	UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
	WASHINGTON, DC 20460

                    OFFICE OF CHEMICAL SAFETY AND POLLUTION PREVENTION
	

	PC Code: 090100
                                       DP Barcode: 410516,412426, 412427, 412479
	Date: November 27, 2013

MEMORANDUM						

Subject:	Chlorantraniliprole (E2Y45): Ecological Risk Assessment to Support New Use on Peanut, Subgroup Additions to Previously Assessed Crop Groups, and Evaluation of Multiple Crop Seasons for Numerous Previously Assessed Uses

To:		Venus Eagle, Product Manager 01
            Jennifer Urbanski, Risk Manager Reviewer
		Registration Division (7505P)
	
From:		Michael B. Lowit, Ph.D., Ecologist
		Christopher M. Koper, Chemist
		Monica Wait, Acting RAPL
      Sujatha Sankula, Ph.D., Branch Chief 
      Environmental Risk Branch I
      Environmental Fate and Effects Division (7507P)
		Office of Pesticide Programs		
		
This memorandum summarizes the ecological risks associated with proposed new uses of the insecticide chlorantraniliprole.  In addition, the Coragen(R) label now includes annual limits for certain crops that reflect multiple crop seasons; risk associated with multiple crop seasons was considered due to the persistence of chlorantraniliprole.  The risk assessment considers three products: Altacor[(R)] (Reg. # 352-730), Coragen[(R)] (Reg. # 352-729), and Prevathon(TM) (Reg. # 352-844).

Foliar applications (ground or aerial spray and overhead chemigation) are proposed up to 0.065 - 0.067 lb ai/A for peanut use depending on the product (Coragen[(R)] or Prevathon(TM)); the minimum application interval is three days and the annual limit is 0.2 lb ai/A of chlorantraniliprole containing products.

The following label changes were proposed:  update stone fruit crops to group 12-12 and tree nut crops to group to 14-2 (commodities added, no rate change); add green onion subgroup 3-07B to the bulb vegetable group (no rate change); increase the tolerance for spice subgroup 19B; and add a last application day before harvest (10 days) for papaya and passionfruit (tropical fruit group).  These changes do not affect the risk conclusions from previous assessments and are not considered further.
Numerous crops were previously assessed assuming that the annual maximum application rate was equivalent to the seasonal application rate (0.2 lb ai/A).  The Coragen[(R)] label now provides an annual limit for many crops that reflect multiple crop seasons (0.4 lb ai/A - 0.8 lb ai/A).  The single application rates, application intervals, and seasonal rates have not changed.
1.	Risk Summary

Risk concerns for the proposed use on peanut and for multiple crop seasons of previously assessed uses (see Table 2) are the same as previous assessments (i.e., the same taxonomic groups); however the RQs for multiple crop seasons are higher than single crop seasons.  There is a risk concern for direct effects on listed and non-listed aquatic invertebrates (acute and chronic).   Risk to terrestrial invertebrates is a concern considering the application rates, the submitted toxicity data, and the mode of action of chlorantraniliprole as an insecticide.  Finally, potential risks to listed terrestrial plants cannot be precluded at this time because a definitive NOEC or EC05 has not been established for dicots.  Risk of direct effects to other aquatic and terrestrial organisms is below the Agency screening levels of concern (LOC).  A summary of risk concerns is presented in Table 1.

Table 1.  Summary of LOC Exceedences for the Assessed Uses of Chlorantraniliprole
                                    Effect
                                Taxonomic Group
                                       
                                     Birds
                                    Mammals
                                  Terrestrial
                                    Plants
                           Terrestrial Invertebrates
                                     Fish
                             Aquatic Invertebrates
                                Aquatic Plants
Direct Effect (LOC Exceedence)
                                      --
                                      --
                                     --[a]
                                    √[b]
                                      --
                                      √
                                      --
Indirect Effect Potential
                                      √
                                      √
                                      √
                                      √
                                      √
                                      √
                                      √
[a]The available data could not preclude potential risk to terrestrial plants: dicots (listed and non-listed species).
[b]RQs were not calculated due to lack of a standard quantification methodology. Therefore, the `LOC exceedance' was based on lines of evidence including application rate, toxicity data, and the mode of action of chlorantraniliprole. 
2.	Data Gaps

 Risk quotients (RQs) could not be calculated for listed dicots (terrestrial plants) because a NOEC or EC05 was not established in the available Tier 1 or Tier II seedling emergence studies.   Risk to listed dicots will be assumed until data is made available that defines a NOEC for dicots.

3.	Summary of Proposed Use

Foliar applications (ground or aerial spray and overhead chemigation) are proposed up to 0.065 - 0.067 lb ai/A for peanut use depending on the product (Coragen[(R)] or Prevathon(TM)).  The Coragen label does not permit overhead chemigation for use on peanut.

The following label changes were proposed:  update stone fruit crops to group 12-12 and tree nut crops to group to 14-2 (commodities added, no rate change); add green onion subgroup 3-07B to the bulb vegetables group (no rate change); increase the tolerance for spice subgroup 19B; and add a last application day before harvest (10 days) for papaya and passionfruit (tropical fruit group). 

Numerous crops were previously assessed assuming that the annual maximum application rate was equivalent to the seasonal application rate (0.2 lb ai/A).  The Coragen[(R)] label now provides an annual limit for many crops that reflect multiple crop seasons (0.4 lb ai/A - 0.8 lb ai/A).  The single application rates, application intervals, and seasonal rates remain the same as previously assessed with two minor exceptions.  Table 2 summarizes the proposed new use and the previously assessed uses with multiple crop seasons; crop grouping additions on the Altacor[(R)] label (as noted above) are not included because application rates did not change.

Table 2.  Assessed Use Rates for Chlorantraniliprole  
                                    Product
                                    Use[1]
                          Single Max Application Rate
                                   (lb ai/A)
                Max Number of Applications (min interval, days)
                               Max Seasonal Rate
                                   (lb ai/A)
                             Max Number of Seasons
                                Max Annual Rate
                                   (lb ai/A)
DuPont Coragen 
                               Proposed New Use

Peanut
                                     0.065
                                     3 (3)
                                      0.2
                                       1
                                      0.2

                        Reassessed Uses (Annual Rates)

Brassica, leafy vegetables[2] 
                                     0.065
                                       
                                     3 (3)
                                       
                                      0.2
                                       
                                       4
                                      0.8

Bulb vegetables; onion, bulb subgroup, green onion subgroup 3-07B
                                     0.065
                                     3 (7)
                                      0.2
                                       3
                                      0.6

Cucurbit vegetables[2]
                                       
                                     0.09
                                       
                                     2 (5)
                                       
                                      0.2
                                       3
                                      0.6

Fruiting vegetables [2]
                                     0.098
                                     2 (5)
                                      0.2
                                       3
                                      0.6

Herbs
                                     0.065
                                     3 (3)
                                      0.2
                                       4
                                      0.8

Leafy vegetables, non-brassica[2]
                                     0.098
                                     2 (3)
                                      0.2
                                       4
                                      0.8

Legume vegetables [3,5]
                                     0.098
                                     2 (3)
                                      0.2
                                       3
                                      0.6

Legume vegetables (foliage)
                                     0.065
                                     3 (3)
                                      0.2
                                       3
                                      0.6

Spices
                                     0.065
                                     3 (3)
                                      0.2
                                       4
                                      0.8

Strawberry
                                     0.065
                                     3 (7)
                                      0.2
                                       2
                                      0.4

Tuberous and corm vegetables[4,5]
                                     0.065
                                     3 (3)
                                      0.2
                                       4
                                      0.8
Dupont Prevathon
                               Proposed New Use

Peanut
                                     0.067
                                     3 (3)
                                      0.2
                                       1
                                      0.2
[1] Foliar (air and ground) applications unless indicated otherwise.
[2] Soil-at planting and drip chemigation applications are permitted at similar rates (see DP 381819+ for details).
[3] Previously assessed at the foliage of legume rate (above).
[4] Previously assessed using a 5 day interval.
[5] It is unknown if the label changed since the initial assessment or if a typographical error was made at the time of the assessment.









4.	Exposure Summary

4.1.	Aquatic Exposure

The PRZM/EXAMS input parameters are shown in Table 3.  EECs are presented in Table 4. A representative PRZM/EXAM model input is presented in Appendix 1.  

Table 3.  PRZM/EXAMS Input Parameters for Chlorantraniliprole
Input Parameter
Value
Comment
Source
Scenarios:
Peanut:
NC Peanut
Onion:
CA, GA Onion
Spice:
CA Lettuce
OR Mint
CA Row Crop
PA Vegetable
Brassica (Cole) Leafy Vegetables:
CA Cole Crop
Cucurbit Vegetables:
FL Cucumber
MI, MO, NJ Melon
Fruiting Vegetables:
CA, FL, PA Tomato
Leafy Vegetables:
CA Lettuce
Legumes:
MI Beans
Leaves of /and Root and Tuber Vegetables:
FL Carrot
ID, ME Potato
MN Sugarbeet
NC Sweet Potato
Strawberry:
FL Strawberry
representative scenarios for each use
N/A 
Maximum Single 
Application Rate
lb ai/acre (kg ai/ha)
Peanut: 0.067 (0.075)  
Onion: 0.067 (0.075)  
Spice: 0.067 (0.075)  
Brassica (Cole) Leafy Vegs:  0.067 (0.075)  
Cucurbit Vegetables:  0.100 (0.112)    
Fruiting Vegetables:  0.100 (0.112)    
Leafy Vegetables:  0.100 (0.112)    
Legumes:  0.100 (0.112)    
Leaves of /and Root and Tuber Vegs:  0.067 (0.075)  
Strawberry:  0.067 (0.075)   
proposed maximum single application rate

modeled single rates were slightly higher than the labeled rates (rate = the seasonal application rate/number of applications per season)
proposed  label
Applications per Year
Peanut:  3

Onion:  9  
(3 apps/season x 3 seasons)

Spice: 12
(3 apps/season x 4 seasons)

Brassica (Cole) Leafy Vegs:  12
(3 apps/season x 4 seasons)

Cucurbit Vegetables:  6
(2 apps/season x 3 seasons)

Fruiting Vegetables:  6
(2 apps/season x 3 seasons)

Leafy Vegetables:  8
(2 apps/season x 4 seasons)

Legumes:  6
(2 apps/season x 3 seasons)

Leaves of /and Root and Tuber Vegs:  12
(3 apps/season x 4 seasons)

Strawberry:  6
(3 apps/season x 3 seasons) 
label directions.  Application number for maximum single application rate.
proposed label
Application Interval (days)
Peanut:  3
Onion:  7  
Spice: 3
Brassica (Cole) Leafy Vegs:  3
Cucurbit Vegetables:  5
Fruiting Vegetables:  5
Leafy Vegetables:  3
Legumes:  3
Leaves of /and Root & Tuber Vegs:  3
Strawberry:  7
proposed application intervals
proposed label
Date of Initial Application
(scenario: day-month)
Peanut:
NC Peanut:  16-05
Onion:
CA Onion:  18-05
GA Onion:  18-05
Spice:
CA Lettuce:  21-04
OR Mint:  11-07
CA Row Crop:  18-03
PA Vegetable:  17-09
Brassica (Cole) Leafy Vegetables:
CA Cole Crop:  08-02
Cucurbit Vegetables:
FL Cucumber:  01-11
MI Melon:  11-06
MO Melon:  17-06
 NJ Melon:  16-06
Fruiting Vegetables:
CA Tomato:  17-06
FL Tomato:  07-04
PA Tomato:  16-06
Leafy Vegetables:
CA Lettuce:  21-04
Legumes:
MI Beans:  13-07
Leaves of /and Root and Tuber Vegetables:
FL Carrot:  01-01
ID Potato:  01-08
ME Potato:  17-09
MN Sugarbeet:  17-09
NC Sweet Potato:  01-09
Strawberry:
FL Strawberry:  27-10
For most crops, to give a representative window of the growing season, the date of initial application (season 1) was selected as two weeks (14 days) before crop maturation from crop scenario data.  

When modeling multiple seasons, a 14 day interval was arbitrarily selected to represent the time between the final application of the preceding season and first application of the following season. 

An arbitrary date of June 1 was selected for FL Citrus and the date of crop emergence of May 16 was selected for NC Peanut due to inconsistencies within the crop scenario dates for these crops.  

For FL Cucumber, November 1 was selected as the initial date of application in order to fit all applications in a given calendar year which is needed to run the model.

Crop Scenarios
Application Method
Foliar:  aerial and ground
label directions.  Aerial only modeled for Brassica, cucurbit, fruiting, leafy, root and tuber vegetables, legumes, and strawberry.
proposed label
CAM Input
2  (foliar: aerial, ground)

(2) linear foliar based on crop canopy
US EPA, 2005
IPSCND Input
Peanut:  1
Onion:  2
Spice: 3
Brassica (Cole) Leafy Vegs:  2
Cucurbit Vegetables:  3
Fruiting Vegetables:  3
Leafy Vegetables:  2
Legumes:  3
Leaves of /and Root & Tuber Vegs:  3
Strawberry:  3
remaining pesticide on foliage is:
 (1) converted to surface application to the top soil layer,
(2) completely removed after harvest
(3) Retained as surface residue and continues to decay.  This input only applies to foliar applications (CAM 2).
US EPA, 2005
Spray Drift Fraction
0.05  (aerial)
0.01  (ground)
--
Input parameter guidance (USEPA, 2009) 
Application Efficiency
0.95  (aerial)
0.99  (ground)
--
Input parameter guidance 
(USEPA, 2009)
Molecular Mass (g/mol)
483.15
--
--
Vapor Pressure at 25°C (torr)
1.57 x 10[-13]
--
DuPont 16517
Henry's Law Constant
(atm-m[3]/mol)
9.76 x 10[-14]
estimated
calculated from solubility, vapor pressure and molecular weight
Solubility in Water (mg/L)
1.023
--
MRID 46889026
Organic Carbon Partition Coefficient (KOC) (L/kgOC)
330
[1] represents the average KOC from 5 values
MRID 46889123
Aerobic Soil Metabolism Half-life (days)
627 
2 , 3, 4 Calculated 90[th] percentile of mean. (mean= 509 days, SD= 253 days, t= 1.40, n= 9)
*Several reported half-lives in MRID 46889124
 were not used because of poor fit with first-order degradation model
MRID 46889014
MRID 46889015
MRID 46889124

Aerobic Aquatic Metabolism Half-life (days)
341
2 Calculated 90[th] percentile of mean.  Mean= 178 days, SD= 74.95 days, t= 3.078, n=2
MRID 46889016
Anaerobic Aquatic Metabolism Half-life (days)
624
208 days single half-life
(3 x 208 days  per EFED guidance)
DuPont 14568
Hydrolysis Half-lives (days)
0  (stable)
pH 7
MRID 46889017
Aqueous Photolysis
Half-life (days)
32.8 [5]
Natural sunlight half-life
MRID 46889122
 N/A = Not Applicable
[1] Koc values include 152, 438, 535, 268, 255.
2 tinput=Mean + (t90,n-1*SD) / √N
[3] EFED recalculated first-order half-lives for both benzo- and pyrazole-labeled chlorantraniliprole. The calculated half-lives are based on aerobic soil metabolism data in non-sterile soil at 25[0]C. Half-lives used in the assessment include 578, 537, 375, 41, 247, 228, 889, 924, 396 days.  
[4] The 90[th] percentile of the mean half-life for chlorantraniliprole was 600 days for half-lives values presented in the OECD Chlorantraniliprole Volume  3(1): Annex B, Environmental Fate and Behavior. (mean = 491 ( 886, 539, 380, 233, 323, 629, 423, 518 days); SD=203; t90, n-1 =1.417; N=8
5 The natural sunlight half-life value of 32.8 days was modeled because this better half-life characterizes the behavior of chlorantraniliprole in the environment.  MRID 46889018 calculates a half-life of 0.31 days from a xenon arc lamp experiment using continuous irradiation.

Table 3.  Chlorantraniliprole Estimated Environmental Concentrations (EECs) for Surface Water Based on Selected Crop Scenarios
                              Proposed Label Use
                                  PRZM/EXAMS
                                  Scenario[1]
                               (first app date)
                                   Method[2]
                               Application Rate
                        (interval between applications)
                               Peak EEC (ug/L)
                                    21 Day
                                  EEC (ug/L)
                                    60 Day
                                  EEC (ug/L)
Dupont(TM) Coragen[(R)] insect control with RYNAXPYR[(R)]  [EPA Reg. No. 352-729]

Peanuts

NC Peanut
(May 16  -  foliar)
                                       A
                           3 app @ 0.067 lb ai/acre
                               (3-day interval)
                                     3.98
                                     3.84
                                     3.68


                                       G

                                     3.23
                                     3.10
                                     2.90

Bulb vegetables; onion, bulb subgroup, green onion subgroup 3-07B
CA Onion
(May 18  -  foliar)
                                       A
                           3 app @ 0.067 lb ai/acre
                               (7-day interval)
                              [0.2 lb ai/A/crop]
                              [0.6 lb ai/A/year]
                                     6.74
                                     6.46
                                     6.10


                                       G

                                     5.02
                                     4.74
                                     4.57

GA Onion
(May 18  -  foliar)
                                       A

                                     24.46
                                     23.86
                                     22.54


                                       G

                                     23.07
                                     22.48
                                     21.22

Spice
Subgroup 19B/Herb Subgroup 19A
CA Lettuce
(April 21  -  foliar)
                                       A
                           3 app @ 0.067 lb ai/acre
                               (3-day interval)
                              [0.2 lb ai/A/crop]
                              [0.8 lb ai/A/year]
                                     30.93
                                     30.07
                                     29.04


                                       G

                                     28.36
                                     27.43
                                     26.34

OR Mint
(July 11  -  foliar)
                                       A

                                     14.43
                                     14.11
                                     13.69


                                       G

                                     10.03
                                     9.84
                                     9.69

CA Row Crop
(March 18  -  foliar)
                                       A

                                     15.66
                                     15.38
                                     15.31


                                       G

                                     12.42
                                     12.11
                                     11.68

PA Vegetable
(Sept 17  -  foliar)
                                       A

                                     28.81
                                     28.50
                                     27.01


                                       G

                                     25.61
                                     24.99
                                     23.63
Brassica (Cole)
Leafy Vegetables

CA Cole Crop
(February 08 - foliar)
                                       A
                           3 app @ 0.067 lb ai/acre
                               (3-day interval)
                              [0.2 lb ai/A/crop]
                              [0.8 lb ai/A/year]
                                     26.43
                                     26.29
                                     25.86
Cucurbit Vegetables
FL Cucumber
(November 01  -  foliar)
                                       A
                           2 app @ 0.100 lb ai/acre
                               (5-day interval)
                              [0.2 lb ai/A/crop]
                              [0.6 lb ai/A/year]
                                     26.16
                                     25.35
                                     22.97

MI Melon
(June 11  -  foliar)
                                       

                                     13.41
                                     13.04
                                     12.58

MO Melon
(June 17  -  foliar)
                                       

                                     19.41
                                     18.58
                                     17.29

NJ Melon
(June 16  -  foliar)
                                       

                                     19.15
                                     18.61
                                     18.01

Fruiting Vegetables


CA Tomato
(June 17   -  foliar)
                                       A
                           2 app @ 0.100 lb ai/acre
                               (5-day interval)
                              [0.2 lb ai/A/crop]
                              [0.6 lb ai/A/year]
                                     13.34
                                     13.08
                                     12.60

FL Tomato
(April 7   -  foliar)
                                       

                                     26.13
                                     25.10
                                     23.74

PA Tomato
(June 16  -  foliar)
                                       

                                     23.67
                                     22.93
                                     22.13
Leafy Vegetables
CA Lettuce
(April 21   -  foliar)
                                       A
                           2 app @ 0.100 lb ai/acre
                               (3-day interval)
                              [0.2 lb ai/A/crop]
                              [0.8 lb ai/A/year]
                                     25.95
                                     24.95
                                     24.00
Legumes
MI Beans
(July 13   -  foliar)
                                       A
                           2 app @ 0.100 lb ai/acre
                               (3-day interval)
                              [0.2 lb ai/A/crop]
                              [0.6 lb ai/A/year]
                                     35.07
                                     34.41
                                     33.58
Root and Tuber Vegetables

Leaves of Root and Tuber Vegetables
FL Carrot
(January 01  -  foliar)
                                       A
                           3 app @ 0.067 lb ai/acre
                               (3-day interval)
                              [0.2 lb ai/A/crop]
                              [0.8 lb ai/A/year]
                                     29.64
                                     28.20
                                     27.15

ID Potato
(August 01   -  foliar)
                                       

                                     17.32
                                     17.13
                                     16.74

ME Potato
(September 17   -  foliar)
                                       

                                     36.13
                                     35.70
                                     35.04

MN Sugarbeet
(September 17   -  foliar)
                                       

                                     27.90
                                     27.71
                                     27.16

NC Sweet Potato
(September 01   -  foliar)
                                       

                                     30.56
                                     30.17
                                     29.65
Strawberry 

FL Strawberry
(October 27   -  foliar)
                                       A
                           3 app @ 0.067 lb ai/acre
                               (7-day interval)
                              [0.2 lb ai/A/crop]
                              [0.4 lb ai/A/year]
                                     9.86
                                     9.57
                                     8.96
Dupont(TM) Prevathon[(R)] insect control with RYNAXPYR[(R)]  [EPA Reg. No. 352-844]

Peanuts

NC Peanut
(May 16   -  foliar)
                                       A
                           3 app @ 0.067 lb ai/acre
                               (3-day interval)
                                     3.98
                                     3.84
                                     3.68


                                       G

                                     3.23
                                     3.10
                                     2.90
Bold numbers denote maximum EEC values.
2  A = aerial application, G = ground application.

4.2.	Terrestrial Exposure
	
In past assessments there was not a risk concern for mammals or birds even assuming a single application at an annual maximum rate of 0.2 lb ai/A (e.g. DP 397575+).  Therefore, there is not a risk concern for the proposed peanut use given the same annual maximum rate; terrestrial exposure was not estimated.

However, exposure was estimated for uses with multiple crop seasons.  As a screen, two methods and sets of assumptions were used to calculate EECs which are intended solely to capture a range of possible exposure scenarios.  (1) Plants may accumulate chlorantraniliprole residues from season to season to the extent that previously treated plant material remains on or off the field.  As a screen, EECs were calculated in T-REX (v 1.5) for multiple crop seasons making the assumption that the same plant material is treated season after season (for example, see Table 4 for the crop scenario resulting in the highest EECs).  (2) EECs for subsequent crop seasons are expected to increase over the EECs based on a single crop season even if previously treated plant material is completely removed from the field given that chlorantraniliprole is persistent in soil and that the Coragen label indicates that the product is translocated into the above ground portions of plants after soil applications. Carryover residues could come from either past soil or foliar applications.  The Briggs model was used as a conservative screening estimate of exposure due to systemic transport into plant material (details and equations provided in White Paper in Support of the Proposed Risk Assessment Process for Bees, September 11  -  14, 2012).  For this screening analysis, it was assumed that estimated concentrations would occur throughout a plant.  The EEC (0.299 mg/kg plant material) was based on an application rate of 0.6 lb ai/A (a maximum of three crop seasons after the initial crop season), log Kow = 2.77, and Koc = 328 L/kgoc.  

Table 4.  Screening Terrestrial Food-Item Residue Estimates for Mammals and Birds for Multiple Crop Seasons of Foliar Applications of Chlorantraniliprole[1]
                              Size Class
(grams)
                        Dietary and Dose-Based EECs[2]

                                  Short Grass
                                  Tall Grass
                               Broadleaf Plants
                              Fruits/Pods/
Seeds
                                  Arthropods
                                    Mammals
Dose-Based EECs
                                      15
                                    112.74
                                     51.67
                                     63.41
                                     7.05
                                     44.15
                                      35
                                     77.92
                                     35.71
                                     43.83
                                     4.87
                                     30.51
                                     1000
                                     18.07
                                     8.28
                                     10.16
                                     1.13
                                     7.07
Dietary-Based EECs[3]
                                      NA
                                    118.24
                                     54.20
                                     66.51
                                     7.39
                                     46.31
                                     Avian
Dose-Based EECs
                                      20
                                    134.67
                                     61.72
                                     75.75
                                     8.42
                                     52.75
                                      100
                                     76.79
                                     35.20
                                     43.20
                                     4.80
                                     30.08
                                     1000
                                     34.38
                                     15.76
                                     19.34
                                     2.15
                                     13.47
Dietary-Based EECs[3]
                                      NA
                                    118.24
                                     54.20
                                     66.51
                                     7.39
                                     46.31
[1] 0.098 lb ai/A, 2 applications at 3 day intervals per season (4 seasons with 14 days between the last and first application of sequential seasons).  For consistency, application intervals are the same as those used for aquatic modeling
2 Based on default foliar dissipation half-life of 35 days 
[3] Size class not used for dietary EECs

EECs for terrestrial plants were determined in past assessments for the proposed application rates (e.g., DP 338512 and DP 397575+).  

5.	Fate and Transport and Ecological Effects Summary 

Fate and toxicity data used for this risk assessment has not changed since the last assessment (DP 404738+).  A detailed description of fate and transport properties can be found in the comprehensive drinking water assessment (DP 348133) dated 10 January 2008 and a detailed description of toxicity data can be found in the 2007 (DP 338512),  2011 (DP 377697+), and 2012 (DP 397575+) risk assessments.

6.	Incidents

Reviews were conducted of the Ecological Incident Information System (EIIS, version 2.1.1), the Agency's Aggregated Incidents Reports database, and the Avian Incident Monitoring System (AIMS) on November 26, 2013.  No incidents were reported in AIMS.  One incident was reported in EIIS involving foraging bee mortality from direct spray in an orchard (it is not clear if the bees were directly sprayed); the product was not identified and the certainty of causation is unlikely.  One minor wildlife incident was reported for one of the assessed products (Coragen[(R)]) as well as another chlorantraniliprole containing product (Dupont DERMACOR X-100 Insect Control) in the aggregated incident database.  In addition, one "other non-target" species (i.e., not coded as plants or wildlife) incident was reported for Altacor[(R)] (the product with proposed commodity additions to already labeled crop groups) in the aggregated incident database.  Several minor plant incidents were reported in the aggregated incident database for a chlorantraniliprole containing product (Grubex) other than those considered in this assessment and one incident for application of chlorantraniliprole and sulfentrazone (product(s) not identified).  There was also one plant incident involving Grubex in the EIIS database (> 45% effects on plants for a residential application  -  certainty of causation is possible).

7.	Ecological Risk

7.1.	Terrestrial Organisms
      
There is not a risk concern for birds or mammals for the use on peanut or for the assessed multiple crop season uses.
      
      Terrestrial Invertebrates

As in past assessments, a risk concern for terrestrial invertebrates cannot be precluded.  The Agency currently does not have a quantitative method to assess risks of pesticides to non-target terrestrial invertebrates. However, it is a reasonable assumption that an insecticide would pose some direct risk to non-target terrestrial invertebrates, including insects.  Second, compared to the proposed application rates (0.065 - 0.099 lb ai/A single maximum rate; 0.2 - 0.8 lb ai/A annual rate), available toxicity data suggest potential direct effects to at least some non-target insects (e.g., LR50 for mortality was < 0.067 lb ai/A for hoverfly).  
      
      Terrestrial Plants

The LOC (1.0) was not exceeded for non-listed or listed monocots located in dry or semi-aquatic locations or from spray drift (RQs < 0.1) in previous assessments of the same application rates.  Toxicity has not been defined for dicots (EC25 undetermined and NOEC < 0.0167 lb/A in the available Tier II seedling emergence study).  At this time, risk cannot be precluded for dicots (listed and non-listed).  There is not a risk concern for monocots from the proposed use on peanut or the assessed multiple crop season uses.

7.2.	Aquatic Organisms

There is not a risk concern for fish (freshwater and marine/estuarine) or aquatic plants (vascular and non-vascular) for the proposed use on peanut or for the assessed multiple crop season uses.

      
      
      
      Aquatic Invertebrates

The acute listed species LOC (0.05) was exceeded for freshwater (RQ = 0.34) and marine/estuarine invertebrates (RQ = 0.09) for use on peanut.  For all crops with multiple crop seasons, the acute listed species LOC was exceeded for freshwater (RQ = 0.85-3.1) and marine/estuarine invertebrates (RQ = 0.25-0.91).  There is also an acute risk concern for non-listed aquatic invertebrate species (LOC = 0.5) for all multiple crop season uses except strawberry (non-listed acute LOC was not exceeded for marine/estuarine invertebrates).

There is not a chronic risk concern for aquatic invertebrates for use on peanut.  However, the chronic LOC (1.0) was exceeded for use on crops with multiple crop seasons: freshwater invertebrate chronic RQ = 2.2 - 8.1[4] and marine/estuarine chronic RQ = 0.4 - 1.5[4].   There is a chronic risk concern for aquatic invertebrates for all multiple crop season uses except strawberry (chronic LOC was not exceeded for marine/estuarine invertebrates).

8.	Endangered and Threatened Species 
 
Table 5 summarizes potential concerns for direct and indirect effects to federally-listed threatened and endangered species (i.e., listed species).

Table 5.  Potential Effects to Federally Listed Taxa
Listed Taxa
                                Direct Effects
                               Indirect Effects
Terrestrial and semi-aquatic plants - monocots
                                      No
                                    Yes[2]
Terrestrial and semi-aquatic plants - dicots
                                    Yes[1]
                                    Yes[2]
Terrestrial invertebrates
                                      Yes
                                   Yes[2,5]
Birds
                                      No
                                 Yes[2,3,4,5]
Terrestrial-phase amphibians
                                      No
                                 Yes[2,3,4,5]
Reptiles
                                      No
                                 Yes[2,3,4,5]
Mammals
                                      No
                                 Yes[2,3,4,5]
Aquatic vascular plants
                                      No
                                 Yes[2,3,4,5]
Freshwater fish
                                      No
                                   Yes[3,5]
Aquatic-phase amphibians
                                      No
                                   Yes[3,5]
Freshwater invertebrates
                                      Yes
                                   Yes[3,5]
Marine/estuarine fish
                                      No
                                   Yes[4,5]
Marine/estuarine invertebrates
                                      Yes
                                   Yes[4,5]
[1] insufficient data to preclude risk 
2 direct effects on terrestrial invertebrates 
3 direct effects on freshwater invertebrates (listed and non-listed)
4 direct effects on estuarine/marine invertebrates (listed and non-listed)
[5]direct effects on terrestrial dicots (listed and non-listed species)

                   Appendix 1.  Representative Model Output




