UNITED
STATES
ENVIRONMENTAL
PROTECTION
AGENCY
WASHINGTON,
D.
C.
20460
OFFICE
OF
PREVENTION,
PESTICIDES
AND
TOXIC
SUBSTANCES
Date:
February
03,
2006
Chemical:
ADBAC/
DDAC
PC
Codes:
069105/
069149
Barcode:
D322872/
D325481
MEMORANDUM
SUBJECT:
Ecological
Risk
Assessment
in
Support
of
the
Antimicrobials
Division's
Reregistration
of
ADBAC
and
DDAC
FROM:
Brian
D.
Kiernan,
Biologist
Marietta
Echeverria,
Environmental
Scientist
Environmental
Risk
Branch
IV
Environmental
Fate
and
Effects
Division
(
7507C)

THRU:
Elizabeth
Behl,
Branch
Chief
Environmental
Risk
Branch
IV
Environmental
Fate
and
Effects
Division
(
7507C)

TO:
Jacqueline
Campbell­
McFarlane
Tracy
Lantz
Chemical
Review
Managers
Antimicrobials
Division
(
7510)

Risk
Assessment
Summary
and
Conclusions
The
Environmental
Fate
and
Effects
Division
has
completed
its
ecological
risk
assessment
for
the
outdoor
uses
of
ADBAC
and
DDAC
in
support
of
the
Antimicrobials
Division
Reregistration
Eligibility
Decision
(
RED)
for
these
chemicals.
DDAC
is
an
active
ingredient
in
only
one
of
the
formulations
assessed,
and
it
does
not
appear
to
pose
high
risk
to
wildlife
when
used
according
to
the
label.
Several
ADBAC
uses
pose
acute
and
chronic
risk
to
aquatic
and
terrestrial
wildlife.
Risk
to
terrestrial
and
aquatic
plants
cannot
be
evaluated
due
to
a
lack
of
data,
but
risk
is
presumed.
Based
on
this
screening­
level
assessment,
risk
to
Federally
listed
species
also
cannot
be
precluded.
Further
work
is
necessary
to
develop
a
refined
risk
assessment
evaluating
endangered
species.
Although
primarily
used
as
antimicrobial
agents,
uses
which
are
not
assessed
in
this
document,
outdoor
applications
of
ADBAC
and
DDAC
included
in
this
assessment
were
ornamental
nurseries,
residential
and
commercial
turf,
mosquito
larvicide
and
algacide
in
ornamental
pools
and
puddles.

Data
gaps
identified
include
chronic
toxicity
studies
of
estuarine/
marine
fish
and
invertebrates,
as
well
as
avian
wildlife.
The
toxicity
of
ADBAC
to
terrestrial
and
aquatic
nontarget
plants
is
not
assessed
either,
due
to
lack
of
data.
1
Problem
Formulation
1.1
Stressor
Source
and
Distribution
The
Environmental
Fate
and
Effects
Division
(
EFED)
has
evaluated
the
outdoor
uses
of
the
quaternary
ammonium
compounds
being
considered
for
reregistration
by
the
Antimicrobial
Division
(
AD).
The
compounds
being
considered
are
alkyl
dimethyl
benzyl
ammonium
chlorides
(
ADBAC)
and
didecyl
ammonium
chlorides
(
DDAC).
ADBAC
and
DDAC
are
used
primarily
as
disinfectants,
sanitizers,
and
microbiocides/
microbiostats.
They
are
also
used
as
algaecides,
bacteriocides/
bacteriostats,
fungicides/
fungistats,
insecticides,
miticides,
virucides,
and
feeding
suppressants.
Use
sites
for
ADBAC
and
DDAC
include
agricultural
premises
and
equipment,
food
handling
equipment,
commercial,
industrial
and
institutional
settings,
residential
areas
or
areas
of
public
access,
pets
and
kennels,
medical
facilities,
swimming
pools,
aquatic
areas,
and
industrial
water
systems.
Although
primarily
used
as
antimicrobial
agents
for
these
diverse
uses,
several
labeled
outdoor
uses
are
being
assessed
by
EFED
because
of
the
potential
for
environmental
exposures
and
ecological
effects.
Specifically,
ADBAC
uses
include
ornamental
plants
and
shrubs
in
nurseries,
residential
lawns
and
commercial
turf
(
not
sod
farms)
and
golf
course
greens,
tees
and
fairways.
Both
ADBAC
and
DDAC
are
labeled
for
use
in
puddles
and
decorative
pools
to
control
algae.
ADBAC
is
also
labeled
for
use
as
mosquito
larvicide
in
standing
waters,
including
decorative
ponds
and
pools,
inactive
spas
and
hot
tubs,
as
well
as
`
old
tires,
empty
tin
cans,
puddles
and
water
drains
around
buildings'
(
RD
20
label).
Only
the
ADBAC
and
DDAC
uses
that
appear
likely
to
result
in
environmental
exposures
and
effects
are
being
evaluated
in
this
assessment
(
Table
1.1).

Table
1.1.
ADBAC
and
DDAC
products
and
uses
being
evaluated.
Class
Trade
Name
Reg.
#
%
ai
Agricultural/
Outdoor
Uses
DDAC
TC
192
499­
482
12
Decorative
ponds,
pools,
puddles
ADBAC
TC
192
499­
482
8
Decorative
ponds,
pools,
puddles
ADBAC
Consan
58044­
3
20
Nursery/
ornamentals
Turf,
golf
courses
ADBAC
RD
20
53642­
1
20
Decorative
ponds,
pools,
puddles
Nursery/
ornamentals,
Turf,
golf
courses,
Mosquito
control
ADBAC
Timsen
507­
3
40
Nursery/
ornamentals
ADBAC
PT
2000
499­
368
20
Decorative
ponds,
pools,
puddles
1.2
Receptors
Ecological
effect
endpoints
are
derived
from
registrant­
submitted
guideline
studies
as
required
for
registration
under
the
Federal
Insecticide,
Fungicide
and
Rodenticide
Act
(
FIFRA;
40
CFR
Part
158),
as
well
as
a
review
of
acceptable
open
literature
(
ECOTOX),
when
available.
The
most
sensitive
endpoints
(
described
below)
from
each
study
of
surrogate
species
are
used
to
estimate
risk
to
the
taxonomic
group(
s)
represented
by
the
surrogate
tested.
Toxicity
testing
reported
in
this
document
represents
all
terrestrial
and
aquatic
organisms.
However,
only
a
few
surrogate
species
for
both
freshwater
fish
and
birds
are
used
to
represent
all
freshwater
fish
Page
3
of
50
(
2000+)
and
bird
(
680+)
species
in
the
United
States.
In
addition,
neither
reptiles
nor
amphibians
are
tested.
Birds
are
used
as
surrogates
for
reptiles
and
terrestrial­
phase
amphibians;
fish
are
used
as
surrogates
for
aquatic­
phase
amphibians.
The
Norway
rat
is
typically
the
surrogate
for
all
mammal
species.

1.3
Identification
of
Assessment
Endpoints
Assessment
endpoints
are
defined,
per
Agency
guidelines,
as
"
explicit
expressions
of
the
actual
environmental
value
that
is
to
be
protected"
which
are
"
operationally
defined
by
an
ecological
entity
and
its
attributes"
(
USEPA,
2004).
The
ecological
entity
can
be
a
species,
a
functional
group
of
species,
a
community,
an
ecosystem,
or
another
entity
of
importance
or
concern.
An
attribute
is
the
characteristic
of
the
entity
that
is
important
to
protect
and
is
potentially
at
risk.

Defining
an
assessment
endpoint
involves
two
steps:
1)
identifying
the
valued
attributes
of
the
environment
that
are
considered
to
be
at
risk,
and
2)
operationally
defining
the
assessment
endpoint
in
terms
of
an
ecological
entity
(
e.
g.,
a
community
of
fish
and
aquatic
invertebrates)
and
its
attributes
(
i.
e.,
survival
and
reproduction).
Therefore,
selection
of
the
assessment
endpoints
is
based
on
valued
entities
(
i.
e.,
ecological
receptors),
the
ecosystems
potentially
at
risk
and
the
routes
by
which
ecological
receptors
are
exposed
to
pesticide­
related
contamination.
The
selection
of
clearly
defined
assessment
endpoints
is
important
because
they
provide
direction
and
boundaries
in
the
risk
assessment
for
addressing
risk
management
issues
of
concern.

Typical
assessment
endpoints
for
screening­
level
pesticide
ecological
risk
assessments
include
reduced
survival
and/
or
reproductive
impairment
for
both
aquatic
and
terrestrial
animal
species
from
direct
acute
or
direct
chronic
exposures.
Aquatic
animal
groups
that
are
typically
characterized
in
the
risk
assessment
include:
freshwater
fish
and
invertebrates,
estuarine/
marine
fish
and
invertebrates.
Terrestrial
animal
groups
include
birds,
mammals,
and
beneficial
insects.
All
assessment
endpoints
are
characterized
at
the
individual
level
in
order
to
protect
threatened
and
endangered
species.
However,
risks
to
higher
biological
levels
(
i.
e.,
populations
and
communities)
can
be
inferred
from
this
approach
(
e.
g.,
pesticide
effects
on
individual
survival
and
fecundity
may
impact
both
population
stability,
growth,
and
habitat
carrying
capacity).
Indirect
effects
to
listed
species
and
critical
habitat
must
also
be
characterized
in
a
speciesspecific
assessment
conducted
after
the
screening­
level
risk
assessment
is
completed.

For
terrestrial
and
semi­
aquatic
plants,
the
screening
assessment
endpoint
is
the
perpetuation
of
populations
of
non­
target
species
(
crops
and
non­
crop
plant
species).
Existing
testing
requirements
only
evaluate
emergence
of
seedlings
and
vegetative
vigor
of
annuals.
Although
it
is
recognized
that
the
endpoints
of
seedling
emergence
and
vegetative
vigor
may
not
address
all
terrestrial
and
semi­
aquatic
plant
life
cycle
components,
it
is
assumed
that
impacts
on
plant
emergence
and/
or
on
active
growth
have
the
potential
to
impact
individual
competitive
ability
and
reproductive
success,
from
which
population
effects
can
be
inferred.

For
aquatic
plants,
the
assessment
endpoint
is
the
maintenance
and
growth
of
standing
crop
or
biomass.
Measurement
endpoints
for
this
assessment
endpoint
focus
on
algal
and
vascular
plant
(
i.
e.,
duckweed)
growth
rates
and
biomass
measurements.
Page
4
of
50
The
ecological
relevance
of
the
assessment
endpoints
assumes
that
complete
exposure
pathways
exist
for
these
receptors,
that
the
receptors
may
be
sensitive
to
pesticides
in
affected
media
and/
or
forage
items
and
that
the
receptors
could
potentially
inhabit
areas
where
pesticides
are
applied,
or
areas
where
runoff
and/
or
spray
drift
may
impact
the
sites
because
suitable
habitat
is
available.

Ecological
measurement
endpoints
for
this
screening­
level
risk
assessment
are
based
on
a
suite
of
registrant­
submitted
toxicity
studies
performed
on
a
limited
number
of
organisms,
supplemented
by
the
open
literature
where
applicable,
in
the
following
broad
groupings:

1.
Birds
(
bobwhite
quail),
also
used
as
surrogate
species
for
terrestrial­
phase
amphibians
and
reptiles,
2.
Mammals
(
laboratory
rat),
3.
Freshwater
Fish
(
bluegill
sunfish,
rainbow
trout
and
fathead
minnow),
also
used
as
a
surrogate
for
aquatic­
phase
amphibians,
4.
Freshwater
invertebrates
(
Daphnia
magna),
5.
Estuarine/
marine
fish
(
sheepshead
minnow,
inland
silverside),
6.
Estuarine/
marine
invertebrates
(
Mysidopsis
bahia,
Eastern
oyster),
7.
Terrestrial
plants
(
no
data
available)
8.
Algae
and
aquatic
plants
(
no
data
available).

Within
each
of
these
very
broad
taxonomic
groups,
an
acute
and
chronic
endpoint
is
selected
from
the
available
test
data.
The
selection
is
made
from
the
most
sensitive
species
tested
within
a
particular
surrogate
group.
If
additional
toxicity
data
are
available
from
other
sources,
the
selection
of
an
endpoint
may
not
be
limited
to
the
surrogate
species
listed
above,
but
may
be
expanded
to
include
those
data
for
other
groups
or
species
which
has
been
deemed
of
sufficient
quality
by
OPP
scientists
for
use
in
the
risk
assessment.

1.4
Conceptual
Model
In
order
for
a
chemical
to
pose
an
ecological
risk,
it
must
reach
ecological
receptors
in
biologically
significant
concentrations.
Exposure
pathways
are
defined
as
the
means
by
which
a
contaminant
moves
in
the
environment
from
a
source
to
an
ecological
receptor.
For
an
ecological
exposure
pathway
to
be
complete,
it
must
have
a
source,
an
environmental
transport
medium,
a
point
of
exposure
for
ecological
receptors,
and
a
feasible
route
of
exposure.

Ecological
receptors
that
may
potentially
be
exposed
to
ADBAC
include
terrestrial
and
semiaquatic
wildlife
(
i.
e.,
mammals,
birds,
amphibians
and
reptiles),
terrestrial
and
semi­
aquatic
plants,
and
terrestrial
soil
and
aquatic
sediment
invertebrates.
Additionally,
aquatic
organisms
(
i.
e.,
freshwater
and
estuarine/
marine
fish
and
invertebrates,
amphibians,
and
aquatic
plants)
are
potential
receptors
in
adjacent
water
bodies
through
the
off­
site
transport
of
ADBAC
from
the
application
site
through
runoff,
erosion
and
spray
drift.
The
primary
route
of
wildlife
exposure
to
DDAC
appears
to
be
through
drinking
treated
water,
though
amphibians
may
be
at
risk
from
these
applications.
Page
5
of
50
1.4.1
Risk
Hypothesis
At
maximum
application
rates
for
the
previously
described
uses
exposure
of
terrestrial,
aquatic
and
semi­
aquatic
wildlife
and
plants
to
ADBAC
and/
or
DDAC
may
be
sufficiently
high
to
result
in
direct
effects
(
i.
e.,
mortality
due
to
acute
exposure
or
impaired
reproduction,
growth,
or
survival
from
chronic
exposure).
Additionally,
endangered
and
threatened
species
may
be
indirectly
affected
by
ADBAC
and/
or
DDAC
due
to
a
loss
of
food
resources
and/
or
changes
to
critical
habitat
resulting
from
proposed
uses.

1.5
Analysis
Plan
This
screening
level
ecological
risk
assessment
characterizes
the
environmental
fate
and
transport
of
ADBAC
to
assess
the
extent
to
which
non­
target
organisms
may
be
exposed
through
the
current
proposed
uses
of
these
pesticides.
EFED
relied
on
AD's
evaluation
of
the
environmental
fate
and
transport
of
ADBAC
and
DDAC,
which
can
be
found
in
the
AD
RED
document.
The
toxicity
of
ADBAC
is
also
characterized,
based
primarily
on
registrantsubmitted
guideline
toxicity
tests
and
additional
information
from
open
literature
available
through
the
Agency's
ECOTOX
database
(
http://
www.
epa.
gov/
ecotox/),
and
evaluated
by
AD
scientists.
Estimated
exposure
and
effects
are
integrated
to
calculate
risk
quotients
(
RQs)
for
non­
target
Federally
listed
endangered/
threatened
and
other
non­
target
animals
and
plants.
RQs
are
compared
to
pre­
determined
levels­
of­
concern
(
LOCs)
to
screen
out
those
taxa
to
which
ADBAC
is
not
likely
to
pose
unacceptable
risk.
Because
of
the
limited
use
and
low
expected
exposure
of
wildlife
to
DDAC,
as
detailed
later
in
this
document,
ADBAC
is
primarily
considered
in
this
document.
Although
risk,
in
the
context
intended
here,
is
often
defined
as
the
likelihood
and
magnitude
of
adverse
ecological
effects,
the
risk
quotient­
based
approach
does
not
provide
a
quantitative
estimate
of
likelihood
and/
or
magnitude
of
adverse
effects.
Such
estimates
may
be
possible
through
a
more
refined,
probabilistic
assessment.
However,
this
is
beyond
the
scope
of
this
screening­
level
assessment.

1.6
Routes
of
Exposure
Routes
of
exposure
to
terrestrial
and
aquatic
organisms
can
occur
from
direct
deposition,
spray
drift
and/
or
runoff.
Exposure
may
be
through
ingestion
of
contaminated
food
or
water
sources,
dermal
contact
or
absorption,
and
inhalation.
The
Agency
assumes
terrestrial
organisms
are
present
and
feeding
on
the
use
site.
All
routes
of
aquatic
exposure
are
assumed
to
be
accounted
for.

This
assessment
does
not
take
into
account
atmospheric
transport
in
estimating
environmental
concentrations,
nor
does
it
account
for
ingestion
of
ADBAC
or
DDAC
residues
by
animals
in
contaminated
grit,
ingestion
through
preening
activities,
or
uptake
through
inhalation
or
dermal
absorption
by
terrestrial
animals.
Exposure
to
terrestrial
animals
is
based
primarily
on
dietary
consumption
of
foliar
residues
and,
in
this
case,
drinking
water.
Aquatic
assessments
assume
that
all
potential
routes
of
direct
exposure
are
accounted
for.
While
ADBAC
and
DDAC
are
registered
for
use
in
greenhouses,
this
use
is
typically
conducted
indoors
and,
thus,
exposure
to
non­
target
animals
is
limited
and
is
therefore
not
considered
in
this
assessment.
Page
6
of
50
2
Analysis
2.1
Use
Characterization
ADBAC
and
DDAC
are
used
primarily
as
antimicrobial
agents;
evaluation
of
these
uses
can
be
found
in
the
Antimicrobials
Division
risk
assessment
in
support
of
the
reregistration
eligibility
decision
(
RED)
for
these
compounds.
Additionally,
ADBAC
is
used
on
ornamental
plants
and
shrubs,
residential
lawns
and
commercial
turf
and
golf
course
greens,
tees
and
fairways.
Both
ADBAC
and
DDAC
are
labeled
for
use
in
puddles
and
decorative
pools
to
control
algae.
ADBAC
is
also
labeled
for
use
as
mosquito
larvicide
in
standing
waters,
including
decorative
ponds
and
pools,
inactive
spas
and
hot
tubs,
as
well
as
`
old
tires,
empty
tin
cans,
puddles
and
water
drains
around
buildings'
(
RD20
®
label).
Only
the
ADBAC/
DDAC
uses
which
could
result
in
potential
environmental
exposures
and
effects
are
being
evaluated
in
this
assessment.
These
uses
are
described
below.

Puddles,
Ornamental
Ponds
and
Pools
Three
products
are
labeled
for
the
control
of
algae
in
puddles
and
ornamental
ponds
and
pools,
RD20
®
,
TC192
®
and
PT2000
®
.
All
three
products
contain
ADBAC;
TC192
also
contains
DDAC
(
the
only
DDAC
use
considered
in
this
assessment).
These
uses
are
labeled
for
direct
application
to
water
with
a
target
maximum
concentration
of
5
ppm
for
the
first
application.
Subsequent
applications
can
be
made
weekly
at
concentrations
of
2.5
ppm.
There
are
no
label
limits
on
the
number
of
applications
that
can
be
made
in
a
year.
These
applications
can
be
a
source
of
exposure
to
terrestrial
wildlife
making
use
of
the
water
for
drinking
or
bathing,
as
well
as
amphibians
making
use
of
these
waterbodies
for
all
or
part
of
their
lifecycle.
Because
the
product
is
applied
directly
into
the
water,
exposure
via
forage
items
is
not
expected
(
emergent
vegetation
is
assumed
not
to
be
present).
The
labels
specifically
state
that
application
should
not
be
made
where
fish
are
present;
therefore
exposure
to
fish
is
not
expected
when
used
in
accordance
with
the
label.
However,
because
there
is
no
explicit
prohibition
on
the
labels,
exposure
to
amphibians
is
possible,
especially
during
the
aquatic
phase.
Because
of
the
persistence
of
ADBAC
and
DDAC,
the
weekly
maintenance
applications
could,
at
least
in
some
instances,
result
in
increased
concentrations
throughout
the
year,
leading
to
the
potential
for
exposure
at
concentrations
greater
than
5
ppm.
This
assessment
assumes,
as
suggested
on
the
labels,
that
the
target
waterbodies
are
ornamental
or
periodic
and
disconnected
from
the
larger
watershed.
The
label
should
be
more
explicit
regarding
this
assumption.
Further
work
would
need
to
be
done
to
evaluate
potential
wildlife
exposure
if
the
registrants
do
not
support
this
assumption.

Mosquito
control
The
mosquito
control
uses
(
RD20
®
product
label)
specify
that
treated
bodies
of
all
sizes
receive
an
initial
treatment
at
a
target
concentration
of
200
ppm
and
allow
weekly
maintenance
dose
at
a
concentration
of
100
ppm.
There
are
no
label
limits
on
the
number
of
applications
that
can
be
made
in
a
year.
Because
of
the
types
of
standing
waters
indicated
on
the
label
(
from
empty
tin
cans
to
decorative
ponds),
this
use
could
be
a
source
of
exposure
to
terrestrial
wildlife
making
use
of
the
water
for
drinking
or
bathing,
or
by
amphibians
for
completion
of
a
lifecycle
phase,
such
as
tadpoles.
Since
the
product
is
applied
directly
into
the
water,
exposure
via
forage
items
is
not
expected
(
emergent
vegetation
is
assumed
not
to
be
present).
The
label
specifically
Page
7
of
50
states
that
application
should
not
be
made
where
fish
are
present;
therefore,
exposure
to
fish
is
not
expected
when
used
in
accordance
with
the
label.
However,
because
there
is
no
explicit
prohibition
on
the
labels,
exposure
to
amphibians
is
possible,
especially
during
the
aquatic
phase.
Because
of
the
persistence
of
ADBAC,
the
weekly
maintenance
applications
could,
at
least
in
some
instances,
result
in
increased
concentrations
throughout
the
year,
leading
to
the
potential
for
exposure
at
doses
far
greater
than
200
ppm
for
other
wildlife.
This
assessment
assumes,
as
suggested
on
the
label,
that
the
target
waterbodies
are
ornamental
or
periodic
and
disconnected
from
the
larger
watershed.
The
label
should
be
more
explicit
regarding
this
assumption.
Further
work
would
need
to
be
done
to
evaluate
potential
wildlife
exposure
if
the
registrants
do
not
support
this
assumption.

Turf
and
Golf
Courses
Two
ADBAC
products
(
Consan
®
and
RD20
®
)
are
labeled
for
use
on
residential
lawns,
commercial
turf
and
golf
courses.
These
uses
control
algal
build­
up
and
fungal
diseases
such
as
fusarium
blight
(
Fusarium
spp.)
and
brown
patch
(
Rhizoctonia
spp.).
Smaller
use
sites,
such
as
residential
lawns,
are
labeled
for
a
concentration
of
790
ppm
which
is
equivalent
to
a
rate
of
6.8
lb
ai/
A.
This
rate
is
also
used
for
golf
courses
and
commercial
(
nonagricultural)
turf
unless
a
commercial
power
sprayer
is
used.
If
a
commercial
power
sprayer
is
used,
the
application
rate
is
reduced
to
512
ppm
(
0.82
lb
ai/
A).
Presumably,
as
implied
on
the
labels,
smaller
areas
would
be
treated
at
the
higher
rate,
while
larger­
scale
applications
would
be
treated
at
the
lower
rate.
However,
this
assumption
is
not
fully
clear
from
the
label
and
should
be
explicitly
expressed.
Further
assessment
would
be
required
if
this
assumption
is
not
supported.

The
product
labels
do
not
specify
seasonal
or
yearly
limits
on
the
maximum
number
of
applications
or
pounds
per
acre.
The
label
does
specify
10­
14
days
between
applications.
The
label
states
applications
should
be
made
during
the
warm
growing
season,
so
the
number
of
applications
may
vary
depending
on
the
geographic
area
where
it
is
used.
Without
a
limit,
a
hypothetical
Florida
golf
course
could
apply
ADBAC
every
ten
days
all
year
long.
Without
data
indicating
otherwise,
this
seems
plausible
given
the
wide
range
of
target
organisms
for
which
ADBAC
controls
(
semi­
terrestrial
alga
species,
numerous
species
of
fungi).
These
organisms
are
generally
a
greater
problem
under
warm
wet
conditions,
so
some
use
sites
may
need
appreciably
fewer
applications
to
achieve
desired
control.
However,
it
is
unclear
what
a
typical
number
of
applications
would
be;
maximum
applications
per
year
should
be
explicitly
stated
on
the
labels.

Terrestrial
wildlife
exposure
could
occur
from
these
uses,
whether
through
foraging
in
the
treated
area
or
by
feeding
on
organisms
affected
by
spray
drift,
runoff
and
or
erosion.
Aquatic
organisms
could
be
affected
by
spray
drift,
runoff
and/
or
erosion.
This
assessment
evaluates
these
potential
routes
of
exposure.

Nursery
Uses
(
bedding
plants,
ornamental
shrubs
and
trees)

The
products
Timsen
®
,
Consan
®
and
RD20
®
are
all
labeled
for
nursery
uses
to
control
various
fungal
and
bacterial
pathogens
that
can
cause
damage
to
ornamental
plants.
The
uses
appear
to
be
limited
to
spray
and
drench
applications,
and
are
assessed
accordingly.
However,
the
intended
application
methods
should
be
explicitly
stated
on
the
labels.
In
2002,
there
were
68,214
acres
of
floriculture
(
bedding/
garden
plants,
cut
flowers
and
cut
florist
greens,
foliage
plants,
and
potted
flowering
plants)
grown
in
14,579
outdoor
nurseries
in
the
US
Page
8
of
50
(
www.
nass.
usda.
gov/
census/).
The
labels
allow
for
use
on
a
variety
of
herbaceous
annuals,
such
as
fuchsia
and
snapdragons,
as
well
as
larger
perennials
such
as
ash
and
sycamore
trees.
Because
different
ornamental
species
have
different
pathogen
pressures,
different
rates
are
recommended
for
each
pathogen
targeted.
For
instance,
palms
needing
protection
from
heart
rot
and
penicillium
leaf
base
rot
are
treated
with
Consan
®
at
a
concentration
of
1563
ppm
while
crepe
myrtle
and
fruit
trees
being
treated
for
fireblight
are
treated
at
a
concentration
of
781
ppm.
Differences
in
amount
of
product
that
will
potentially
be
available
for
exposure
to
non­
target
organisms
depends
on
the
quantity
of
solution
applied.
The
palm
treatment
uses
a
small
amount
of
solution
poured
into
the
`
cup'
formed
at
the
base
of
the
leaves;
this
treatment
is
repeated
weekly
until
control
is
achieved.
For
fireblight
control,
the
entire
tree
is
sprayed
at
two­
week
intervals,
with
some
phenological
limitations
(
e.
g.,
early
spring
and
fall
after
harvest;
Consan
®

label
only).
For
some
larger
ornamentals,
such
as
ash
or
sycamore,
the
label
states
that
50­
60
gallons
of
solution
(
528
ppm)
may
be
required
to
achieve
full
coverage.
These
applications
can
be
repeated
up
to
three
times,
at
intervals
determined
by
leaf
emergence
and
development.
These
treatments
are
equivalent
to
application
of
0.25
lbs
ai/
tree/
treatment.
If
40
gallons
is
assumed
to
be
required
for
adequate
coverage
of
somewhat
smaller
trees,
such
as
fruit
trees
(
781
ppm),
the
mass
applied
is
also
0.25
lbs
ai/
tree/
treatment.
Wildlife
could
be
exposed
through
runoff
or
drift
contaminating
food
or
water
sources,
or
foraging
on
either
the
treated
plant
or
nontarget
plants
in
the
vicinity
of
the
treatment.

2.2
Exposure
Characterization
2.2.1
Environmental
Fate
and
Transport
Characterization
ADBAC
is
immobile
and
persistent;
while
it
is
not
likely
to
leach
in
to
groundwater,
it
may
enter
surface
water
through
erosion.
The
available
soil
mobility
study
shows
that
ADBAC
has
a
strong
tendency
to
bind
to
sediment/
soil
with
Freundlich
Kads
values
of
6,172
for
sand
soil,
10,797
for
silt
loam,
5,123
for
sandy
loam
soil,
and
32,429
for
clay
loam.
The
corresponding
Koc
values
are
6,171,657
for
sand
soil,
2,159,346
for
silt
loam,
640,389
for
sandy
loam
soil,
and
1,663,039
for
clay
loam
(
MRID
424148­
01).
There
are
no
guideline
data
for
aerobic
soil
degradation
of
ADBAC.
Because
of
its
strong
adsorption
to
soils,
the
potential
to
reach
aquatic
water
bodies
via
runoff
or
leaching
is
limited.
ADBAC
may,
however,
be
transported
off­
site
to
aquatic
water
bodies
as
entrained
sediment
or
via
spray
drift
during
aerial
or
ground
spray
applications.
Once
in
aquatic
environments,
ADBAC
is
hydrolytically
stable
under
abiotic
and
buffered
conditions
over
the
pH
5­
9
range
(
MRID
408356­
02).
ADBAC
is
also
stable
to
photodegradation
in
pH
7
buffered
aqueous
solutions
(
MRID
408356­
03).

Aquatic
metabolism
studies
under
aerobic
and
anaerobic
conditions
indicate
that
ADBAC
is
stable
to
microbial
degradation.
ADBAC
did
not
degrade
in
flooded
sand
loam
soil
that
was
incubated
at
24­
27
°
C
in
the
dark
for
up
to
30
days
in
an
aerobic
aquatic
metabolism
study
(
MRID
408356­
04).
Under
anaerobic
conditions,
ADBAC
was
found
to
be
very
resistant
to
degradation
with
a
calculated
half­
life
of
1,815
days
(
MRID
424151­
01).

Bioaccumulation
of
ADBAC
in
freshwater
fish
is
not
likely
to
occur.
Maximum
bioconcentration
factors
(
BCF)
were
33X
for
edible
tissues
(
muscle,
skin),
160X
for
nonedible
tissues
(
viscera,
head,
carcass),
and
79X
for
whole
fish
tissues
(
MRID
410268­
01).
ADBAC
is
not
expected
to
pose
a
concern
for
bioconcentration
in
aquatic
organisms.
Page
9
of
50
Major
degradates
were
not
identified
in
any
of
the
available
studies.
The
environmental
fate
and
physical­
chemical
properties,
based
on
submitted
guideline
studies,
are
summarized
in
Table
2.1.
Details
of
individual
studies
can
be
found
in
the
ADBAC
Environmental
Fate
Assessment
conducted
by
the
AD.

Table
2.1
General
fate
and
physical­
chemical
data
for
ADBAC.
Parameter
Value
Source
Molecular
Weight
377.83
Product
chemistry
Solubility
(
25
º
C)
Completely
Soluble
Product
chemistry
Vapor
Pressure
(
25
º
C)
3.53
x
10­
12
torr
Product
chemistry
Hydrolysis
Half­
life
(
25
º
C)
pH
5
pH
7
pH
9
150
d
183
d
379
d
MRID
408356­
2,
424152­
01
Aqueous
Photolysis
Half­
life
stable
MRIDs
411055­
01,
424152­
01
Soil
Photolysis
Half­
life
no
data
Aerobic
Soil
Metabolism
Half­
life
no
data
Aerobic
Aquatic
Metabolism
Half­
life
stable
(
sand
loam)
MRIDs
408356­
04,
424149­
01
Anaerobic
Aquatic
Metabolism
Half­
life
1,815
d
(
sandy
loam)
MRIDs
411055­
01,
424150­
02
Organic
Carbon
Partitioning
Coefficient
(
Koc,
L/
kgoc)
6.2
x
106,
2.2
x
106,
6.4
x
105,
1.7
x
106
MRID
408356­
05
Soil
Partitioning
Coefficient
(
kd,
L/
kg)
6172,
10797,
5123,
32429
MRID
408356­
05
Bioconcentration
Factors
(
BCF)
Edible
tissue
Nonedible
tissue
Whole
fish
tissue
33X
160X
79X
MRID
410268­
01
2.2.2
Measures
of
Aquatic
Exposure
This
assessment
involves
Tier
II
modeling
(
PRZM/
EXAMS)
for
selected
scenarios
representing
all
proposed
outdoor
uses.
Monitoring
data
were
not
considered
because
nationalscale
monitoring
studies
were
not
identified.
For
Tier
II,
two
models
are
used
in
tandem.
The
Pesticide
Root
Zone
Model,
(
PRZM,
Carsel
et
al.,
1997)
simulates
fate
and
transport
on
the
agricultural
field.
The
version
of
PRZM
used
was
PRZM
3.12
beta
dated
May
24,
2001.
The
water
body
is
simulated
with
Exposure
Analysis
Modeling
System
(
EXAMS),
version
2.98,
dated
July
18,
2002
(
Burns,
1997).
Simulations
are
run
for
multiple
(
usually
30)
years
and
the
estimated
environmental
concentrations
(
EECs)
represent
peak
values
that
are
expected
once
every
ten
years
based
on
the
thirty
years
of
daily
values
generated
during
the
simulation.

For
aquatic
endpoints,
the
exposure
is
estimated
for
the
maximum
application
pattern
to
a
10­
ha
field
bordering
a
1­
ha
pond,
2­
m
deep
(
20,000
m3)
with
no
outlet.
Exposure
estimates
generated
using
this
standard
pond
are
intended
to
represent
a
wide
variety
of
vulnerable
water
bodies
that
occur
at
the
top
of
watersheds
including
prairie
pot
holes,
playa
lakes,
wetlands,
vernal
pools,
man­
made
and
natural
ponds,
and
intermittent
and
first­
order
streams.
As
a
group,
there
are
factors
that
make
these
water
bodies
more
or
less
vulnerable
than
the
standard
surrogate
pond.
Static
water
bodies
that
have
larger
ratios
of
drainage
area
to
water
body
volume
would
be
expected
to
have
higher
peak
EECs
than
the
standard
pond.
These
water
bodies
will
be
either
smaller
in
size
or
have
large
drainage
areas.
Smaller
water
bodies
tend
to
have
limited
storage
capacity
and
thus
tend
to
overflow
and
carry
pesticide
in
the
discharge
whereas
the
standard
pond
has
no
discharge.
As
watershed
size
increases
beyond
10­
ha,
it
becomes
increasingly
unlikely
that
the
entire
watershed
is
planted
with
a
non­
major
single
crop
that
is
all
treated
with
Page
10
of
50
the
pesticide.
Headwater
streams
can
also
have
peak
concentrations
higher
than
the
standard
pond,
but
they
tend
to
persist
for
only
short
periods
of
time
and
are
then
carried
downstream.

OPP
standard
PRZM
crop
or
orchard
scenarios,
which
consist
of
soils,
weather
and
cropping
practices
that
are
location­
specific,
are
used
in
the
simulations
to
represent
labeled
uses
of
ADBAC.
These
scenarios
are
developed
to
represent
high­
end
exposure
sites
in
terms
of
vulnerability
to
runoff
and
erosion
and
subsequent
off­
site
transport
of
pesticide.

2.2.2.1
Aquatic
exposure
modeling
Tier
II
EECs
are
estimated
using
EFED's
aquatic
models
PRZM
and
EXAMS
(
described
in
previous
section).
PRZM
is
used
to
simulate
pesticide
transport
as
a
result
of
runoff,
erosion
and
spray
drift
from
a
10­
ha
agricultural
field
and
EXAMS
considers
environmental
fate
and
transport
of
pesticides
in
surface
water
and
predicts
EECs
in
a
standard
pond
(
10,000­
m2
pond,
2­
m
deep),
with
the
assumption
that
the
small
field
is
cropped
at
100%.
Simulations
are
carried
out
with
the
linkage
program
shell,
PE4V01.
pl
(
dated
8/
13/
2003),
which
incorporates
the
standard
crop
and
orchard
scenarios
developed
by
EFED.
Additional
information
on
these
models
can
be
found
at:
http://
www.
epa.
gov/
oppefed1/
models/
water/
index.
htm.

All
horticultural
or
aquatic
ADBAC/
DDAC
uses
are
considered
in
this
assessment
(
puddles,
ornamental
ponds
and
pools;
mosquito
control;
turf
and
golf
courses;
ornamental
shrubs
and
trees).
For
aquatic
exposures,
it
is
assumed
that
the
direct
applications
to
puddles,
ornamental
ponds
and
pools
and
the
mosquito
control
uses
result
in
minimal
exposure
to
aquatic
environments
since
the
labels
specify
that
applications
should
not
be
made
where
fish
are
present
and
it
is
implied
on
the
label
that
the
application
sites
are
ornamental
or
periodic
and
disconnected
from
the
greater
watershed.
However,
even
small,
ephemeral
puddles
can
be
used
wildlife
for
drinking
water
and,
as
in
the
case
of
amphibians,
for
critical
life
stages.
Labels
need
to
explicitly
state
any
restrictions.
For
the
turf
and
golf
course
uses,
two
standard
scenarios
were
used
for
PRZM/
EXAMS
modeling,
FL
turf
and
PA
turf.
For
the
ornamental
uses,
two
standard
scenarios
were
used
as
surrogates
for
ornamental
trees,
OR
Xmas
tree
and
GA
pecan.
A
summary
of
the
crop
scenarios
used
to
estimate
ADBAC
concentrations
in
the
aquatic
systems
for
ecological
risk
assessment
are
listed
in
Table
2.2,
along
with
some
characterization
of
why
the
scenario
was
chosen.

Table
2.2.
Summary
of
crop
scenarios
used
in
estimating
EECs.

ADBAC
Uses
(
EPA
Reg.
#)
Crop
Scenario
MLRA/
Met
Station
Scenario
Characterization
FL
turf:
Osceola
County,
Adamsville
sand
MLRA
156A;
W12834
Turf
and
golf
courses
(
58044­
3,
53642­
1)

PA
turf:
York
County,
Glenville
silt
loam
MLRA
148;
W14737
Selected
based
on
geographical
location,
agricultural
practices,
and
use
patterns.

OR
Xmas
tree:
Benton
County,
Pilchuck
fine
sand
MLRA
A2;
W24232
Selected
as
a
surrogate
for
ornamental
trees
in
Pacific
northwest
Ornamental
trees
(
58044­
3,
53642­
1,
507­
3)

GA
pecan:
Mitchell
County;
Greenville
fine
sandy
loam
MLRA
133A;
W93805
Selected
as
a
surrogate
for
ornamental
trees
in
the
southeast
PRZM/
EXAMS
modeling
of
ADBAC
uses
four
PRZM
scenarios
identified
in
Table
2.2
at
the
current
maximum
label
rate,
maximum
number
of
applications
per
year
and
the
minimum
Page
11
of
50
application
interval
of
the
ADBAC
use
represented
by
each
scenario.
For
the
turf/
golf
course
uses
application
rates
for
use
with
a
commercial
sprayer
and
for
more
limited
residential
use
are
both
modeled
at
0.8
and
6.8
lbs
ai/
A,
respectively).
The
maximum
number
of
applications
per
year
is
currently
not
specified
on
product
labels
for
the
turf/
golf
course
use.
Therefore
a
number
of
application
scenarios,
ranging
from
1
application
per
year
to
26
applications
per
year
(
Table
2.3),
are
simulated
to
cover
the
range
of
possibilities.
Although,
the
label
specifies
a
maximum
of
3
applications
per
year
for
the
ornamentals
use,
the
minimum
application
interval
is
not
specified.
A
minimum
application
interval
of
7
days
is
assumed
(
Table
2.3).
The
modeled
application
rate
for
the
ornamental
use
(
302
lbs
ai/
A)
assumes
a
tree
spacing
of
6'
x
6'
and
a
maximum
application
of
60
gallons
(
0.25
lbs
a)
per
tree.
For
both
the
ornamental
and
residential
turf
uses
the
default
10
ha
(
25
A)
field
scenario
is
modeled
in
addition
to
a
number
of
smaller
fields
(
10,
1,
and
0.5
A)
since
it
is
possible
that
these
uses
are
limited
in
area
and
the
default
25­
A
scenario
may
result
in
unrealistically
high
exposure
concentrations.

Where
applicable,
modeling
input
parameters
are
selected
according
to
current
guidance
(
Guidance
for
Selecting
Input
Parameters
in
Modeling
the
Environmental
Fate
and
Transport
of
Pesticides
Version
II,
EFED,
February
28,
2002).
Application­
specific
and
chemical­
specific
input
parameters
for
PRZM/
EXAMS
modeling
are
listed
in
Table
2.3
and
Table
2.4,
respectively.
All
scenarios
simulate
aerial
spray
applications
(
PRZM
chemical
application
method,
CAM
=
2),
with
corresponding
application
efficiency
and
drift
fractions
equal
to
0.95
and
0.05,
respectively.
The
condition
for
disposition
of
the
pesticide
remaining
on
foliage
after
harvest
(
PRZM
variable
IPSCND)
is
set
to
1
(
pesticide
remaining
on
foliage
is
converted
to
surface
application)
for
all
uses
consistent
with
turf
and
nursery
practices.
Application
dates
are
chosen
based
on
the
label
information
when
available.

A
soil
organic
carbon
partitioning
coefficient
(
Koc)
of
2.7
x
106
L/
kgoc,
the
mean
of
four
soils,
is
used.
The
aerobic
soil
metabolism
is
assumed
stable
since
there
are
no
available
guideline
studies.
The
aquatic
metabolism
and
aerobic
aquatic
metabolism
are
assumed
stable
as
indicated
by
the
submitted
guideline
studies.
Since
there
is
only
one
study
for
the
anaerobic
aquatic
metabolism,
three
times
the
half­
life
was
used
to
account
for
variability
in
the
environment
(
5445
days).
The
hydrolysis
half­
life
of
183
days
is
used
since
the
ecological
water
body
is
a
constant
pH
7.

Table
2.3
PRZM/
EXAMS
application­
specific
input
parameters.

ADBAC
Use(
s)
(
EPA
Reg.
#)
PRZM
scenarios
Maximum
app.
rate
(
lbs
a.
i./
A)
No.
of
app.
per
year/
interval
(
d)
1
App.
method
drift/
app.
efficiency
Application
timing
First
application
date
Turf
and
golf
courses
(
58044­
3,
53642­
1)
FL
turf
PA
turf
0.8
26/
10
10/
10
5/
10
1
aerial
spray
0.05/
0.95
Warm
growing
season
June
1
Ornamental
trees
(
58044­
3,
53642­
1,
507­
3)
OR
Xmas
tree
GA
Pecans
302
3/
7
aerial
spray
0.05/
0.95
Not
specified
May
10
1
Number
of
applications
not
specified
on
label
for
turf
uses;
four
scenarios
considered:
26,
10,
5
and
1
application
per
year.
Minimum
interval
between
applications
not
specified
on
labels
for
ornamental
uses;
a
7
day
interval
was
assumed.
Page
12
of
50
Table
2.4
Chemical­
specific
PRZM/
EXAMS
inputs.

Parameter
Value
Source
(
MRID
#
or
citation)
Comment
Soil
Partition
Coefficient
(
Koc
mL/
g)
2.7
x
106
MRID
408356­
05
average
value
Aerobic
Soil
Metabolism
Half­
life
(
days)
0
no
data
stable
to
aerobic
soil
metabolism
Molecular
Weight
(
g/
mol)
377.83
Product
chemistry
Vapor
Pressure
(
torr)
3.53
x
10­
12
Product
chemistry
Henry's
Law
Constant
(
atm­
m3­
mol)
7.76
x
10­
13
Product
chemistry
Solubility
in
Water
at
25oC
(
ppm)
Completely
sol.
Product
chemistry
10X
solubility
Aerobic
Aquatic
Metabolism
Half­
life
(
days)
0
MRIDs
408356­
04,
424149­
01
stable
to
aerobic
aquatic
metabolism
Anaerobic
Aquatic
Metabolism
Half­
life
(
days)
5445
MRIDs
411055­
01,
424150­
02
one
study:
3x
1,815
d
Hydrolysis
Half­
life
@
pH
7
(
days)
183
MRID408356­
02
water
body
constant
pH
7
Aquatic
Photolysis
Half­
life
(
days)
0
MRIDs
408356­
03,
424152­
01
stable
to
aquatic
photolysis
Foliar
extraction
0.5
Default
Foliar
decay
rate
0
Default
stable
to
foliar
degradation
Simulated
EECs
for
all
scenarios
are
presented
in
Table
2.5.
Copies
of
the
input
and
output
files
are
in
Appendix
A.
Acute
EECs
range
from
0.67
­
1473
µ
g/
L,
21­
day
chronic
EECs
range
from
0.37
­
920
µ
g/
L
and
60­
day
average
EECs
range
from
0.36
­
903
µ
g/
L.

Table
2.5
Estimated
Aquatic
Exposure
Concentrations
Calculated
with
PRZM/
EXAMS.

ADBAC
Uses/
EPA
Reg.
#
Scenario
App.
Rate
(
lbs
ai/
A)
#
Apps.
Interval
Area
treated
(
A)
Acute
(
Fg/
L)
21­
day
Chronic
(
Fg/
L)
60­
day
Chronic
(
Fg/
L)

26
10
15.6
9.4
9.1
10
10
6.0
3.6
3.5
5
10
3.1
1.8
1.8
Turf
FL
turf
0.8*

1
­­
25**

0.67
0.37
0.36
26
10
20.6
10.9
10.6
10
10
7.8
4.2
4.1
5
10
3.9
2.1
2.0
Turf
PA
turf
0.8*

1
­­
25**

0.80
0.43
0.41
Page
13
of
50
ADBAC
Uses/
EPA
Reg.
#
Scenario
App.
Rate
(
lbs
ai/
A)
#
Apps.
Interval
Area
treated
(
A)
Acute
(
Fg/
L)
21­
day
Chronic
(
Fg/
L)
60­
day
Chronic
(
Fg/
L)

25**
49.2
26.5
25.5
10
19.7
10.6
10.2
1
1.97
1.06
1.02
Turf
Fl
turf
6.8***
10
10
0.5
0.98
0.53
0.51
25**
62.5
30.3
29.3
10
25.0
12.1
11.7
1
2.50
1.21
1.17
Turf
PA
turf
6.8***
10
10
0.5
1.25
0.61
0.59
25**
1473
920
903
10
589
368
361
1
58.9
36.8
36.1
Ornamental
GA
pecan
302****
3
7
0.5
29.5
18.4
18.1
25**
557
361
339
10
223
144
136
1
22.3
14.4
13.6
Ornamental
OR
Christmas
tree
302****
3
7
0.5
11.2
7.2
6.8
*
Golf
course
tees,
greens
and
fairways
and
commercial
turf
applications
**
Standard
default
scenario,
10
ha
field,
100%
treated
***
Residential
turf
applications
****
Assumes
6'
x
6'
spacing
of
trees,
0.25
lbs
ai/
tree
2.2.2.2
Aquatic
exposure
monitoring
data
No
monitoring
data
are
identified
for
either
ADBAC
or
DDAC.

2.2.3
Terrestrial
Exposure
Assessment
Application
methods
for
ADBAC
include
spray
and
drench
treatments
of
individual
plants
and
flats
as
well
as
turf
spray.
Both
ADBAC
and
DDAC
are
labeled
for
direct
application
into
small
waterbodies,
such
as
puddles,
ornamental
ponds,
old
tires,
etc.
The
combination
of
many
uses
and
assorted
application
methods
can
potentially
result
in
various
routes
of
non­
target
exposure
to
terrestrial
organisms.
However,
the
only
use
of
DDAC
is
labeled
for
5
ppm
formulated
product
(
3
ppm
ai
DDAC).

The
EEC
values
used
for
terrestrial
exposure
from
direct
application
are
calculated
using
the
TREX
model
(
Version
1.2.3),
and
are
derived
from
the
Kenaga
nomograph,
as
modified
by
Fletcher
et
al.
(
1994),
based
on
a
large
set
of
actual
field
residue
data.
The
upper
limit
values
from
the
nomograph
represent
the
95th
percentile
of
residue
values
from
actual
field
Page
14
of
50
measurements
(
Hoerger
and
Kenaga,
1972).
The
Fletcher
et
al.
(
1994)
modifications
to
the
Kenaga
nomograph
are
based
on
measured
field
residues
from
249
published
research
papers,
including
information
on
118
species
of
plants,
121
pesticides,
and
17
chemical
classes.
These
modifications
represent
the
95th
percentile
of
the
expanded
data
set.
Risk
quotients
are
based
on
the
most
sensitive
LC50
and
NOAEC
for
birds
(
in
this
instance,
bobwhite
quail)
and
LD50
for
mammals
(
based
on
lab
rat
studies).
Dietary
EECs,
unadjusted
for
organism
type
or
size,
range
from
42
ppm
on
fruits/
pods/
large
insects
for
turf
application,
five
times
per
year
at
10­
day
intervals
to
180,814
ppm
on
short
grass
for
ornamental
applications
three
times
per
year
at
10­
day
intervals
(
Table
2.6).
Since
the
labels
do
not
limit
the
number
of
applications
for
most
uses,
modeled
exposure
scenarios
may
not
represent
the
most
conservative
assumptions.
More
scenarios
are
considered
in
the
Risk
Description
section
of
this
document.

Table
2.6.
Unadjusted
dietary­
based
EECs
for
two
possible
application
scenarios.
Use
Pattern
Forage
Item
Upper
bound
EEC
(
ppm)
Turf
Short
Grass
1062
0.8
lbs
ai/
A
Tall
Grass
487
26
applications/
year
Broadleaf
plants/
sm
insects
598
10
day
interval
Fruits/
pods/
seeds/
lg
insects
66
Ornamentals
Short
Grass
180713
302
lbs
ai/
A
Tall
Grass
82827
3
applications/
year
Broadleaf
plants/
sm
insects
101651
10
day
interval
Fruits/
pods/
seeds/
lg
insects
11295
Since
direct
application
to
small
waterbodies
is
prescribed
for
some
uses,
drinking
water
is
likely
to
be
a
route
of
exposure
for
wildlife
of
various
sizes.
Therefore
drinking
water
exposure
is
estimated
using
allometric
equations
(
Appendix
C)
from
The
Wildlife
Exposure
Factors
Handbook
(
USEPA
1994).
Because
birds
and
mammals
have
different
water
requirements,
estimates
of
exposure
are
considered
separately
(
Table
2.7).
The
modeled
concentrations
are
those
resulting
from
initial
direct
application
of
ADBAC/
DDAC
to
small
waterbodies
according
to
the
labels.
Additionally,
amphibians
may
be
exposed
at
critical
stages
in
their
lifecycle.
Exposure
may
be
greater
following
subsequent
applications
due
to
the
persistence
of
the
chemicals.

Table
2.7.
Estimated
exposure
to
total
active
ingredient
to
wildlife
through
drinking
water.
Avian
Daily
Exposure
Estimate
(
mg/
kg­
bw)
Concentration
(
ppm)
20g
100g
1000g
5*
1.1
0.6
0.3
200
43
25
12
Mammalian
Daily
Exposure
Estimate
(
mg/
kg­
bw)
15g
35g
1000g
5*
0.8
0.7
0.5
200
30
28
20
*
Formulation
is
12%
DDAC,
8%
ADBAC
3
Ecotoxicity
The
ecotoxicological
endpoints
used
in
this
assessment
are
those
used
by
AD
in
their
assessment.
The
endpoints
are
summarized
and
briefly
described
here.
Greater
detail
is
provided
in
Appendix
B.
Only
ADBAC
is
considered
in
this
section,
as
DDAC
endpoints
were
Page
15
of
50
not
provided.
However,
a
previous
EFED
assessment
of
DDAC
(
Review
of
Data
Submitted
to
Support
the
New
Use
of
BARDAC
MOLLUSCICIDE
®
(
Didecyl
dimethyl
ammonium
chloride)
for
Salt
Water
Cooling
Systems;
DP
Barcode:
D215429)
suggests
similar
toxicity
to
wildlife.
Nevertheless,
the
toxicity
of
DDAC
remains
an
uncertainty
in
this
assessment.
As
described
in
other
parts
of
this
document,
wildlife
exposure
to
DDAC
is
expected
to
be
limited.

3.1
Toxicity
to
Terrestrial
Animals
3.1.1
Avian,
Acute
and
Chronic
An
acute
toxicity
study
was
conducted
with
Bobwhite
quail
(
Colinus
virginianus;
MRID
428859­
01).
The
results
of
one
acute
oral
toxicity
study,
submitted
for
ADBAC
established
an
LD50
of
136
mg/
kg­
bw.
The
results
from
the
acceptable
study
indicate
that
ADBAC
is
moderately
toxic
to
avian
species
on
an
acute
oral
basis.
The
study
fulfills
guideline
requirements.
No
data
are
available
to
assess
the
toxicity
of
ADBAC
on
a
subacute
dietary
exposure
basis
though
and
this
represents
a
data
gap.

No
data
are
available
regarding
the
chronic
toxicity
of
ADBAC
to
birds.
Chronic
risk
to
avian
species
cannot
be
precluded
in
the
absence
of
data;
chronic
risk
to
birds
is
presumed.

3.1.2
Mammals,
Acute
and
Chronic
Toxicity
The
endpoints
used
in
this
risk
assessment
were
chosen
by
AD
and
used
without
details
of
the
studies
available.
The
acute
LD50
for
rats
exposed
to
ADBAC
is
304.5
mg/
kg­
bw
(
MRID
451092­
04).
Based
on
these
data,
ADBAC
is
classified
as
slightly
toxic
to
mammals
on
an
acute
oral
exposure
basis.
The
NOAEL
from
a
chronic
toxicity
study
with
rats
(
MRID
41947501)
is
44
mg/
kg/
day
(
1000
ppm).

3.2
Toxicity
to
Aquatic
Animals
The
Agency
requested
that
aquatic
toxicity
studies
be
conducted
with
ADBAC
since,
under
typical
use
conditions,
it
may
be
introduced
into
the
aquatic
environment.

3.2.1
Freshwater
Fish,
Acute
The
most
sensitive
result
from
freshwater
fish
acute
studies
submitted
for
ADBAC
established
an
LC50
of
280
µ
g
a.
i./
L
(
fathead
minnow;
MRID
437401­
03).
The
results
indicate
that
ADBAC
is
highly
toxic
to
on
an
acute
exposure
basis.

3.2.2
Freshwater
Invertebrates,
Acute
An
acceptable
study
(
MRID
419472­
03)
with
the
freshwater
invertebrate,
Daphnia
magna,
established
an
LC50
of
5.9
µ
g
a.
i./
L.
Results
of
the
studies
indicate
that
ADBAC
is
very
highly
toxic
to
freshwater
invertebrates
on
an
acute
exposure
basis.
The
guideline
requirement
has
been
fulfilled.
Page
16
of
50
3.2.3
Estuarine
and
Marine
Organisms,
Acute
The
most
sensitive
estuarine/
marine
fish
to
acute
exposure
to
ADBAC
was
the
inland
silverside
(
Menidia
beryllina),
selected
from
open
literature
(
Dobbs,
M.
G.
et
al.,
1995),
with
an
LC50
=
310
µ
g
a.
i./
L.
The
most
sensitive
invertebrate
was
the
Eastern
oyster
(
Crassostrea
virginica),
with
an
EC50
=
55
µ
g
a.
i./
L
(
MRID
424795­
03).

3.2.4
Aquatic
Organisms,
Chronic
The
results
from
an
early
life
stage
study
with
the
warmwater
fathead
minnow
(
Pimephales
promelas)
indicate
that
exposure
to
ADBAC
on
a
chronic
basis
results
in
measurable
effects
at
a
concentration
of
32.2
µ
g
a.
i./
L
(
MRID
423021­
02).
This
study
fulfills
guideline
requirements
for
a
fish
early
life
stage
chronic
test
(
72­
4(
a)/
OPPTS
850.1400).
In
a
chronic
study
with
the
waterflea
(
Daphnia
magna),
no
measurable
effects
were
noted
at
a
concentration
of
4.15
µ
g/
L
(
MRID
423021­
01).
However,
an
MATC
could
not
be
determined
in
this
study.
Therefore,
the
study
was
classified
as
supplemental
and
does
not
fulfill
guideline
requirements
for
an
aquatic
invertebrate
life
cycle
test
(
72­
4b/
OPPTS
850.1300).
The
lack
of
chronic
toxicity
data
on
ADBAC
represents
a
data
gap.

No
data
on
the
chronic
toxicity
of
ADBAC
on
estuarine/
marine
organisms
are
available
for
this
assessment.
The
potential
chronic
toxicity
of
ADBAC
is
uncertain;
therefore,
chronic
toxicity
is
presumed.

3.2.5
Non­
target
Plants
No
data
regarding
the
toxicity
of
ADBAC
to
non­
target
plants
were
available
for
review.

4
Risk
Characterization
4.1
Risk
Estimation
In
a
screening­
level
deterministic
(
point
estimate)
approach
to
evaluating
potential
risk
to
non­
target
organisms
from
the
proposed
uses
of
ADBAC,
risk
quotients
(
RQs)
are
calculated
from
the
ratio
of
estimated
environmental
concentrations
(
EECs)
to
ecotoxicity
values.
RQs
are
then
compared
to
levels
of
concern
(
LOCs)
used
by
OPP
to
indicate
potential
risk
to
non­
target
organisms
and
the
need
to
consider
regulatory
action.
For
studies
on
taxa
where
no
effects
are
observed
(
with
no
endpoint
established),
the
highest
dose
tested
is
used
in
RQ
calculation.
As
discussed
in
other
sections,
DDAC
is
not
expected
to
occur
at
biologically
relevant
concentrations
in
the
environment
when
applied
according
to
the
label
directions,
IF
the
toxicity
of
DDAC
is
similar
to
ADBAC.

Chronic
risk
to
estuarine/
marine
organisms,
chronic
risk
to
birds
and
risk
to
non­
target
plants
cannot
be
estimated
due
to
lack
of
data.
When
data
are
absent,
risk
to
the
organism
in
question
in
presumed.
Page
17
of
50
Nursery
Ornamentals
Use
of
ADBAC
on
ornamentals
can
lead
to
wildlife
exposure
via
direct
ingestion
of
contaminated
food
items,
drift
exposure
to
food
items
or
water
sources,
and
through
runoff
to
adjacent
waterbodies.
Therefore,
exposure
is
possible
to
both
aquatic
and
terrestrial
organisms.
The
maximum
label
rate,
calculated
assuming
a
6'
x
6'
spacing
of
trees,
is
302
lbs
ai/
A.
There
are
annual
limits
on
some
applications;
some
applications
have
no
annual
limits.
It
is
beyond
the
scope
of
this
document
to
assess
all
possible
exposure
scenarios;
therefore
risk
to
wildlife
for
this
use
may
be
underestimated.

Aquatic
Risk
Acute
RQs
are
calculated
by
dividing
the
peak
EEC
by
the
LC50/
EC50
for
the
most
sensitive
species
tested.
Acute
risk
LOCs
(
0.5)
are
exceeded
by
four­
to
500­
fold
for
both
freshwater
and
estuarine/
marine
fish
and
invertebrates
for
both
scenarios
modeled
(
Table
4.1.).
The
LOC
for
acute
risk
to
endangered
species
(
RQ>
0.05)
is
exceeded
by
factors
as
high
as
5,000X.

Table
4.1.
Acute
RQs
for
aquatic
organisms
resulting
from
use
of
ADBAC
on
nursery
ornamentals
at
the
maximum
rate
of
302
lb
ai/
A,
applied
three
times
at
seven
day
intervals,
assuming
entire
10­
ha
area
is
treated.
All
RQs
exceed
LOCs.
Scenario
FW
fish
FW
invert
Est/
Mar
fish
Est/
Mar
invert
GA
pecan
5.26
249.66
4.75
26.78
OR
Christmas
tree
1.99
94.41
1.80
10.13
Chronic
RQs
are
calculated
by
dividing
the
21­
day
EEC
(
for
invertebrates)
or
the
60­
day
EEC
(
for
fish)
by
the
LC50/
EC50
for
the
most
sensitive
species
tested.
Chronic
LOCs
(
1.0)
are
exceeded
by
10­
to
over
200­
fold
for
freshwater
organisms
for
both
scenarios
modeled
(
Table
4.2).
Due
to
lack
of
data
on
the
chronic
toxicity
of
ADBAC
to
estuarine/
marine
organisms,
risk
cannot
be
estimated
and
therefore
chronic
risk
to
estuarine/
marine
organisms
is
presumed.

Table
4.2.
Chronic
RQs
for
aquatic
organisms
resulting
from
use
of
ADBAC
on
nursery
ornamentals
at
the
maximum
rate
of
302
lb
ai/
A,
applied
three
times
at
seven
day
intervals.
All
RQs
exceed
LOCs.
Scenario
chronic
FW
fish
chronic
FW
invert
chronic
Est/
Mar
fish
chronic
Est/
Mar
invert
GA
pecan
28.04
221.69
unknown
unknown
OR
Christmas
tree
10.53
86.99
unknown
unknown
Terrestrial
Risk­
Avian
The
avian
acute
LOC
(
0.5)
is
exceeded
38­
to
4200­
fold
for
all
forage
items
for
all
size
birds
(
Table
4.3).
Chronic
risk
to
birds
cannot
be
estimated
due
to
lack
of
toxicity
data.
In
the
absence
of
data,
chronic
risk
to
birds
is
presumed.
Page
18
of
50
Table
4.3.
Acute
RQs
for
avian
wildlife
resulting
from
use
of
ADBAC
on
nursery
ornamentals
at
the
maximum
rate
of
302
lb
ai/
A,
applied
three
times
at
10
day
intervals.

20
g
100
g
1000
g
Short
Grass
2101
941
298
Tall
Grass
963
431
137
Broadleaf
plants/
sm
insects
1182
529
168
Fruits/
pods/
seeds/
lg
insects
131
59
19
Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.2)
Exceeds
listed
spp
LOC
(
0.1)

Terrestrial
Risk­
Mammalian
The
acute
LOC
(
0.5)
for
mammals
is
exceeded
3­
to
360­
fold
in
all
size
classes
for
all
forage
items.
The
chronic
LOC
(
1.0)
is
exceeded
for
mammals
in
all
size
classes
for
all
forage
items
10­
to
1780­
fold
(
Table
4.4).

Table
4.4.
Acute
and
chronic
dose­
based
RQs
for
mammalian
wildlife
resulting
from
use
of
ADBAC
on
nursery
ornamentals
at
the
maximum
rate
of
302
lb
ai/
A,
applied
three
times
at
10­
day
intervals.

Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.2)
Exceeds
listed
spp
LOC
(
0.1)
or
chronic
risk
LOC
(
1.0)

Turf
and
Golf
Courses
Use
of
ADBAC
on
turf
and
golf
courses
can
lead
to
wildlife
exposure
via
direct
ingestion
of
contaminated
food
items,
drift
exposure
to
food
items
or
water
sources,
and
through
runoff
to
adjacent
waterbodies.
Therefore,
exposure
is
possible
to
both
aquatic
and
terrestrial
organisms.
The
maximum
label
rate
for
ground
commercial
power
spray
application
is
0.8
lbs
ai/
A.
A
higher
rate
is
allowed
for
non­
commercial
sprayers
(
6.8
lbs
ai/
A)
and
is
presumably
intended
for
smaller
areas
such
as
residential
lawns.

Aquatic
Risk
Acute
RQs
are
calculated
by
dividing
the
peak
EEC
by
the
LC50/
EC50
for
the
most
sensitive
species
tested.
Acute
risk
LOC
(
RQ>
0.5)
is
exceeded
for
freshwater
invertebrates
for
both
scenarios
modeled
(
Table
4.5.),
and
for
estuarine/
marine
invertebrates
for
the
higher
rate.
The
acute
risk
to
endangered
species
LOC
(
RQ>
0.05)
is
exceeded
for
freshwater
fish
in
both
scenarios
and
the
restricted
use
LOC
(
0.1)
is
exceeded
at
the
higher
rate
for
both
freshwater
and
estuarine/
marine
fish.
15
g
mammal
35
g
mammal
1000
g
mammal
Acute
Chronic
Acute
Chronic
Acute
Chronic
Short
Grass
182
1782
156
1522
83
816
Tall
Grass
84
817
71
698
38
374
Broadleaf
plants/
sm
insects
103
1002
88
856
47
459
Fruits/
pods/
lg
insects
11
111
9.73
95
5.22
51
Seeds
2.5
25
2.2
21
1.2
11
Page
19
of
50
Table
4.5.
Acute
RQs
for
aquatic
organisms
resulting
from
use
of
ADBAC
on
golf
courses
and
turf
applied
26
times
at
10
day
intervals
for
the
0.8
lbs
ai/
A
rate
and
10
times
at
10
day
intervals
for
the
6.8
lb
ai/
A
rate.
Scenario
FW
fish
FW
invert
Est/
Mar
fish
Est/
Mar
invert
FL
turf
(
0.8
lbs
ai/
A)
0.06
2.64
0.05
0.28
PA
turf
(
0.8
lbs
ai/
A)
0.07
3.49
0.07
0.37
FL
turf
(
6.8
lbs
ai/
A)
0.18
8.34
0.16
0.89
PA
turf
(
6.8
lbs
ai/
A)
0.22
10.59
0.20
1.14
Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.1)
Exceeds
listed
spp
LOC
(
0.05)
or
chronic
risk
LOC
(
1.0)

Chronic
LOCs
(
1.0)
are
exceeded
for
freshwater
invertebrates
for
both
scenarios
modeled
and
for
freshwater
fish
at
the
higher
application
rate
(
Table
4.6).
Due
to
lack
of
data
on
the
chronic
toxicity
of
ADBAC
to
estuarine/
marine
organisms,
risk
cannot
be
estimated
and
is
therefore
presumed.

Table
4.6.
Chronic
RQs
for
aquatic
organisms
resulting
from
use
of
ADBAC
on
golf
courses
and
turf
applied
26
times
at
10
day
intervals
for
the
0.8
lbs
ai/
A
rate
and
10
times
at
10
day
intervals
for
the
6.8
lb
ai/
A
rate.
Scenario
FW
fish
FW
invert
Est/
Mar
fish
Est/
Mar
invert
FL
turf
(
0.8
lbs
ai/
A)
0.28
2.27
unknown
unknown
PA
turf
(
0.8
lbs
ai/
A)
0.33
2.63
unknown
unknown
FL
turf
(
6.8
lbs
ai/
A)
0.79
6.39
unknown
unknown
PA
turf
(
6.8
lbs
ai/
A)
0.91
7.30
unknown
unknown
Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.1)
Exceeds
listed
spp
LOC
(
0.05)
or
chronic
risk
LOC
(
1.0)

Terrestrial
Risk­
Avian
At
the
0.8
lb
ai/
A
rate,
the
avian
acute
risk
LOC
is
exceeded
for
all
forage
items
for
all
size
birds
(
Table
4.7),
except
for
the
1000g
size
class
foraging
on
fruits/
pods/
large
insects.
Chronic
risk
to
birds
cannot
be
estimated
due
to
lack
of
toxicity
data.
In
the
absence
of
data,
chronic
risk
to
birds
is
presumed.

Table
4.7.
Acute
RQs
for
avian
wildlife
resulting
from
use
of
ADBAC
on
nursery
ornamentals
at
the
maximum
rate
of
0.8
lb
ai/
A,
applied
26
times
at
10
day
intervals.

20
g
100
g
1000
g
Short
Grass
12.35
5.53
1.75
Tall
Grass
5.66
2.54
0.80
Broadleaf
plants/
sm
insects
6.95
3.11
0.99
Fruits/
pods/
seeds/
lg
insects
0.77
0.35
0.11
Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.2)
Exceeds
listed
spp
LOC
(
0.1)

At
the
6.8
lb
ai/
A
rate,
the
avian
acute
risk
LOC
is
exceeded
for
all
forage
items
for
all
size
birds
(
Table
4.8).
Chronic
risk
to
birds
cannot
be
estimated
due
to
lack
of
toxicity
data.
In
the
absence
of
data,
chronic
risk
to
birds
is
presumed.
Page
20
of
50
Table
4.8.
Acute
RQs
for
avian
wildlife
resulting
from
use
of
ADBAC
on
lawns/
turf
at
the
maximum
rate
of
6.8
lb
ai/
A,
applied
10
times
at
10
day
intervals.

20
g
100
g
1000
g
Short
Grass
91.02
40.77
12.92
Tall
Grass
41.72
18.69
5.92
Broadleaf
plants/
sm
insects
51.20
22.93
7.27
Fruits/
pods/
seeds/
lg
insects
5.69
2.55
0.81
Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.2)
Exceeds
listed
spp
LOC
(
0.1)

Terrestrial
Risk­
Mammalian
At
the
0.8
lbs
ai/
A
rate,
the
acute
LOC
is
exceeded
for
mammals
in
the
15g
and
35g
size
classes
foraging
on
short
grass
and
broadleaf
plants/
small
insects
(
Table
4.9).
The
acute
risk
to
endangered
species
LOC
is
exceeded
for
all
mammal
size
classes
foraging
on
short
grass,
tall
grass
and
broadleaf
plant/
small
insects.
The
chronic
risk
LOC
is
exceeded
for
all
mammal
size
classes
on
the
short
grass,
tall
grass
and
broadleaf
plant/
small
insect
forage
items.

Table
4.9.
Acute
and
chronic
dose­
based
RQs
for
mammalian
wildlife
resulting
from
use
of
ADBAC
on
turf/
golf
courses
at
the
maximum
rate
of
0.8
lb
ai/
A,
applied
26
times
at
10
day
intervals.

Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.2)
Exceeds
listed
spp
LOC
(
0.1)
or
chronic
risk
LOC
(
1.0)

At
the
6.8
lbs
ai/
A
rate,
the
acute
risk
LOC
is
exceeded
for
mammals
in
all
size
classes
foraging
on
short
grass,
tall
grass
and
broadleaf
plants/
small
insects
(
Table
4.10).
The
acute
risk
to
endangered
species
LOC
is
exceeded
for
all
mammal
size
classes
foraging
on
short
grass,
tall
grass
and
broadleaf
plant/
small
insects.
The
chronic
risk
LOC
is
exceeded
for
all
mammal
size
classes
foraging
on
any
of
the
food
items
evaluated,
except
medium
and
large
size
classes
foraging
on
seeds.
15
g
mammal
35
g
mammal
1000
g
mammal
Acute
Chronic
Acute
Chronic
Acute
Chronic
Short
Grass
1.07
10.47
0.92
8.95
0.49
4.80
Tall
Grass
0.49
4.80
0.42
4.10
0.22
2.20
Broadleaf
plants/
sm
insects
0.60
5.89
0.52
5.03
0.28
2.70
Fruits/
pods/
lg
insects
0.07
0.65
0.06
0.56
0.03
0.30
Seeds
0.01
0.15
0.01
0.12
0.01
0.07
Page
21
of
50
Table
4.10.
Acute
and
chronic
dose­
based
RQs
for
mammalian
wildlife
resulting
from
use
of
ADBAC
on
nursery
ornamentals
at
the
maximum
rate
of
6.8
lb
ai/
A,
applied
10
times
at
10
day
intervals.

Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.2)
Exceeds
listed
spp
LOC
(
0.1)
or
chronic
risk
LOC
(
1.0)

Mosquito
control
For
mosquito
control
uses,
drinking
water
is
presumed
to
be
the
most
likely
route
of
exposure
to
wildlife.
At
the
labeled
rate
of
200
ppm
in
the
target
waterbody,
RQs
exceed
the
acute
risk
to
endangered
species
LOC
for
birds
in
the
20g
and
100g
size
classes
(
Table
4.11.).
The
restricted
use
LOC
(
0.2)
is
exceeded
for
20g
birds.
Due
to
lack
of
data
on
chronic
toxicity
of
ADBAC
to
birds,
chronic
RQs
cannot
be
calculated
and
chronic
effects
are
assumed.
Neither
acute
nor
chronic
mammalian
RQs
are
exceeded.
Equations
are
included
in
Appendix
C.

Since
it
is
possible
that
amphibians
would
use
many
of
the
potentially
treated
waterbodies
for
at
least
their
reproductive
stage,
RQs
were
calculated
using
the
most
sensitive
freshwater
fish
endpoint.
Assuming
a
concentration
of
200
ppm,
RQs
were
0.71
for
acute
risk
and
6.2
for
chronic
risk,
both
of
which
exceed
the
LOCs.
It
is
possible
that,
due
to
additional
applications
indicated
on
the
label,
concentrations
greater
than
200
ppm
may
be
attained.
In
such
instances,
RQs
would
be
higher.

Table
4.11.
Wildlife
drinking
water
RQs
for
ADBAC
use
in
mosquito
control
applications.
Birds
20g
100g
1000g
DWIRa
0.004
0.013
0.059
DPEb
42.91
25.23
11.80
RQc
0.32
0.19
0.09
Mammals
15g
35g
1000g
DWIRa
0.002
0.005
0.099
DPEb
30.13
27.69
19.80
RQc
0.07
0.06
0.05
aDWIR­
drinking
water
ingestion
rate
(
L/
day)
bDPE­
daily
pesticide
exposure
(
mg/
kg­
bw/
day)
cRQ­
risk
quotient
Puddles,
Ornamental
Ponds
and
Pools
For
the
of
ADBAC/
DDAC
in
puddles,
ornamental
ponds
and
pools,
drinking
water
is
presumed
to
be
the
most
likely
route
of
exposure
to
terrestrial
wildlife
At
the
labeled
rate
of
5
ppm
in
the
target
waterbody,
acute
avian
and
mammalian
RQs
are
all
below
0.01,
using
toxicity
15
g
mammal
35
g
mammal
1000
g
mammal
Acute
Chronic
Acute
Chronic
Acute
Chronic
Short
Grass
7.90
77.20
6.75
65.94
3.62
35.35
Tall
Grass
3.62
35.38
3.09
30.22
1.66
16.20
Broadleaf
plants/
sm
insects
4.44
43.42
3.80
37.09
2.03
19.88
Fruits/
pods/
lg
insects
0.49
4.82
0.42
4.12
0.23
2.21
Seeds
0.11
1.1
0.09
0.92
0.05
0.49
Page
22
of
50
endpoints
from
ADBAC.
The
acute
risk
LOC
for
terrestrial
animals
is
0.5
and
the
acute
endangered
LOC
is
0.1.
The
RQs
were
calculated
using
the
total
active
ingredient.
The
formulations
for
these
applications
are
12%
DDAC
and
8%
ADBAC.
Unless
the
wildlife
endpoints
for
DDAC
are
more
than
10
times
more
sensitive
than
for
ADBAC,
acute
environmental
risk
from
this
use
appears
to
be
unlikely.
Mammalian
chronic
risk
quotients
are
also
all
below
the
LOC
of
1.0;
chronic
risk
to
birds
cannot
be
estimated
due
to
lack
of
data.
Chronic
risk
to
birds
cannot
be
precluded.

Since
it
is
possible
that
amphibians
would
use
many
of
the
potentially
treated
waterbodies
for
at
least
their
reproductive
stage,
RQs
were
calculated
using
the
most
sensitive
freshwater
fish
endpoint.
Assuming
a
concentration
of
5
ppm,
RQs
were
0.02
for
acute
risk
and
0.2
for
chronic
risk,
neither
of
which
exceed
the
LOCs.
It
is
possible
that,
due
to
additional
applications
indicated
on
the
label,
concentrations
greater
than
5
ppm
may
be
attained.
In
such
instances,
RQs
would
be
higher.

4.2
Risk
Description
As
presented
in
the
previous
section,
LOCs
are
exceeded
for
several
of
the
outdoor
uses
of
ADBAC.
The
one
outdoor
use
of
DDAC
appears
to
result
in
low
exposure
to
wildlife.
It
is
not
possible
to
evaluate
whether
this
exposure
results
in
risk
to
organisms
due
to
the
lack
of
toxicity
data.
However,
DDAC
toxicity
would
need
to
be
considerably
greater
than
that
of
ADBAC
to
pose
a
risk
to
wildlife
based
on
this
screening­
level
assessment,
and
further
discussion
of
DDAC
is
not
warranted
included
in
this
document.
Risk
from
the
various
uses
of
ADBAC,
as
estimated
in
the
previous
section,
is
highly
dependant
on
the
assumption
of
the
model.
In
the
risk
estimation
section,
conservative
assumptions
are
used
to
provide
a
protective
assessment.
Because
the
labels
for
these
uses
are
not
explicitly
directive,
a
variety
of
assumptions
were
explored
to
give
the
risk
manager
a
better
sense
of
the
range
of
possible
exposure,
and
therefore
risk,
to
wildlife
species
under
the
current
labels.

Nursery
Ornamentals
This
use
has
the
highest
application
rates
of
any
outdoor
uses,
and
subsequently
results
in
the
highest
RQs.
Because
the
labels
have
no
restrictions
on
the
amount
of
product
applied
per
unit
area
per
year,
several
assumptions
are
made.
The
RQs
vary
with
differing
assumptions.
For
this
document,
it
is
assumed
that
large­
and
medium­
sized
shrubs/
trees
represent
the
greatest
use
of
the
products,
that
the
trees
are
treated
with
0.25
lbs
ai
each,
for
each
application.
Though
the
concentration
in
ppm
varies
among
tree/
shrub,
the
volume
needed
for
adequate
coverage
is
assumed
to
be
less
for
smaller
trees
(
higher
concentration),
thus
the
0.25
lbs
ai/
tree
is
used
to
calculate
RQs.
Many
of
the
applications
are
limited
to
three
per
year,
i.
e.,
the
number
used
in
the
modeling.
It
is
possible
that,
in
some
instances,
more
applications
will
be
made.
It
is
also
assumed
that
the
shrubs/
trees
were
evenly
spaced
at
6'
x6';
however,
changing
the
spacing
would
affect
the
maximum
application
rate
(
lbs
ai/
A).

Aquatic
Aquatic
RQs
from
nursery
uses
exceed
the
acute
risk
LOC
for
freshwater
fish
by
a
factor
of
four
to
10,
and
exceed
the
acute
risk
LOC
for
estuarine
marine
fish
by
a
similar
magnitude.
The
acute
risk
LOC
is
exceeded
by
up
to
500­
fold
for
freshwater
invertebrates,
and
up
to
54­
fold
Page
23
of
50
for
estuarine/
marine
invertebrates.
Chronic
risk
LOCs
for
freshwater
organisms
are
exceeded
factors
ranging
from
10
to
over
200­
fold.
While
data
on
chronic
toxicity
to
estuarine/
marine
organisms
were
not
available
for
review,
the
lines
of
evidence
strongly
suggest
potential
chronic
risk
to
these
animals.
These
RQs
are
based
on
EECs
derived
from
standard
scenarios
that
assume
25
acres
treated.
It
may
not
be
realistic
to
assume
25
acres
of
treated
shrubs
and
trees
in
a
given
nursery
are
treated
at
the
same
time,
so
RQs
assuming
10,
one
and
0.5
acres
are
also
calculated
(
Table
4.12).
These
adjustments
assume
a
linear
relationship
between
EEC
and
area
treated.
If
only
one
acre
were
treated,
following
the
stated
assumptions,
the
acute
risk
to
endangered
species
LOC
would
still
be
exceeded
for
fish
in
both
PRZM/
EXAMS
scenarios
and
the
restricted
use
LOC
would
still
be
exceeded
in
the
GA
pecan
scenario.
The
freshwater
chronic
risk
LOC
would
still
be
exceeded
in
the
GA
pecan
scenario.
If
only
a
half
acre
were
treated,
the
restricted
use
LOC
would
still
be
exceeded
for
fish
in
the
GA
pecan
scenario.
The
freshwater
invertebrate
acute
and
chronic
risk
LOCs
are
exceeded
regardless
of
the
size
of
the
treated
area.
The
estuarine/
marine
invertebrate
acute
risk
LOC
is
exceeded
for
treated
areas
of
all
sizes
in
the
GA
pecan
scenario,
and
the
restricted
use
LOC
is
exceeded
for
treated
areas
of
all
sizes
in
the
OR
Christmas
tree
scenario.

Table
4.12.
Aquatic
RQs
adjusted
for
area
treated.
Scenarios
Area
treated
(
acres)
acute
FW
fish
chronic
FW
fish
acute
FW
invert
chronic
FW
invert
acute
Est/
Mar
fish
acute
Est/
Mar
invert
25
5.26
28.04
249.66
221.69
4.75
26.78
10
2.10
11.21
99.83
88.67
1.90
10.71
1
0.21
1.12
9.98
8.87
0.19
1.07
GA
pecan
0.5
0.11
.0.56
5.00
4.43
0.10
0.54
25
1.99
10.53
94.41
86.99
1.80
10.13
10
0.80
4.22
37.80
34.70
0.72
4.05
1
0.08
0.42
3.78
3.47
0.07
0.41
OR
Christmas
tree
0.5
0.04
0.21
1.90
1.73
0.04
0.20
Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.1)
Exceeds
listed
spp
LOC
(
0.05)
or
chronic
risk
LOC
(
1.0)

Terrestrial
Acute
avian
RQs
are
exceeded
from
this
use,
by
a
minimum
of
38­
fold,
and
both
acute
and
chronic
risk
LOCs
mammalian
RQs
are
exceeded
10­
to
1700­
fold,
and
even
a
single
application
results
in
LOC
exceedances
four­
to
1400­
fold.
Chronic
RQs
for
birds
cannot
be
calculated
due
to
lack
of
data
and
is
therefore
presumed.
The
labels
do
make
some
effort
to
minimize
wildlife
exposure,
by
limiting
applications
to
before
and
after
fruit
production,
though
the
flowers
and
foliage
would
remain
potentially
attractive
forage.
Even
at
an
application
rate
of
one
half
of
one
percent
of
the
modeled
rate
(
0.5%;
1.5
lbs
ai/
A),
an
amount
less
than
is
typically
modeled
for
off­
site
drift,
there
are
exceedances
for
almost
all
size
classes
and
forage
items
for
birds
and
most
mammal
size
categories.
It
is
presumed
that
nursery
ornamentals
are
not
intended
to
present
forage,
and
that
efforts
are
made
by
operators
to
make
the
plants
unappealing
to
wildlife.
However,
non­
target
plants
may
receive
unintentional
exposure
and
may
be
used
by
wildlife
as
forage.
While
the
areal
extent
of
ADBAC
application
in
nurseries
is
not
known,
these
uses
may
present
a
risk
to
wildlife
in
proximity
to
nurseries.
Page
24
of
50
Turf
and
Golf
Courses
These
uses
have
two
considerably
different
maximum
application
rates.
The
type
of
sprayer
used
determines
which
maximum
rate
can
be
used.
For
commercial
power
sprayers,
presumably
used
on
golf
course
fairways
and
larger
commercial
lawns,
the
label
allows
a
rate
of
0.8
lbs
ai/
A.
For
other
sprayers,
the
labels
allow
a
rate
of
6.8
lbs
ai/
A.
The
distinction
between
these
types
of
sprayers
is
not
further
delineated,
which
presumably
leaves
interpretation
to
the
applicator.

Because
the
labels
lack
limits
on
the
number
of
applications
that
can
be
made
per
year,
the
scenarios
presented
in
the
Risk
Estimation
section
of
this
document
represent
high­
end
usage
patterns,
though
not
necessarily
the
maximum
allowable.
For
example,
the
0.8
lbs
ai/
A
rate
is
modeled
assuming
26
applications
at
10
day
intervals,
the
minimum
allowable
interval
for
this
use
on
the
label.
However,
there
could
be
situations
where
36
applications
could
occur,
since
there
is
no
restriction
on
the
maximum
number
of
applications.
Since
many
of
the
target
pathogens
thrive
in
warm
humid
weather,
applicators
in
areas
with
such
climatic
conditions
year
round
could
choose
to
apply
ADBAC
at
the
limit.
In
such
situations,
the
RQs
for
all
wildlife
would
increase
by
about
25%.
In
areas
where
growth
conditions
for
the
target
pathogens
are
less
ideal,
fewer
applications
may
be
necessary,
with
an
associated
decrease
in
the
RQs
for
wildlife.

Aquatic
As
the
number
of
applications
decline,
so
do
the
aquatic
RQs.
At
26
applications
at
the
0.8
lbs
ai/
A
rate,
acute
RQs
meet
or
exceed
the
acute
risk
to
endangered
species
LOC
for
freshwater
and
estuarine/
marine
fish.
Applications
of
ten,
five
and
one
per
year
were
also
modeled
(
Table
4.13)
and
the
LOC
is
not
exceeded.
The
same
pattern
of
decreasing
RQs
is
found
for
invertebrates,
but
exceedances
are
not
fully
mitigated
by
limiting
the
number
of
applications.
Acute
freshwater
invertebrate
RQs
remain
above
the
acute
risk
LOC
at
five
applications
and
the
acute
risk
to
endangered
species
LOC
is
exceeded
after
a
single
application.
Acute
estuarine/
marine
RQs
remain
above
the
restricted
use
LOC
at
after
10
applications,
and
above
the
acute
risk
to
endangered
species
LOC
after
five
applications.

Table
4.13.
Acute
and
chronic
RQs
from
different
numbers
of
applications
per
year,
assuming
a
rate
of
0.8
lbs
ai/
A
over
25
acres.
Scenario
Number
of
App.
acute
FW
fish
chronic
FW
fish
acute
FW
invert
chronic
FW
invert
acute
Est/
Mar
fish
acute
Est/
Mar
invert
FL
turf
26
0.06
0.48
2.64
2.27
0.05
0.28
10
0.02
0.19
1.02
0.87
0.02
0.11
5
0.01
0.10
0.53
0.43
0.01
0.06
1
0.00
0.02
0.11
0.09
0.00
0.01
PA
turf
26
0.07
0.64
3.49
2.63
0.07
0.37
10
0.03
0.24
1.32
1.01
0.03
0.14
5
0.01
0.12
0.66
0.51
0.01
0.07
1
0.00
0.02
0.14
0.10
0.00
0.01
Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.1)
Exceeds
listed
spp
LOC
(
0.05)
or
chronic
risk
LOC
(
1.0)
Page
25
of
50
At
the
6.8
lbs
ai/
A
rate,
allowed
by
the
label
if
the
applicator
is
not
using
`
commercial
power
sprayers',
RQs
exceed
the
restricted
use
and
chronic
risk
LOCs
for
fish
and
both
the
acute
and
chronic
LOCs
for
invertebrates.
These
RQs
are
calculated
assuming
10
applications
per
year,
though
the
label
doesn't
limit
the
number
of
applications
per
year.
Therefore,
if
additional
applications
are
made,
the
RQs
would
be
higher.
However,
there
is
uncertainty
about
how
much
area
will
actually
be
treated
at
this
rate.
Several
different
application
areas
are
modeled
to
explore
the
effect
area
treated
would
have
on
the
RQs,
assuming
a
linear
relationship
between
area
applied
and
EEC
(
Table
4.14).
It
is
conceivable
that
aggregate
use
in
a
community
could
approach
25
acres
treated
in
a
given
area,
and
a
half
acre
treated
is
considered
a
reasonable
lowend
assumption.
Like
the
previous
scenario,
RQs
are
greatest
for
aquatic
invertebrates,
where
even
at
the
smallest
treatment
area,
the
restricted
use
LOC
is
exceeded.

Table
4.14.
Acute
and
chronic
RQs
from
different
size
areas
treated,
assuming
a
rate
of
6.8
lbs
ai/
A
and
10
applications
per
year.
Scenario
Acres
treated
acute
FW
fish
chronic
FW
fish
acute
FW
invert
chronic
FW
invert
acute
Est/
Mar
fish
acute
Est/
Mar
invert
FL
turf
25
0.18
1.53
8.34
6.39
0.16
0.89
10
0.07
0.61
3.34
2.55
0.06
0.36
1
0.01
0.06
0.33
0.26
0.01
0.04
0.5
0.00
0.03
0.17
0.13
0.00
0.02
PA
turf
25
0.22
1.94
10.59
7.30
0.20
1.14
10
0.09
0.78
4.24
2.92
0.08
0.45
1
0.01
0.08
0.42
0.29
0.01
0.05
0.5
0.00
0.04
0.21
0.15
0.00
0.02
Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.1)
Exceeds
listed
spp
LOC
(
0.05)
or
chronic
risk
LOC
(
1.0)

Terrestrial
The
avian
and
mammalian
model,
TREX
assumes
wildlife
is
present
and
foraging
on
the
treated
area;
therefore
no
area
adjustment
is
necessary.
For
these
scenarios,
drift
is
not
considered
for
exposure;
it
would
be
some
fraction
of
the
application
rate
but
is
not
routinely
considered
in
screening­
level
assessments.
The
terrestrial
RQ
values
are
based
on
upper
bound
exposure
estimates.
The
mean
exposure
values
are
somewhat
lower;
however,
50%
of
the
time,
exposure
values
would
be
expected
to
exceed
the
means.
Where
multiple
applications
are
considered,
the
default
foliar
half­
life
of
35
days
is
used.
If
data
were
submitted
to
show
that
the
actual
foliar
half­
life
were
shorter
than
the
default
value,
the
RQs
would
be
somewhat
lower.

Avian
While
ADBAC
is
classified
as
moderately
toxic
to
birds
on
an
acute
exposure
basis,
the
avian
acute
LOC
was
exceed
by
two­
to
24­
fold
for
most
forage
items
at
the
0.8
lbs
ai/
A
rate,
assuming
26
applications
at
10
day
intervals.
The
acute
risk
to
endangered
species
LOC
is
exceeded
for
all
size
birds
foraging
on
all
of
the
feed
items
evaluated.
Several
alternate
numbers
of
applications
are
explored
to
see
the
effect
on
the
RQs
(
Table
4.15).
Reducing
the
number
of
applications
to
just
one
still
results
in
RQs
exceeding
the
acute
risk
to
endangered
species
LOC
for
all
categories
except
100g
and
1000g
birds
foraging
on
fruit/
pods/
large
insects.
Avian
Page
26
of
50
reproduction
studies
were
not
submitted
for
ADBAC,
therefore
chronic
avian
risk
cannot
be
assessed.
In
the
absence
of
data,
risk
is
presumed.

Table
4.15.
Acute
avian
RQs
resulting
from
different
numbers
of
applications
pre
year.
App
rate
Number
Forage
Dose­
based
RQs
Use
lb
ai/
A
apps
Item(
s)
20g
100g
1000g
Turf
0.8
10
short
grass
10.71
4.80
1.52
tall
grass
4.91
2.20
0.70
bdlf/
sm
ins
6.02
2.70
0.86
Fr/
pods/
lg
ins
0.67
0.30
0.10
5
short
grass
7.81
3.50
1.11
tall
grass
3.58
1.60
0.51
bdlf/
sm
ins
4.39
1.97
0.62
Fr/
pods/
lg
ins
0.49
0.22
0.07
1
short
grass
2.23
1.00
0.32
tall
grass
1.02
0.46
0.15
bdlf/
sm
ins
1.26
0.56
0.18
Fr/
pods/
lg
ins
0.14
0.06
0.02
Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.2)
Exceeds
listed
spp
LOC
(
0.1)

For
the
6.8
lbs
ai/
A
application
rate,
at
the
assumed
10
applications
per
year
at
10
day
intervals,
the
acute
risk
LOC
is
exceeded
for
all
size
birds
for
all
forage
items.
Since
the
label
does
not
limit
the
number
of
applications,
these
RQs
may
not
be
indicative
of
actual
risk,
as
more
applications
would
increase
the
RQ
values.
To
establish
a
base­
line,
one
application
is
modeled
at
this
rate
(
Table
4.16).
One
application
of
ADBAC
at
the
label
rate
of
6.8
lbs
ai/
A
results
in
exceedances
of
the
acute
risk
LOC
for
all
forage
items
and
all
size
birds,
except
1000g
birds
foraging
on
fruits/
pods/
large
insects.
That
exception
still
exceeds
the
acute
risk
to
endangered
species
LOC
though.
While
RQs
cannot
be
calculated
for
chronic
risk
to
birds,
chronic
risk
is
presumed.

T
able
4.16.
Acute
RQs
for
avian
wildlife
resulting
from
use
of
ADBAC
on
lawns/
turf
at
the
maximum
rate
of
6.8
lb
ai/
A,
applied
once
per
year.

20
g
100
g
1000
g
Short
Grass
18.97
8.50
2.69
Tall
Grass
8.69
3.89
1.23
Broadleaf
plants/
sm
insects
10.67
4.78
1.51
Fruits/
pods/
seeds/
lg
insects
1.19
0.53
0.17
Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.2)
Exceeds
listed
spp
LOC
(
0.1)

Mammals
As
seen
in
the
Risk
Estimation
section
of
this
document,
there
are
acute
and
chronic
risk
LOC
exceedances
for
all
size
classes
and
most
forage
items
when
the
0.8
lbs
ai/
A
rate
is
modeled
assuming
26
applications
at
10
day
intervals.
Again,
since
it
possible
to
have
more
than
26
Page
27
of
50
applications
in
a
given
year,
those
RQs
are
not
entirely
conservative.
However,
to
provide
a
sense
of
perspective,
RQs
resulting
from
a
single
application
are
modeled
(
Table
4.17).
One
application
results
in
acute
risk
to
endangered
species
LOC
exceedances
for
15g
and
35g
mammals
foraging
on
short
grass,
15g
mammals
foraging
on
broadleaf
plants/
small
insects;
additionally,
the
chronic
risk
LOC
is
exceeded
for
those
same
categories.
Given
the
nature
of
the
target
pathogens,
it
does
not
seem
likely
that
one
application
would
be
sufficient
to
achieve
control.
Therefore,
five
applications
at
10
day
intervals
are
also
modeled
(
Table.
4.18).
Resulting
RQs
increase
approximately
three­
fold
and
many
more
LOCs
are
exceeded.
The
typical
number
of
applications
at
this
rate
is
unknown
for
these
products.

Table
4.17.
Acute
and
chronic
dose­
based
RQs
for
mammalian
wildlife
resulting
from
use
of
ADBAC
on
turf/
golf
courses
at
the
maximum
rate
of
0.8
lb
ai/
A,
applied
once
(
exceedances
in
bold).

Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.2)
Exceeds
listed
spp
LOC
(
0.1)

Table
4.18.
Acute
and
chronic
dose­
based
RQs
for
mammalian
wildlife
resulting
from
use
of
ADBAC
on
turf/
golf
courses
at
the
maximum
rate
of
0.8
lb
ai/
A,
applied
five
times
with
a
10
day
interval.

Exceeds
acute
risk
LOC
(
0.5)
Exceeds
restricted
use
LOC
(
0.2)
Exceeds
listed
spp
LOC
(
0.1)

At
the
higher
application
rate
(
6.8
lbs
ai/
A),
the
acute
risk
LOC
is
exceeded
four­
to
16­
fold
for
all
size
class
mammals
foraging
on
short
grass,
tall
grass
and
broadleaf
plants/
small
insects.
The
restricted
use
LOC
is
exceeded
for
all
size
classes
foraging
on
fruits/
pods/
large
insects.
The
chronic
risk
LOC
is
exceeded
for
all
size
classes
and
forage
items.
These
exceedances
result
from
10
applications
at
10
day
intervals.
However,
if
only
five
applications
are
made,
there
would
still
be
exceedances
of
acute
and
chronic
LOCs
for
all
forage
items
and
all
size
classes.
In
fact,
at
the
6.8
lbs
ai/
A
rate,
there
would
still
be
acute,
restricted
use
and
acute
risk
to
endangered
species
LOC
exceedances
for
all
categories
except
the
35g
and
1000g
size
classes
foraging
on
fruits/
pods/
large
insects.
Chronic
RQs
would
also
exceed
the
LOC
in
the
same
categories.
15
g
mammal
35
g
mammal
1000
g
mammal
Acute
Chronic
Acute
Chronic
Acute
Chronic
Short
Grass
0.19
1.89
0.17
1.62
0.09
0.87
Tall
Grass
0.09
0.87
0.08
0.74
0.04
0.40
Broadleaf
plants/
sm
insects
0.11
1.06
0.09
0.91
0.05
0.49
Fruits/
pods/
lg
insects
0.01
0.12
0.01
0.10
0.01
0.05
15
g
mammal
35
g
mammal
1000
g
mammal
Acute
Chronic
Acute
Chronic
Acute
Chronic
Short
Grass
0.68
6.62
0.58
5.66
0.31
3.03
Tall
Grass
0.31
3.04
0.27
2.59
0.14
1.39
Broadleaf
plants/
sm
insects
0.38
3.72
0.33
3.18
0.17
1.71
Fruits/
pods/
lg
insects
0.04
0.41
0.04
0.35
0.02
0.19
Page
28
of
50
Mosquito
control
Since
ADBAC
is
applied
directly
to
target
waterbodies,
disconnected
from
the
greater
watershed,
limited
exposure
to
non­
target
aquatic
wildlife
is
expected;
however,
ephemeral
pools
and
ornamental
ponds
often
play
an
important
role
in
the
lifecycle
of
amphibians.
The
label
does
not
preclude
potential
exposure
to
these
organisms
and
therefore
these
uses
may
pose
a
significant
risk
to
amphibians.
EFED
uses
freshwater
fish
as
surrogate
for
aquatic­
phase
amphibians.
At
the
initial
concentration
of
200
ppm,
the
acute
RQ
would
be
0.71,
which
exceeds
LOC.
The
chronic
RQ,
based
on
a
concentration
of
200
ppm
would
be
6.1,
which
also
exceeds
the
LOC.

As
stated
previously,
drinking
water
is
presumed
to
be
the
most
likely
route
of
exposure
to
terrestrial
wildlife
from
these
uses.
Terrestrial
wildlife
exposure
via
forage
items
is
also
expected
to
be
low,
due
to
the
application
method
and
the
limited
scale
of
the
target
waterbody.
Estimated
exposure
via
drinking
water
is
based
on
allometric
equations,
specific
to
birds
and
mammals
(
Appendix
C),
that
are
used
to
calculate
daily
pesticide
exposure,
assuming
the
animal
gets
100%
of
its
water
from
the
treated
water.
However,
it
is
possible
that
to
small
(
15­
g)
mammals
feeding
on
short
grasses,
an
ephemeral
pond
could
represent
a
sizable
area
in
which
to
forage.
Grasses
may
preferentially
grow
along
or
within
these
areas
and
attract
these
animals.

At
the
labeled
rate
of
200
ppm
in
the
target
waterbody,
RQs
exceed
the
acute
risk
to
endangered
species
LOC
for
birds
in
the
20g
and
100
g
size
classes.
The
restricted
use
LOC
is
exceeded
for
20g
birds.
An
increase
in
concentration
to
220
ppm
in
the
drinking
water
source
would
elevate
the
RQ
for
1000g
birds
above
the
acute
risk
to
endangered
species
LOC.
Due
to
lack
of
data
on
chronic
toxicity
of
ADBAC
to
birds,
chronic
RQs
cannot
be
calculated
and
chronic
risk
is
assumed.

Neither
acute
nor
chronic
mammalian
RQs
are
exceeded
at
200
ppm.
The
acute
RQ
for
15g
mammals
would
exceed
the
acute
risk
to
endangered
species
LOC
at
a
concentration
of
280
ppm.
The
acute
RQs
for
mammals
of
all
size
classes
exceed
the
acute
risk
to
endangered
species
LOC
at
a
concentration
of
450
ppm,
though
at
this
concentration,
restricted
use
LOC
is
not
exceeded.
The
chronic
risk
LOC
for
15g
mammals
would
be
exceeded
at
a
concentration
of
300
ppm
and
exceeded
for
mammals
of
all
size
classes
at
a
concentration
of
450
ppm.

The
fate
of
the
initial
concentrations
of
ADBAC
is
unknown,
and
therefore
subsequent
weekly
`
maintenance'
applications
of
100
ppm
may
result
in
cumulative
concentration
greater
than
the
initial
200
ppm.
If
each
application
were
wholly
cumulative
(
i.
e.
no
dissipation),
the
concentration
in
any
given
treated
waterbody
after
five
weeks
would
be
600
ppm.
The
likelihood
of
reaching
these
concentrations
from
these
labeled
uses
is
not
known;
it
is
clear
that
at
such
a
concentration,
calculable
RQs
would
exceed
LOCs
for
wildlife
many­
fold.

The
labels
should
state
specific
limitations,
such
as
size
of
target
waterbodies
and
application
timing,
which
could
mitigate
potential
exposure
to
non­
target
organisms.
Due
to
the
lack
of
explicit
limitations
on
the
labels,
risk
to
non­
target
organisms
may
be
under­
estimated
in
this
assessment.
Page
29
of
50
Puddles,
Ornamental
Ponds
and
Pools
The
risk
to
terrestrial
wildlife
from
this
use
appears
to
be
minimal,
based
on
the
initial
target
concentration
of
5
ppm.
Calculable
RQs
all
fall
below
0.01,
and
the
most
conservative
LOC
for
terrestrial
animals
is
0.1,
for
threatened
and
endangered
species.
Exposure
to
fish
and
non­
target
populations
of
aquatic
invertebrates
is
likely
to
be
minimal,
based
on
label
descriptions;
specific
limitations
in
number
of
applications
and
size
of
target
waterbody
should
be
stated
on
the
labels.
However,
ephemeral
waterbodies
play
an
important
role
in
the
lifecycle
of
amphibians.
The
label
does
not
preclude
potential
exposure
to
these
organisms
and
therefore
these
uses
may
pose
a
risk
to
amphibians.
EFED
uses
freshwater
fish
as
surrogate
for
aquaticphase
amphibians.
At
the
initial
concentration
of
5
ppm,
both
the
acute
and
chronic
RQs
are
well
below
the
LOCs.
The
acute
listed
species
LOC
is
exceeded
at
15
ppm
and
the
chronic
LOC
is
exceeded
at
35
ppm.
Thus,
multiple
applications,
as
allowed
by
the
label,
may
result
in
acute
and/
or
chronic
risk
to
listed
amphibians.

Since
this
use
is
the
only
one
identified
as
of
concern
to
EFED
containing
DDAC,
it
appears
that
ADBAC
and
DDAC
are
of
low
concern
for
terrestrial
wildlife
exposure
for
these
uses.
DDAC
would
be
of
concern
if
avian
or
mammalian
endpoints
were
significantly
more
sensitive
(>
10X)
than
for
ADBAC;
however,
since
toxicity
of
DDAC
is
unavailable
for
this
assessment,
potential
risk
due
to
DDAC
remains
an
uncertainty.
This
use
would
also
be
of
concern
if
concentrations
in
target
waterbodies
increase
due
to
repeated
applications.

The
fate
of
the
initial
applications
of
ADBAC
and
DDAC
is
unknown.
Since
the
label
allows
weekly
application
of
2.5
ppm,
after
the
initial
5
ppm
application,
it
is
possible
a
cumulative
concentration
of
greater
than
5
ppm
may
occur.
If
each
application
were
cumulative
(
i.
e.
no
dissipation),
the
concentration
in
any
given
treated
waterbody
after
five
weeks
would
be
20
ppm.
The
LOC
for
listed
mammals
in
the
15g
size
class
is
exceeded
at
concentrations
greater
than
280
ppm
and
for
listed
birds
in
the
20g
size
class
at
>
65
ppm.
The
likelihood
of
reaching
these
concentrations
from
these
labeled
uses
it
uncertain;
however,
given
the
chemical's
persistence
and
immobility,
it
is
likely
that
concentrations
would
increase
with
repeatedly
applications.

Additionally,
the
lack
of
data
on
the
chronic
toxicity
of
ADBAC
and
DDAC
on
birds
makes
quantified
chronic
risk
estimation
impossible
5
Threatened
and
Endangered
Species
Concerns
5.1
Action
Area
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
co­
located
with
the
pesticide
treatment
area.
This
means
that
terrestrial
plants
and
wildlife
are
assumed
to
be
located
on
or
adjacent
to
the
treated
site
and
aquatic
organisms
are
assumed
to
be
located
in
a
surface
water
body
adjacent
to
the
treated
site.
The
assessment
also
assumes
that
the
listed
species
are
located
within
an
assumed
area
that
has
the
relatively
highest
potential
Page
30
of
50
exposure
to
the
pesticide,
and
that
exposures
are
likely
to
decrease
with
distance
from
the
treatment
area.

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.

5.2
Taxonomic
Groups
Potentially
at
Risk
Based
on
available
screening
level
information,
it
is
possible
that
ADBAC
may
have
acute
and/
or
chronic
toxic
effects
on
endangered
or
threatened
aquatic
or
terrestrial
organisms.
Should
estimated
exposure
levels
occur
in
proximity
to
listed
resources,
the
available
screening
level
information
suggests
a
potential
concern
for
effects
on
some
listed
species
associated
with
the
outdoor
use
of
ADBAC.
This
screening
assessment
is
based
on
the
initial
assumption
that
listed
species
within
the
taxonomic
groups
of
concern
are
actually
present
in
areas
for
which
the
estimated
exposure
levels
used
for
RQ
calculation
can
be
expected
to
occur.
A
specific
determination
of
"
may
affect"
for
any
RQ
in
excess
of
listed
species
LOCs
cannot
be
made
without
further
refinement
of
the
co­
occurrence
of
listed
species
in
ADBAC
use
areas.

The
LOCATES
database
was
used
to
identify
those
U.
S.
counties
that
have
nurseries
and
have
Federally
listed
endangered
or
threatened
species.
A
count
summary
of
listed
taxa
that
have
been
known
to
occur
in
those
areas
is
presented
in
Appendix
D,
by
State.
Further
refinements
to
the
risk
assessment
must
be
made
for
the
Agency
to
be
in
compliance
with
the
Endangered
Species
Act
and
to
determine
the
need
for
consultation
with
the
Services.
There
is
no
general
scenario
for
determining
the
co­
occurrence
of
turf
or
golf
courses
with
listed
species.
Page
31
of
50
Appendix
A.
PRZM/
EXAMS
Input
Files
FL
Turf
(
0.8
lbs
ai/
A;
26
applications/
year)
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Output
File:
FLturf26
Metfile:
w12834.
dvf
PRZM
scenario:
FLturfC.
txt
EXAMS
environment
file:
pond298.
exv
Chemical
Name:
ADBAC
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
368.05
g/
mol
Henry's
Law
Const.
henry
7.76e­
13
atm­
m^
3/
mol
Vapor
Pressure
vapr
3.53e­
12
torr
Solubility
sol
184.4
mg/
L
Kd
Kd
mg/
L
Koc
Koc
2.7e6
mg/
L
Photolysis
half­
life
kdp
0
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
0
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
5445
days
Halfife
Aerobic
Soil
Metabolism
asm
0
days
Halfife
Hydrolysis:
pH
7
183
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
cm
Application
Rate:
TAPP
0.9
kg/
ha
Application
Efficiency:
APPEFF
.95
fraction
Spray
Drift
DRFT
.05
fraction
of
application
rate
applied
to
pond
Application
Date
Date
2­
1
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Interval
1
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
2
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
3
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
4
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
5
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
6
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
7
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
8
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
9
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
10
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
11
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
12
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
13
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
14
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
15
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
16
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
17
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
18
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
19
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
20
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
21
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
22
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
23
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
24
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
25
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Record
17:
FILTRA
IPSCND
1
UPTKF
Record
18:
PLVKRT
PLDKRT
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
Pond
Flag
for
runoff
calc.
RUNOFF
none
none,
monthly
or
total(
average
of
entire
run)
Page
32
of
50
FL
Turf
(
0.8
lbs
ai/
A;
10
applications/
year)
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Output
File:
FLturf10
Metfile:
w12834.
dvf
PRZM
scenario:
FLturfC.
txt
EXAMS
environment
file:
pond298.
exv
Chemical
Name:
ADBAC
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
368.05
g/
mol
Henry's
Law
Const.
henry
7.76e­
13
atm­
m^
3/
mol
Vapor
Pressure
vapr
3.53e­
12
torr
Solubility
sol
184.4
mg/
L
Kd
Kd
mg/
L
Koc
Koc
2.7e6
mg/
L
Photolysis
half­
life
kdp
0
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
0
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
5445
days
Halfife
Aerobic
Soil
Metabolism
asm
0
days
Halfife
Hydrolysis:
pH
7
183
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
cm
Application
Rate:
TAPP
0.9
kg/
ha
Application
Efficiency:
APPEFF
.95
fraction
Spray
Drift
DRFT
.05
fraction
of
application
rate
applied
to
pond
Application
Date
Date
1­
4
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Interval
1
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
2
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
3
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
4
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
5
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
6
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
7
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
8
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
9
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Record
17:
FILTRA
IPSCND
1
UPTKF
Record
18:
PLVKRT
PLDKRT
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
Pond
Flag
for
runoff
calc.
RUNOFF
none
none,
monthly
or
total(
average
of
entire
run)

FL
Turf
(
0.8
lbs
ai/
A;
5
applications/
year)
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Output
File:
FLturf5
Metfile:
w12834.
dvf
PRZM
scenario:
FLturfC.
txt
EXAMS
environment
file:
pond298.
exv
Chemical
Name:
ADBAC
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
368.05
g/
mol
Henry's
Law
Const.
henry
7.76e­
13
atm­
m^
3/
mol
Vapor
Pressure
vapr
3.53e­
12
torr
Solubility
sol
184.4
mg/
L
Kd
Kd
mg/
L
Koc
Koc
2.7e6
mg/
L
Photolysis
half­
life
kdp
0
days
Half­
life
Page
33
of
50
Aerobic
Aquatic
Metabolism
kbacw
0
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
5445
days
Halfife
Aerobic
Soil
Metabolism
asm
0
days
Halfife
Hydrolysis:
pH
7
183
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
cm
Application
Rate:
TAPP
0.9
kg/
ha
Application
Efficiency:
APPEFF
.95
fraction
Spray
Drift
DRFT
.05
fraction
of
application
rate
applied
to
pond
Application
Date
Date
1­
4
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Interval
1
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
2
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
3
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
4
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Record
17:
FILTRA
IPSCND
1
UPTKF
Record
18:
PLVKRT
PLDKRT
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
Pond
Flag
for
runoff
calc.
RUNOFF
none
none,
monthly
or
total(
average
of
entire
run)

FL
Turf
(
0.8
lbs
ai/
A;
1
applications/
year)
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Output
File:
FLturf1
Metfile:
w12834.
dvf
PRZM
scenario:
FLturfC.
txt
EXAMS
environment
file:
pond298.
exv
Chemical
Name:
ADBAC
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
368.05
g/
mol
Henry's
Law
Const.
henry
7.76e­
13
atm­
m^
3/
mol
Vapor
Pressure
vapr
3.53e­
12
torr
Solubility
sol
184.4
mg/
L
Kd
Kd
mg/
L
Koc
Koc
2.7e6
mg/
L
Photolysis
half­
life
kdp
0
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
0
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
5445
days
Halfife
Aerobic
Soil
Metabolism
asm
0
days
Halfife
Hydrolysis:
pH
7
183
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
cm
Application
Rate:
TAPP
0.9
kg/
ha
Application
Efficiency:
APPEFF
.95
fraction
Spray
Drift
DRFT
.05
fraction
of
application
rate
applied
to
pond
Application
Date
Date
1­
4
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Record
17:
FILTRA
IPSCND
1
UPTKF
Record
18:
PLVKRT
PLDKRT
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
Pond
Flag
for
runoff
calc.
RUNOFF
none
none,
monthly
or
total(
average
of
entire
run)

FL
Turf
(
6.8
lbs
ai/
A;
10
applications/
year)
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Page
34
of
50
Output
File:
FLturfRES
Metfile:
w12834.
dvf
PRZM
scenario:
FLturfC.
txt
EXAMS
environment
file:
pond298.
exv
Chemical
Name:
ADBAC
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
368.05
g/
mol
Henry's
Law
Const.
henry
7.76e­
13
atm­
m^
3/
mol
Vapor
Pressure
vapr
3.53e­
12
torr
Solubility
sol
184.4
mg/
L
Kd
Kd
mg/
L
Koc
Koc
2.7e6
mg/
L
Photolysis
half­
life
kdp
0
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
0
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
5445
days
Halfife
Aerobic
Soil
Metabolism
asm
0
days
Halfife
Hydrolysis:
pH
7
183
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
cm
Application
Rate:
TAPP
7.62
kg/
ha
Application
Efficiency:
APPEFF
.99
fraction
Spray
Drift
DRFT
.01
fraction
of
application
rate
applied
to
pond
Application
Date
Date
1­
4
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Interval
1
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
2
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
3
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
4
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
5
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
6
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
7
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
8
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
9
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Record
17:
FILTRA
IPSCND
1
UPTKF
Record
18:
PLVKRT
PLDKRT
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
Pond
Flag
for
runoff
calc.
RUNOFF
none
none,
monthly
or
total(
average
of
entire
run)

PA
Turf
(
0.8
lbs
ai/
A;
26
applications/
year)
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Output
File:
PAturf26
Metfile:
w14737.
dvf
PRZM
scenario:
PAturfC.
txt
EXAMS
environment
file:
pond298.
exv
Chemical
Name:
ADBAC
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
368.05
g/
mol
Henry's
Law
Const.
henry
7.76e­
13
atm­
m^
3/
mol
Vapor
Pressure
vapr
3.53e­
12
torr
Solubility
sol
184.4
mg/
L
Kd
Kd
mg/
L
Koc
Koc
2.7e6
mg/
L
Photolysis
half­
life
kdp
0
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
0
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
5445
days
Halfife
Aerobic
Soil
Metabolism
asm
0
days
Halfife
Hydrolysis:
pH
7
183
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Page
35
of
50
Incorporation
Depth:
DEPI
cm
Application
Rate:
TAPP
0.9
kg/
ha
Application
Efficiency:
APPEFF
.95
fraction
Spray
Drift
DRFT
.05
fraction
of
application
rate
applied
to
pond
Application
Date
Date
2­
1
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Interval
1
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
2
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
3
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
4
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
5
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
6
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
7
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
8
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
9
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
10
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
11
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
12
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
13
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
14
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
15
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
16
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
17
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
18
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
19
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
20
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
21
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
22
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
23
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
24
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
25
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Record
17:
FILTRA
IPSCND
1
UPTKF
Record
18:
PLVKRT
PLDKRT
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
Pond
Flag
for
runoff
calc.
RUNOFF
none
none,
monthly
or
total(
average
of
entire
run)

PA
Turf
(
0.8
lbs
ai/
A;
10
applications/
year)
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Output
File:
PAturf10
Metfile:
w14737.
dvf
PRZM
scenario:
PAturfC.
txt
EXAMS
environment
file:
pond298.
exv
Chemical
Name:
ADBAC
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
368.05
g/
mol
Henry's
Law
Const.
henry
7.76e­
13
atm­
m^
3/
mol
Vapor
Pressure
vapr
3.53e­
12
torr
Solubility
sol
184.4
mg/
L
Kd
Kd
mg/
L
Koc
Koc
2.7e6
mg/
L
Photolysis
half­
life
kdp
0
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
0
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
5445
days
Halfife
Aerobic
Soil
Metabolism
asm
0
days
Halfife
Hydrolysis:
pH
7
183
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
cm
Application
Rate:
TAPP
0.9
kg/
ha
Page
36
of
50
Application
Efficiency:
APPEFF
.95
fraction
Spray
Drift
DRFT
.05
fraction
of
application
rate
applied
to
pond
Application
Date
Date
1­
5
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Interval
1
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
2
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
3
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
4
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
5
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
6
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
7
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
8
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
9
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Record
17:
FILTRA
IPSCND
1
UPTKF
Record
18:
PLVKRT
PLDKRT
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
Pond
Flag
for
runoff
calc.
RUNOFF
none
none,
monthly
or
total(
average
of
entire
run)

PA
Turf
(
0.8
lbs
ai/
A;
5
applications/
year)
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Output
File:
PAturf5
Metfile:
w14737.
dvf
PRZM
scenario:
PAturfC.
txt
EXAMS
environment
file:
pond298.
exv
Chemical
Name:
ADBAC
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
368.05
g/
mol
Henry's
Law
Const.
henry
7.76e­
13
atm­
m^
3/
mol
Vapor
Pressure
vapr
3.53e­
12
torr
Solubility
sol
184.4
mg/
L
Kd
Kd
mg/
L
Koc
Koc
2.7e6
mg/
L
Photolysis
half­
life
kdp
0
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
0
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
5445
days
Halfife
Aerobic
Soil
Metabolism
asm
0
days
Halfife
Hydrolysis:
pH
7
183
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
cm
Application
Rate:
TAPP
0.9
kg/
ha
Application
Efficiency:
APPEFF
.95
fraction
Spray
Drift
DRFT
.05
fraction
of
application
rate
applied
to
pond
Application
Date
Date
1­
5
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Interval
1
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
2
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
3
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
4
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Record
17:
FILTRA
IPSCND
1
UPTKF
Record
18:
PLVKRT
PLDKRT
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
Pond
Flag
for
runoff
calc.
RUNOFF
none
none,
monthly
or
total(
average
of
entire
run)

PA
Turf
(
0.8
lbs
ai/
A;
1
applications/
year)
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Page
37
of
50
Data
used
for
this
run:
Output
File:
PAturf1
Metfile:
w14737.
dvf
PRZM
scenario:
PAturfC.
txt
EXAMS
environment
file:
pond298.
exv
Chemical
Name:
ADBAC
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
368.05
g/
mol
Henry's
Law
Const.
henry
7.76e­
13
atm­
m^
3/
mol
Vapor
Pressure
vapr
3.53e­
12
torr
Solubility
sol
184.4
mg/
L
Kd
Kd
mg/
L
Koc
Koc
2.7e6
mg/
L
Photolysis
half­
life
kdp
0
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
0
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
5445
days
Halfife
Aerobic
Soil
Metabolism
asm
0
days
Halfife
Hydrolysis:
pH
7
183
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
cm
Application
Rate:
TAPP
0.9
kg/
ha
Application
Efficiency:
APPEFF
.95
fraction
Spray
Drift
DRFT
.05
fraction
of
application
rate
applied
to
pond
Application
Date
Date
1­
5
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Record
17:
FILTRA
IPSCND
1
UPTKF
Record
18:
PLVKRT
PLDKRT
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
Pond
Flag
for
runoff
calc.
RUNOFF
none
none,
monthly
or
total(
average
of
entire
run)

PA
Turf
(
6.8
lbs
ai/
A;
10
applications/
year)
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Output
File:
PAturfRES
Metfile:
w14737.
dvf
PRZM
scenario:
PAturfC.
txt
EXAMS
environment
file:
pond298.
exv
Chemical
Name:
ADBAC
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
368.05
g/
mol
Henry's
Law
Const.
henry
7.76e­
13
atm­
m^
3/
mol
Vapor
Pressure
vapr
3.53e­
12
torr
Solubility
sol
184.4
mg/
L
Kd
Kd
mg/
L
Koc
Koc
2.7e6
mg/
L
Photolysis
half­
life
kdp
0
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
0
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
5445
days
Halfife
Aerobic
Soil
Metabolism
asm
0
days
Halfife
Hydrolysis:
pH
7
183
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
cm
Application
Rate:
TAPP
7.62
kg/
ha
Application
Efficiency:
APPEFF
.99
fraction
Spray
Drift
DRFT
.01
fraction
of
application
rate
applied
to
pond
Application
Date
Date
1­
5
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Interval
1
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
2
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Page
38
of
50
Interval
3
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
4
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
5
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
6
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
7
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
8
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Interval
9
interval
10
days
Set
to
0
or
delete
line
for
single
app.
Record
17:
FILTRA
IPSCND
1
UPTKF
Record
18:
PLVKRT
PLDKRT
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
Pond
Flag
for
runoff
calc.
RUNOFF
none
none,
monthly
or
total(
average
of
entire
run)

GA
Pecans
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Output
File:
GApecans
Metfile:
w93805.
dvf
PRZM
scenario:
GAPecansC.
txt
EXAMS
environment
file:
pond298.
exv
Chemical
Name:
ADBAC
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
368.05
g/
mol
Henry's
Law
Const.
henry
7.76e­
13
atm­
m^
3/
mol
Vapor
Pressure
vapr
3.53e­
12
torr
Solubility
sol
184.4
mg/
L
Kd
Kd
mg/
L
Koc
Koc
2.7e6
mg/
L
Photolysis
half­
life
kdp
0
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
0
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
5445
days
Halfife
Aerobic
Soil
Metabolism
asm
0
days
Halfife
Hydrolysis:
pH
7
183
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
cm
Application
Rate:
TAPP
339
kg/
ha
Application
Efficiency:
APPEFF
.95
fraction
Spray
Drift
DRFT
.05
fraction
of
application
rate
applied
to
pond
Application
Date
Date
10­
5
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Interval
1
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
2
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Record
17:
FILTRA
IPSCND
1
UPTKF
Record
18:
PLVKRT
PLDKRT
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
Pond
Flag
for
runoff
calc.
RUNOFF
none
none,
monthly
or
total(
average
of
entire
run)

OR
Christmas
Tree
Inputs
generated
by
pe4.
pl
­
8­
August­
2003
Data
used
for
this
run:
Output
File:
ORXmasstree
Metfile:
w24232.
dvf
PRZM
scenario:
ORXmasTreeC.
txt
EXAMS
environment
file:
pond298.
exv
Chemical
Name:
ADBAC
Page
39
of
50
Description
Variable
Name
Value
Units
Comments
Molecular
weight
mwt
368.05
g/
mol
Henry's
Law
Const.
henry
7.76e­
13
atm­
m^
3/
mol
Vapor
Pressure
vapr
3.53e­
12
torr
Solubility
sol
184.4
mg/
L
Kd
Kd
mg/
L
Koc
Koc
2.7e6
mg/
L
Photolysis
half­
life
kdp
0
days
Half­
life
Aerobic
Aquatic
Metabolism
kbacw
0
days
Halfife
Anaerobic
Aquatic
Metabolism
kbacs
5445
days
Halfife
Aerobic
Soil
Metabolism
asm
0
days
Halfife
Hydrolysis:
pH
7
183
days
Half­
life
Method:
CAM
2
integer
See
PRZM
manual
Incorporation
Depth:
DEPI
cm
Application
Rate:
TAPP
339
kg/
ha
Application
Efficiency:
APPEFF
.95
fraction
Spray
Drift
DRFT
.05
fraction
of
application
rate
applied
to
pond
Application
Date
Date
10­
5
dd/
mm
or
dd/
mmm
or
dd­
mm
or
dd­
mmm
Interval
1
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Interval
2
interval
7
days
Set
to
0
or
delete
line
for
single
app.
Record
17:
FILTRA
IPSCND
1
UPTKF
Record
18:
PLVKRT
PLDKRT
FEXTRC
0.5
Flag
for
Index
Res.
Run
IR
Pond
Flag
for
runoff
calc.
RUNOFF
none
none,
monthly
or
total(
average
of
entire
run)
Page
40
of
50
Appendix
B.
Ecotoxicity
The
ecotoxicologic
endpoints
used
in
this
assessment
are
those
used
by
AD
in
their
assessments.
Refer
to
the
RED
details
of
the
studies.
The
endpoints
are
summarized
and
briefly
described
here.
Only
ADBAC
is
considered
in
this
section,
as
DDAC
endpoints
were
not
provided.
As
described
in
other
parts
of
this
document,
wildlife
exposure
to
DDAC
is
expected
to
be
limited.

A.
Toxicity
to
Terrestrial
Animals
(
1)
Avian,
Acute
and
Chronic
In
order
to
establish
the
toxicity
of
ADBAC
to
avian
species
for
indoor,
aquatic
industrial,
and
wood
preservative
uses,
the
Agency
requires
an
acute
oral
toxicity
study
using
the
technical
grade
active
ingredient
(
TGAI).
The
preferred­
test
species
is
either
mallard
duck
(
a
waterfowl)
or
bobwhite
quail
(
an
upland
game
bird).
The
results
of
one
acute
oral
toxicity
study,
submitted
for
ADBAC,
are
provided
in
the
following
table
(
Table
1).
The
results
from
the
acceptable
study
indicate
that
ADBAC
is
moderately
toxic
to
avian
species
on
an
acute
oral
basis.
The
study
fulfills
guideline
requirements.

Table
1.
Acute
Oral
Toxicity
of
ADBAC
to
Birds
Species
Chemical,
%
Active
Ingredient
(
a.
i.)
Endpoint
(
mg/
kg)
Toxicity
Category
Satisfies
Guidelines/
Comments
Reference
(
MRID
No.)

Bobwhite
quail
(
Colinus
virginianus
ADBAC
80%
LD50
=
136
NOEC
=
62.5
(
a.
i.)
Moderately
toxic
Yes
428859­
01
No
data
are
available
regarding
the
chronic
toxicity
of
ADBAC
to
birds.
Chronic
risk
to
avian
species
cannot
be
precluded
in
the
absence
of
data.

(
2)
Mammals,
Acute
and
Chronic
Toxicity
The
endpoints
used
in
this
risk
assessment
were
chosen
by
AD
and
used
without
details
of
the
studies
available.
The
acute
LD50
for
rats
exposed
to
ADBAC
is
430
mg/
kg­
bw
(
MRID
232269).
The
NOAEL,
from
a
chronic
toxicity
study
with
rats
(
MRID
41947501),
is
44
mg/
kg/
day
(
1000
ppm).

B.
Toxicity
to
Aquatic
Animals
The
Agency
requested
that
aquatic
toxicity
studies
be
conducted
with
ADBAC
since,
under
typical
use
conditions,
it
may
be
introduced
into
the
aquatic
environment.

(
1)
Freshwater
Fish,
Acute
In
order
to
establish
the
acute
toxicity
of
ADBAC
to
freshwater
fish,
the
Agency
requires
freshwater
fish
toxicity
studies
using
the
TGAI.
The
preferred
test
species
are
rainbow
trout
(
a
Page
41
of
50
coldwater
fish)
and
bluegill
sunfish
(
a
warmwater
fish).
Results
of
freshwater
fish
acute
studies,
submitted
for
ADBAC
and
obtained
from
the
open
literature,
are
presented
in
Table
3.
The
results
indicate
that
ADBAC
is
highly
toxic
to
on
an
acute
basis.
The
core
studies
fulfill
guideline
requirements.

Table
3.
Acute
Toxicity
of
ADBAC
to
Freshwater
Fish
Species
Chemical,
%
Active
Ingredient
(
a.
i.)
Endpoint
(
ppm)
Toxicity
Category
Satisfies
Guidelines/
Comments
Reference
(
MRID
No.)

Bluegill
sunfish
(
Lepomis
macrochirus)
ADBAC
30%*
LC50
=
0.515
NOEC
=
0.456
(
a.
i.)
Highly
toxic
Yes
core
study
419472­
01
Fathead
minnow
(
Pimephales
promelas)
ADBAC
80%
LC50
=
0.28
NOEC
=
ND
(
a.
i.)
Highly
toxic
Yes
core
study
437401­
03
Rainbow
Trout
(
Oncorhynchus
mykiss)
ADBAC
30%
LC50
=
0.923
NOEC
=
0.619
(
a.
i.)
Highly
toxic
Yes
core
study
419472­
02
Rainbow
Trout
(
Oncorhynchus
mykiss)
ADBAC
50%
LC50
=
1.01
(
a.
i.)
Highly/
moderately
toxic
No
open
literature
Dobbs,
M.
G.
et
al.

(
2)
Freshwater
Invertebrates,
Acute
The
Agency
requires
a
freshwater
aquatic
invertebrate
study
using
the
TGAI
to
establish
the
acute
toxicity
to
freshwater
invertebrates.
The
preferred
test
species
is
Daphnia
magna.
Results
of
two
studies,
submitted
for
ADBAC
and
obtained
from
the
open
literature,
are
provided
in
the
following
table
(
Table
4).
Results
of
the
studies
indicate
that
ADBAC
is
very
highly
toxic
to
freshwater
invertebrates.
The
guideline
requirement
has
been
fulfilled.

Table
4.
Acute
Toxicity
of
ADBAC
to
Freshwater
Invertebrates
Species
Chemical,
%
Active
Ingredient
(
a.
i.)
Endpoint
(
ppm)
Toxicity
Category
Satisfies
Guidelines/
Comments
Reference
(
MRID
No.)

Waterflea
(
Daphnia
magna)
ADBAC
30%*
EC50
=
0.0059
NOEC
=
ND
(
a.
i.)
Very
highly
toxic
Yes
core
study
419472­
03
Waterflea
(
Daphnia
magna)
ADBAC
50%
LC50
=
0.02
(
a.
i.)
Very
highly
toxic
No
open
literature
Dobbs,
M.
G.,
et
al.

(
3)
Estuarine
and
Marine
Organisms,
Acute
Acute
toxicity
testing
with
estuarine
and
marine
organisms
using
the
TGAI
is
required
when
the
end­
use
product
is
intended
for
direct
application
to
the
marine/
estuarine
environment
*
Comparable
to
typical
ADBAC
Manufacturing
Use
Product
(
MUP)
80%
with
regard
to
actual
composition
of
ADBAC
and
its
impurities
Page
42
of
50
or
effluent
containing
the
active
ingredient
is
expected
to
reach
this
environment.
The
preferred
fish
test
species
is
sheepshead
minnow.
The
preferred
invertebrate
test
species
are
mysid
shrimp
and
eastern
oysters.
This
testing
is
required
for
ADBAC
based
on
the
chemical's
use
in
aquatic
sites
such
as
pulp
and
paper
mills,
once­
through
cooling
towers,
oil
field
recovery
systems
and
as
a
wood
preservative.
Results
of
toxicity
studies,
submitted
for
ADBAC
and
obtained
from
the
open
literature,
are
presented
in
Table
5.

Table
5.
Acute
Toxicity
of
ADBAC
to
Estuarine
and
Marine
Organisms
Species
Chemical,
%
Active
Ingredient
(
a.
i.)
Endpoint
(
ppm
ai)
Toxicity
Category
Satisfies
Guidelines/
Comments
Reference
(
MRID
No.)

Sheepshead
minnow
(
Cyprinodon
variegatus)
ADBAC
80%
LC50
=
0.86
NOEC
=
0.68
Highly
toxic
Yes
core
study
424795­
02
Inland
silverside
(
Menidia
beryllina)
ADBAC
50%
LC50
=
0.31
Highly
toxic
No
open
literature
Dobbs,
M.
G.
et
al.

Mysid
shrimp
(
Mysidopsis
bahia)
ADBAC
80%
LC50
=
0.092
NOEC
=
0.047
Very
highly
toxic
Yes
core
study
424795­
01
Mysid
shrimp
(
Mysidopsis
bahia)
ADBAC
50%
LC50
=
0.08
Very
highly
toxic
No
supplemental
study
Dobbs,
M.
G.
et
al.

Eastern
oyster
(
Crassostrea
virginica)
ADBAC
80%
LC50
=
0.055
Very
highly
toxic
No
supplemental
study
424795­
03
The
results
of
the
studies
indicate
that
ADBAC
is
highly
toxic
to
estuarine/
marine
fish
and
very
highly
toxic
to
estuarine/
marine
invertebrates
on
an
acute
basis.
The
two
core
studies
(
MRID
424795­
01
and
MRID
424795­
02)
fulfill
guideline
requirements
for
acute
toxicity
tests
using
estuarine/
marine
fish
and
shrimp.
However,
the
one
study
using
an
estuarine/
marine
mollusk
(
MRID
424795­
03)
was
classified
as
supplemental
and
does
not
fulfill
guideline
requirements.

(
4)
Aquatic
Organisms,
Chronic
Chronic
toxicity
testing
(
fish
early
life
stage,
72­
4a/
OPPTS
850.1400
and
aquatic
invertebrate
life
cycle,
72­
4b/
OPPTS
850.1300)
is
required
for
pesticides
when
certain
conditions
of
use
and
environmental
fate
apply.
The
preferred
freshwater
fish
test
species
is
fathead
minnow
(
Pimephales
promelas),
but
other
species
may
be
used.
The
preferred
freshwater
invertebrate
is
Daphnia
magna.
This
testing
is
required
for
ADBAC.
Results
of
these
toxicity
studies,
submitted
for
ADBAC,
are
presented
in
Table
6.
The
results
indicate
that
exposure
to
ADBAC
on
a
chronic
basis
results
in
measurable
effects
on
warmwater
fish
at
a
concentration
of
75.9
µ
g
a.
i./
L.
This
study
fulfills
guideline
requirements
for
a
fish
early
life
stage
chronic
test
(
72­
4(
a)/
OPPTS
850.1400).
No
measurable
effects
on
freshwater
invertebrates
were
noted
at
a
concentration
of
4.15
µ
g/
L.
However,
an
MATC
could
not
be
determined
in
this
study.
Therefore,
the
study
was
classified
as
supplemental
and
does
not
fulfill
guideline
requirements
for
an
aquatic
invertebrate
life
cycle
test
(
72­
4b/
OPPTS
850.1300).
Page
43
of
50
Table
6.
Chronic
Toxicity
of
ADBAC
to
Freshwater
Organisms
Species
Chemical,
%
Active
Ingredient
(
a.
i.)
Endpoint
(
µ
g/
L
ai)
Satisfies
Guidelines/
Comments
Reference
(
MRID
No.)

Fathead
Minnow
(
Pimephales
promelas)
ADBAC
30%
LOEC
=
75.9
NOEC
=
32.2
MATC
=
49.4
Yes
acceptable
study
423021­
02
Waterflea
(
Daphnia
magna)
ADBAC
30%
LOEC
=
ND
NOEC
=
4.15
MATC
=
ND
No
supplemental
study
423021­
01
Page
44
of
50
Appendix
C.
Wildlife
Drinking
Water
Exposure
Problem:
ADBAC
is
a
antimicrobial
pesticide
used
to
control
algae
in
outdoor
fountains,
bird
baths,
puddles
and
decorative
pools.
No
running
water
uses.

Issue
is
wildlife
exposure
via
drinking
water.

Assumption
wildlife
is
using
puddles
and
bird
baths
as
a
source
of
drinking
water.

Method
will
be
based
on
daily
oral
exposure.
Daily
dose
is
expressed
as
mass
of
pesticide/
kgbw
Inputs
needed:

Concentration
of
pesticide
in
water
source:
labeled
rate
is
5
and
200
mg/
L
Body
weight
of
target
species:
Avian
20g,
100g,
1000
g
Mammalian
15,
35,
1000
g
Calculations:
Drinking
water
intake
rate
(
IRw):
EPA
(
1994)
intake
L/
day
=
0.059(
bw
kg)^
0.67
(
birds)
intake
L/
day
=
0.099(
bw
kg)^
0.90
(
mammals)

Daily
pesticide
exposure
(
Water
dose
mg/
kg­
bw)
=
[(
Cwater
mg/
L)(
IRw
L)]/
bw
kg
Caveats
:

1.
Does
not
consider
additional
exposure
from
dermal
contact
nor
from
preening
after
bathing
events
2.
Chronic
exposures
are
likely
over
estimated
as
concentration
is
based
on
target
concentration
at
time
of
application.

Acute
RQ
=
(
Water
dose
mg/
kg­
bw)/(
LD50
mg/
kg­
bw)

Source:
Wildlife
Exposure
Factors
Handbook,
USEPA,
1994.
Page
45
of
50
Appendix
D.
Endangered
Species
Species
Taxa
Count
Report
for
Crops
foliage
plants
No
species
were
excluded
Minimum
of
1
Acre.

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
1
species
affected
by
indicated
crops.
The
taxa
Bird
has
4
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
20
species
affected
by
indicated
crops.
The
taxa
Dicot
has
6
species
affected
by
indicated
crops.
The
taxa
Fish
has
8
species
affected
by
indicated
crops.
The
taxa
Gastropod
has
9
species
affected
by
indicated
crops.
The
taxa
Mammal
has
4
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
The
taxa
other
has
2
species
affected
by
indicated
crops.
The
taxa
Reptile
has
5
species
affected
by
indicated
crops.
Arizona
The
taxa
Amphibian
has
1
species
affected
by
indicated
crops.
The
taxa
Bird
has
7
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
9
species
affected
by
indicated
crops.
The
taxa
Fish
has
9
species
affected
by
indicated
crops.
The
taxa
Gastropod
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
6
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
The
taxa
Reptile
has
1
species
affected
by
indicated
crops.
Arkansas
The
taxa
Bird
has
3
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
4
species
affected
by
indicated
crops.
The
taxa
Crustacean
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
1
species
affected
by
indicated
crops.
The
taxa
Insect
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
3
species
affected
by
indicated
crops.
California
The
taxa
Amphibian
has
6
species
affected
by
indicated
crops.
The
taxa
Bird
has
15
species
affected
by
indicated
crops.
The
taxa
Crustacean
has
7
species
affected
by
indicated
crops.
The
taxa
Dicot
has
135
species
affected
by
indicated
crops.
The
taxa
Fish
has
24
species
affected
by
indicated
crops.
The
taxa
Gastropod
has
1
species
affected
by
indicated
crops.
The
taxa
Insect
has
19
species
affected
by
indicated
crops.
The
taxa
Mammal
has
21
species
affected
by
indicated
crops.
The
taxa
Monocot
has
14
species
affected
by
indicated
crops.
The
taxa
other
has
2
species
affected
by
indicated
crops.
The
taxa
Reptile
has
8
species
affected
by
indicated
crops.
Colorado
The
taxa
Bird
has
2
species
affected
by
indicated
crops.
The
taxa
Dicot
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
1
species
affected
by
indicated
crops.
Connecticut
Page
46
of
50
The
taxa
Bird
has
1
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
1
species
affected
by
indicated
crops.
The
taxa
Fish
has
1
species
affected
by
indicated
crops.
Florida
The
taxa
Bird
has
10
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
1
species
affected
by
indicated
crops.
The
taxa
Crustacean
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
41
species
affected
by
indicated
crops.
The
taxa
Fish
has
3
species
affected
by
indicated
crops.
The
taxa
Gastropod
has
1
species
affected
by
indicated
crops.
The
taxa
Insect
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
11
species
affected
by
indicated
crops.
The
taxa
Monocot
has
2
species
affected
by
indicated
crops.
The
taxa
other
has
1
species
affected
by
indicated
crops.
The
taxa
Reptile
has
10
species
affected
by
indicated
crops.
Georgia
The
taxa
Bird
has
5
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
13
species
affected
by
indicated
crops.
The
taxa
Dicot
has
5
species
affected
by
indicated
crops.
The
taxa
Fish
has
7
species
affected
by
indicated
crops.
The
taxa
Mammal
has
3
species
affected
by
indicated
crops.
The
taxa
Monocot
has
3
species
affected
by
indicated
crops.
The
taxa
other
has
3
species
affected
by
indicated
crops.
The
taxa
Reptile
has
2
species
affected
by
indicated
crops.
Hawaii
The
taxa
Arachnid
has
1
species
affected
by
indicated
crops.
The
taxa
Bird
has
32
species
affected
by
indicated
crops.
The
taxa
Crustacean
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
233
species
affected
by
indicated
crops.
The
taxa
Gastropod
has
39
species
affected
by
indicated
crops.
The
taxa
Insect
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
2
species
affected
by
indicated
crops.
The
taxa
Monocot
has
22
species
affected
by
indicated
crops.
The
taxa
other
has
12
species
affected
by
indicated
crops.
The
taxa
Reptile
has
2
species
affected
by
indicated
crops.
Idaho
The
taxa
Bird
has
1
species
affected
by
indicated
crops.
The
taxa
Fish
has
3
species
affected
by
indicated
crops.
Illinois
The
taxa
Bird
has
3
species
affected
by
indicated
crops.
The
taxa
Dicot
has
3
species
affected
by
indicated
crops.
The
taxa
Fish
has
1
species
affected
by
indicated
crops.
The
taxa
Insect
has
2
species
affected
by
indicated
crops.
The
taxa
Mammal
has
2
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
Indiana
The
taxa
Bird
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
2
species
affected
by
indicated
crops.
The
taxa
Insect
has
2
species
affected
by
indicated
crops.
The
taxa
Mammal
has
1
species
affected
by
indicated
crops.
The
taxa
Reptile
has
1
species
affected
by
indicated
crops.
Iowa
The
taxa
Bird
has
3
species
affected
by
indicated
crops.
The
taxa
Dicot
has
2
species
affected
by
indicated
crops.
The
taxa
Fish
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
1
species
affected
by
indicated
crops.
The
taxa
Monocot
has
2
species
affected
by
indicated
crops.
Kentucky
Page
47
of
50
The
taxa
Bird
has
3
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
9
species
affected
by
indicated
crops.
The
taxa
Mammal
has
2
species
affected
by
indicated
crops.
Louisiana
The
taxa
Bird
has
4
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
2
species
affected
by
indicated
crops.
The
taxa
Fish
has
2
species
affected
by
indicated
crops.
The
taxa
Mammal
has
2
species
affected
by
indicated
crops.
The
taxa
other
has
1
species
affected
by
indicated
crops.
The
taxa
Reptile
has
7
species
affected
by
indicated
crops.
Maine
The
taxa
Bird
has
3
species
affected
by
indicated
crops.
The
taxa
Fish
has
2
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
Maryland
The
taxa
Bird
has
2
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
1
species
affected
by
indicated
crops.
The
taxa
Fish
has
1
species
affected
by
indicated
crops.
The
taxa
Insect
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
2
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
The
taxa
Reptile
has
1
species
affected
by
indicated
crops.
Massachusetts
The
taxa
Bird
has
4
species
affected
by
indicated
crops.
The
taxa
Dicot
has
1
species
affected
by
indicated
crops.
The
taxa
Fish
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
1
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
The
taxa
Reptile
has
1
species
affected
by
indicated
crops.
Michigan
The
taxa
Bird
has
3
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
1
species
affected
by
indicated
crops.
The
taxa
Insect
has
2
species
affected
by
indicated
crops.
The
taxa
Mammal
has
1
species
affected
by
indicated
crops.
The
taxa
Monocot
has
2
species
affected
by
indicated
crops.
The
taxa
Reptile
has
1
species
affected
by
indicated
crops.
Minnesota
The
taxa
Bird
has
2
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
2
species
affected
by
indicated
crops.
The
taxa
Dicot
has
1
species
affected
by
indicated
crops.
The
taxa
Insect
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
2
species
affected
by
indicated
crops.
Mississippi
The
taxa
Amphibian
has
1
species
affected
by
indicated
crops.
The
taxa
Bird
has
5
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
6
species
affected
by
indicated
crops.
The
taxa
Fish
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
1
species
affected
by
indicated
crops.
The
taxa
other
has
1
species
affected
by
indicated
crops.
The
taxa
Reptile
has
7
species
affected
by
indicated
crops.
Missouri
The
taxa
Bird
has
3
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
2
species
affected
by
indicated
crops.
The
taxa
Dicot
has
4
species
affected
by
indicated
crops.
The
taxa
Fish
has
3
species
affected
by
indicated
crops.
The
taxa
Insect
has
2
species
affected
by
indicated
crops.
Page
48
of
50
The
taxa
Mammal
has
2
species
affected
by
indicated
crops.
Montana
The
taxa
Bird
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
1
species
affected
by
indicated
crops.
The
taxa
Fish
has
3
species
affected
by
indicated
crops.
The
taxa
Mammal
has
2
species
affected
by
indicated
crops.
Nebraska
The
taxa
Bird
has
4
species
affected
by
indicated
crops.
The
taxa
Fish
has
1
species
affected
by
indicated
crops.
The
taxa
Insect
has
1
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
Nevada
The
taxa
Bird
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
8
species
affected
by
indicated
crops.
The
taxa
Fish
has
7
species
affected
by
indicated
crops.
The
taxa
Insect
has
1
species
affected
by
indicated
crops.
The
taxa
Reptile
has
1
species
affected
by
indicated
crops.
New
Hampshire
The
taxa
Bird
has
1
species
affected
by
indicated
crops.
The
taxa
Insect
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
1
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
New
Jersey
The
taxa
Bird
has
2
species
affected
by
indicated
crops.
The
taxa
Dicot
has
2
species
affected
by
indicated
crops.
The
taxa
Fish
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
1
species
affected
by
indicated
crops.
The
taxa
Monocot
has
2
species
affected
by
indicated
crops.
The
taxa
Reptile
has
1
species
affected
by
indicated
crops.
New
Mexico
The
taxa
Amphibian
has
1
species
affected
by
indicated
crops.
The
taxa
Bird
has
7
species
affected
by
indicated
crops.
The
taxa
Crustacean
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
1
species
affected
by
indicated
crops.
The
taxa
Fish
has
1
species
affected
by
indicated
crops.
The
taxa
Gastropod
has
2
species
affected
by
indicated
crops.
The
taxa
Mammal
has
1
species
affected
by
indicated
crops.
New
York
The
taxa
Bird
has
3
species
affected
by
indicated
crops.
The
taxa
Dicot
has
4
species
affected
by
indicated
crops.
The
taxa
Fish
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
1
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
The
taxa
other
has
1
species
affected
by
indicated
crops.
The
taxa
Reptile
has
1
species
affected
by
indicated
crops.
North
Carolina
The
taxa
Arachnid
has
1
species
affected
by
indicated
crops.
The
taxa
Bird
has
4
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
8
species
affected
by
indicated
crops.
The
taxa
Dicot
has
15
species
affected
by
indicated
crops.
The
taxa
Fish
has
3
species
affected
by
indicated
crops.
The
taxa
Mammal
has
5
species
affected
by
indicated
crops.
The
taxa
Monocot
has
4
species
affected
by
indicated
crops.
The
taxa
other
has
1
species
affected
by
indicated
crops.
The
taxa
Reptile
has
5
species
affected
by
indicated
crops.
Ohio
The
taxa
Bird
has
2
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
1
species
affected
by
indicated
crops.
Page
49
of
50
The
taxa
Dicot
has
2
species
affected
by
indicated
crops.
The
taxa
Insect
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
1
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
Oklahoma
The
taxa
Bird
has
4
species
affected
by
indicated
crops.
The
taxa
Fish
has
1
species
affected
by
indicated
crops.
The
taxa
Insect
has
1
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
Oregon
The
taxa
Bird
has
5
species
affected
by
indicated
crops.
The
taxa
Dicot
has
6
species
affected
by
indicated
crops.
The
taxa
Fish
has
18
species
affected
by
indicated
crops.
The
taxa
Insect
has
2
species
affected
by
indicated
crops.
The
taxa
Mammal
has
1
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
Pennsylvania
The
taxa
Bird
has
2
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
2
species
affected
by
indicated
crops.
The
taxa
Mammal
has
1
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
The
taxa
Reptile
has
1
species
affected
by
indicated
crops.
Rhode
Island
The
taxa
Bird
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
1
species
affected
by
indicated
crops.
The
taxa
Fish
has
1
species
affected
by
indicated
crops.
The
taxa
Insect
has
1
species
affected
by
indicated
crops.
South
Carolina
The
taxa
Amphibian
has
1
species
affected
by
indicated
crops.
The
taxa
Bird
has
5
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
9
species
affected
by
indicated
crops.
The
taxa
Fish
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
7
species
affected
by
indicated
crops.
The
taxa
Monocot
has
3
species
affected
by
indicated
crops.
The
taxa
Reptile
has
4
species
affected
by
indicated
crops.
Tennessee
The
taxa
Bird
has
2
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
22
species
affected
by
indicated
crops.
The
taxa
Crustacean
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
9
species
affected
by
indicated
crops.
The
taxa
Fish
has
10
species
affected
by
indicated
crops.
The
taxa
Gastropod
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
2
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
Texas
The
taxa
Amphibian
has
4
species
affected
by
indicated
crops.
The
taxa
Arachnid
has
4
species
affected
by
indicated
crops.
The
taxa
Bird
has
12
species
affected
by
indicated
crops.
The
taxa
Crustacean
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
16
species
affected
by
indicated
crops.
The
taxa
Fish
has
3
species
affected
by
indicated
crops.
The
taxa
Insect
has
5
species
affected
by
indicated
crops.
The
taxa
Mammal
has
5
species
affected
by
indicated
crops.
The
taxa
Monocot
has
2
species
affected
by
indicated
crops.
The
taxa
Reptile
has
5
species
affected
by
indicated
crops.
Utah
The
taxa
Bird
has
1
species
affected
by
indicated
crops.
Page
50
of
50
The
taxa
Dicot
has
2
species
affected
by
indicated
crops.
The
taxa
Fish
has
1
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
Virginia
The
taxa
Bird
has
2
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
2
species
affected
by
indicated
crops.
The
taxa
Dicot
has
5
species
affected
by
indicated
crops.

The
taxa
Fish
has
2
species
affected
by
indicated
crops.
The
taxa
Insect
has
2
species
affected
by
indicated
crops.
The
taxa
Mammal
has
2
species
affected
by
indicated
crops.
The
taxa
Monocot
has
2
species
affected
by
indicated
crops.
The
taxa
Reptile
has
1
species
affected
by
indicated
crops.
Washington
The
taxa
Bird
has
3
species
affected
by
indicated
crops.
The
taxa
Dicot
has
3
species
affected
by
indicated
crops.
The
taxa
Fish
has
17
species
affected
by
indicated
crops.
The
taxa
Mammal
has
4
species
affected
by
indicated
crops.
West
Virginia
The
taxa
Amphibian
has
1
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
4
species
affected
by
indicated
crops.
The
taxa
Dicot
has
2
species
affected
by
indicated
crops.
The
taxa
Gastropod
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
3
species
affected
by
indicated
crops.
Wisconsin
The
taxa
Bird
has
2
species
affected
by
indicated
crops.
The
taxa
Bivalve
has
1
species
affected
by
indicated
crops.
The
taxa
Dicot
has
2
species
affected
by
indicated
crops.
The
taxa
Insect
has
1
species
affected
by
indicated
crops.
The
taxa
Mammal
has
2
species
affected
by
indicated
crops.
The
taxa
Monocot
has
1
species
affected
by
indicated
crops.
