	U. S. ENVIRONMENTAL PROTECTION AGENCY

	WASHINGTON, DC 20460

	

OFFICE OF  

PREVENTION, PESTICIDES

AND TOXIC SUBSTANCES 

MEMORANDUM							PC Code No. 129106

DP Barcode: D323681

Date:  September 20, 2006

SUBJECT:	IR-4 Tolerance Petition for Cymoxanil (Tanos®) Use on Grapes
and Hops		

TO:		Shaja Brothers, Risk Manager Reviewer

Daniel Rosenblat, Risk Manager

Registration Division (7505P)

FROM:	Dirk Young, Ph.D., Environmental Engineer

Thomas Steeger, Ph.D., Senior Scientist

Environmental Fate and Effects Division (7507P)

THROUGH:	Elizabeth Behl, Chief

Environmental Risk Branch IV/EFED (7507P)

The Environmental Fate and Effects Division (EFED) has reviewed the
Inter-Region 4 (IR-4)  tolerance petition (DP Barcode D271572) for use
of cymoxanil (Tanos®) on grapes (east of the Rocky Mountains) and hops
to control downy mildew (Plasmopara viticola). Tanos® is a formulated
endproduct containing 25% famoxadone (PC Code 113202) and 25% cymoxanil.
Based on cymoxanil alone, the maximum proposed application rate for
grapes is 0.25 lb a.i./acre with a maximum of 10 applications; the
maximum proposed application rate for hops is 6 applications of 0.25 lbs
a.i./A..  The reapplication interval is 7 days.  The maximum annual rate
of cymoxanil alone on grapes is 2.5 lb a.i./acre while the maximum
annual rate on hops is 1.5 lbs a.i./A.  

The newly proposed application rates are higher than those evaluated in
the previous Section 3 registration for the use of cymoxanil on potatoes
(DP Barcode D233366) and for the initial IR-4 tolerance petition for use
of cymoxanil (Curzate 60 DF) on hops (DP Barcode D271572).  Based on
environmental fate and ecological effect data contained in the original
Section 3 and on estimates of terrestrial and aquatic exposure generated
using the newly proposed application rates, neither acute nor chronic
levels of concern (LOCs) are exceeded for aquatic animals.   There is
substantial uncertainty introduced into the assessment due to the lack
of data on foliar dissipation rates.  If the rate is significantly lower
than 35 days (default value), for example 2 days, risk estimates are
below both acute and chronic risk levels of concern all non-target
animals except mammals where chronic risk LOC is exceeded.  However, if
the default foliar dissipation half-life (35 days) is used for
terrestrial assessments, the chronic risk LOC is exceeded for both birds
and mammals.  

In the previous Section 3, cymoxanil was expected to pose negligible
risks to terrestrial and aquatic animals on both an acute and chronic
exposure basis.  Although no chronic levels of concern were exceeded for
animals, the chronic reproductive toxicity endpoints (reduced number of
young) in birds, fish and aquatic invertebrates were sufficient to
trigger future studies to examine the endocrine disrupting potential of
this compound.  Although the newly proposed application rates are higher
than those previously assessed, the generally low acute toxicity of the
chemical combined with the chemical’s rapid degradation, reduced risk
estimates below levels of concern when less conservative estimates of
the foliar dissipation half-life were considered.  Since no magnitude of
residue data have been reviewed to substantiate the potentially rapid
dissipation of cymoxanil from foliar surfaces, there is uncertainty
regarding the potential for chronic risk.  

EFED is uncertain about the ecological effects of cymoxanil when it is
used in combination with famoxadone as is the case with Tanos®   In
2003, a Section 3 registration of famoxadone (DP Barcode D276071) noted
that technical grade cymoxanil is less toxic than famoxadone to fish on
an acute exposure basis.  Famoxadone is very highly toxic to fish and
aquatic invertebrates on an acute exposure basis and the end-use
product, Tanos® 50DF, appears to be at least as toxic as famoxadone to
rainbow trout (Oncorhynchus mykiss).  Famoxodone is practically nontoxic
to birds on both an acute oral and subacute dietary exposure basis. 
End-product testing with birds indicated that cymoxanil/famoxadone
combined is practically nontoxic to birds on an acute oral exposure
basis; however, the end product tested did not contain the same ratio of
cymoxanil/famoxadone as that of Tanos® 50DF. 

EFED recommends that the label restrictions imposed for the previous
registration be maintained for this tolerance petition as well.  For
further details on the environmental fate and ecological effects of
cymoxanil, please refer to DP Barcode D233366, a portion of which is
attached.

Environmental Fate Assessment

For a more thorough review of the environmental fate of cymoxanil, the
reader is referred to  the ecclogical risk assessment written in support
of the Section 3 registration (DP Barcode D233366).  Cymoxanil is
expected to degrade quickly in the environment.  Cymoxanil hydrolyzes
rapidly under both alkaline and neutral media, but is stable to
hydrolysis at pH 5.  Cymoxanil photodegrades quickly in aqueous media,
and is very susceptible to aerobic and anaerobic biodegradation.

The major degradates observed in the hydrolysis and photolysis in water
studies, were not observed in large amounts in the aerobic soil
metabolism study.  These degradation products are expected to be more
likely to occur in surface waters after runoff events. 

In aerobic soil metabolism studies conducted in foreign soils, various
degradates were detected and identified.  The distribution and
concentration of such degradates was dependent on the soil types.  In
most cases, the degradates comprised a small fraction of the applied
material, or were quickly degraded further.  In metabolism studies
conducted in domestic soils, with the exception of carbon dioxide, no
single degradate exceeded 10% of the applied material.  

The lack of persistence predicted by the laboratory studies is confirmed
in the field.  The reported half-lives of cymoxanil at both an Elkton,
MD test site, and at a Madera, CA test site were short and ranged
between 1 to 9 days.  Additionally, no detections of cymoxanil were
observed during the field dissipation studies below the 0 to 15 cm soil
depth at any of the test intervals. 

Even though cymoxanil was reported to be mobile in four soils tested,
EFED believes that cymoxanil does not pose a threat to ground waters. 
Cymoxanil is not expected to persist in soils due to the chemical’s
susceptibility to microbial-mediated degradation.  The four minor
degradates of these processes appear to be only weakly adsorbed to
soils, and are also predicted to be short lived and of little concern to
the fate assessment.  Furthermore, EFED believes that cymoxanil is not
likely to persist in surface waters because it is vulnerable to both
hydrolysis in alkaline and neutral media, and to aqueous photolysis.

Ecological Effects Assessment

For a more comprehensive assessment of the ecological effects of
cymoxanil, the reader is referred to the ecological risk assessment
written in support of the Section 3 registration (DP Barcode D233366). 
Cymoxanil is practically nontoxic to birds on both an acute exposure
(LD50 > 2,250 mg/kg) and subacute dietary exposure (LC50 > 5,620 mg/kg
of diet) basis; chronic toxicity in birds (NOAEC = 100 mg/kg) included
reductions in the number of eggs laid, number of viable embryos, number
of normal hatchlings, number of 14-day survivors and reductions in
hatchling weight.  Cymoxanil was only slightly toxic (LD50 = 760 mg/kg)
to mammals on an acute exposure basis; chronic toxicity in mammals
(NOAEC=6.5 mg/kg) included reductions in first-generation pup viability.
 Cymoxanil is practically nontoxic to bees (LD50 > 25) and earthworms
(LC50 = 2,208) on an acute exposure basis.  Additionally, cymoxanil is
slightly toxic to freshwater and marine fish (LC50 range 29 - 91 mg/L)
and invertebrates (EC50 range: 27 - 47 mg/L).  Chronic toxicity testing
in freshwater (NOEC = 0.00098 mg/L) and marine fish (NOEC = 0.094 mg/L)
reduced growth and survival.  Chronic toxicity testing in freshwater
(NOEC = 0.067 mg/L) and marine (NOEC = 1.70 mg/L) invertebrates reduced
survival, growth and reproduction (number of young produced per female).

Aquatic Exposure Assessment

Estimated environmental concentrations for surface water were derived
using GENEEC 2 (Appendix A).  Peak, 1-in-10 year 21-day and 60-day
average concentrations are 8.8, 1.8 and 0.63 µg/L, respectively, for
aerial applications at the maximum proposed rate.

Terrestrial Exposure Assessment

Estimated environmental concentrations for terrestrial exposure were
derived using TREX (Version 1.2.3).  The initial Section 3 assessment
relied on a foliar dissipation half-life of 2 days based on the upper
90th percentile aerobic soil metabolism half-life; however, without
magnitude of residue data with which to estimate foliar dissipation
half-lives, the current OPP policy is to utilize a default half-life of
35 days.  Since cymoxanil appears to be susceptible to both biotic and
abiotic (aqueous photolysis t½=1.8 days; hydrolysis at pH 7 t½=1.4
days), the use of the 35-day default value is likely highly
conservative.  Therefore, estimated environmental concentrations on
terrestrial forage items are calculated based both on the 35-day default
foliar dissipation half-life and assuming a half-life roughly an order
of magnitude lower.  Output from TREX can be found in Appendix B.

Ecological Risk Characterization

Estimation

Following the methodologies described in the initial risk assessment,
risk quotients (RQs) were calculated for the proposed use of cymoxanil
on grapes and hops and compared to acute and chronic risk levels of
concern (LOCs).  Since cymoxanil is practically nontoxic to birds and
mammals on an acute oral exposure basis and is also practically nontoxic
to birds on a subacute dietary exposure basis [where median lethal doses
and concentrations exceeded the maximum concentration tested], acute
risk to terrestrial animals is not quantified.  At the maximum
application rate for hops and grapes and using a default foliar
dissipation half-life of 35 days, dietary-based RQ values exceed the
chronic risk LOC for birds foraging on short grass (RQ=3.5), tall grass
(RQ=1.6) and broadleaf plants/small insects (RQ=2.0) (Appendix B) at the
maximum proposed application rate for grapes.  Application rates would
have to be reduced to 0.07 lbs a.i./acre to get RQ values below the
chronic risk LOC if 10 applications are made with a 7-day reapplication
interval.  Alternatively, if the reapplication interval is extended to
35 days and the number of applications is reduced to two, then RQ values
would fall below the chronic risk LOC for birds if 0.25 lbs a.i./A is
used per application.

Similarly, for mammals, the default 35-day foliar dissipation half-life
results in exceedances of the chronic risk LOC for animals foraging on
short grass (RQ=2.7), tall grass (RQ=1.2) and broadleaf plants/small
insects (RQ=1.5) (Appendix B).  To get mammalian RQ values below the
chronic risk LOC, the reapplication interval would have to be extended
to 32 days or the number of applications per year would have to be
reduced two [as opposed to 10].  Alternatively, if the maximum
application rate was reduced to 0.09 lbs a.i/acre, RQ values would fall
below the chronic risk LOC.  

For aquatic animals, neither acute nor chronic RQ values exceed any
level of concern (Table 2) and thus the likelihood of adverse effects to
aquatic animals from the proposed use of cymoxanil on hops and grapes is
considered low.

  SEQ CHAPTER \h \r 1 Table 2: Risk Quotients for aquatic organisms
based on toxicity values and EEC values based on the GENEEC 2 model.

Species	Acute toxicity

(ppm)	Chronic toxicity NOEC

(ppm)	EEC

Peak

(ppm)	EEC 

21-day Ave. 

(ppm)	EEC

60-Day Ave.

(ppm)	Acute RQ 

	Chronic RQ

 

Bluegill 

Lepomis macrochirus 	29	n/a	0.009	n/a	n/a

	<0.01	--

Waterflea

Daphnia magna	27	0.067	0.009	0.0018	n/a

	<0.01	0.20

Mysid

Mysidopsis bahia	>44.4	1.7	0.009	0.0018	n/a

	<0.01	0.00

Rainbow  trout

Oncorhynchus mykis	n/a	0.00098	n/a	n/a	0.0006	n/a	0.61

Sheepshead

Cyprinodon variegates	

>47.5	

0.0942	

n/a	

n/a	

0.0006	

<0.01	

0.01

Daphnia

Daphnia magna	n/a	0.067	n/a	0.0018	n/a	0.03	0.03

Duckweed

Lemna gibba	>100	n/a	0.009	n/a	n/a	<0.01	--

Navicula pelliculosa	0.202	n/a	0.009	n/a	n/a	0.04	--



Risk Discussion

	The likelihood of either acute or chronic risk to aquatic animals from
the proposed use of cymoxanil on hops and grapes is considered low. 
Additionally, the likelihood of acute risk to birds or mammals from
cymoxanil is also considered low.  However, based on a default 35-day
foliar dissipation half-life for cymoxanil on avian and mammalian forage
items, the chronic risk level of concern is exceeded for terrestrial
animals.

μg/L), estuarine/marine fish (96-hr LC50=49 μg/L), freshwater
invertebrates (48-hr EC50=11.8 μg/L) and estuarine/marine invertebrates
(EC50=1.6 μg/L); famoxodone is highly toxic to aquatic plants (EC50=13
μg/L).  Toxicity testing of the formulated product itself (MRID
449463-02) failed to establish a 96-hr LC50 (LC50<44.6 μg
famoxodone/L).  For more information on the ecological effects of
famoxodone, see DP Barcode D276071.  

The likelihood of chronic effects from cymoxanil on terrestrial mammals
is uncertain primarily because of the lack of data on a foliar
dissipation half-life.  However, birds appear to be more sensitive to
famoxodone (NOAEC=46 mg/kg diet than cymoxanil (NOAEC=100 mg/kg diet)
but mammals appear to more sensitive to cymoxanil (NOAEC 6.5 mg/kg diet)
compared to famoxodone (NOAEC=40 mg/kg diet).  Given the exceedances
with cymoxanil alone using a 35-day foliar dissipation value, it is
likely that the formulated product will exceed the chronic risk LOC.

As stated previously, the default foliar dissipation value of 35 days is
considered conservative given the limited persistence of cymoxanil in
the environment.  The 2-day foliar dissipation value used in the
previous assessments of cymoxanil is more consistent with the abiotic
and biotic degradation half-lives observed in laboratory studies but is
not supported by magnitude of residue studies.  If chronic risk
quotients for terrestrial animals had been based on a 2-day foliar
dissipation half-life, then RQ values would not have exceeded the
chronic risk LOC for birds; however, RQ values would have exceeded the
chronic risk LOC for all-sized mammals feeding on a range of forage
items. 

  SEQ CHAPTER \h \r 1 Federally Threatened and Endangered (Listed)
Species Concerns 

 tc "4.2.4.  Federally Threatened and Endangered (Listed) Species
Concerns " \l 3 

	Section 7 of the Endangered Species Act, 16 U.S.C. Section 1536(a)(2),
requires all federal agencies to consult with the National Marine
Fisheries Service (NMFS) for marine and anadromous listed species, or
the United States Fish and Wildlife Services (FWS) for listed wildlife
and freshwater organisms, if they are proposing an "action" that may
affect listed species or their designated habitat.  Each federal agency
is required under the Act to insure that any action they authorize,
fund, or carry out is not likely to jeopardize the continued existence
of a listed species or result in the destruction or adverse modification
of designated critical habitat.  To jeopardize the continued existence
of a listed species means "to engage in an action that reasonably would
be expected, directly or indirectly, to reduce appreciably the
likelihood of both the survival and recovery of a listed species in the
wild by reducing the reproduction, numbers, or distribution of the
species."

	To facilitate compliance with the requirements of the Endangered
Species Act subsection (a)(2), the Environmental Protection Agency
Office of Pesticide Programs has established procedures to evaluate
whether a proposed registration action may directly or indirectly reduce
appreciably the likelihood of both the survival and recovery of a listed
species in the wild by reducing the reproduction, numbers, or
distribution of any listed species (U.S. EPA 2004).  After the
Agency’s screening-level risk assessment is conducted, if any of the
Agency’s listed species LOCs are exceeded for either direct or
indirect effects, an analysis is conducted to determine if any listed or
candidate species may co-occur in the area of the proposed pesticide use
or areas downstream or downwind that could be contaminated from drift or
runoff/erosion.  If determined that listed or candidate species may be
present in the proposed action areas, further biological assessment is
undertaken.  The extent to which listed species may be at risk then
determines the need for the development of a more comprehensive
consultation package as required by the Endangered Species Act.

	The federal action addressed herein is the proposed IR-4 registration
of pesticide product that contains the active ingredient cymoxanil for
use on grapes (east of the Rocky Mountains) and hops. 

Action Area  tc "4.2.4.1.  Action Area " \l 4 

	

	For listed species assessment purposes, the action area is considered
to be the area affected directly or indirectly by the Federal action and
not merely the immediate area involved in the action.  At the initial
screening level, the risk assessment considers broadly described
taxonomic groups and so conservatively assumes that listed species
within those broad groups are collocated with the pesticide treatment
area.  This means that terrestrial plants and wildlife are assumed to be
located adjacent to the treated site and aquatic organisms are assumed
to be located in a surface water that is the treated site.  The
assessment also assumes that the listed species are located within an
assumed area which has the relatively highest potential exposure to the
pesticide, and that exposures are likely to decrease with distance from
the treatment area.  The use characterization section of this risk
assessment presents the pesticide use sites that are used to establish
initial collocation of species with treatment areas.  

	

Taxonomic Groups Potentially at Risk  tc "4.2.4.2. Taxonomic Groups
Potentially at Risk " \l 4 

	If the assumptions associated with the screening-level action area
result in RQs that are below the listed species LOCs, a "no effect"
determination conclusion is made with respect to listed species in that
taxa, and no further refinement of the action area is necessary. 
Furthermore, RQs below the listed species LOCs for a given taxonomic
group indicate no concern for indirect effects upon listed species that
depend upon the taxonomic group covered by the RQ as a resource. 
However, in situations where the screening assumptions lead to RQs in
excess of the listed species LOCs for a given taxonomic group, a
potential for a "may affect" conclusion exists and may be associated
with direct effects on listed species belonging to that taxonomic group
or may extend to indirect effects upon listed species that depend upon
that taxonomic group as a resource.  In such cases, additional
information on the biology of listed species, the locations of these
species, and the locations of use sites could be considered to determine
the extent to which screening assumptions regarding an action area apply
to a particular listed organism.  These subsequent refinement steps
could consider how this information would impact the action area for a
particular listed organism and may potentially include areas of exposure
that are downwind and downstream of the pesticide use site.

	The assessment endpoints used in the screening-level risk assessment
include those defined operationally as reduced survival, reproduction,
and growth for both aquatic and terrestrial animal species from direct
acute and direct chronic exposures.  These assessment endpoints address
the standard set forth in the Endangered Species Act requiring federal
agencies to ensure that any action they authorize does not reduce
appreciably the likelihood of both the survival and recovery of a listed
species in the wild by reducing the reproduction, numbers, or
distribution of the species.  Risk estimates (i.e., RQs integrating
exposure and effects) are calculated for broad-based taxa groups for the
screening-level risk assessment and presented in Section 6.

	Listed Species Risk Quotients 

 tc "4.2.4.2.1. Listed Species Risk Quotients " \l 5 

	A description of the potential direct effects associated with exposure
to cymoxanil is discussed for each of the taxonomic groups below.  Table
2 provides a summary of the direct effects for Federally-listed
threatened/endangered species, including the range of RQ values and the
acute dose-response slopes used in evaluating the probability of
individual effects on listed species.

Table 2.  Summary of direct effects for Federally listed species from
agricultural uses.  

Listed Species Taxonomic Group of Concern	Direct Effects	Slopea	RQ

Freshwater Fish	Acute: mortality	31	<0.01

Freshwater Invertebrates	Acute: mortality/immobilization	4.5a	<0.01

Estuarine/Marine Fish

	<0.01

Estuarine/Marine Mollusk 	Acute mortality	4.5a	<0.01

Aquatic Plants:

 Vascular 

 Non-vascular	

no data

no data	

—

—	

—

—

Birds	Acute: mortality/sublethal	4.5a

	1.9 – 3.5

Mammals	Acute: mortality	4.5a	1.5 – 2.7

Terrestrial Plants:

 Monocots

 Dicots	

Acute: no data

Acute: no data	

—

—	

—

—

aRaw data were not provided so the default value of 4.5 is used.

*Dose-based value.

Freshwater Fish and Amphibians

	No freshwater vertebrate acute toxicity LOCs are exceeded from the
proposed use of cymoxanil on grapes and hops

		Freshwater Invertebrates

	No freshwater vertebrate acute toxicity LOCs are exceeded from the
proposed use of cymoxanil on grapes and hops

	.

Estuarine/Marine Fish and Invertebrates

	No estuarine/marine vertebrate acute toxicity LOCs are exceeded from
the proposed use of cymoxanil on grapes and hops

Aquatic Plants

	No aquatic plant toxicity data were submitted and no useable data were
located in the open literature for antimycin; therefore, risks
associated with aquatic plant exposure to antimycin are unknown.

Birds

	No acute risk LOCs are exceeded for birds; however, the chronic risk
LOC is exceeded for birds when a more conservative value (35 days) is
used to estimate the foliar dissipation half-life.  Since birds serve as
surrogates for terrestrial-phase amphibans and reptiles, chronic risk to
these taxa is also presumed. 

Mammals

	No acute risk LOCs are exceeded for mammals; however, the chronic risk
LOC is exceeded for mammals when a more conservative value (35 days) is
used to estimate the foliar dissipation half-life.  

Probit Dose Response Relationship  tc "4.2.4.3.  Probit Dose Response
Relationship " \l 4 

Aquatic Listed Species Probability of Effects on Individuals

  tc "4.2.4.3.1 Aquatic Listed Species Probability of Effects on
Individuals " \l 5 

	The probability of individual effects at estimated acute RQs above the
listed species acute risk LOC was calculated (Appendix D).  The probit
slopes used in this analysis were obtained from dose-response
relationships used in calculating RQs.  For freshwater fish, the probit
dose-response slope is 31 based on the bluegill sunfish (LC50=29 mg
a.i.//L; Appendix C), the chance of an individual effect is 1 out of
1x1016.

	The probability of individual effects to the remaining aquatic and
terrestrial animals based on a probit dose-response default slope of 4.5
is 1 out of 4 x 108.

Appendix E contains a list of the number of potentially affected
Federally-listed endangered and/or threatened species by state based on
the LOCATES database.

APPENDIX A Estimated Environmental Concentrations Using FIRST, GENEEC 2
and SCIGROW Models.

FIRST MODEL (Drinking Water Concentrations using Index Reservoir
Scenario)

  

   RUN No.   1 FOR Cymoxanil        ON   Grapes        * INPUT VALUES * 

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

   RATE (#/AC)   No.APPS &   SOIL  SOLUBIL   APPL TYPE  %CROPPED INCORP

    ONE(MULT)    INTERVAL     Kd   (PPM )    (%DRIFT)     AREA    (IN)

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

   .250(   .274)  10   7        .3  780.0   AERIAL(16.0)  87.0      .0

   FIELD AND RESERVOIR HALFLIFE VALUES (DAYS) 

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

   METABOLIC  DAYS UNTIL  HYDROLYSIS   PHOTOLYSIS   METABOLIC  COMBINED

    (FIELD)  RAIN/RUNOFF  (RESERVOIR)  (RES.-EFF)   (RESER.)   (RESER.) 

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

      2.00        2           1.40    1.80-  223.20     .00       1.39

   UNTREATED WATER CONC (MICROGRAMS/LITER (PPB)) Ver 1.1.0 DEC 12, 2005

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

        PEAK DAY  (ACUTE)      ANNUAL AVERAGE (CHRONIC)      

          CONCENTRATION             CONCENTRATION            

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

             11.717                       .060

GENEEC 2 (Environmental Concentrations)

AERIAL

   RUN No.   1 FOR Cymoxanil        ON   Grapes        * INPUT VALUES * 

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

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

    ONE(MULT)    INTERVAL     Kd   (PPM )    (%DRIFT)   ZONE(FT)  (IN)

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

   .250(   .274)  10   7        .3  780.0   AERL_B( 13.0)    .0    .0

   FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) 

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

   METABOLIC  DAYS UNTIL  HYDROLYSIS   PHOTOLYSIS   METABOLIC  COMBINED

    (FIELD)   RAIN/RUNOFF   (POND)     (POND-EFF)    (POND)     (POND) 

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

      2.00        2           1.40    1.80-  223.20     .00       1.39

   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

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

        7.95        5.65          1.62           .57           .38

GROUND

   RUN No.   2 FOR Cymoxanil        ON   Grapes        * INPUT VALUES * 

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

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

    ONE(MULT)    INTERVAL     Kd   (PPM )    (%DRIFT)   ZONE(FT)  (IN)

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

   .250(   .274)  10   7        .3  780.0   GRHIFI(  6.6)    .0    .0

   FIELD AND STANDARD POND HALFLIFE VALUES (DAYS) 

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

   METABOLIC  DAYS UNTIL  HYDROLYSIS   PHOTOLYSIS   METABOLIC  COMBINED

    (FIELD)   RAIN/RUNOFF   (POND)     (POND-EFF)    (POND)     (POND) 

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

      2.00        2           1.40    1.80-  223.20     .00       1.39

   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

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

        7.78        5.47          1.56           .55           .37

   

SCIGROW (Groundwater Concentrations)

 

Appendix B  TREX Model Output with Foliar Dissipation Half-life of 2.0
Days.



TREX Output with Foliar Dissipation Half-life of 35 Days.



APPENDIX C  PROBIT ANALYSIS (LOG10) OF BLUEGILL SUNFISH MORTALITY AFTER
96-HR Cymoxanil EXPOSURE (441807-18 7

                                        Probit Procedure

                            Iteration History for Parameter Estimates

                 Iter    Ridge    Loglikelihood       Intercept    
Log10(DOSE)

                    0        0       -34.657359               0         
     0

                    1        0       -15.136711    -4.011072953   
2.6600722052

                    2        0       -10.372624    -6.820867501   
4.5752892208

                    3        0       -8.1433154    -10.00696525   
6.7784080513

                    4        0       -7.2809497    -13.26496173   
9.0441355425

                    5        0       -7.0317841    -16.09609085   
11.000246522

                    6        0       -6.9620761    -18.49883412   
12.648536961

                    7        0       -6.9411854    -20.60399811   
14.088943641

                    8        0       -6.9346346    -22.49770029   
15.384040828

                    9        0       -6.9325203    -24.23342099   
16.570990537

                   10        0        -6.931824    -25.84567195   
17.673477962

                   11        0       -6.9315914    -27.35801204   
18.707634606

                   12        0       -6.9315127    -28.78733018   
19.685016375

                   13        0       -6.9314859    -30.14621494   
20.614233879

                   14        0       -6.9314767    -31.44434696   
21.501907687

                   15        0       -6.9314735    -32.68936205   
22.353259522

                   16        0       -6.9314724     -33.8874106   
23.172495189

                   17        0        -6.931472    -35.04353432   
23.963062286

                   18        0       -6.9314719    -36.16192814    
24.72782935

                   19        0       -6.9314718    -37.24612739   
25.469213884

                   20        0       -6.9314718    -38.29914488   
26.189276059

                   21        0       -6.9314718    -39.32357319   
26.889788718

                   22        0       -6.9314718     -40.3216627   
27.572290686

                   23        0       -6.9314718    -41.29538163   
28.238127847

                   24        0       -6.9314718    -42.24646353   
28.888485617

                   25        0       -6.9314718    -43.17644436   
29.524414298

                   26        0       -6.9314718    -44.08669259   
30.146849665

                   27        0       -6.9314718    -44.97843109   
30.756627919

                   28        0       -6.9314718    -44.97843109   
30.756627919

                                       Model Information

                             Data Set                        WORK.B

                             Events Variable               RESPONSE

                             Trials Variable                      N

                             Number of Observations               5

                             Number of Events                    35

                             Number of Trials                    50

                             Name of Distribution            Normal

                             Log Likelihood            -6.931471806

                             Number of Observations Read           6

                             Number of Observations Used           5

                             Number of Events                     35

                             Number of Trials                     50

PROBIT ANALYSIS (LOG10) OF BLUEGILL SUNFISH MORTALITY AFTER 96-HR
Cymoxanil EXPOSURE (441807-18 8

                                        Probit Procedure

                                     Parameter Information

                                     Parameter    Effect

                                     Intercept    Intercept

                                     DOSE         DOSE

                        Last Evaluation of the Negative of the Gradient

                                      Intercept   Log10(DOSE)

                                   2.062335E-11  1.892886E-11

                          Last Evaluation of the Negative of the Hessian

                                             Intercept   Log10(DOSE)

                             Intercept     6.366197724  9.3099148058

                             Log10(DOSE)  9.3099148058  13.614800773

           Algorithm converged.

                                     Goodness-of-Fit Tests

                 Statistic                         Value       DF    Pr
> ChiSq

                 Pearson Chi-Square               0.0000        3       
1.0000

                 L.R.    Chi-Square               0.0000        3       
1.0000

                                   Response-Covariate Profile

                                 Response Levels               2

                                 Number of Covariate Values    5

Since the chi-square is small (p > 0.1000), fiducial limits will be
calculated using a t value

of  1.96.

                                  Type III Analysis of Effects

                                                       Wald

                       Effect              DF    Chi-Square    Pr >
ChiSq

                       Log10(DOSE)          1        0.0000       
0.9999

PROBIT ANALYSIS (LOG10) OF BLUEGILL SUNFISH MORTALITY AFTER 96-HR
Cymoxanil EXPOSURE (441807-18 9

                                        Probit Procedure

                                 Analysis of Parameter Estimates

                                      Standard   95% Confidence     Chi-

              Parameter   DF Estimate    Error       Limits       Square
Pr > ChiSq

              Intercept    1 -44.9784 337438.9  -661413 661323.1    0.00
    0.9999

              Log10(DOSE)  1  30.7566 230743.5  -452218 452279.8    0.00
    0.9999

                                   Estimated Covariance Matrix

                                             Intercept   Log10(DOSE)

                             Intercept    113864994083  -77861836687

                             Log10(DOSE)  -77861836687   53242576097

                        Probit Model in Terms of Tolerance Distribution

                                            MU         SIGMA

                                      1.462398    0.03251332

                                   Estimated Covariance Matrix

                                    for Tolerance Parameters

                                                 MU             SIGMA

                            MU             0.000166          0.000011

                            SIGMA          0.000011      59498.249046

PROBIT ANALYSIS (LOG10) OF BLUEGILL SUNFISH MORTALITY AFTER 96-HR
Cymoxanil EXPOSURE (441807-1 10

                                        Probit Procedure

                                 Probit Analysis on Log10(DOSE)

                  Probability          Log10(DOSE)       95% Fiducial
Limits

                         0.01              1.38676        .            
.

                         0.02              1.39562        .            
.

                         0.03              1.40125        .            
.

                         0.04              1.40548        .            
.

                         0.05              1.40892        .            
.

                         0.06              1.41185        .            
.

                         0.07              1.41442        .            
.

                         0.08              1.41671        .            
.

                         0.09              1.41881        .            
.

                         0.10              1.42073        .            
.

                         0.15              1.42870        .            
.

                         0.20              1.43503        .            
.

                         0.25              1.44047        .            
.

                         0.30              1.44535        .            
.

                         0.35              1.44987        .            
.

                         0.40              1.45416        .            
.

                         0.45              1.45831        .            
.

                         0.50              1.46240        .            
.

                         0.55              1.46648        .            
.

                         0.60              1.47064        .            
.

                         0.65              1.47493        .            
.

                         0.70              1.47945        .            
.

                         0.75              1.48433        .            
.

                         0.80              1.48976        .            
.

                         0.85              1.49610        .            
.

                         0.90              1.50407        .            
.

                         0.91              1.50599        .            
.

                         0.92              1.50808        .            
.

                         0.93              1.51038        .            
.

                         0.94              1.51295        .            
.

                         0.95              1.51588        .            
.

                         0.96              1.51932        .            
.

                         0.97              1.52355        .            
.

                         0.98              1.52917        .            
.

                         0.99              1.53804        .            
.

PROBIT ANALYSIS (LOG10) OF BLUEGILL SUNFISH MORTALITY AFTER 96-HR
Cymoxanil EXPOSURE (441807-1 11

                                        Probit Procedure

                                     Probit Analysis on DOSE

                      Probability          DOSE       95% Fiducial
Limits

                             0.01      24.36468        .             .

                             0.02      24.86702        .             .

                             0.03      25.19110        .             .

                             0.04      25.43767        .             .

                             0.05      25.64002        .             .

                             0.06      25.81352        .             .

                             0.07      25.96660        .             .

                             0.08      26.10444        .             .

                             0.09      26.23044        .             .

                             0.10      26.34696        .             .

                             0.15      26.83491        .             .

                             0.20      27.22915        .             .

                             0.25      27.57199        .             .

                             0.30      27.88355        .             .

                             0.35      28.17539        .             .

                             0.40      28.45515        .             .

                             0.45      28.72846        .             .

                             0.50      29.00000        .             .

                             0.55      29.27411        .             .

                             0.60      29.55529        .             .

                             0.65      29.84874        .             .

                             0.70      30.16116        .             .

                             0.75      30.50197        .             .

                             0.80      30.88602        .             .

                             0.85      31.33978        .             .

                             0.90      31.92019        .             .

                             0.91      32.06198        .             .

                             0.92      32.21674        .             .

                             0.93      32.38776        .             .

                             0.94      32.57983        .             .

                             0.95      32.80029        .             .

                             0.96      33.06120        .             .

                             0.97      33.38480        .             .

                             0.98      33.81989        .             .

                             0.99      34.51718        .             .

APPENDIX D.  Probit Dose-Response 

APPENDIX E.  List of Potentially Affected Endangered and/or Threatened
Species.

	Species Counts by State for Indicated Crops

	No species were excluded.

	Minimum of 1 Acre.

	All Medium Types Reported

	grapes, hops, hops (irrigated)

	AL, AK, AZ, AR, CA, CO, CT, DE, DC, FL, GA, HI, ID, IL, IN, IA, KS, KY,
LA, ME, MD, MA, MI, MN, MS, MO, MT, NE, NV, 

	NH, NJ, NM, NY, NC, ND, OH, OK, OR, PA, PR, RI, SC, SD, TN, TX, UT, VT,
VA, WA, WV, WI, WY

	Alabama

	The taxa Amphibian has 2 species co-occurring with indicated crops.

	The taxa Bird has 4 species co-occurring with indicated crops.

	The taxa Mammal has 4 species co-occurring with indicated crops.

	The taxa Reptile has 5 species co-occurring with indicated crops.

	Arizona

	The taxa Amphibian has 2 species co-occurring with indicated crops.

	The taxa Bird has 8 species co-occurring with indicated crops.

	The taxa Mammal has 9 species co-occurring with indicated crops.

	The taxa Reptile has 2 species co-occurring with indicated crops.

	Arkansas

	The taxa Bird has 3 species co-occurring with indicated crops.

	The taxa Mammal has 3 species co-occurring with indicated crops.

	California

	The taxa Amphibian has 6 species co-occurring with indicated crops.

	The taxa Bird has 15 species co-occurring with indicated crops.

	The taxa Mammal has 20 species co-occurring with indicated crops.

	The taxa Reptile has 8 species co-occurring with indicated crops.

	Colorado

	The taxa Bird has 2 species co-occurring with indicated crops.

	The taxa Mammal has 2 species co-occurring with indicated crops.

	Connecticut

	The taxa Bird has 3 species co-occurring with indicated crops.

	

	The taxa Mammal has 1 species co-occurring with indicated crops.

	The taxa Reptile has 1 species co-occurring with indicated crops.

	Delaware

	The taxa Bird has 2 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	Florida

	The taxa Amphibian has 1 species co-occurring with indicated crops.

	The taxa Bird has 9 species co-occurring with indicated crops.

	The taxa Mammal has 7 species co-occurring with indicated crops.

	The taxa Reptile has 10 species co-occurring with indicated crops.

	Georgia

	The taxa Amphibian has 1 species co-occurring with indicated crops.

	The taxa Bird has 5 species co-occurring with indicated crops.

	The taxa Mammal has 3 species co-occurring with indicated crops.

	The taxa Reptile has 2 species co-occurring with indicated crops.

	Hawaii

	The taxa Bird has 25 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	The taxa Reptile has 2 species co-occurring with indicated crops.

	Idaho

	The taxa Bird has 2 species co-occurring with indicated crops.

	The taxa Mammal has 4 species co-occurring with indicated crops.

	Illinois

	The taxa Bird has 3 species co-occurring with indicated crops.

	The taxa Mammal has 2 species co-occurring with indicated crops.

	Indiana

	The taxa Bird has 2 species co-occurring with indicated crops.

	The taxa Mammal has 2 species co-occurring with indicated crops.

	The taxa Reptile has 1 species co-occurring with indicated crops.

	Iowa

	The taxa Bird has 3 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	Kansas

	The taxa Bird has 4 species co-occurring with indicated crops.

	The taxa Mammal has 2 species co-occurring with indicated crops.

	Kentucky

	The taxa Bird has 7 species co-occurring with indicated crops.

	The taxa Mammal has 3 species co-occurring with indicated crops.

	Louisiana

	The taxa Bird has 5 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	The taxa Reptile has 7 species co-occurring with indicated crops.

	Maine

	The taxa Bird has 3 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	Maryland

	The taxa Bird has 2 species co-occurring with indicated crops.

	The taxa Mammal has 2 species co-occurring with indicated crops.

	The taxa Reptile has 1 species co-occurring with indicated crops.

	Massachusetts

	The taxa Bird has 4 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	The taxa Reptile has 2 species co-occurring with indicated crops.

	Michigan

	The taxa Bird has 3 species co-occurring with indicated crops.

	The taxa Mammal has 3 species co-occurring with indicated crops.

	The taxa Reptile has 1 species co-occurring with indicated crops.

	Minnesota

	The taxa Bird has 2 species co-occurring with indicated crops.

	The taxa Mammal has 2 species co-occurring with indicated crops.

	Mississippi

	The taxa Amphibian has 1 species co-occurring with indicated crops.

	The taxa Bird has 6 species co-occurring with indicated crops.

	The taxa Mammal has 3 species co-occurring with indicated crops.

	The taxa Reptile has 7 species co-occurring with indicated crops.

	Missouri

	The taxa Bird has 3 species co-occurring with indicated crops.

	The taxa Mammal has 2 species co-occurring with indicated crops.

	Montana

	The taxa Bird has 1 species co-occurring with indicated crops.

	The taxa Mammal has 3 species co-occurring with indicated crops.

	Nebraska

	The taxa Bird has 4 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	Nevada

	The taxa Bird has 3 species co-occurring with indicated crops.

	The taxa Reptile has 1 species co-occurring with indicated crops.

	New Hampshire

	The taxa Bird has 1 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	New Jersey

	The taxa Bird has 3 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	The taxa Reptile has 1 species co-occurring with indicated crops.

	New Mexico

	The taxa Amphibian has 1 species co-occurring with indicated crops.

	The taxa Bird has 7 species co-occurring with indicated crops.

	The taxa Mammal has 5 species co-occurring with indicated crops.

	The taxa Reptile has 1 species co-occurring with indicated crops.

	New York

	The taxa Bird has 3 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	The taxa Reptile has 1 species co-occurring with indicated crops.

	North Carolina

	The taxa Bird has 5 species co-occurring with indicated crops.

	The taxa Mammal has 4 species co-occurring with indicated crops.

	The taxa Reptile has 5 species co-occurring with indicated crops.

	North Dakota

	The taxa Bird has 1 species co-occurring with indicated crops.

	Ohio

	The taxa Bird has 2 species co-occurring with indicated crops.

	The taxa Mammal has 2 species co-occurring with indicated crops.

	The taxa Reptile has 2 species co-occurring with indicated crops.

	Oklahoma

	The taxa Bird has 7 species co-occurring with indicated crops.

	The taxa Mammal has 3 species co-occurring with indicated crops.

	Oregon

	The taxa Bird has 5 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	Pennsylvania

	The taxa Bird has 2 species co-occurring with indicated crops.

	The taxa Mammal has 2 species co-occurring with indicated crops.

	The taxa Reptile has 1 species co-occurring with indicated crops.

	Rhode Island

	The taxa Bird has 1 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	South Carolina

	The taxa Amphibian has 1 species co-occurring with indicated crops.

	The taxa Bird has 5 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	The taxa Reptile has 5 species co-occurring with indicated crops.

	South Dakota

	The taxa Bird has 3 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	Tennessee

	The taxa Bird has 4 species co-occurring with indicated crops.

	The taxa Mammal has 3 species co-occurring with indicated crops.

	Texas

	The taxa Amphibian has 4 species co-occurring with indicated crops.

	The taxa Bird has 13 species co-occurring with indicated crops.

	The taxa Mammal has 5 species co-occurring with indicated crops.

	The taxa Reptile has 6 species co-occurring with indicated crops.

	Utah

	The taxa Bird has 3 species co-occurring with indicated crops.

	The taxa Mammal has 2 species co-occurring with indicated crops.

	The taxa Reptile has 1 species co-occurring with indicated crops.

	Vermont

	The taxa Bird has 1 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	Virginia

	The taxa Amphibian has 1 species co-occurring with indicated crops.

	The taxa Bird has 2 species co-occurring with indicated crops.

	The taxa Mammal has 5 species co-occurring with indicated crops.

	The taxa Reptile has 1 species co-occurring with indicated crops.

	Washington

	The taxa Bird has 5 species co-occurring with indicated crops.

	The taxa Mammal has 4 species co-occurring with indicated crops.

	West Virginia

	The taxa Amphibian has 1 species co-occurring with indicated crops.

	The taxa Bird has 1 species co-occurring with indicated crops.

	The taxa Mammal has 4 species co-occurring with indicated crops.

	Wisconsin

	The taxa Bird has 4 species co-occurring with indicated crops.

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ꐓ[ᘀThe taxa Mammal has 2 species co-occurring with indicated crops.

	Wyoming

	The taxa Bird has 1 species co-occurring with indicated crops.

	The taxa Mammal has 1 species co-occurring with indicated crops.

	

 50 C.F.R. § 402.02

 PAGE  6 

