /mol) / (373.45 g parent/mol) Rate = 0. 34 lb spirotetramat
- ketoh ydrox y/A/season This value is ~15% smaller than the one modeled using the application rate for the parent.
**C .**  **Conclusions for Surface Waters** In conclusion , the Tier 1 Rice M odel v.1.0 is conservative. It is apparent that the combination of crop interception, pesticide degradation , stream flow , and runoff dilution from the areas in the watershed which are not treated (see **Tables I.A**  and **I.B** ) , has the potential to reduce the conservative EDWCs provided in **Table 1 -**  **1**
.12 **Appendix II Groundwater EDWCs**  Bananas are also considered a minor use. “ US banana production is very limited; in 2009, US total banana production reached almost 7,000 mmt, or 0.01% of the total world production, on an estimated 16,000 acres. Hawaii is by far the largest banana producer in the United States, followed by Florida.” 8 The NASS shows, however, that the banana acreage in HI in 2008 was only

1,300 A. 9 The modeling approach for groundwater calculations was described in the previous DWA ( DP Barcode D 345275, dated 01/22/2008 ) . Thus, focus is placed onl y in the changes related to the application rate . The application rates are calculated in the same way (see sample calculation of the application rate in the previous DWA)
. The tables of input parameters follow.
**A . Input Values for Groundwater**  **Tables II.A** , **II.B** and **II.C** provide the input parameter values in SCI
- GROW, in modeling groundwater. **Table II**  **. A**  **. SCI -**  **GROW (v2.3) input parameter values for spirotetramat use on bananas**  **and plantains 1** 

**PARAMETER (units) VALUE(S)**  **SOURCE COMMENT**  Maximum Application Rate (lb a.i./A) 0.25 Proposed label. Maximum single application rate in five applications on bananas and plantains. Number of Applications per Year 5 Proposed label.

– Organic Carbon Partition Coefficient (Koc ; mL/g) 237 OECD Monograph Annex B. Spirotetramat. B.8 Fate and Behaviour Represents the median of five values as

follows: 184, 437, 201, 385, 237 mL/g OC for the parent compound (KOC does not show mo re than a three
- fold variation among values). Aerobic Soil Metabolism Half
- life (days) 0.25 Represents the median value, since there are four or more values ( FL SL , t 1/2 = 0.30 days; SL , t 1/2 = 0.24 days ; SiL, t 1/2 = 0.26 days; Si , t 1/2 = 0.09 days)
. 1 Parameters are selected as per Guidance for Selecting Input Parameters in Modeling the Environmental Fate and Transport of Pesticides; Version 2.1, 10/22/2009 (http://www.epa.gov/oppefed1/models/water/input_parameter_guidance.htm 07/17 /12)
.

8 http://edis.ifas.ufl.edu/fe901 (accessed 07/19/2012). 9 http://www.nass.usda.gov/Statistics_by_State/Hawaii/Publicatio ns/Fruits_and_Nuts/annban.pdf (accessed 07/18/2012). See also http://www.ipmcenters.org/cropprofiles/docs/hibananas.html
.13

**Table II .**  **B . SCI**  **- GROW (v2.3) input parameter values for transformation product**  **spirotetramat -**  **enol use on bananas and plantains**  **1**

**PARAMETER (units) VALUE(S)**  **SOURCE COMMENT** 
Maximum Application Rate (lb a.i./A) 0.202 Proposed label. It is assumed that the transformation is quantitative in the aerobic soil metabolism study. Maximum concentration observed in the aerobic soil metabolism study or 100% by application rate by mole ratio = (1.00)(0.25)(301.39/373.45) = 0.202 lb a.i./A for bananas and plantains Number of Applications per Year 5 Proposed label.

– Organic Carbon Partition Coefficient (Koc ; mL/g) 27 OECD Monograph Annex B. Spirotetramat. B.8 Fate and Behaviour Represents the lowest of four values as

follows: 27, 65, 29 and 99 mL/g OC for the parent compound (there is greater than a three
- fold variation among values).
Aerobic Soil Metabolism Half
- life (days) 0.035 Represents the median value, since there are four or more values ( FL SL , t 1/2 = 0.30 days ; SL , t 1/2 = 0.02 days ; SiL , t 1/2 = 0.16 days ; Si , t 1/2 = 0.02 days). It is noted that there is mo re than 5
- fold difference from the lowest to the highe st values. 1 Parameters are selected as per Guidance for Selecting Input Parameters in Modeling the Environmental Fate and Transport of Pesticides; Version 2.1, 10/22/2009 (http://www.epa.gov/oppefed1/models/water/input_parameter_guidance.htm 07/17 /12)
. **Table II .**  **C . SCI**  **- GROW (v2.3) input parameter values for transformation product**  **spirotetra ma**  **t -**  **ketohydroxy use on bananas and plantains**  **1**

**PARAMETER (units) VALUE(S)**  **SOURCE COMMENT**  Maximum Application Rate (lb a.i./A) 0.0 510 Proposed label. Maximum concentration observed in the aerobic soil metabolism study by application rate by mole ratio = (0.240)(0. 25 )(317.39/373.45) = 0. 0510 lb a.i./A for bananas and plantains Number of Applications per Year 5 Proposed label.

– Organic Carbon Partition Coefficient (Koc ; mL/g) 48.1 OECD Monograph Annex B. Spirotetramat. B.8 Fate and Behaviour Represents the median of five values as

follows: 43.1, 48.1, 42.0, 99.7 and 93.7 mL/g OC for the parent compound (there is less than a three
- fold variation among values).
Aerobic Soil Metabolism Half
- life (days) 4.65 Represents the median value, since there are four or more values ( FL sandy loam , t 1/2 = 16.7 days ; Sandy loam , t 1/2 = 4.2 days ; Silt loam , t 1/2 = 5.1 days; Silt , t 1/2 = 1.5 days). There is more than 5
- fold difference from the lowest to the highest values. 1 Parameters are selected as per Guidance for Selecting Input Parameters in Modeling the Environmental Fate and Transport of Pesticides; Version 2.1, 10/22/2009 (http://www.epa.gov/oppefed1/models/water/input_parameter_guidance.htm 07/17 /12)
.14

**B . Resulting Values for Groundwater**  **Table II**  **. D**  summarizes the groundwater estimates from SCI
- GROW. For the total residues (spirotetramat, spirotetramat
- enol and spirotetramat
- ketoh ydrox y) the EDWC , suitable for acute and chronic exposure , is 1.24 x 10 - 3 ppb
. **Table II .**  **D . Maximum Tier I Estim**  **ated Dri nking Water Concentrations (EDWCs) for drinking**  **water risk assessment based on aerial application on bananas and plantains at 1.25**  **lb a.i.**  **/A/season Drinking**  **Water Source (M**  **odel) Type of** 

**Exposure ESTIMATED DRINKING WATER CONCENTRATION (EDWC)**  **( ppb) Spirotetram**  **at Spirotetram**  **at**  

** enol** **Spirotetram at**  ****

**ketohydroxy Total** 

**Residues** Ground
- water (SCI
- GROW) Ac ute and

Chronic 7.06 x 10 - 5 5.1 5 x 10 - 5 1.12 x 10 - 3 1.24 x 10 - 3 **C. Output Files from SCI -**  **GROW**

SCIGROW VERSION 2.3 ENVIRONMENTAL FATE AND EFFECTS DIVISION OFFICE OF PESTICIDE PROGRAMS U.S. ENVIRONMENTAL PROTECTION AGENCY

SCREENING MODEL FOR AQUATIC PESTICIDE EXPOSURE SciGrow version 2.3 chemical:Spirotetramat time is 5/29/2012 11: 7: 9

------------------------------------------------------------------------ Application Number of Total Use Koc S oil Aerobic rate (lb/acre) applications (lb/acre/yr) (ml/g) metabolism (days)

------------------------------------------------------------------------ 0.250 5.0 1.250 2.37E+02 0.2

---------------------------- -------------------------------------------- groundwater screening cond (ppb) = 7.06E
- 05 ************************************************************************15 SCIGROW VERSION 2.3 ENVIRONMENTAL FATE AND EFFECTS DIVISION OFFICE OF PESTICIDE PROGRAMS U.S. ENVIRONMENTAL PROTECTION AGENCY

SCREENING MODEL FOR AQUATIC PESTICIDE EXPOSURE SciGrow version 2.3 chemical:Spirotetramat (enol) time is 5/29/2012 11: 9:58

------------------------------------------------------------------------ Application Number of Total Use Koc Soil Aerobic rate (lb/acre) applications (lb/acre/yr) (ml/g) metabolism (days)

------------------------------------------------------------------------ 0.202 5.0 1.010 2.70E+01 0.0

---------------------------------------------- -------------------------- groundwater screening cond (ppb) = 5.15E
- 05 ************************************************************************

SCIGROW VERSION 2.3 ENVIRONMENTAL FAT E AND EFFECTS DIVISION OFFICE OF PESTICIDE PROGRAMS U.S. ENVIRONMENTAL PROTECTION AGENCY

SCREENING MODEL FOR AQUATIC PESTICIDE EXPOSURE SciGrow version 2.3 chemical:Spirotetramat
- ket o (hydroxy) time is 5/29/2012 11:11:52

------------------------------------------------------------------------ Application Number of Total Use Koc Soil Aerobic rate (lb/acre) applications (lb/acre/yr) (ml/g) metabolism (days)

------------------------------------------------------------------------ 0.051 5.0 0.255 4.81E+01 4.7

---------------------------------------------- -------------------------- groundwater screening cond (ppb) = 1.12E
- 03 ************************************************************************16 **Appendix III Use Characterization**  **Table IIIA**  is a summary of all agricultural use patterns for spirotetramat in the l abels for BYI 8330 150 OD Insecticide (oil dispersion , Reg. No. 264
- 1051 ) , MOVENTO ® SC (suspension concentrate , Reg. No. 264
- 1050 ) , and the UL TOR® (suspension concentrate, Reg. No. 264
- 1075)
. The use s shaded ye llow are the proposed new one s while the uses **bold and underlined** are the modeled ones
. **Table IIIA**  **. Summary use information for spirotetramat based on labels for BYI 8330 150 OD Insecticide), MOVENTO**  **® and ULTOR** **® .**  **The new uses are shaded yellow**  **.**

**USE SINGLE**  **APP. RATE**  **(lb. a.i./A) NUMBER** 

**OF APPS. SEASONAL** 

**APP. RATE**  **(lb. a.i./A) INTERVAL** 

**BETWEEN APP**  **S . (days)**  **APP.**

**METHOD PHI** 

**(days)** Soy bean 0.08 2 0.16 7 G* , A 21 Tropical Fruits (acerola, avocado, black sapote, canistel, feijoa, guava, longan, lychee, mamey sapote, mango, papaya, passionfruit, persimmon, pulasan, rambutan, sapodilla, Spanish lime, star apple, starfruit, wax jambo, white sapote , jaboticaba) 0.16 3 0. 40 14 G* , A, Airblast 1

Legume Vegetables (Crop Group 6, except dry soybean) ( Edible Podded and Succulent Shelled Pea and Bean and Dried Shelled Pea and Bean Bean ( Lupinus spp., including grain lupin, sweet lupin, white lupin, and white sweet lupin) Bean ( Phaseolus spp., including field bean, kidney bean, lima bean, navy bean, pinto bean, runner bean, snap bean, tepary bean, wax bean) Bean ( Vigna spp., including adzuki bean, asparagus bean, blackeyed pea, catjang, Chinese longbean, cowpea, Crowder pea, moth bean, mun g bean, rice bean, Southern pea, urd bean, yardlong bean) Pea ( Pisum spp. including dwarf pea, edible
-pod pea, English pea, field pea, garden pea, green pea, snow pea, sugar snap pea) Other Beans and Peas (Broad bean (fava), Chickpea (garbanzo bean), Guar, Jackbean, Lablab bean (hyacinth bean), Lentil, Pigeon pea, soybean (immature seed), Sword bean ) 0.08 2 0.16 7 G* , A, C 1 edible podded, succulent beans and peas; 7 dry shelled beans and peas

Globe artichoke 0.12 ~5 0.5 7 G, A, C 317

**Table IIIA**  **. Summary use information for spirotetramat based on labels for BYI 8330 150 OD Insecticide), MOVENTO**  **® and ULTOR** **® .**  **The new uses are shaded yellow**  **.**

**USE SINGLE**  **APP. RATE**  **(lb. a.i./A) NUMBER** 

**OF APPS. SEASONAL** 

**APP. RATE**  **(lb. a.i./A) INTERVAL** 

**BETWEEN APP**  **S . (days)**  **APP.**

**METHOD PHI** 

**(days)** Citrus Fruit (Crop Group 10
- 10 , including , calamondin, citrus citron, citrus hybrids like chironja, tangelo and tangor, grapefruit, kumquat, lemon, lime, mandarin or tangelo, sweet and sour orange, pummelo, Satsuma mandarin, Australian lime (desert, finger, and round), Brown River finger lime, Japanese summer grapefruit, Mediterranean mandarin, Mount White lime, New Guinea wild lime, Russell River lime, s weet lime, Tachibana orange, T ahiti lime, Trifoliate orange, uniq fruit, including cultivars, varieties and/or hybrids of these commodities ) 0.16 2 0.3 2 21 G* , A, Airblast 1

Grape and Small Fruit Vine Climbing Crop Subgroup 13
- 07F (except Fuzzy kiwifruit/ includes grape, gooseberry, maypop, Schisandra berry, hardy kiwifruit) 0.13 2 0.2 30 G* , A, Airblast 7

Pome Fruit (Crop Group 11
- 10 , including apple, crabapple, loquat, mayhaw, pear, Asian pear, quince , azarole, Chinese quince, Japanese quince, medlar, tejocote , hybrids, cultivars and/or varieties of these ) 0.14 3 0. 4 14 G* , A, Airblast 7

Stone Fruit (Crop Group 12 , including apricot, sweet and tart cherry, nectarine, peach, plum
various kinds, plumcot , and fresh and dried prune) 0.14 2 0.24 14 G* , A, Airblast 7

Tree Nuts (Crop Group 14 plus pistachio , including almond, beechnut, Brazil nut, butternut, cashew, chestnut, chinquapin, filbert or hazelnut, hickory nut, macadamia nut or bush nut, pecan, pistachio, black walnut , and English or Persian walnut) 0.14 3 0.34 14 G* , A, Airblast 7

Hops 0. 10 2 0.2 14 G* , A, Airblast 7 Christmas Tree Plantations 0.16 2 0.3 2 14 G* , A, Airblast N/A18

**Table IIIA**  **. Summary use information for spirotetramat based on labels for BYI 8330 150 OD Insecticide), MOVENTO**  **® and ULTOR** **® .**  **The new uses are shaded yellow**  **.**

**USE SINGLE**  **APP. RATE**  **(lb. a.i./A) NUMBER** 

**OF APPS. SEASONAL** 

**APP. RATE**  **(lb. a.i./A) INTERVAL** 

**BETWEEN APP**  **S . (days)**  **APP.**

**METHOD PHI** 

**(days)** Fruiting Vegetables (Crop Group 8
- 10 including eggplant, groundcherry, okra, pepinos, bell and non
-bell pepper ( cayenne, chili pepper, habanero, jalapeno, pablano, pimento and serranero ) , tomatillo , tomato , African eggplant, Bush tomato, cocona, currant tomato, garden huckleberry, goji berry, martynia, naranjilla, pea eggplant, roselle, scarlet eggplant, sunberry, tree tomato, including varieties and/ or hybrids of these commodities ) 0.08 2 0.16 7 G, A, C 1

Leafy Vegetables (Crop Group 4 including amaranth
- various kinds, arugula
- roquette, cardoon, celery, celtuce , chervil, Chinese celery, chrysanthemum, corn salad, garden cress, cress - various kinds, dandelion, sorrel dock, endive, Florence fennel, lettuce
- head and leaf, orach, parsley, garden and winter purslane, radicchio or red chicory, rhubarb, spinach
- various kinds, Swiss chard , taro leaves ) 0.08 2 0.16 7 G, A, C 3

Brassica (Cole) Leafy Vegetables (Crop Group 5 including broccoli, broccoli raab, Brussels sprouts, cabbage, cauliflower, cavalo broccolo, Chinese broccoli, Chinese cabbage (bok choy), Chinese cabb age (napa) , Chinese mustard cabbage (gai choy) , collards, kale, kohlrabi, mizuna, mustard greens, mustard spinach, rape greens) 0.08 2 0.16 7 G, A, C 1

Potato and Other Tuberous and Corm Vegetables (Crop Subgroup 1C including arracacha , arrowroot, Chinese and Jerusalem artichoke, edible canna, bitter and sweet cassava, chayote
- root, chufa, dasheen or taro, ginger, leren, potato, sweet potato, tanier, turmeric, yam bean, true yam) 0.08 2 0.16 7 G, A, C 71 9

**Table IIIA**  **. Summary use information for spirotetramat based on labels for BYI 8330 150 OD Insecticide), MOVENTO**  **® and ULTOR** **® .**  **The new uses are shaded yellow**  **.**

**USE SINGLE**  **APP. RATE**  **(lb. a.i./A) NUMBER** 

**OF APPS. SEASONAL** 

**APP. RATE**  **(lb. a.i./A) INTERVAL** 

**BETWEEN APP**  **S . (days)**  **APP.**

**METHOD PHI** 

**(days)** Bushberry and Low Growing Berry Subgroups ( Crop Subgroups 13
- 07B and 13
- 07H i ncluding aronia berry, b earberry, b ilberry, blueberry (highbush and lowbush), Chilean guava, c loudberry, c ranberry **10** , c urrant (black, buffalo, native, and red), e lderberry, European barberry, g ooseberry, e dible honeysuckle, j ostaberry, Juneberry, m

untries, l ingonberry, Partridgeberry, salal, s ea buckthorn, and cultivars, varieties, and/or hybrids of these ) 0.16 3 0.47 7 G* , A, Airblast 7

**Watercress 11**  **0.2 2**  **0.4 7**  **G, A, C 3**  **Banana and Plantains 12**  **0.25 5**  **1.25 14**  **G*, A,** **Airblast 1**  Coffee 0.16 3 0.47 21 G* , A, Airblast 14 Pineapple 0.16 2 0.32 14 G* , A, Airblast 1
Pomegranate 0.16 2 0.32 14 G* , A, Airblast 1 Bulb Vegetables Crops of Crop Subgroup 3
- 07A (i ncluding: d aylily (bulb), f ritillaria (bulb), g arlic (bulbs of common, great - headed, s erpent), l ily (bulb), o n ion (bulbs of common, Chinese, p earl, potato onion), s hallot (bulb), plus cultivars, varieties, and/or hybrids of these ); Crops of Crop Subgroup 3
- 07B , (i ncluding: Chinese chive (fresh leaves), c hive (fresh leaves), e legans hosta, f ritillaria (leaves), k

urrat, l eek (Allium porrum, Lady’s, wild), o nion (Beltsville bunching, fresh, green, macrostem, tree [tops], w elsh [tops]), s hallot (fresh leaves), plus cultivars, varieties, and/or hybrids of thes e ) 0.08 2 0.16 7 G, A, C 3 for CS 3
- 07A; 7 for CS 3
- 07B

*High air velocity, low volume or air curtain sprayers; G = ground; A = aerial; C = chemigation
10 Cranberry was modeled using the provisional cranberry model, yielding lower EDWCs than watercress. 11 Crop selected to model surface water EDWCs. 12 Crop selected to model groundwater EDWCs.