1
30­
DAY
ERROR
RESPONSE
TO
"
REVISED
DRINKING
WATER
ASSESSMENT
FOR
NAPROPAMIDE"
AND
"
DRINKING
WATER
ASSESSMENT
FOR
NAPROPAMIDE
FOR
TERRESTRIAL
USES".
DP
Barcode
D305601.
11/
12/
04.

Header
Page
and
Location
(
Document
is
not
paginated)
Error
Correction
EFED
Response
Summary
1,
paragraph
1
The
vapor
pressure
should
be
corrected
to
1.7x10­
7
torr
(
see
Product
Chemistry
Considerations,
D305599,

10/
29/
04).
The
vapor
pressure
used
(
4
x
10­
6
torr)
is
an
error,
but
substituting
the
correct
value
(
1.7
x
10­
7
torr)
does
not
change
the
estimates
of
surface
water
exposure
and
risk
using
PRZM­
EXAMS.
The
correct
value
was
placed
in
the
document
at
this
time.

Summary
2,
paragraph
3
The
SCI­
GROW
surface
water
drinking
water
concentration
is
overestimated
and
should
be
recalculated
using
correct
input
values.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Surface
Water
Modeling
of
Terrestrial
Uses
for
Napropamide
3,
paragraph
2
Add
"
ppb"
after
the
value
1.67.

Modeling
does
not
take
into
account
that
only
1/
3
of
an
orchard
acre
receives
a
napropamide
treatment
since
band
applications
are
made.
"
ppb"
label
will
be
added
at
this
time.

Banding
comment
is
substantive
comment
and
will
be
addressed
after
public
comment
has
been
received.

Surface
Water
Modeling
of
Terrestrial
Uses
for
Napropamide
3,
Table
1
and
Appendix
A,
Table
1
The
EECs
presented
for
GA
pecan
reflect
two
applications
of
6
lb
ai/
A
at
7
day
intervals.
There
are
no
current
labels
with
a
food
crop
use
rate
at
6
lb
ai/
A.

Labels
allow
two
applications
only
in
the
Western
region.
The
minimum
reapplication
interval
is
90
days.

A
reassessment
of
the
EEC
values
for
various
scenarios
should
be
re­
done
using
correct
label
information.

There
is
a
footnote
1
at
the
end
of
the
table
but
it
is
not
found
in
the
table.

The
registrant
does
not
have
a
copy
of
the
"
2/
8/
02
Input
Parameter
Guidance"
to
verify
that
the
input
values
are
appropriate.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.
The
modeling
was
conducted
based
on
the
Use
Closure
Memo
between
the
registrant
and
Agency.

Error
was
corrected
by
adding
references
in
Table
1
to
the
footnotes.

Document
will
be
provided
to
the
registrant.

Surface
Water
Modeling
of
4,
Table
2
and
Appendix
A,
Table
2
There
are
no
current
labels
with
a
pecan
use
rate
at
6
lb
ai/
A.
The
maximum
use
rate
for
pecans
is
4
lb
ai/
A.
A
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.
The
modeling
2
30­
DAY
ERROR
RESPONSE
TO
"
REVISED
DRINKING
WATER
ASSESSMENT
FOR
NAPROPAMIDE"
AND
"
DRINKING
WATER
ASSESSMENT
FOR
NAPROPAMIDE
FOR
TERRESTRIAL
USES".
DP
Barcode
D305601.
11/
12/
04.

Header
Page
and
Location
(
Document
is
not
paginated)
Error
Correction
EFED
Response
Terrestrial
Uses
for
Napropamide
second
application
is
only
allowed
for
pecans
grown
in
the
Western
region
at
a
90
day
interval.
Napropamide
is
mainly
applied
as
a
band
application,
not
broadcast.

Modeling
should
be
revised
to
take
into
consideration
a
lower
total
lb
ai
applied
per
acre.

Appendix
A,
Table
2
Input
Parameters:

GA
pecans
do
not
receive
a
second
application
so
no
interval
between
applications
should
be
included
in
this
assessment.

The
vapor
pressure
should
be
corrected
to
1.7
x
10­
7
torr.
The
water
solubility
is
74
mg/
L
at
25
°
C;
delete
the
"
x
10"
after
the
°
C.
(
see
Product
Chemistry
Considerations).

The
photolytic
half­
life
should
be
corrected
to
0.0047
d
(
6.8
min
x
1hr/
60
min
x
1
day/
24
hr)
as
noted
in
the
EFED
risk
assessment
document
(
D303453,
11/
30/
04,

pages
20,
28).

Footnote
2
should
be
corrected
to
delete
the
reference
to
the
6
lb
ai/
A
rate.
was
conducted
based
on
the
Use
Closure
Memo
between
the
registrant
and
Agency.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.
The
modeling
was
conducted
based
on
the
Use
Closure
Memo
between
the
registrant
and
Agency.

The
vapor
pressure
used
(
4
x
10­
6
torr)
is
an
error,
but
substituting
the
correct
value
(
1.7
x
10­
7
torr)
does
not
change
the
estimates
of
surface
water
exposure
and
risk
using
PRZM­
EXAMS.
Use
of
the
correct
water
solubility
value
(
74
mg/
L)
also
does
not
change
estimated
exposure.
The
correct
water
solubility
value
was
placed
in
the
document
at
this
time.

The
correct
half­
life
for
parent
napropamide
(
6.8
minutes)
was
added
to
the
document.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Ground
Water
Assessment
5,
paragraph
2
Delete
reference
to
the
6
lb
ai/
A
rate
since
this
is
not
a
use
pattern
for
napropamide
except
in
turf
and
ornamentals.
Repeat
applications
are
only
permitted
for
certain
crops
in
the
Western
region.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received
3
30­
DAY
ERROR
RESPONSE
TO
"
REVISED
DRINKING
WATER
ASSESSMENT
FOR
NAPROPAMIDE"
AND
"
DRINKING
WATER
ASSESSMENT
FOR
NAPROPAMIDE
FOR
TERRESTRIAL
USES".
DP
Barcode
D305601.
11/
12/
04.

Header
Page
and
Location
(
Document
is
not
paginated)
Error
Correction
EFED
Response
The
SCI­
GROW
surface
water
drinking
water
concentration
is
overestimated
and
should
be
recalculated
using
current
input
values.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.
Modeling
was
conducted
using
the
Input
Parameter
Guidance
dated
2/
28/
02.

Ground
Water
Assessment
5,
Table
3
and
Appendix
B,
Table
1
The
table
mistakenly
includes
a
reference
to
"
NC
Tobacco",
which
should
be
changed
to
"
GA
Pecan".

There
are
no
current
labels
with
a
pecan
use
rate
at
6
lb
ai/
A.

The
maximum
use
rate
for
pecans
is
4
lb
ai/
A.
A
second
application
is
only
allowed
for
pecans
grown
in
the
Western
region.
Even
if
a
second
application
were
made,
the
typical
interval
between
herbicide
applications
is
90
days.

Napropamide
is
mainly
applied
as
a
band
application,

not
broadcast
so
that
modeling
should
take
into
consideration
a
lower
total
lb
ai
applied
per
acre.
There
is
precedent
for
EFED
to
use
33%
of
the
total
use
rate
for
band
applications
in
tree
nut
and
fruit
orchards
and
this
factor
should
be
applied
to
the
risk
assessments
for
napropamide.
Reference
to
document
is
unclear.
This
comment
will
be
addressed
after
public
comment
has
been
received.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.
The
modeling
was
conducted
based
on
the
Use
Closure
Memo
between
the
registrant
and
Agency.
4
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
1,
List
of
end
use
products
Remove
the
50­
WP,
5­
G,
and
2­
E,
since
they
have
been
cancelled.
Current
products
include:
Devrinol
50­
DF
Selective,
2­
G
Ornamental,
10­
G
Selective,

4­
F
Selective,
4­
F
Ornamental,
50­
DF
Ornamental,

2­
EC
and
2­
EC
Ornamental.
Remove
50­
DF
at
the
end
of
the
list
since
it
is
a
duplicate.
Information
on
formulations
supported
in
reregistration
will
be
corrected
in
document
at
this
time.

I.
Executive
Summary
4,
first
paragraph
In
the
fourth
line,
remove
"
wettable
powder",
as
all
registrations
with
this
formulation
have
been
cancelled.
Information
on
formulations
will
be
corrected
in
document
at
this
time.

I.
Executive
Summary
4,
second
paragraph;
8,
5th
paragraph
See
comments
under
Section
I.
B
of
this
document
for
comments
on
the
difference
between
the
laboratory
and
field
data.
Registrant
intends
to
submit
additional
information
that
will
be
considered
at
a
later
date.
EFED
will
review
the
data
when
it
is
submitted
to
the
Agency.

I.
Executive
Summary
4,
third
paragraph
Regarding
the
comment
"
Because
the
label
does
not
specifically
require
soil
incorporation ."
All
labels
specify
that
the
product
must
be
mechanically
or
watered­
in.
Newer
labeling
has
included
the
comment
that
the
product
should
be
incorporated
or
irrigated
within
24
hours.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

A.
Potential
Risks
to
Non­
target
Nonendangered
Organisms
4,
first
paragraph
Devrinol
50­
WP
has
been
cancelled.

No
other
label
allows
for
the
6
lb
ai/
A
use
rate
except
on
turf
and
ornamentals.

For
cranberries,
the
15
lb
ai/
A
rate
is
for
muck
soils
only
found
in
the
PNW;
this
rate
represents
less
than
3%
of
the
entire
cranberry
acreage
and
is
not
representative
of
the
maximum
use
rate
(
9
lb
ai/
A).

Risk
assessments
should
be
refined
to
reflect
these
more
representative
use
rates.
Information
on
formulations
will
be
corrected
in
document
at
this
time.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Aquatic
organism
5,
second
paragraph,
8
The
registrant
has
data
for
Lemna
and
Anabaena
Specific
data
on
Lemna
and
Anabaena
will
be
5
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
risks
which
will
be
submitted.
considered
after
the
data
is
submitted
to
the
Agency.

Mammalian
Risks
5
Risk
assessment
inputs
need
to
be
corrected.
Substantive
comment
that
will
be
addressed
at
a
later
date.

B.
Potential
Risks
to
Non­
target
Listed
and
Endangered
Organisms/
Aquatic
Listed
Species
6,
third
paragraph
Applications
of
napropamide
are
never
made
at
7­

day
intervals
between
applications
but
rather
90
day
intervals.
Risk
assessments
should
be
refined
to
include
this
information.
Substantive
comment
that
will
be
addressed
at
a
later
date.

C.
Major
Uncertainties
and
Data
Gaps
8,
bullet
1
Data
are
available
for
Lemma
and
Anabaena
and
will
be
submitted.
Specific
data
on
Lemna
and
Anabaena
will
be
considered
when
they
are
submitted
to
the
Agency.

C.
Major
Uncertainties
and
Data
Gaps
8,
bullet
2
Applications
of
napropamide
are
never
made
at
7­

day
intervals
between
applications
but
90
days.

Risk
assessments
should
be
refined
to
reflect
this
actual
use
pattern.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

C.
Major
Uncertainties
and
Data
Gaps
8,
bullet
3,
4
The
aqueous
photolysis
half­
life
should
be
corrected
to
6.8
min.
The
correct
half­
life
for
parent
napropamide
(
6.8
minutes)
was
added
to
the
document.

C.
Major
Uncertainties
and
Data
Gaps
8,
bullet
5
See
comments
under
Section
II.
C.
of
this
document
for
a
discussion
of
the
difference
between
the
laboratory
and
field
data.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

C.
Major
Uncertainties
and
Data
Gaps
8,
bullet
6
Foliar
dissipation
data
were
never
developed
for
napropamide
since
it
is
applied
to
the
soil
or
areas
under
trees
and
only
a
small
portion
of
the
applied
product
will
reach
off­
site
areas
from
spray
drift
or
runoff.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

A.
Stressor
Source
and
Distribution
9
Remove
the
reference
to
the
50­
WP
and
2­
E
since
these
registrations
have
been
cancelled.
Information
on
formulations
will
be
corrected
in
document
at
this
time.

2.
Overview
of
Pesticide
Usage
10,
first
paragraph
The
registrant
notes
that
the
data
from
NCFAP
is
almost
8
years
old
and
not
representative
of
current
sales.
See
Section
II
of
this
document
for
further
EFED
used
best
available
data
from
all
sources.
6
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
comments.

10,
second
paragraph
Correct
the
following
statement:
"
Maximum
label
rates 
range
from
2
lbs
ai/
A
to
8
lbs
ai/
A".
No
label
bears
a
single
application
rate
of
8
lb
ai/
A
for
any
crop.

Correct
the
following
statement:
"
Maximum
rates
for 
tomatoes 
hot
peppers 
strawberries 
are
2
applications
per
year
at
4
lbs
ai/
A
or
one
application
per
year
at
6
lbs
ai/
A."
All
labels
for
these
crops
allow
a
single
application
at
4
lbs
ai/
A.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

2.
Overview
of
Pesticide
Usage
10,
Table
1
Delete
all
references
in
the
table
to
the
WP
formulation.
Correct
the
formulation
type
"
FIC"
to
"
FlC:
Information
on
formulations
will
be
corrected
in
document
at
this
time.

2.
Overview
of
Pesticide
Usage,

Table
1
10,
Almond,
Pistachio
The
footnotes
c
and
d
deleted
from
the
WP
rows
should
be
moved
elsewhere
in
the
document.
The
reference
to
these
footnotes
was
placed
in
the
table
under
the
heading
"
application
interval."

10­
13,
Table
1
Almond,

Pistachio
All
nut
crop
application
methods
should
be
corrected
to
C,
BT,
IR,
DS.

For
the
DF,
revise
the
information
to
separate
use
patterns
for
Almonds
from
Pistachios.
Almond
use
should
read
as
it
now
stands
in
the
section,
but
for
Pistachios
the
information
should
read:
App
Rate
4,
No
App
1,
App
Interval
NA,
Max
Load
4.

Add
information
for
the
FlC
to
include
all
nuts
(
Almond,
Pecan,
Filbert,
Pistachio,
Walnut),
as
follows:
Max
App
Rate
4,
No
App
1,
App
Interval
NA,
Max
Load
4,
App
Method
C,
BT,
IR,
DS.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

10­
13,
Berries
and
Small
Fruit
Correct
the
application
methods
to
BT,
C,
IR,
DS
unless
as
specified
for
individual
crops.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

10­
13,
Blueberry
For
the
DF
formulation,
change
No.
App
to
1
and
Substantive
comment
that
will
be
addressed
after
7
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
Max
load
to
4.
public
comment
has
been
received.

11,
Strawberry
Correct
application
methods
to
BT,
IR,
DS,
C
for
all
formulations.

Add
a
row
for
the
EC
formulation,
as
follows:

Max
App
4,
No.
App.
NS,
App
Interval
NS,
Max
Load
NS.

For
the
DF
formulation,
change
No.
App.
to
1,

change
App
Interval
to
NA,
change
Max
Load
to
4.

Add
a
row
for
the
FlC
formulation
as
follows:
Max
App
1,
No
App
1,
App
Interval
NA,
Max
Load
4.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

11,
Cranberries
For
15
lb
ai/
A,
change
No.
App.
to
1,
change
App
Interval
to
NA,
change
Max
Load
to
15.
Note
that
this
is
not
the
most
representative
use
rate
in
cranberries
(
see
comments
under
"
A.
Potential
Risks
to
Non­
target
Non­
endangered
Organisms"
in
this
table).

Change
the
application
method
for
the
Granular
formulation
to
A,
B,
IR,
G.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

11,
Currants
Change
No.
App.
to
1,
change
App
Interval
to
NA,

change
Max
Load
to
4.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

11,
Brassica
and
Leafy
Vegetables
Separate
Asparagus
from
other
listed
vegetables.

New
row
for
Asparagus
should
contain
the
following
information
for
the
DF
formulation:
Max
App
4,
No.
App.
1,
App
Interval
NS,
Max
Load
4.

Correct
the
application
methods
to
BT,
B,
C,
SI,
IR
for
all
listed
Brassica
and
Leafy
Vegetables.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

11,
Citrus
Remove
Nectarines
from
this
section
and
include
in
Stone
Fruit,
below.

Add
row
for
the
FlC
formulation
for
all
citrus,
as
follows:
Max
App
Rate
4,
No
App
1,
App
Interval
NA,
Max
Load
4.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.
8
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
Correct
all
citrus
application
methods
to
BT,
DS,
C,

IR
for
all
formulations.

11,
Stone
Fruit
Add
a
row
for
the
FlC
formulation
as
follows:
Max
App
Rate
4,
No
App
1,
App
Interval
NA,
Max
Load
4.
Correct
all
application
methods
to
BT,
DS,
C,
IR
for
all
formulations.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

12,
Apple,
Pear
Add
a
row
for
the
FlC
formulation,
as
follows:

Max
App
Rate
4,
No
App
1,
App
Interval
NA,
Max
Load
4.
Correct
all
application
methods
for
Pome
Fruit
to
BT,
DS,
C,
IR
for
all
formulations.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

12,
Eggplant
Correct
application
methods
for
all
Fruiting
Vegetables
to
BT,
C,
SI,
IR.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

12,
Pepper
and
Tomato
Correct
application
methods
for
all
Fruiting
Vegetables
to
BT,
C,
SI,
IR
for
all
formulations.

Add
a
row
for
the
DF
formulation,
as
follows:

Max
App
Rate
2,
No
App
NS,
App
Interval
NS,

Max
Load
2.

Add
a
row
for
the
FlC
formulation,
as
follows:

Max
App
Rate
2,
No
App
1,
App
Interval
NA,
Max
Load
2.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

12,
Other
Vegetables
For
the
DF
row,
change
No
App
to
1,
change
App
Interval
to
NA,
and
change
Max
Load
to
4.
Correct
application
methods
to
BT,
C,
SI,
IR.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

12,
Tropical
Fruits
Correct
the
spelling
of
Avocado.

Correct
application
methods
to
BT,
DS,
C,
IR
for
all
formulations.
Spelling
corrected
in
document.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

12,
Tobacco
Add
a
row
for
the
G
formulation,
as
follows:

Max
App
Rate
1.4,
No
App
NS,
App
Interval
NS,

Max
Load
unknown.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.
9
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
Correct
application
methods
to
B,
BT,
SI,
IR
for
all
formulations.

12,
Sweet
Potato
For
the
DF
row
change
No.
App
to
1,
change
App
Interval
to
NA,
and
change
Max
Load
to
2.

Correct
application
methods
to
BT,
B,
SI,
IR.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

13,
Mint
For
the
DF
row,
change
No.
App
to
1,
change
App
Interval
to
NA,
and
change
Max
Load
to
4.

Correct
application
methods
to
B,
IR
for
all
formulations.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

13,
Olive
Correct
application
methods
to
BT,
DS,
C,
IR.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

13,
Trees/
Ornamentals,

Ground
Covers,

Herbaceous
plants/
woody
shrubs/
vines,
lawns
and
turf,
potting
soil
Add
DF
uses
from
EPA
Reg.
No.
70506­
38.

Add
FlC
uses
from
EPA
Reg.
No.
70506­
37.

Correct
application
methods
for
Shade
Trees,

Ground
cover,
Herbaceous
plants
to
G,
BT,
SI,
SB,

DS,
IR
for
all
formulations.

Correct
application
methods
for
turf
to
B,
DS,
IR,
G
for
all
formulations.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

13,
Footnotes
Add
FlC
=
Flowable,
A=
air.
The
registrant
assumed
that
there
was
no
difference
between
the
application
methods
ST
and
BT,
and
B
and
SB.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

2.
Overview
of
Pesticide
Usage
14,
Table
2
The
number
of
applications
to
pecans
should
be
1
(
based
on
UPI
market
research
data).
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

3.
Chemical
and
Physical
Properties
15,
Table
3
Correct
the
vapor
pressure
to
1.7
x
10­
7
mm
at
25
°
C.
Correct
Henry's
Law
constant
to
8.1x
10­
10at
25
°
C.

Correct
the
water
solubility
to
74
at
25
º
C
(
see
comments
to
"
Napropamide
RED
Product
Chemistry
Considerations").

Correct
the
soil
photolysis
half
life
to
28
days.
Vapor
pressure,
Henry's
Law,
water
solubility,
soil
photolysis
half­
life,
and
aqueous
photolysis
halflife
values
will
be
corrected
in
document
at
this
time.
However,
correcting
these
input
values
in
modeling
did
not
change
the
estimates
of
exposure.
10
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
a.
Fate
in
the
Terrestrial
Environment
16
Correct
the
vapor
pressure
to
1.7x10­
7
mm.

a.
Fate
in
the
Aquatic
Environment
16
Correct
Henry's
Law
constant
to
8.1x10­
10
atmm3
mole.

b.
Aquatic
Environment
22,
paragraph
1
Correct
the
laboratory
data
half­
life
to
6.8
minutes.

D.
Key
Uncertainties
and
Information
Gaps
27,
second
bullet,
third
bullet
Correct
the
aqueous
photolysis
half­
life
to
6.8
minutes.

1.
Specific
Considerations
28,
section
1.
d
Correct
the
word
"
increased"
to
"
increase".
Corrected
in
document
at
this
time.

2.
Planned
Analysis
30
Paragraph
1:
delete
the
reference
to
WP.

Paragraph
2:
change
"
Devrinol
G"
to
"
Devrinol
10G".
Corrected
in
document
at
this
time.

Corrected
in
document
at
this
time.

a.
Fate
in
the
Terrestrial
Environment
33,
paragraph
1
Correct
the
vapor
pressure
to
1.7x10­
7
mm.

a.
Fate
in
the
Aquatic
Environment
34,
third
paragraph
Correct
Henry's
Law
constant
to
8.1x10­
10
atmm3
mole
(
based
on
the
correct
vapor
pressure
and
water
solubility).
Vapor
pressure
and
Henry's
Law
values
will
be
corrected
in
document
at
this
time.

3.
Aquatic
Resource
Exposure
Assessment
35
The
information
from
NCFAP
is
almost
8
years
old
and
not
accurate
for
the
current
use
data
for
napropamide.
See
Section
II.
A.
of
this
document
for
further
comments.
EFED
used
best
available
data
from
all
sources.

3.
Aquatic
Resource
Exposure
Assessment
36,
paragraph
2
Correct
the
assumption
regarding
the
7
day
application
interval
to
90
days.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

3.
Aquatic
Resource
Exposure
Assessment
36,
paragraph
4
Correct
the
model
assumptions
for
cranberries
to
reflect
the
fact
that
herbicides
are
not
applied
to
a
field
which
is
flooded
0­
4
hours
after
application.

According
to
Dr.
Hilary
Sandler,
University
of
Massachusetts
Cranberry
Research
Station,
fields
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.
11
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
are
not
flooded
for
at
least
5
months
after
a
napropamide
(
or
other
herbicide)
application.
A
copy
of
the
"
Best
Management
Practices
Guide
for
Massachusetts
Cranberry
Production"
can
be
provided
to
support
this
use
pattern.

3.
Aquatic
Resource
Exposure
Assessment,

Table
7
37­
38,
Table
7
Header:
correct
the
kg/
h
units
for
Application
Rate
 
the
rates
in
the
table
are
in
lb
ai/
A.

Correct
maximum
application
rates
for
all
crops
to
4
(
the
WP
formulation
registration
is
cancelled)

except
for
turf
which
is
applied
at
either
4
or
6
lb.

ai/
A.
Under
"
Maximum
No.
of
Applications"
for
1
application,
delete
all
but
PA
turf
since
there
are
no
other
uses
at
the
6
lb
ai/
A
rate.
Under
"
Maximum
No.
of
Applications"
for
two
applications,
delete
OR,
PA,
NC
apples,
GA
pecan,
and
FL
citrus
since
the
labels
only
allow
a
single
application.
CA
tomato
and
FL
pepper
were
not
included
in
the
modeling
so
these
should
also
be
deleted.

Correct
the
model
input
to
90
day
application
intervals
for
Western
region
crops
only.
Note
that
the
granular
may
be
applied
by
air
to
cranberries.

Correct
the
vapor
pressure
to
1.7x10­
7
mm
at
25
°
C.

Correct
the
water
solubility
to
74
mg/
L
at
25
°
C.

Correct
the
photolysis
half­
life
to
0.0047
days.
Proper
application
amounts
in
kg/
ha
were
used
as
inputs
into
Table
7.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Vapor
pressure,
water
solubility,
and
soil
photolysis
half­
life
will
be
corrected
in
document
at
this
time.
However,
correcting
these
input
values
in
modeling
did
not
change
the
estimates
of
exposure.

3.
Aquatic
Resource
Exposure
Assessment
39,
Table
8
Correct
the
time
from
application
to
flooding
to
135
days
(
typical
application­
to­
flooding
dates
range
from
120­
150
days).
The
typical
application
dates
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.
12
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
for
napropamide
is
from
the
end
of
March
to
mid­

April;
harvest
is
in
mid­
September.
Input
for
cranberry
model
from
Dr.
Hilary
Sandler,
UMass
Amherst
Cranberry
Research
Station.
Copies
of
cranberry
BMP
available
upon
request.

Correct
the
maximum
use
rate
to
9
since
the
maximum
use
rate
of
15
is
only
for
muck
soils
in
the
PNW
(
WA
and
OR)
and
the
model
does
not
model
this
type
of
soil
(
muck
soils
are
high
in
organic
carbon
unlike
the
soil
modeled).
Muck
soils
represent
less
than
3%
of
the
total
cranberry
acres
in
the
US.

Correct
the
aqueous
photolysis
half­
life
to
0.113
hr.

(
based
on
the
6.8
min
half­
life).

3.
Aquatic
Resource
Exposure
Assessment
40,
Table
9
Correct
all
models
for
maximum
use
rate
of
4
lb
ai/
A.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

b.
Spray
Applications
and
Residues
43,
Table
11
The
application
interval
is
90
days,
not
7
days
and
the
maximum
use
rate
is
4
lbs
ai/
A.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

5.
Non­
Target
Plant
Exposure
Modeling
43­
45,
Tables
12,
13,
14
Correct
model
inputs
to
delete
6
lb
ai/
A
scenarios.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Napropamide
Toxicity
Categories
46,
Table
15
The
footnote
is
unclear
since
none
of
the
fish
acute
toxicity
tests
demonstrated
acute
toxicity
<
1
mg/
L.
EFED
corrected
statement:
acute
toxicity
>
1
mg/
LH
Napropamide
Toxicity
Categories
47,
Table
16
The
accession
number
for
acute
toxicity
for
mallard
duck
refers
to
other
studies
and
the
appropriate
MRIDs
are
79548
and
79555.
The
MRID
for
acute
toxicity
for
laboratory
rats
is
not
a
valid
number
and
should
be
corrected
to
40362902
(
for
technical).
EFED
agrees
with
comments
and
corrections
will
be
made.

A.
Risk
Estimation
 
Integration
of
Exposure
and
Effects
Data
49
Paragraph
1:
Correct
the
last
sentence
since
Appendix
G
does
not
summarize
the
LOCs
used
in
the
risk
assessment.
The
author
might
be
referring
to
Appendix
E.
Document
was
corrected
according
to
the
registrant's
comment.
13
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
Paragraph
2:
The
use
patterns
should
be
corrected
since
two
applications
are
only
allowed
in
the
Western
region.

Paragraph
6:
Correct
the
interval
between
applications
for
the
Western
region
from
7
days
to
90
days.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

A.
Risk
Estimation
 
Integration
of
Exposure
and
Effects
Data
50,
Table
18
None
of
the
crop
scenarios
except
turf
and
ornamentals
are
applied
at
6
lb
ai/
A.
and
these
assessments
should
be
removed.
The
interval
between
applications
should
be
corrected
to
90
days.
The
crop
scenarios
with
two
applications
should
be
deleted
except
for
the
Western
region
scenarios
[
i.
e.,
delete
FL
citrus,
PA
apple,
NC
apple,
GA
pecan
with
two
applications
of
4
lb
ai/
A].
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

A.
Risk
Estimation
 
Integration
of
Exposure
and
Effects
Data
51,
Table
19
A
revised
risk
assessment
should
be
conducted
with
appropriate
input
parameters
(
see
comments
for
Table
8)
and
the
RQs
revised.

Correct
the
Note
at
the
end
of
the
footnote
section
which
refers
to
Table
18
 
it
should
refer
to
Table
10.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

A.
Risk
Estimation
 
Integration
of
Exposure
and
Effects
Data
51­
52,
Table
20
None
of
the
crop
scenarios
except
turf
are
applied
at
6
lb
ai/
A.
and
these
assessments
should
be
removed.

The
interval
between
applications
should
be
corrected
to
90
days.
The
crop
scenarios
with
two
applications
should
be
deleted
except
for
the
Western
region
scenarios
[
i.
e.,
delete
FL
citrus,
PA
apple,
NC
apple,
GA
pecan
with
two
applications
of
4
lb
ai/
A].
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

A.
Risk
Estimation
 
Integration
of
53,
Table
21
None
of
the
crop
scenarios
except
turf
and
ornamentals
are
applied
at
6
lb
ai/
A.
and
these
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.
14
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
Exposure
and
Effects
Data
assessments
should
be
removed.

Delete
the
crop
scenario
"
Aerial
Airblast,
Spray
Chemigation"
since
only
the
10G
formulation
is
allowed
to
be
applied
by
air
and
only
to
cranberries.

The
interval
between
applications
should
be
corrected
to
90
days.
The
crop
scenarios
with
two
applications
should
be
deleted
except
for
the
Western
region
scenarios
[
i.
e.,
delete
FL
citrus,
PA
apple,
NC
apple,
GA
pecan
with
two
applications
of
4
lb
ai/
A].

Footnote
1,
found
at
the
end
of
the
table,
needs
to
be
added
to
the
table.
Footnote
is
already
in
Table.

A.
Risk
Estimation
 
Integration
of
Exposure
and
Effects
Data
53
The
input
parameters
for
TERRPLANT
should
be
corrected
so
that
the
orchard/
vineyard
rate
is
4
lb
ai/
A
and
the
interval
between
applications
corrected
from
7
to
90
days.
In
addition,
the
fact
that
in
most
cases
(
turf
excluded),
napropamide
is
applied
as
a
band
treatment
such
that
an
entire
acre
is
not
treated
is
not
taken
into
account.
Except
for
mint,
turf,
and
cranberry,
napropamide
is
not
applied
by
air.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

A.
Risk
Estimation
 
Integration
of
Exposure
and
Effects
Data
54,
Table
22
None
of
the
crop
scenarios
except
turf
and
ornamentals
are
applied
at
6
lb
ai/
A.
and
these
assessments
should
be
removed.
The
interval
between
applications
should
be
corrected
to
90
days.
The
crop
scenarios
with
two
applications
should
be
deleted
except
for
the
Western
region
scenarios
[
i.
e.,
delete
FL
citrus,
PA
apple,
NC
apple,
GA
pecan
with
two
applications
of
4
lb
ai/
A].
Footnote
1,
found
at
the
end
of
the
table,
needs
to
be
added
to
the
table.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Footnote
is
already
in
Table.
15
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
B.
Risk
Description
 
Interpretation
of
Direct
Effects
57
Bullet
3:
Correct
the
half­
life
to
6.8
minutes.

Bullet
4:
Correct
the
statements
after
a
reassessment
of
Fl
citrus
and
GA
pecans
scenarios
at
a
single
application
of
4
lb
a.
i/
A.

Bullet
5:
After
the
cranberry
model
is
re­
run
with
more
realistic
input
parameters
based
on
discussions
with
Dr.
Hilary
Sandler,
the
concentration
cited
should
be
corrected.
Based
on
the
half
life
in
soil,
it
is
unlikely
that
water
will
become
contaminated
with
napropamide
when
cranberry
fields
are
flooded
120­
150
days
after
the
application.

Bullet
6:
Reports
for
some
aquatic
plant
species
are
available
and
will
be
submitted.
Half­
life
was
corrected
in
the
document.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

EFED
will
review
the
data
when
it
is
submitted
to
the
Agency.

B.
Risk
Description
 
Interpretation
of
Direct
Effects
59
Paragraph
1:
The
last
sentence
should
be
revised
after
the
correct
use
pattern
(
one
application
at
4
lb
ai/
A)
is
included
in
the
risk
assessment.

Paragraph
2:
Correct
the
use
pattern
for
orchards
and
vineyards.

Paragraph
3:
delete
6
lb
ai/
A
as
the
highest
application
rate
for
food
crop
uses.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

B.
Risk
Description
 
Interpretation
of
Direct
Effects
60
Second
paragraph:
The
first
sentence
should
be
corrected
to
give
the
correct
use
pattern
(
one
application
at
4
lb
ai/
A).
The
chronic
risk
to
mammals
was
carried
out
using
the
incorrect
assumption
that
the
interval
between
applications
in
the
Western
region
is
7
days;
this
interval
should
be
90
days.
The
risk
assessment
did
not
take
into
consideration
the
fact
that
napropamide
is
most
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.
16
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
often
applied
by
band
application
such
that
an
entire
acre
is
not
treated.

B.
Risk
Description
 
Interpretation
of
Direct
Effects
65
Paragraph
1:
the
last
sentence
is
correct
with
the
exception
that
the
10G
formulation
can
be
applied
to
cranberries
by
air.

Bullet
2:
Correct
the
aqueous
half­
life
to
6.8
minutes.

Bullet
3:
See
comments
in
Section
II.
C.
above.

Bullet
4:
the
appropriate
time
between
applications
is
90
days,
not
7.

Bullet
5:
Band
applications
are
appropriate
for
many
crops.
See
Section
II.
B.
above
for
additional
comments.
Document
will
be
corrected
at
this
time.

Document
will
be
corrected
at
this
time.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received
B.
Risk
Description
 
Interpretation
of
Direct
Effects
66
Bullet
1:
Correct
the
first
sentence
since
none
of
the
labels
prohibit
use
on
tobacco
in
NC.

Bullet
6:
Agronomic
factors
are
readily
available
from
either
the
cranberry
grower
associations
or
university
personnel
involved
with
cranberry
production.

Bullet
8:
correct
the
spelling
of
the
word
"
content".
EFED
used
NC
tobacco
as
a
surrogate
in
the
absence
of
other
PRZM­
EXAMS
tobacco
scenarios.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received
Document
corrected
at
this
time.

B.
Risk
Description
 
Interpretation
of
Direct
Effects
68
Paragraph
1:
Correct
the
half­
life
to
6.8
minutes.

Bullet
2:
EFED
should
conduct
a
review
of
the
open
literature
from
ECOTOX
in
case
data
are
available
to
refine
the
risk
assessments.
Document
was
corrected.

Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Appendix
A
A­
1,
Table
The
MRID
for
accumulation
in
fish
is
missing
and
is
39774.
Footnote
2
should
be
corrected
to
replace
Document
was
corrected.
17
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
Syngenta
with
United
Phosphorus.

Appendix
B
B­
1­
2,
Table
B­
1
Inputs
should
be
corrected
for
use
rates
and
application
interval.

The
water
solubility
is
74
mg/
L
at
25
°
C.

Correct
the
aqueous
photolysis
half­
life
to
6.8
min.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received
Water
solubility
and
the
aqueous
photolysis
halflife
were
corrected
in
the
document.

Appendix
B
B­
3­
46
Comments
were
previously
noted
regarding
the
input
parameters
for
the
PRZM­
EXAMS
modeling.
Correct
input
parameters
were
included
in
document
but
did
not
change
the
estimates
of
exposure.

Appendix
B
B­
44,
paragraph
1
The
last
sentence
refers
to
Table
XXX
and
should
be
Table
B­
2.
Document
was
corrected.

Appendix
B
B­
44,
paragraph
2
The
last
sentence
refers
to
Table
YYY
and
should
be
Table
B­
3.
Document
was
corrected.

Appendix
B
Table
B­
3
Application
rate
should
be
9
lb
ai/
A.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Appendix
C
C­
1­
3
Comments
were
previously
noted
regarding
the
input
parameters
for
the
SCI­
GROW
modeling.
Substantive
comment
that
will
be
addressed
after
public
comment
has
been
received.

Appendix
D
The
last
page
of
what
appears
to
be
Appendix
D
is
paginated
as
E­
1
but
labeled
as
Table
D­
1.

Highlighted
information
in
red
was
blacked
out
in
the
black
and
white
copy
submitted
to
registrant,

making
it
impossible
to
verify
the
accuracy
of
the
information.

There
are
no
MRIDs
associated
with
the
data
and
the
endpoints
could
not
be
verified.
Page
number
was
fixed.

Redlining
was
removed
from
the
document
for
public
comment.

Registrant
is
referring
to
Table
D.
1.
The
MRIDs
are
found
in
Table
E.
1.

Appendix
E
Pages
should
be
repaginated.
Document
was
corrected.

Appendix
E
E­
2,
Table
71­
1:
the
accession
number
is
incorrect
and
should
be
MRID
79548
and
79555
71­
2:
The
MRIDs
2005019,
2005025
and
2005026
are
incorrect
and
not
found
in
NPIRS.
One
other
EFED
agrees
with
the
following
comment:

71­
1:
the
accession
number
is
incorrect
and
should
be
MRID
79548
and
79555
71­
2:
In
regards
to
MRIDs
2005019,
2005025
and
18
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
MRID
for
this
guideline
which
should
be
added
is
41610202.

72­
1:
MRID
2005027
is
not
found
in
NPRIS.
2005026.
The
following
corrections
have
been
made:
MRID
2005025
is
replaced
with
MRID
25893
MRID
2005026
is
replaced
with
MRID
25894
MRID
2005019
is
replaced
with
MRID
49497
Additionally
the
LC50
of
this
study
in
this
should
be
changed
from
5600
ppm
to
>
56,000
ppm.

In
response
to
the
comment:
"
One
other
MRID
for
this
guideline
which
should
be
added
is
41610202"

EFED
has
no
record
of
this
MRID.

In
response
to
the
comment
"
72­
1:
MRID
2005027
is
not
found
in
NPRIS",
this
MRID
is
not
listed
in
Table
E2.

Appendix
E
E­
5,
Table
1
The
accession
number
is
not
valid
and
the
MRIDs
should
be
79548
and
79555.
EFED
agrees
with
comment.
Correction
will
be
made.

Appendix
E
E­
5,
Table
2
The
MRIDs
2005019,
2005025
and
2005026
are
not
valid.
The
MRID
listed
as
25894
should
be
corrected
to
125894.
One
additional
study
not
listed
is
a
mallard
duck
study
41610202.
In
response
to
comment
"
The
MRIDs
2005019,

2005025
and
2005026,
the
corrections
have
been
madents.

In
response
to
comment
"
The
MRID
listed
as
25894
should
be
corrected
to
125894".
The
Agency
records
indicate
that
MRID
25894
is
the
correct
number.

In
response
to
comment
"
One
additional
study
not
listed
is
a
mallard
duck
study
41610202",
the
Agency
will
make
the
correction
will
be
made
once
the
data
evaluation
of
the
study
is
located.
19
30­
DAY
ERROR
RESPONSE
TO
"
EFED
RISK
ASSESSMENT
FOR
THE
NAPROPAMIDE
REREGISTRATION
ELIGIBILITY
DOCUMENT".
DP
Barcode
D303453.

Header
Page
and
Location
Error
Correction
EFED
Response
Appendix
E
E­
6,
Table
3
The
accession
number
230602
is
not
valid
and
should
be
40362902.
The
Agency
agrees
with
this
comment.
The
correction
will
be
made.

Appendix
E
E­
7,
Table
4
The
MRID
2005027
is
not
valid
and
should
be
removed.
The
Agency
agrees
with
this
comment.
The
correction
will
be
made.

Appendix
E
E­
9,
Table
7
The
accession
number
229228
is
not
valid
for
the
listed
species.
The
correct
MRID
is
65360.
The
Agency
agrees
with
this
comment.
The
correction
will
be
made.

Appendix
G
Pages
of
this
appendix
are
numbered
as
part
of
Appendix
F.
The
Appendix
G
should
be
labeled
Appendix
F
