Based on possible endocrine related effects related to mammals ( via reproductive effects) MRID 116345 and MRID 42883603, MCPB may be classified as a potential endocrine disruptor. EPA is required under the Federal Food, Drug, and Cosmetic Act ( FFDCA), as amended by the Food Quality Protection Act ( FQPA), to develop a screening program to determine whether certain substances ( including all pesticide active and other ingredients) " may have an effect in humans that is similar to an effect produced by a naturally occurring estrogen, or other such endocrine effects as the Administrator may designate." Following the recommendations of its Endocrine Disruptor Screening and Testing Advisory Committee ( EDSTAC), EPA determined that there was a scientific basis for including, as part of the program, the androgen and thyroid hormone systems, in addition to the estrogen hormone system. EPA also adopted EDSTAC's recommendation that the Program include evaluations of potential effects in wildlife. For pesticide chemicals, EPA will use the Federal Insecticide, Fungicide, and Rodenticide Act ( FIFRA) and, to the extent that effects in wildlife may help determine whether a substance may have an effect in humans, FFDCA authority to require the wildlife evaluations. As the science develops and resources allow, screening of additional hormone systems may be added to the Endocrine Disruptor Screening Program ( EDSP). When the appropriate screening Page 50 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) and/ or testing protocols being considered under the Agency's EDSP have been developed, MCPB may be subjected to additional screening and/ or testing to better characterize effects related to endocrine disruption.

Terrestrial Non target Insects EFED currently does not quantify risks to terrestrial non target insects. Risk quotients are therefore not calculated for these organisms. MCPB was practically non toxic to honey bees ( LD 50 of > 23

g ae/ bee) in an acute contact study, but potential exposure has not been quantified.

Terrestrial Plants in Dryland and Semi aquatic Areas An analysis of the results indicates exceedance of the Acute Risk LOC for non endangered monocots and dicots located adjacent to treated areas, in semi aquatic areas, and as a result of spray drift. ( Table IV. g). The Endangered Species LOC was exceeded for monocots and dicots located in dryland and semi aquatic areas adjacent to treated areas and for dicots as a result of spray drift. The potential risk to endangered terrestrial plants will be discussed in greater detail in Section IV. B. 4.

In spite of the uncertainty in the magnitude of the EC 25 values used to calculate the RQs for MCPB, other data in the vegetative vigor studies indicate the potential for risk to nontarget dicots from spray drift alone. Using the spray drift model AgDrift, the distances were calculated at which exposure would be equivalent to the lowest application rates tested in the vegetative vigor study which led to adverse effects. This Tier 1 AgDrift assessment assumed a fine to medium droplet size spectrum, and an aerial application. Table IV. h. shows these rates for each crop, the level of effect seen at that rate, and the distance at which that deposition would occur.

TABLE IV. h.  Distance of Deposition of MCPB Equivalent to Rates Tested in Vegetative Vigor Study Crop Lowest Rate Tested with Adverse Effect ( lb ae/ acre) % Effect to Shoot Weight at that Rate Distance of Deposition at that Rate ( ft)

Cabbage 0.08 49 177 Lettuce 0.039 26 361 Soybean 0.17 53 85 Tomato 0.08 43 177 Highly active herbicides, such as the growth regulators, present the greatest drift hazard because extremely small amounts can cause severe problems. Even if only a small surface area of the plant is exposed to MCPB, or a seedling is exposed to MCPB as it breaks through the soil surface, there is a possibility that the plant may be severely damaged or die as a result. In the vegetative vigor test, effects observed included mortality ( one cucmber plant, two radish plants), leaf necrosis, decreased plant size, leaf curl, and stem tumors. Such damage, even if only minor, may be sufficient to prevent the plant from competing successfully with other plants for resources and water. Page 51 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Currently, the labels for the registered MCPB herbicides do not place restrictions on droplet size or wind speed during application. The exception is the state of Florida, which has promulgated a rule ( Organo Auxin Herbicide Rule) that stipulates that buffer zones up to a half mile wide be observed when spraying phenoxy herbicides. The width of the required buffer zone is dependent on the wind speed and direction, and whether aerial or ground spray equipment is used. This has the potential to reduce the exposure susceptible non target plants to spray drift. However, since the vegetative vigor tests could not determine a no effect application rate for MCPB, the effectiveness of these buffers to eliminate risk to plants cannot be evaluated.

Direct effects to plant species could result in indirect effects at the higher levels of organization ( i. e. population, trophic level, community, ecosystem). In terrestrial and shallow water aquatic communities, plants are the primary producers upon which the succeeding trophic levels depend. If the available plant material is impacted due to the effects of MCPB and MCPB sodium, this may have negative effects not only on the herbivores, but throughout the food chain. Also, depending on the severity of impacts to the plant communities ( edge and riparian vegetation), community assemblages and ecosystem stability may be altered ( i. e. reduced bird populations in edge habitats; reduced riparian vegetation resulting in increased light penetration and temperature in aquatic habitats). Furthermore, reduction of upstream riparian vegetation that would otherwise supply downstream habitats could result not only in a loss of a significant component of food for aquatic herbivores and detritivores, but also of habitat ( i. e. leaf packs, materials for case building for invertebrates). The assessment of risk to aquatic receptors will focus on freshwater systems and exclude saltwater/ estuarine systems based on the regional use patterns of the herbicide. Field studies are not available to quantify actual risk to plant and animal communities in edge and riparian habitats; however, the potential for adverse effects may occur.

3. Review of Incident Data: FIFRA 6( a)( 2) incident data add lines of evidence to provide evidence that the risk predictions from the screening level assessment are substantiated with actual effects in the field. No aquatic or terrestrial incidents have been reported to the Agency for MCPB as of March 1, 2005. The lack of reported incidents cannot be considered as evidence of lack of hazard. Incident reporting is a voluntary process. At the present time, the lack of mortality incidents in the Ecological Incident Information System ( EIIS) database cannot be considered as evidence of a lack of hazard to aquatic and/ or terrestrial organisms.

4. Federally Threatened and Endangered ( Listed) Species Concerns 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 collocated 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 Page 52 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) 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 which has the relatively highest potential exposure to the pesticide, and that exposures are likely to decrease with distance from the treatment area. Section II. A. 4. of this risk assessment presents the pesticide use sites that are used to establish initial collocation of species with treatment areas.

If the assumptions associated with the screening level action area result in RQs that are below the listed species LOCs, direct effects to listed species are not expected for that taxon. 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 addition, if no toxicity data are available on which to calculate RQs, then risk to listed species in a particular taxon cannot be dismissed.

If it is not possible to come to a " not likely to adversely affect" conclusion, additional information on the biology of listed species, the locations of these species, and the locations of use sites could be considered along with available information on the fate and transport properties of the pesticide 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.

Taxonomic Groups Potentially at Risk The preliminary risk assessment for endangered species indicates that MCPB exceeds the Endangered Species LOCs for the single application per year for peas with an application rate of 1.5 lbs ae/ acre: ° freshwater vascular plants ° small ( 20g), medium ( 100 g) and large birds ( 1000 g) feeding on short grass, tall grass, and broadleaf forage/ small insects; small birds feeding on fruit, pods, seeds, and large insects ° ( 15 and 35 g) mammals feeding on short grass; small mammals ( 15 g) feeding on broadleaf forage/ small insects. ° non target terrestrial plants  monocots and dicots adjacent to treated areas and semiaquatic

Discussion of Risk Quotients The Agency's LOC for listed freshwater vascular plants, birds, mammals, and non target terrestrial plants is exceeded for the use of MCPB as outlined in previous sections. Should estimated exposure levels occur in proximity to listed resources, the available screening level information suggests a potential concern for direct effects on listed species within Page 53 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) these taxonomic groups listed above associated with the use of MCPB as described in Section II. A. 4. The registrant must provide information on the proximity of Federally listed freshwater vascular plants, small and large birds, small mammals, and non target terrestrial plants to the MCPB use sites. This requirement may be satisfied in one of three ways: 1) having membership in the FIFRA Endangered Species Task Force ( Pesticide Registration [ PR] Notice 2000 2); 2) citing FIFRA Endangered Species Task Force data; or 3) independently producing these data, provided the information is of sufficient quality to meet FIFRA requirements. The information will be used by the OPP Endangered Species Protection Program to develop recommendations to avoid adverse effects to listed species.

Use of Probit Slope Response Relationship to Provide Information on the Endangered Species Levels of Concern The Agency uses the probit dose response relationship as a tool for providing additional information on the listed animal species acute levels of concern. The acute listed species LOCs of 0.1 and 0.05 are used for terrestrial and aquatic animals, respectively. As part of the risk characterization, an interpretation of acute LOCs for listed species is discussed. This interpretation is presented in terms of the chance of an individual event ( i. e., mortality or immobilization) should exposure at the estimated environmental concentration actually occur for a species with sensitivity to difenoconazole on par with the acute toxicity endpoint selected for RQ calculation. To accomplish this interpretation, the Agency uses the slope of the dose response relationship available from the toxicity study used to establish the acute toxicity measurement endpoints for each taxonomic group. The individual effects probability associated with the LOCs is based on the mean estimate of the slope and an assumption of a probit dose response relationship. In addition to a single effects probability estimate based on the mean, upper and lower estimates of the effects probability are also provided to account for variance in the slope. The upper and lower bounds of the effects probability are based on available information on the 95% confidence interval of the slope. A statement regarding the confidence in the applicability of the assumed probit dose response relationship for predicting individual event probabilities is also included. Studies with good probit fit characteristics ( i. e., statistically appropriate for the data set) are associated with a high degree of confidence. Conversely, a low degree of confidence is associated with data from studies that do not statistically support a probit dose response relationship. In addition, confidence in the data set may be reduced by high variance in the slope ( i. e., large 95% confidence intervals), despite good probit fit characteristics.

Individual effect probabilities are calculated based on an Excel spreadsheet tool IECV1.1 ( Individual Effect Chance Model Version 1.1) developed by the U. S. EPA, OPP, Environmental Fate and Effects Division ( June 22, 2004). The model allows for such calculations by entering the mean slope estimate ( and the 95% confidence bounds of that estimate) as the slope parameter for the spreadsheet. In addition, the LOC ( 0.1 for terrestrial animals and 0.05 for aquatic animals) is entered as the desired threshold.

Probit Slope Analysis Page 54 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) The probit slope response relationship is evaluated to calculate the change of an individual event corresponding to the listed species acute LOCs. If information is unavailable to estimate a slope for a particular study, a default slope assumption of 4.5 is used as per original Agency assumptions of typical slope cited in Urban and Cook ( 1986).

Freshwater Fish The following calculations were calculated by the probit method. Analysis of raw data from the rainbow trout LC 50 3.9 mg ae/ L study ( MRID 42532608) estimate a slope of 9.39( 95% C. I. 5.46 13.33) Based on this slope, and taking into account the RQs that occur for aquatic species at 1.5 ae/ A application rate for MCPB the individual mortality associated with the maximum calculated RQ value (. 01) results in an estimated chance of individual mortality of 1 in 1.00E + 16. RQ's exceedences do not occur for freshwater fish species at MCPB application 1.5 ae/ A. The corresponding estimated chance of individual mortality associated with the listed species LOC of 0.05 is 1 in 1.00E + 16.

Freshwater Invertebrates Analysis of raw data from the daphnid acute LC 50 50.0study ( MRID 42532602) estimates a slope of 9.22( 95% C. I. 5.41 13.03). Based on this slope, and taking into account the RQs that occur for aquatic species for MCPB at 1.5ae/ A application rate the individual mortality associated with the maximum calculated RQ values (. 01) result in an estimated chance of individual mortality of 1 in 1.00E + 16. RQ's exceedences do not occur for freshwater invertebrate species at 1.5 ae/ A application rate . The corresponding estimated chance of individual mortality associated with the listed species LOC of 0.05 is 1 in 1.00E + 16.

Estuarine and Marine Fish No probit dose can be determined due to lack of submitted data.

Estuarine and Marine Invertebrates No probit dose can be determined due to lack of submitted data.

Avian Analysis of raw data from the bobwhite quail LD50 257 study ( MRID 42560801) estimates a slope of 5.68 ( 95% C. I. 3.12  8.25). Based on this slope, and taking into account the RQs that occur for avian terrestrial species at MCPB application rate of 1.5ae/ A, the individual mortality associated with the maximum calculated RQ value ( 2.26) for a 20 gram bird eating short grass results is an estimated chance of individual mortality of 1 in 1.02E + 00 . RQ's exceedances do not occur for avian species at all food type scenarios. The corresponding estimated chance of individual mortality associated with the listed species LOC of 0.1 is 1 in 1.48E + 08.

Mammals Raw data is not provided in the rat acute LD 50 832 ae mg / kg bwt study ( MRID 116340) to calculate a slope. The default slope of 4.5 was used in the probit analysis. Based on this slope, and taking into account the RQs that occur for mammal terrestrial species at MCPB application Page 55 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) rate 1.5ae/ A , the individual mortality associated with the maximum RQ value ( 15 gram mammal and 35 gram mammal), respectively eating short grass, calculated RQ values (. 17 and .15) result in an estimated chance of individual mortality of 1 in 3.74E + 03 and 1 in 9.56E + 03, respectively. RQ's exceedences do not occur for mammal species at all food type scenarios. The corresponding estimated chance of individual mortality associated with the listed species LOC of 0.1 is 1 in 4.17E + 08.

Data Related to Under represented Taxa: Additional effects data from other analyzed sources ( ECOTOX Database) requires further evaluation for data related to underrepresented taxa and support study data for MCPB.

Implications of Sublethal Effects: Chronic studies were not available for freshwater and estuarine marine aquatic species and for birds. RQs did exceed Chronic LOCs for mammals in all weight classes ( 15 g, 35 g, and 1000g) for consumption of short grass, tall grass and broadleaf forage/ small insects and in 15 g and 35g mammals for consumption of fruit and large insects. Maternal toxicity observed in a rat developmental toxicity study ( MRID 40865402) included decreased body weight and body weight gain during gestation and developmental toxicity observed in the same study included decreased mean body weights/ litter, increases in unossified or poorly ossified sites, and skeletal variations. Maternal toxicity observed in a rabbit developmental toxicity study ( MRID 40865401) included death, clinical signs of toxicity, decrease in body weight gain, and change in color of liver and kidneys. It should be noted that in acute bird guideline studies, discolorations on several organs, including white areas/ film on the heart, liver, gizzard, gallbladder, crop and intestines were also observed. In addition, sublethal effects in subchronic feeding studies ( 13 weeks) with dogs included testicular and prostate atrophy and curtailment of spermatogenic activity ( MRID 116345); reduced testes weights and physiological changes in clinical chemistry ( MRID 42883603). The reproductive and developmental effects observed in these studies may lead to a potential concern for impacts to populations of mammals consuming feed items contaminated with MCPB and to the predators that feed on them.

Indirect Effects Analysis Acute Risk and Acute Restricted Use LOCs were exceeded for birds ( 20, 100, and 1000 g) consuming the various feed items and results of the probit dose analysis for bobwhite quail indicated a 1 in 15 chance of mortality based on the maximum use scenario EEC. Consequently, there may be a concern for potential indirect effects to listed species dependent upon birds that consume feed items ( short and tall grasses; broadleaf plants; small and/ or large insects; and fruits, seeds, and pods) contaminated with MCPB residues; such as predatory birds and mammals.

The Acute Risk LOCs for non target monocots and dicots were exceeded for plants located adjacent to treated areas and in semi aquatic areas. Exposure to MCPB results in direct effects to plant species that could result in indirect effects at the higher levels of organization ( i. e. population, trophic level, community, ecosystem). The guideline terrestrial plant studies indicate direct adverse effects to seedling emergence as well as non Page 56 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) lethal effects including brown leaf tips in cabbage, corn, onion, ryegrass, radish, and soybean; necrosis in corn, radish, onion, and soybean; chlorosis in onion, cucumber, and lettuce; stem tumors in soybean and tomato; leaf curl in tomato, and decrease in size in cabbage, cucumber, lettuce, onion, and ryegrass. In the guideline aquatic vascular plant studies, concentrations as low as 0.16 mg ae/ L resulted in chlorosis, curling, and decreased root formation in the plant. In terrestrial and shallow water aquatic communities, plants are the primary producers upon which the succeeding trophic levels depend.

If the available plant material is impacted due to the effects of MCPB, this may have negative effects not only on the herbivorous animals, but throughout the food chain. Also, depending on the severity of impacts to the plant communities ( edge and riparian vegetation), community assemblages and ecosystem stability may be altered ( i. e. reduced bird populations in edge habitats; reduced riparian vegetation resulting in increased light penetration and temperature in aquatic habitats). Furthermore, reduction of upstream riparian vegetation that would otherwise supply downstream habitats could result not only in a loss of a significant component of food for aquatic herbivores and detritivores, but also of habitat ( i. e. leaf packs, materials for case building for invertebrates). The assessment of risk to aquatic receptors both freshwater and saltwater/ estuarine systems is also of potential concern.

Critical Habitat In the evaluation of pesticide effects on designated critical habitat, consideration is given to the physical and biological features ( constituent elements) of a critical habitat identified by the U. S Fish and Wildlife and National Marine Fisheries Services as essential to the conservation of a listed species and which may require special management considerations or protection. The evaluation of impacts for a screening level pesticide risk assessment focuses on the biological features that are constituent elements and is accomplished using the screening level taxonomic analysis ( risk quotients, RQs) and listed species levels of concern ( LOCs) that are used to evaluate direct and indirect effects to listed organisms.

The screening level risk assessment has identified potential concerns for indirect effects on listed species for those organisms dependent upon birds, small mammals, aquatic vascular plants, and terrestrial and semi aquatic plants. In light of the potential for indirect effects, the next step for EPA and the Service( s) is to identify which listed species and critical habitat are potentially implicated. Analytically, the identification of such species and critical habitat can occur in either of two ways. First, the agencies could determine whether the action area overlaps critical habitat or the occupied range of any listed species. If so, EPA would examine whether the pesticide's potential impacts on non endangered species would affect the listed species indirectly or directly affect a constituent element of the critical habitat. Alternatively, the agencies could determine which listed species depend on biological resources, or have constituent elements that fall into, the taxa that may be directly or indirectly impacted by the pesticide. Then EPA would determine whether use of the pesticide overlaps the critical habitat or the occupied range of those listed species. At present, the information reviewed by EPA does not permit use of either analytical approach to make a definitive identification of species that are potentially impacted indirectly or critical habitats that is potentially impacted directly by the use of the pesticide. EPA and the Service( s) are working together to conduct the necessary analysis. Page 57 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) This screening level risk assessment for critical habitat provides a listing of potential biological features that, if they are constituent elements of one or more critical habitats, would be of potential concern. These correspond to the taxa identified above as being of potential concern for indirect effects and include the following: birds, small mammals, aquatic vascular plants, and terrestrial and semi aquatic plants. This list should serve as an initial step in problem formulation for further assessment of critical habitat impacts outlined above, should additional work be necessary.

Co occurrence Analysis Because the Endangered Species LOCs for freshwater vascular plants and for terrestrial monocots and dicots are exceeded for the use of MCPB, the LOCATES was run for all taxonomic groups. Therefore, a potential concern exists with species that are obligates and have very specific habitats or feeding requirements. For terrestrial monocots and dicots, both the Acute Risk LOCs for non endangered species and the Endangered Species LOCs were exceeded; consequently a potential concern arises for species with both narrow and general dependencies. In addition, Endangered Species LOCs were exceeded for small ( 20g) medium ( 100 g) and large birds ( 1000 g) feeding on short grass, tall grass, and broadleaf forage/ small insects; small birds feeding on fruit and large insects; small ( 15 and 35 g) mammals feeding on short grass; and small mammals ( 15 g) feeding on broadleaf forage/ small insects. Information from LOCATES, as presented in Table IV. i. below, indicates that several potentially affected species of birds, mammals and plants appear to be co located with pesticide use areas. Results of the probit dose analysis for bobwhite quail indicated a 1 in 15 chance of mortality based on the maximum use scenario EEC. Consequently, there may be a concern for potential indirect effects to listed species dependent upon birds that consume feed items ( short and tall grasses; broadleaf plants; small and/ or large insects; and fruits, seeds, and pods) contaminated with MCPB residues; such as predatory birds and mammals. In addition, there may be a potential concern for indirect effects related to plants that require birds and/ or mammals for pollination or seed dispersal and for animals that use burrows for shelter or breeding habitat. Results of this risk assessment indicate no direct risk to freshwater fish and invertebrates; however, these species may be dependent on aquatic plants for survival. Page 58 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Birds Mammals Reptiles Amphibians Fish Crustaceans Arachnids Insects Snails Clams Plants Table IV . i. Tabulation by taxonomic group and crop of listed species that occur in MCPB use areas summarized by Locates Taxonomic Group Peas ( all varieties) 48 38 21 10 39 11 1 27 10 37 350 Total States 39 36 12 5 22 5 1 14 5 20 37 C. Description of Assumptions, Limitations, Uncertainties, Strengths and Data Gaps Uncertainties, assumptions, and limitations associated with models Extrapolating the risk conclusions from the standard pond scenario modeled by PRZM/ EXAMS may either underestimate or overestimate the potential risks. Major uncertainties with the standard runoff scenario are associated with the physical construct of the watershed and representation of vulnerable aquatic environments for different geographic regions. The physicochemical properties ( pH, redox conditions, etc.) of the standard farm pond are based on a Georgia farm pond. These properties are likely to be regionally specific because of local hydrogeological conditions. Any alteration in water quality parameters may impact the environmental behavior of the pesticide. The farm pond represents a well mixed, static water body. Because the farm pond is a static water body ( no flow through), it does not account for pesticide removal through flow through or accidental water releases. However, the lack of water flow in the farm pond provides an environmental condition for accumulation of persistent pesticides. The assumption of uniform mixing does not account for stratification due to thermoclines ( e. g., seasonal stratification in deep water bodies). Additionally, the physical construct of the standard runoff scenario assumes a watershed: pond area ratio of 10. This ratio is recommended to maintain a sustainable pond in the Southeastern United States. The use of higher watershed: pond ratios ( as recommended for sustainable ponds in drier regions of the United States) may lead to higher pesticide concentrations when compared to the standard watershed: pond ratio.

The standard pond scenario assumes that uniform environmental and management conditions exist over the standard 10 hectare watershed. Soils can vary substantially across even small areas, and thus, this variation is not reflected in the model simulations. Additionally, the impact of unique soil characteristics ( e. g., fragipan) and soil management practices ( e. g., tile drainage) are not considered in the standard runoff scenario. The assumption of uniform site and management conditions is not expected to represent some site specific conditions. Extrapolating the risk conclusions from the standard pond scenario Page 59 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) to other aquatic habitats ( e. g., marshes, streams, creeks, and shallow rivers, intermittent aquatic areas) may either underestimate or overestimate the potential risks in those habitats.

Uncertainties and data gaps associated with the environmental fate and toxicity data There are a number of areas of uncertainty in the terrestrial and the aquatic organism risk assessments that could potentially cause an underestimation of risk. First, this assessment accounts only for exposure of non target organisms to MCPB, but not to its degradates. The risks presented in this assessment could be underestimated if degradates also exhibit toxicity under the conditions of use proposed on the label. Data are not available concerning the fate and toxicity of the photolytic degradation products of MCPB. MCPA is a degradation product of biodegradation in soil and this assessment provides available toxicity data for MCPA that indicates that the toxicity of MCPA acid is very similar to that of MCPB ( Reregistration Eligibility Decision for MCPA, 2004). Second, the risk assessment only considers the most sensitive species tested and only considers a subset of possible use scenarios. For the aquatic organism risk assessment, there are uncertainties associated with the PRZM/ EXAMS model, input values, and scenarios including the use of surrogate scenarios, however these uncertainties cannot be quantified. The potential impacts of these uncertainties are outlined in the Aquatic Exposure and Risk Assessment and the Terrestrial Exposure and Risk Assessment sections of this document.

Additional uncertainty results from the lack of information and/ or data in several components of this ecological risk assessment. First, MCPB chronic toxicity data for birds and aquatic organisms are not available, thus the potential risk due to prolonged exposures cannot be estimated. Second, data are unavailable concerning residue levels in foliage, flowers, and seeds to accurately predict potential risks to terrestrial organisms which may contact MCPB residues after application. Third, estuarine/ marine fish and invertebrate data are not available. Finally, aerobic and anaerobic aquatic metabolism and terrestrial field dissipation studies have not been submitted for MCPB. APPENDIX A: Environmental Fate Studies and Selected Chemical Structures Page 61 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Cl O OH O Cl O OO Na+

Cl O O OH MCPB ( acid)

MCPB ( sodium salt)

MCPA Page 62 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Cl O O OH HO Cl O O OH O O OH OH OH HO CHPA ( transient intermediate)

CHPA hexose conjugate Page 63 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Environmental Fate Studies Hydrolysis Das, Y. T. 1992. Hydrolysis of [ 14C] MCPB in aqueous solutions buffered at pH 5, 7 and 9. Unpublished study performed by Innovative Scientific Services, Inc., Piscataway, NJ and sponsored by Rhône Poulenc Agrochemie, Lyon Cedex, France. ISSI Study Number 92010; Rhone Poulenc Study Number 92 06. Study was initiated on February 17, 1992 and completed on September 23, 1992. MRID 42574301 The hydrolysis of [ phenyl U 14C] labeled ( 4( 2 methyl 4 chlorophenoxy) butyric acid ( MCPB), at 10.3 mg a. i/ L, was studied in the dark at 25 ± 1  C in sterile aqueous 0.1 M buffer solutions adjusted to pH 5 ( acetate), pH 7 ( phosphate) and pH 9 ( borate) for 30 days. The experiment was conducted in accordance with the US EPA Pesticide Assessment Guidelines, Subdivision N, Section 161 1 and in compliance with 40 CFR 160 ( FIFRA Good Laboratory Practice Standards). Samples were analyzed for MCPB and its transformation products without extraction or concentration using HPLC. Identification was made by comparison to unlabeled reference standards and confirmed by GC MS.

Total radiocarbon recovery in the pH 5 solution averaged ( n = 14) 99.8 ± 0.6% of the applied, in the pH 7 solution averaged 101.0 ± 0.4%, and in the pH 9 solution averaged 102.1 ± 0.4%. The concentration of [ 14C] MCPB decreased from 94.4% at day 0 to 91.5% of the applied at study termination in the pH 5 solution, from 95.8% to 91.9% at pH 7, and from 95.7% to 93.2% of the applied at pH 9. No major transformation product was detected in any of the pH solutions. Five [ 14C] compounds were isolated at maximum concentrations of 1.6 5.2% of the recovered; one was tentatively identified as 4( o tolyloxy) butyric acid. Volatiles were not measured. Half life values were not calculated. Since < 5% of the applied MCPB degraded during the 30 days, the slope of the regression line was not significantly different from zero ( a grossly extrapolated half life would be approximately 500 days).

Photolysis Das, Y. T. 1992. Photodegradation of [ 14C] MCPB in aqueous solutions buffered at pH 5, 7 and 9 under artificial sunlight. Unpublished study performed by Innovative Scientific Services, Inc., Piscataway, NJ and sponsored by Rhône Poulenc Agrochemie, Lyon Cedex, France. ISSI Study Number 92011; Rhone Poulenc Study Number 92 07. Study was initiated on February 17, 1992, and completed on September 23, 1992. MRID 42574302 The aqueous phototransformation of [ phenyl U 14C] labeled ( 4( 2 methyl 4 chlorophenoxy) butyric acid ( MCPB) was studied at 25 ± 1  C in sterile aqueous acetate, phosphate and borate buffer solutions at pH 5, 7 and 9, respectively at an initial concentration of 10.3 mg a. i/ L under irradiation using a filtered xenon arc lamp for 30 days ( 12 hours light/ 12 hours dark). Test vessels were not connected to traps for the collection of CO 2 and organic volatiles in the definitive study. Irradiated and dark control samples were sampled at 0, 1, 2, 3, 4, 7, 14 and 30 days; and 0, 1, 3, 7, 14, 21 and 30 days, respectively. Samples were analyzed for MCPB and its transformation products without extraction or concentration using HPLC. Identification was made by comparison to unlabeled reference standards and confirmed by GC MS. Page 64 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) In the irradiated samples, total radiocarbon recovery total radiocarbon recovery in the pH 5 solution averaged ( n = 14) 96.9 ± 1.6%, in the pH 7 solution averaged 98.3 ± 1.5%, and in the pH 9 solution averaged 99.3 ± 1.6% of the applied amount at pH 5, 7 and 9, respectively. The reviewer calculated concentrations of [ 14C] MCPB decreased from 94.4% at day 0 to 0.2% of the applied at day 30 in the pH 5 solution, from 95.9% to < 0.1% at pH 7, and from 95.7% to < 0.1% at pH 9. Five transformation products were isolated at > 10% of the applied: 4 ( 4 hydroxy otolyloxy butyric acid; 2,4 dihyroxyphenyl formate; o cresol; benzoic acid; and 2 hydroxyphenyl formate. 4( 4 Hydroxy o tolyloxy) butyric acid was a mean maximum of 32.0% of the applied at 4 days and decreased to 4.8% by 30 days in the pH 5 solution; was 27.5% at 7 days and decreased to 5.1% in the pH 7 solution; and was 17.4% at 30 days in pH 9 solution. 2,4 Dihyroxyphenyl formate was a maximum mean concentration of 39.5% of the applied at 30 days in the pH 5 solution; was 33.0 35.3% at 14 30 days in the pH 7 solution; and was 22.8% at 30 days in the pH 9 solution. o Cresol was a maximum mean concentration of 17.1%, 47.3% and 25.7% of the applied at 30 days in pH 5, 7 and 9 solutions, respectively. Benzoic acid was at a maximum mean concentration of 13.1% at 30 days inthe pH 5 solution, 1.6% at 7 days in the pH 7 solution, and 7.2% at 30 days in the pH 9 solution. 2 Hydroxyphenyl formate was a maximum mean concentration of 10.0%, 4.7% and 14.0% of the applied at 14 days in pH 5, 7 and 9 solutions, respectively, and decreased in all solutions by 30 days. There were two minor transformation products: 4( o tolyloxy) butyric acid at a maximum mean 1.5 2.5% of the applied and 4 chloro ocresol ( pH 5 and 9 only) at a maximum 3.6 5.1%. Volatiles were not measured. Eight unidentified [ 14C] compounds, each a maximum of  8.8% of the applied, totaled < 14.3% at all sampling intervals. Volatiles were not measured.

In the nonirradiated samples, total radiocarbon recovery in the pH 5 solution averaged ( n = 14) 99.8 ± 0.6% of the applied, in the pH 7 solution averaged 101.0 ± 0.4%, and in the pH 9 solution averaged 102.1 ± 0.4%. The reviewer calculated concentrations of [ 14C] MCPB decreased from 94.4% at day 0 to 91.5% of the applied at day 30 in the pH 5 solution, from 95.8% to 91.9% at pH 7, and from 95.7% to 93.2% of the applied at pH 9. No major transformation product was detected in any of the pH solutions. Fifteen [ 14C] compounds were isolated, of which five were detected at maximum concentrations of 1.6 5.2% of the recovered. Volatiles were not measured.

The half lives of MCPB in the irradiated pH 5, 7 and 9 buffer solutions were calculated assuming pseudo first order reaction kinetics. Respective values were determined to be 2.2, 2.6 and 2.4 days, respectively. There was no statistically significant difference between the rate of degradation at different pHs. Since there was no degradation in the dark control, the phototransformation halflives do not need to be adjusted for degradation in the controls. Likewise, since the wavelengths and intensity of the light source were equivalent to sunlight, no adjustments for light source are necessary.

Transformation Products: In the irradiated samples, five transformation products were isolated at > 10% of the applied: 4 ( 4 hydroxy o tolyloxy) butyric acid; 2,4 dihyroxyphenyl formate; o cresol; benzoic acid; and 2 hydroxyphenyl formate. 4( 4 Hydroxy o tolyloxy) butyric acid was a mean maximum of 32.0% of the applied at 4 days and decreased to 4.8% by 30 days in the pH 5 solution; was 27.5% at 7 days and decreased to 5.1% in the pH 7 solution; and was 17.4% at 30 days in pH 9 solution. 2,4 Dihyroxyphenyl formate was a maximum mean concentration of 39.5% of the applied at 30 days in the pH 5 solution; was 33.0 35.3% at 14 30 days in the pH 7 solution; and was 22.8% at 30 days in the pH 9 solution. o Cresol was a maximum mean concentration of Page 65 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) 17.1%, 47.3% and 25.7% of the applied at 30 days in pH 5, 7 and 9 solutions, respectively. Benzoic acid was at a maximum mean concentration of 13.1% at 30 days in the pH 5 solution, 1.6% at 7 days in the pH 7 solution, and 7.2% at 30 days in the pH 9 solution. 2 Hydroxyphenyl formate was a maximum mean concentration of 10.0%, 4.7% and 14.0% of the applied at 14 days in pH 5, 7 and 9 solutions, respectively, and decreased in all solutions by 30 days. There were two minor transformation products: 4( o tolyloxy) butyric acid at a maximum mean 1.5 2.5% of the applied and 4 chloro o cresol ( pH 5 and 9 only) at a maximum 3.6 5.1%. Volatiles were not measured. Eight unidentified [ 14C] compounds, each a maximum of  8.8% of the applied, totaled < 14.3% at all sampling intervals. Volatiles were not measured.

In the non irradiated samples, no major transformation product was detected in any of the pH solutions. Fifteen [ 14C] compounds were isolated, of which five were detected at maximum concentrations of 1.6 5.2% of the recovered. Volatiles were not measured.

Pathway: It was proposed that at all pHs, MCPB was dechlorinated then hydroxylated, resulting in the formation of 4( 4 hydroxy o tolyloxy) butyric acid ( p. 33, Figure 80, p. 138, MRID 42574302).

Aqueous Photolysis Summary Half lives for irradiated samples: 2.2 days ( pH 5), 2.6 days ( pH 7) and 2.4 days ( pH 9)

Major identified transformation products: 4( 4 hydroxy o tolyloxy) butyric acid, 2,4 dihyroxyphenyl formate, o cresol, benzoic acid and 2 hydroxyphenyl formate.

Minor identified transformation products: 4( o tolyloxy) butyric acid and 4 chloro o cresol.

Adsorption/ Desorption in Soil Robson, M. M. 1993. Determination of adsorption/ desorption characteristics of 4( 2 methyl, 4 chlorophenoxy) butyric acid ( MCPB) in soil. Unpublished study performed by Hazleton UK, North Yorkshire, England. HUK Study No. 68/ 127. Study sponsored by Rhône Poulenc Agriculture, Essex, England. Study initiated April 3, 1992 and completed February 10, 1993. MRID 42693701 The adsorption/ desorption characteristics of phenyl ring labeled [ 14C] MCPB ( 4( 2 methyl 4 chlorophenoxy) butyric acid dissolved in methanol was studied in sterile sandy clay loam soil [ pH 6.09, organic carbon  1.3%] from France, and the following three soils and one sediment from England: sand soil [ pH  7.93, organic carbon  0.53%], sandy loam soil [ pH  6.08, organic carbon  0.76%], clay loam soil [ pH  7.6, organic carbon  2.49%], and sandy loam aquatic sediment [ pH  5.95, organic carbon  2.85%] in a batch equilibrium experiment. The soils and sediment were sterilized using gamma irradiation ( 25 kGy). The adsorption phase of the study was carried out by equilibrating sterilized soil with [ 14C] MCPB at nominal concentrations of 0.04, 0.2, 1.0, and 5.0

g/ mL at ambient temperature ( 19 23  C) for 48 hours; lighting conditions were not reported. The equilibrating solution used was 0.01 M CaCl 2, with soil/ solution ratios of 1: 5 ( w: v) for the four soils and one sediment. The desorption phase of the study was carried out by replacing the adsorption solution with an equivalent volume of sterilized, pesticide free 0.01 M Page 66 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) CaCl 2 solution and equilibrating once for 48 hours at 19 23  C. The desorption phase was conducted once.

After 48 hours of equilibration, 0.33 13.99, 0.05 11.20, 0.09 11.99, 0.13 11.11, and 0.69 76.33

g/ g of the applied [ 14C] MCPB was adsorbed to the sandy clay loam, sand, sandy loam, and clay loam soils and sediment, respectively. The mean adsorption K ads values were 1.69, 0.26, 0.65, 0.78, and 10.58 mL/ g for the sandy clay loam, sand, sandy loam, and clay loam soils and sandy loam sediment, respectively. Adsorption K oc values were 129.57, 47.91, 85.54, 31.27, and 371.17 mL/ g for the sandy clay loam, sand, sandy loam, and clay loam soils and sandy loam sediment, respectively. At the end of the desorption, 64.0%, 32.18%, 60.22%, 60.59%, and 24.63% of the adsorbed amount was desorbed in the sandy clay loam, sandy, sandy loam, and clay loam soils and sandy loam sediment, respectively. The desorption K oc and K d values were not provided.

Anaerobic Biotransformation in Soil Goodyear, A. 1993. ( 14C) MCPB: anaerobic soil metabolism. Unpublished study performed by Hazleton UK, North Yorkshire, England, and sponsored by MCPB Task Force, c/ o Rhône Poulenc Agricultural Limited, Essex, England. Laboratory Study No. 68/ 131 and Report No. 68/ 131 1015. MRID 43015501 The biotransformation of [ phenyl U 14C] labeled ( 4( 2 methyl 4 chlorophenoxy) butyric acid ( MCPB) was studied in sandy loam soil ( pH in water 7.7, organic carbon 0.3%) incubated for 62 days under anaerobic conditions ( flooding plus nitrogen atmosphere) in darkness at 25 ± 1  C following 4 days of aerobic incubation. [ 14C] MCPB was applied at a nominal rate of 3.4 mg a. i./ kg soil ( equivalent to 3.8 kg a. i./ ha). Soil samples were analysed after 0 and 4 days of aerobic incubation and after 8, 14, 29 and 62 days of anaerobic incubation ( 12, 18, 33 and 66 days posttreatment).

Overall material balance averaged 99.6 ± 5.9% ( range 91.1 110.3%, n = 2) of the applied radioactivity, with material balances declining from 109.6 ± 0.7% at day 0 to 91.7 ± 0.6% ( 91.1 92.3%) after 29 days of anaerobic incubation ( 33 days posttreatment), then increasing to 96.2 ± 0.5% after 62 days ( 66 days posttreatment, final sampling interval). Distribution ratios for [ 14C] residues between the soil and water layer were 5: 1 after 8 days of anaerobic incubation, 10: 1 after 29 days and 7: 1 after 62 days ( Attachment 2).

In the sandy loam soil: water systems, [ 14C] MCPB decreased from an average 40.9 ± 2.6% of the applied at 4 days posttreatment just prior to flooding to 17.7 ± 1.8% after 14 days of anaerobic incubation ( 18 days posttreatment) and 7.8 ± 0.1% after 29 days ( 33 days posttreatment), then increased to 22.5 ± 4.9% after 62 days ( 66 days posttreatment). [ 14C] MCPB in the soil decreased from 106.3 ± 0.0% of the applied at day 0 to 40.9 ± 2.6% at 4 days just prior to flooding, 17.0 ± 2.3% after 8 days of anaerobic incubation, 3.0 ± 0.7% after 29 days, then increased to 14.2 ± 1.5% after 62 days. [ 14C] MCPB in the water decreased from 11.9 ± 5.0% of the applied after 8 days of anaerobic incubation ( 12 days post.) to 4.7 ± 0.7% after 29 days, then increased to 8.3 ± 3.4% after 62 days.

The major transformation product of [ 14C] MCPB was ( 4 chloro 2 methylphenoxy) acetic acid ( MCPA) detected at maximums of 34.8% in the soil at 4 days just prior to flooding, 33.4% in the water after 14 days of anaerobic incubation, and 46.9% in the total soil: water system after 29 days. Page 67 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) After 62 days of anaerobic incubation, [ 14C] MCPA was 6.6 ± 2.1% of the applied in the soil, 27.8 ± 4.8% in the water and 34.3 ± 2.7% in the entire soil: water system.

Half life: Half life values of [ phenyl U 14C] MCPB in the total soil: water system were determined by the registrant using linear regression analysis and the Timme Freshe square root of first order decay model of the mean [ 14C] MCPB recovered at the 8, 14 and 33 day anaerobic intervals ( 12 to 33 day posttreatment intervals; pp. 25, 28, 31, see Reviewer's Comment no. 1). Half life values of [ 14C] MCPB in the water, soil and entire system were determined by the Dynamac reviewer using least squares linear regression analysis, based on first order kinetics, of [ 14C] MCPB recovered in each sample as calculated by Corel Quattro Pro 8 software ( Attachment 2).

Table 7: Half life ( t 1/ 2) values of MCPB in sandy loam soil under 62 days of anaerobic conditions following 4 days of aerobic incubation.

Regression Equation System Intervals used ( days posttreatment) half life ( days)

t1/ 2 r2 First Order  linear least squares regression. Linear form y = mx + b as lnC=  kt + lnC0; lnC0 is initial concentration ( b = y intercept), lnC is concentration at time t ( y), k is the slope ( m), t is time ( x) or kt = lnC0  lnC. Half life ( t ½ ) = ( ln 2/ k). water 12 33 18.9 0.520 soil 4 33 7.8 0.975 entire system 4 33 11.9 0.946 entire system 12 33 11.4 0.996 Timme Freshe  computer model fits data to 1st, 1.5 and 2nd order decay curves; a square root of the 1st order decline curve was utilized. entire system 12 33 9.5 not reported Transformation Products: The major transformation product of [ 14C] MCPB was ( 4 chloro 2 methylphenoxy) acetic acid ( MCPA) detected at maximums of 34.8% in the soil at 4 days just prior to flooding, 33.4% in the water after 14 days of anaerobic incubation, and 46.9% in the total soil: water system after 29 days ( pp. 41 43). After 62 days of anaerobic incubation, [ 14C] MCPA was 6.6 ± 2.1% ( 4.5 8.6%) of the applied in the soil, 27.8 ± 4.8% ( 23.0 32.6%) in the water, and 34.3 ± 2.7% ( 31.6 37.0%) in the entire system.

Aerobic Soil Biotransformation John, A., et al. 1994. MCPB: aerobic soil metabolism. Unpublished study performed and sponsored by MCPB Task Force, c/ o Rhône Poulenc Agricultural Limited, Essex, England. Laboratory Project and Study ID: P 93/ 194. MRID 43247601 The biotransformation of [ phenyl U 14C] labeled ( 4( 2 methyl 4 chlorophenoxy) butyric acid ( MCPB) was studied in sandy loam soil ( pH in water 5.38, organic carbon 2.3%) from the United Kingdom for 120 days under aerobic conditions in darkness at 22 ± 1  C and soil moisture of 75% of 1/ 3 bar. [ 14C] MCPB was applied at a nominal rate of 3.4 mg a. i./ kg soil ( equivalent to 3.8 kg a. i./ ha). The test system consisted of flasks ( not described) containing treated soil attached in Page 68 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) series to a flow through apparatus with traps for the collection of CO 2 and volatile organics. Soil samples were analysed after 0, 1, 3, 8, 15, 21, 29, 65, 90 and 120 days of incubation.

The major transformation product of [ 14C] MCPB was volatilized 14CO 2 which increased to a maximum 64.9 ± 0.6% of the applied at 65 days and was 54.5 61.8% at 90 120 days; no organic volatiles were detected. Two minor transformation products identified in soil extracts were the hexose conjugate of ( 4 chloro 2 methylphenoxy) 2   glucopyranoside acetic acid minor ( CHPA) and ( 4 chloro 2 methylphenoxy) acetic acid ( MCPA), which were each detected at maximums of 9.5% ( 8 days) and 7.2% ( 15 days) of the applied radioactivity, respectively, with both decreasing to  2.1% by 120 days. Five unidentified [ 14C] compounds ( Metabolites 3 7) were each  5.3% of the applied at any sampling interval. Extractable [ 14C] residues decreased from 99.7 ± 1.9% of the applied at day 0 to 4.9 5.8% at 65 120 days. Non extractable residues increased from 1.0% at day 0 to 41.5 ± 1.3% at 29 days, then gradually decreased to 30.9 ± 0.2% at 120 days. In 8 and 120 day extracted soil, 6.2 9.5%, 9.9 13.8%, and 7.7 10% of the applied was associated with the fulvic acid, humic acid, and humin fractions, respectively.

Soil type: United Kingdom ( Essex) sandy loam. First order half life for parent MCPB*: 18 days ( data from 0 120 days) Combined first order half life for MCPB, MCPA, and CHPA hexose conjugate: 26 days ( data from 0 120 days)

* Note: There was an error in the calculation of half life of MCPB in the original Data Evaluation Report ( DER). In the original DER the half life for the 120 day period was incorrectly calculated to be approximately 27 days.

Major transformation product: CO 2.

Minor transformation products: ( 4 Chloro 2 methylphenoxy) acetic acid ( MCPA) ( 4 chloro 2 methylphenoxy) 2   glucopyranoside acetic acid ( CHPA, as hexose conjugate) Five unidentified [ 14C] compounds.

A biotransformation pathway for the degradation of MCPB in aerobic soil was proposed by the registrant ( p. 42). The putative path was MCPB degradation to ( 4 chloro 2 methylphenoxy) acetic acid ( MCPA), which degrades to ( 4 chloro 2 methylphenoxy) 2   glucopyranoside acetic acid minor ( CHPA) and conjugates with hexose. There was significant production of CO 2 and soil bound residues.

Soil Leaching John, A. E., M. K. Jones and P. Lowden. 1994. MCPB: Fresh and aged leaching study in five soils. Laboratory Project ID. P 92/ 333. Unpublished study performed and submitted by Rhône Poulenc Agriculture Limited, Essex, England. Laboratory Project ID: P 92/ 333. MRID 43466401 Page 69 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) This column leaching study was previously considered supplemental because the CEC of the test soils and sediment was not reported, and, for the aging portion of the study, degradates were not identified after aging and prior to leaching. In the course of the current fate assessment, we again evaluated the results of this study for possible utility in characterization of mobility. We noted that missing from the report was the concentration of MCPB, if any, in any of the leachates. Therefore, although ostensible K d values were reported in the study, it is unclear what these values and their method of computation represent or whether these reasonably approximate equilibrium values. Therefore, the reported K d values are presently of indeterminate value. However, since the Agency does not rely on column leaching studies for quantitative exposure assessments, and since we do have an acceptable batch equilibrium study ( see adsorption desorption study above, MRID 42693701), which is the preferred method for quantitative modeling purposes, results from the column leaching study are not needed for MCPB. Therefore, if the registrant so chooses, no further work is required for this study. APPENDIX B: Aquatic Exposure Model Results Page 71 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Aquatic Exposure Modeling PRZM 3.12 and EXAMS 2.98 models in tandem Aquatic exposure concentrations for MCPB in the standard field pond were estimated using the PRZM 3.12 and EXAMS 2.98 models in tandem. PRZM/ EXAMS is a Tier II screening model designed to estimate pesticide concentrations found in water at the edge of a treated field. As such, it provides high end values of the pesticide concentrations that might be found in ecologically sensitive environments following pesticide application.

PRZM/ EXAMS is a multi year runoff model that also accounts for spray drift from single and multiple applications. In the ecological exposure assessment, PRZM/ EXAMS simulates a 10 hectare ( ha) field immediately adjacent to a 1 ha pond, 2 meters deep with no outlet. The geographic location of the field is specific to the crop being simulated using site specific information on the soils, weather, cropping, and management factors associated with the scenario. The crop/ location scenario is intended to represent a high end vulnerable site on which the crop is normally grown. Based on historical rainfall patterns, the pond receives multiple runoff events during the years simulated.

Acute risk assessments are performed using 1 in 10 year peak EEC values for single applications of MCPB. Chronic risk assessments for aquatic invertebrates and fish are performed using the average 21 day and 60 day EECs, respectively.

Table B. 1. presents the input parameters used in the Tier II PRZM/ EXAMS modeling for ecological assessment of MCPB for surface water sources. To simulate field application of MCPB to peas, two scenarios were selected representing different MCPB usage areas based on geography and weather. A California lettuce and an Oregon snap bean scenario were chosen as representative of the agricultural practices and areas in which peas are grown. The EECs for the two scenarios are presented in Table B. 2. The Oregon scenario represents the typical use of MCPB application to peas, and the California scenario represents a reasonable upper bound estimate. Results for the two cases are similar. We also investigated several other possible scenarios ( approximately six others), and found all EECs to be rather tightly grouped in a range from approximately 15 to 40 µ g ae/ L. The PRZM/ EXAMS input and output files from the California and Oregon aquatic ecological exposure assessments for aerial and ground applications are presented in Tables B. 3., B. 4., B. 5. and B. 6. Page 72 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) TABLE B. 1. PRZM/ EXAMS Input Parameters for MCPB.

Model Parameter Value Comments Source Application Rate per Event 1.68 kg ae/ acre ( 1.5 lbs ae/ acre) application to peas by ground and aerial spray application Label Number of Applications per Crop Season 1 application per year; assumes one planting season per year Label Spray Application Efficiencies ground aerial 0.99 0.95 EFED Guidance, 2002 Spray Drift Fraction ground aerial 0.01 0.05 EFED Guidance, 2002 Aerobic Soil Metabolism t ½ 78 days 1 estimated upper 90 th percentile MRID 43247601 Anaerobic Soil Metabolism t ½ 34 days 2 estimated upper 90 th percentile MRID 43015501 Aerobic Aquatic Degradation t ½ 156 days 3 estimated ( 2x aerobic soil metabolism half life) EFED Guidance, 2002 Anaerobic Aquatic Degradation t ½ 68 days 4 estimated ( 2x anaerobic soil metabolism half life) EFED Guidance, 2002 Aqueous Photolysis t ½ 2.6 days pH 7 MRID 42574302 Hydrolysis t ½ stable MRID 42574301 Kd/ Koc 0.85 mL/ g 5 Average Kd MRID 42693701 Molecular Weight 228.6 Chemical Formula Water Solubility 600 mg/ L 10 x solubility Product Chemistry Vapor Pressure 4.0E 7 torr Product Chemistry Henry's Law Constant ( estimated at 25

C) 3.42 x 10 9 atmm3 mol ( Howard and Meylan, 1997)

1 Upper 90th Percentile based on three times the single value for the combined/ total aerobic soil metabolism half life of 26 days for MCPB, MCPA, and CHPA/ CHPA hexose conjugate. 2 Upper 90th Percentile based on three times the single anaerobic soil metabolism half life of 11.4 days. 3 2x aerobic soil metabolism half life ( EFED Modeling Input Parameter Guidance, 2002).

4 2x anaerobic soil metabolism half life ( EFED Modeling Input Parameter Guidance, 2002). 5 From adsorption/ desorption data including Kd values of 1.69, 0.26, 0.65, and 0.78 mL/ g from MRID 42693701. Page 73 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) TABLE B. 2. Estimated Environmental Concentrations ( µ g ae/ L) of MCPB + Metabolites ( MCPA and CHPA/ CHPA hexose) in Surface Water ( PRZM EXAMS) from All Uses for Ecological Assessment.

Simulation Scenario Concentration ( µ g ae/ L)

Crop and Location Application rate 1 in 10 year Peak 21 Day Max. 60 Day Max.

Lettuce ( CA) ( Surrogate for Peas) 1.5 lbs ae/ acre ( 1.68 kg ae/ ha) ground spray aerial spray 40.4 43.2 39.0 41.7 36.4 38.9 Snap Beans ( OR) ( Surrogate for Peas) 1.5 lbs ae/ acre ( 1.68 kg ae/ ha) ground spray aerial spray 29.5 33.1 29.0 32.5 28.1 31.5 The following surrogate scenarios are among those available in PRZM/ EXAMS to simulate peas grown in different regions of the US: California lettuce scenario represents a reasonable upper bound estimate for areas in which peasare or may be grown. Oregon snap bean scenario represents a typical use scenario for areas in which peas are grown. Page 74 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) TABLE B. 3. Prism/ Exams Output California Lettuce Scenario Aerial Application stored as MCPBCAa1. out Chemical: MCPB_ CA_ lettuce_ NEW_ aerial PRZM environment: CAlettuceC. tx t modified Monday, 11 October 2004 at 16: 23: 40 EXAMS environment: pond298. exv modified Thuday, 29 August 2002 at 16: 33: 30 Metfile: w23273. dvf modified Wedday, 3 July 2002 at 09: 04: 22 Water segment concentrations ( ppb)

Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1961 4.2 4.154 4.051 3.799 3.598 2.235 1962 7.448 7.396 7.179 6.72 6.385 4.147 1963 24.08 23.9 23.18 22.21 21.21 12.61 1964 15.23 15.12 14.82 14.03 13.37 9.328 1965 8.774 8.711 8.525 8.26 7.947 5.532 1966 6.675 6.625 6.416 5.967 5.65 3.851 1967 9.819 9.748 9.562 9.12 8.687 5.602 1968 13.05 12.94 12.55 11.75 11.11 6.992 1969 10.97 10.88 10.52 9.773 9.254 6.351 1970 29.48 29.23 28.21 26.09 24.69 14.91 1971 11.81 11.73 11.37 10.77 10.42 8.076 1972 7.908 7.846 7.591 7.05 6.668 4.785 1973 11.5 11.45 11.11 10.35 9.881 6.413 1974 45.33 45.09 44.28 41.48 39.31 23.36 1975 25.37 25.19 24.46 22.86 21.7 14.91 1976 16.15 16.03 15.51 14.69 14.09 9.64 1977 20.08 19.92 19.27 18.11 17.72 11.5 1978 30.72 30.48 29.77 27.78 26.28 16.12 1979 12.8 12.74 12.38 11.89 11.47 8.159 1980 11.46 11.37 11.05 10.29 9.765 6.318 Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1981 47.84 47.48 46.21 43.17 40.99 23.96 1982 17.61 17.49 17.07 16.2 15.56 11.28 1983 23.98 23.83 23.12 21.61 20.49 12.42 1984 10.05 9.973 9.658 9.242 8.776 5.989 1985 7.51 7.455 7.232 6.807 6.468 4.185 1986 18.29 18.17 17.72 16.68 15.83 9.474 1987 44.61 44.39 43.06 40.08 37.91 22.61 1988 19.15 19.01 18.5 17.25 16.29 12.38 1989 10.12 10.07 9.77 9.091 8.599 6.005 1990 6.794 6.744 6.54 6.095 5.776 3.858 Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly Page 75 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) 0.032258065 47.84 47.48 46.21 43.17 40.99 23.96 0.064516129 45.33 45.09 44.28 41.48 39.31 23.36 0.096774194 44.61 44.39 43.06 40.08 37.91 22.61 0.129032258 30.72 30.48 29.77 27.78 26.28 16.12 0.161290323 29.48 29.23 28.21 26.09 24.69 14.91 0.193548387 25.37 25.19 24.46 22.86 21.7 14.91 0.225806452 24.08 23.9 23.18 22.21 21.21 12.61 0.258064516 23.98 23.83 23.12 21.61 20.49 12.42 0.290322581 20.08 19.92 19.27 18.11 17.72 12.38 0.322580645 19.15 19.01 18.5 17.25 16.29 11.5 0.35483871 18.29 18.17 17.72 16.68 15.83 11.28 0.387096774 17.61 17.49 17.07 16.2 15.56 9.64 0.419354839 16.15 16.03 15.51 14.69 14.09 9.474 0.451612903 15.23 15.12 14.82 14.03 13.37 9.328 0.483870968 13.05 12.94 12.55 11.89 11.47 8.159 0.516129032 12.8 12.74 12.38 11.75 11.11 8.076 0.548387097 11.81 11.73 11.37 10.77 10.42 6.992 0.580645161 11.5 11.45 11.11 10.35 9.881 6.413 0.612903226 11.46 11.37 11.05 10.29 9.765 6.351 0.64516129 10.97 10.88 10.52 9.773 9.254 6.318 0.677419355 10.12 10.07 9.77 9.242 8.776 6.005 0.709677419 10.05 9.973 9.658 9.12 8.687 5.989 0.741935484 9.819 9.748 9.562 9.091 8.599 5.602 0.774193548 8.774 8.711 8.525 8.26 7.947 5.532 0.806451613 7.908 7.846 7.591 7.05 6.668 4.785 0.838709677 7.51 7.455 7.232 6.807 6.468 4.185 0.870967742 7.448 7.396 7.179 6.72 6.385 4.147 0.903225806 6.794 6.744 6.54 6.095 5.776 3.858 0.935483871 6.675 6.625 6.416 5.967 5.65 3.851 0.967741935 4.2 4.154 4.051 3.799 3.598 2.235 0.1 43.221 42.999 41.731 38.85 36.747 21.96 1 Average of yearly averages: 9.766 667 Inputs generated by pe4. pl  8 August 2003 Data used for this run: Output File: MCPBCAa1 Metfile: w23273. dvf PRZM scenario: CAlettuceC. txt EXAMS environment file: pond298. ex v Chemical Name: MCPB_ CA_ lettuce_ NEW_ aerial Description Variable Name Value Units Comments Molecular weight mwt 228.6 g/ mol Henry's Law Const. henry 3.42E 09 atm m^ 3/ mol Page 76 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Vapor Pressure vapr 4.00E 07 torr Solubility sol 600 mg/ L Kd Kd 0.85 mg/ L Koc Koc mg/ L Photolysis half life kdp 2.6 days Half life Aerobic Aquatic Metabolism kbacw 156 days Halfife Anaerobic Aquatic Metabolism kbacs 68 days Halfife Aerobic Soil Metabolism asm 78 days Halfife Hydrolysis: pH 7 0 days Half life Method: CAM 1 integer See PRZM manual Incorporation Depth: DEPI 0 cm Application Rate: TAPP 1.68 kg/ ha Application Efficiency: APPEFF 0.95 fraction Spray Drift DRFT 0.05 fraction of application rate applied to pond Application Date Date 3 Jan dd/ mm or dd/ mmm or dd mm or ddmmm 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 77 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) TABLE B. 4. Prism/ Exams Output California Lettuce Scenario Ground Application stored as MCPBCAg1. out Chemical: MCPB_ CA_ lettuce_ NEW_ ground PRZM environment: CAlettuceC. txt modified Monday, 11 October 2004 at 16: 23: 40 EXAMS environment: pond298. exv modified Thuday, 29 August 2002 at 16: 33: 30 Metfile: w23273. dvf modified Wedday, 3 July 2002 at 09: 04: 22 Water segment concentrations ( ppb)

Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1961 2.02 2.008 1.949 1.406 1.06 0.6341 1962 3.426 3.402 3.304 3.081 2.919 1.995 1963 20.89 20.73 20.1 19.2 18.35 10.65 1964 11.66 11.57 11.27 10.71 10.21 7.169 1965 4.57 4.546 4.469 4.335 4.227 3.181 1966 2.199 2.183 2.116 1.972 1.869 1.471 1967 5.77 5.728 5.612 5.408 5.165 3.271 1968 9.071 9 8.728 8.212 7.771 4.791 1969 7.345 7.287 7.046 6.54 6.191 4.118 1970 26.08 25.85 24.95 23.06 21.79 13.06 1971 8.319 8.262 8.024 7.522 7.411 5.876 1972 3.499 3.473 3.364 3.131 3.072 2.473 1973 7.576 7.542 7.32 6.806 6.437 4.151 1974 42.5 42.29 41.57 38.96 36.93 21.79 1975 21.81 21.65 21.03 19.66 18.67 12.97 1976 12.12 12.03 11.65 11.11 10.7 7.54 1977 16.53 16.4 15.85 14.95 14.76 9.52 1978 27.41 27.19 26.6 24.83 23.49 14.34 1979 9.092 9.046 8.786 8.236 7.981 6.015 1980 7.354 7.298 7.085 6.607 6.276 4.096 1981 45.23 44.89 43.69 40.82 38.72 22.5 1982 13.96 13.86 13.53 12.7 12.48 9.261 1983 20.3 20.17 19.58 18.31 17.35 10.48 1984 6.079 6.034 5.845 5.528 5.353 3.885 1985 3.34 3.316 3.218 3 2.85 1.964 1986 14.67 14.57 14.21 13.34 12.67 7.416 1987 41.87 41.67 40.42 37.63 35.59 21.06 1988 16.17 16.05 15.6 14.55 13.75 10.44 1989 6.001 5.961 5.795 5.463 5.496 3.79 1990 2.415 2.398 2.328 2.173 2.065 1.571 Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly Page 78 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) 0.032258 45.23 44.89 43.69 40.82 38.72 22.5 0.064516 42.5 42.29 41.57 38.96 36.93 21.79 0.096774 41.87 41.67 40.42 37.63 35.59 21.06 0.129032 27.41 27.19 26.6 24.83 23.49 14.34 0.16129 26.08 25.85 24.95 23.06 21.79 13.06 0.193548 21.81 21.65 21.03 19.66 18.67 12.97 0.225806 20.89 20.73 20.1 19.2 18.35 10.65 0.258065 20.3 20.17 19.58 18.31 17.35 10.48 Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.290323 16.53 16.4 15.85 14.95 14.76 10.44 0.322581 16.17 16.05 15.6 14.55 13.75 9.52 0.354839 14.67 14.57 14.21 13.34 12.67 9.261 0.387097 13.96 13.86 13.53 12.7 12.48 7.54 0.419355 12.12 12.03 11.65 11.11 10.7 7.416 0.451613 11.66 11.57 11.27 10.71 10.21 7.169 0.483871 9.092 9.046 8.786 8.236 7.981 6.015 0.516129 9.071 9 8.728 8.212 7.771 5.876 0.548387 8.319 8.262 8.024 7.522 7.411 4.791 0.580645 7.576 7.542 7.32 6.806 6.437 4.151 0.612903 7.354 7.298 7.085 6.607 6.276 4.118 0.645161 7.345 7.287 7.046 6.54 6.191 4.096 0.677419 6.079 6.034 5.845 5.528 5.496 3.885 0.709677 6.001 5.961 5.795 5.463 5.353 3.79 0.741935 5.77 5.728 5.612 5.408 5.165 3.271 0.774194 4.57 4.546 4.469 4.335 4.227 3.181 0.806452 3.499 3.473 3.364 3.131 3.072 2.473 0.83871 3.426 3.402 3.304 3.081 2.919 1.995 0.870968 3.34 3.316 3.218 3 2.85 1.964 0.903226 2.415 2.398 2.328 2.173 2.065 1.571 0.935484 2.199 2.183 2.116 1.972 1.869 1.471 0.967742 2.02 2.008 1.949 1.406 1.06 0.6341 0.1 40.424 40.22 2 39.038 36.35 34.38 20.388 Average of yearly averages: 7.715937 Inputs generated by pe4. pl  8 August 2003 Data used for this run: Output File: MCPBCAg1 Metfile: w23273. dvf PRZM scenario: CAlettuceC. txt EXAMS environment file: pond298. exv Chemical Name: MCPB_ CA_ lettuce_ NEW_ ground Description Variable Name Value Units Comment s Molecular weight mwt 228.6 g/ mol Henry's Law Const. henry 3.42 E 09 atm m^ 3/ mol Vapor Pressure vapr 4.00 E 07 torr Solubility sol 600 mg/ L Kd Kd 0.85 mg/ L Page 79 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Koc Koc mg/ L Photolysis halflife kdp 2.6 days Half life Aerobic Aquatic Metabolism kbacw 156 days Halfife Anaerobic Aquatic Metabolism kbacs 68 days Halfife Aerobic Soil Metabolism asm 78 days Halfife Hydrolysis: pH 7 0 days Half life Method: CAM 1 integer See PRZM manual Incorporation Depth: DEPI 0 cm Application Rate: TAPP 1.68 kg/ ha Application Efficiency: APPEFF 0.99 fraction Spray Drift DRFT 0.01 fraction of application rate applied to pond Application Date Date 3 Jan 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) Page 80 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) TABLE B. 5. Prism/ Exams Output Oregon Bean Scenario Aerial Application stored as MCPBORa1. out Chemical: MCPB_ OR_ snapbean_ NEW_ aerial PRZM environme nt: ORsnbean sC. txt modified Satday, 12 October 2002 at 17: 20: 58 EXAMS environme nt: pond298. e xv modified Thuday, 29 August 2002 at 16: 33: 30 Metfile: w24232. dv f modified Wedday, 3 July 2002 at 09: 06: 10 Water segment concentrations ( ppb)

Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1961 39.96 39.78 39.16 37.25 35.7 21.12 1962 18.43 18.33 18.14 17.61 16.99 12.51 1963 14.98 14.93 14.63 13.96 13.54 9.535 1964 19.47 19.39 19 18.24 17.57 11.51 1965 11.6 11.54 11.27 10.96 10.78 7.885 1966 25.77 25.62 25.15 23.75 22.71 14.12 1967 15.06 15.02 14.75 14.05 13.54 9.435 1968 13.02 12.94 12.71 12.06 11.56 7.818 1969 13.17 13.09 12.82 12.24 11.68 7.82 1970 16.94 16.87 16.49 15.74 15.1 9.766 1971 25.85 25.76 25.26 24.12 23.23 14.93 1972 37.5 37.38 37.06 35.37 33.94 21.53 1973 27.86 27.71 27.48 26.45 25.38 17.23 1974 23.75 23.63 23.19 22.04 21.21 14.33 1975 16.66 16.6 16.26 15.44 14.77 10.37 1976 13.63 13.56 13.28 12.59 12.04 8.439 1977 17.95 17.89 17.56 16.63 15.94 10.31 1978 11.13 11.06 10.9 10.42 10.19 7.179 1979 22.32 22.18 21.7 20.53 19.61 12.14 1980 19.67 19.56 19.2 18.16 17.4 11.71 1981 33.45 33.25 32.84 31.87 30.68 19.47 1982 27.84 27.73 27.31 26.01 24.93 16.67 1983 26.25 26.13 25.62 24.29 23.2 15.34 1984 16.72 16.67 16.35 15.53 14.89 10.52 1985 14.75 14.7 14.4 13.62 13 8.816 1986 22.81 22.67 22.37 21.61 20.74 13.1 1987 21.24 21.12 20.74 19.77 18.92 12.39 1988 15.01 14.92 14.63 14.23 13.71 9.378 1989 29.8 29.68 29.33 27.86 26.6 16.58 1990 22.58 22.49 22.01 20.78 19.9 13.45 Page 81 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.032258 39.96 39.78 39.16 37.25 35.7 21.53 0.064516 37.5 37.38 37.06 35.37 33.94 21.12 0.096774 33.45 33.25 32.84 31.87 30.68 19.47 0.129032 29.8 29.68 29.33 27.86 26.6 17.23 0.16129 27.86 27.73 27.48 26.45 25.38 16.67 0.193548 27.84 27.71 27.31 26.01 24.93 16.58 0.225806 26.25 26.13 25.62 24.29 23.23 15.34 Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.258065 25.85 25.76 25.26 24.12 23.2 14.93 0.290323 25.77 25.62 25.15 23.75 22.71 14.33 0.322581 23.75 23.63 23.19 22.04 21.21 14.12 0.354839 22.81 22.67 22.37 21.61 20.74 13.45 0.387097 22.58 22.49 22.01 20.78 19.9 13.1 0.419355 22.32 22.18 21.7 20.53 19.61 12.51 0.451613 21.24 21.12 20.74 19.77 18.92 12.39 0.483871 19.67 19.56 19.2 18.24 17.57 12.14 0.516129 19.47 19.39 19 18.16 17.4 11.71 0.548387 18.43 18.33 18.14 17.61 16.99 11.51 0.580645 17.95 17.89 17.56 16.63 15.94 10.52 0.612903 16.94 16.87 16.49 15.74 15.1 10.37 0.645161 16.72 16.67 16.35 15.53 14.89 10.31 0.677419 16.66 16.6 16.26 15.44 14.77 9.766 0.709677 15.06 15.02 14.75 14.23 13.71 9.535 0.741935 15.01 14.93 14.63 14.05 13.54 9.435 0.774194 14.98 14.92 14.63 13.96 13.54 9.378 0.806452 14.75 14.7 14.4 13.62 13 8.816 0.83871 13.63 13.56 13.28 12.59 12.04 8.439 0.870968 13.17 13.09 12.82 12.24 11.68 7.885 0.903226 13.02 12.94 12.71 12.06 11.56 7.82 0.935484 11.6 11.54 11.27 10.96 10.78 7.818 0.967742 11.13 11.06 10.9 10.42 10.19 7.179 0.1 33.085 32.893 32.489 31.469 30.272 19.24 6 Average of yearly averages : 12.51 337 Inputs generated by pe4. pl  8 August 2003 Data used for this run: Output File: MCPBORa1 Metfile: w24232. dvf PRZM scenario: ORsnbeansC. txt EXAMS environme nt file: pond298. exv Chemical Name: MCPB_ OR_ snapbean_ NEW_ aerial Descriptio n Variable Name Value Units Comme nts Molecular weight mwt 228.6 g/ mol Page 82 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Henry's Law Const. henry 3.42E 09 atm m^ 3/ mol Vapor Pressure vapr 4.00E 07 torr Solubility sol 600 mg/ L Kd Kd 0.85 mg/ L Koc Koc mg/ L Photolysis half life kdp 2.6 days Half life Aerobic Aquatic Metabolis m kbacw 156 days Halfife Anaerobic Aquatic Metabolis m kbacs 68 days Halfife Aerobic Soil Metabolis m asm 78 days Halfife Hydrolysis : pH 7 0 days Half life Method: CAM 1 integer See PRZM manual Incorporati on Depth: DEPI 0 cm Applicatio n Rate: TAPP 1.68 kg/ ha Applicatio n Efficiency: APPEFF 0.95 fraction Spray Drift DRFT 0.05 fraction of application rate applied to pond Applicatio n Date Date 3 Jan 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) Page 83 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) TABLE B. 6. Prism/ Exams Output Oregon Bean Scenario Ground Application stored as MCPBORg1. out Chemical: MCPB_ OR_ snapbean_ NEW_ ground PRZM environment : ORsnbeans C. txt modified Satday, 12 October 2002 at 17: 20: 58 EXAMS environment : pond298. ex v modified Thuday, 29 August 2002 at 16: 33: 30 Metfile: w24232. dvf modified Wedday, 3 July 2002 at 09: 06: 10 Water segment concentrations ( ppb)

Year Peak 96 hr 21 Day 60 Day 90 Day Yearly 1961 38.19 38.03 37.42 35.6 34.13 20.18 1962 14.67 14.6 14.45 14.07 13.64 10.39 1963 10.95 10.91 10.69 10.17 9.749 6.991 1964 15.25 15.19 14.89 14.27 13.72 8.96 1965 7.58 7.536 7.367 6.997 6.81 5.206 1966 21.78 21.65 21.28 20.09 19.18 11.74 1967 10.75 10.72 10.54 10.05 9.628 6.903 1968 8.725 8.677 8.52 8.086 7.741 5.231 1969 8.776 8.722 8.571 8.214 7.847 5.177 1970 12.65 12.59 12.3 11.78 11.3 7.21 1971 21.89 21.81 21.38 20.37 19.62 12.52 1972 33.99 33.89 33.56 32.05 30.76 19.42 1973 23.96 23.84 23.61 22.78 21.87 14.96 1974 19.74 19.64 19.26 18.31 17.58 11.93 1975 12.44 12.41 12.17 11.55 11.05 7.803 1976 9.316 9.275 9.087 8.601 8.231 5.754 1977 13.61 13.57 13.33 12.63 12.1 7.728 1978 6.75 6.713 6.64 6.389 6.113 4.515 1979 18.1 17.98 17.58 16.64 15.9 9.694 1980 15.53 15.45 15.17 14.36 13.74 9.225 1981 29.9 29.72 29.41 28.5 27.46 17.31 1982 23.87 23.76 23.44 22.35 21.43 14.41 1983 22.33 22.23 21.82 20.68 19.75 13.03 1984 12.52 12.48 12.24 11.64 11.16 7.997 1985 10.54 10.5 10.27 9.716 9.274 6.221 1986 18.96 18.84 18.42 17.9 17.19 10.72 1987 17.17 17.08 16.76 15.93 15.27 10.03 1988 10.93 10.87 10.65 10.28 9.931 6.886 1989 26.1 25.99 25.65 24.39 23.29 14.36 1990 18.53 18.46 18.08 17.07 16.33 11.11 Page 84 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Sorted results Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.032258 38.19 38.03 37.42 35.6 34.13 20.18 0.064516 33.99 33.89 33.56 32.05 30.76 19.42 0.096774 29.9 29.72 29.41 28.5 27.46 17.31 0.129032 26.1 25.99 25.65 24.39 23.29 14.96 0.16129 23.96 23.84 23.61 22.78 21.87 14.41 0.193548 23.87 23.76 23.44 22.35 21.43 14.36 0.225806 22.33 22.23 21.82 20.68 19.75 13.03 0.258065 21.89 21.81 21.38 20.37 19.62 12.52 0.290323 21.78 21.65 21.28 20.09 19.18 11.93 Prob. Peak 96 hr 21 Day 60 Day 90 Day Yearly 0.322581 19.74 19.64 19.26 18.31 17.58 11.74 0.354839 18.96 18.84 18.42 17.9 17.19 11.11 0.387097 18.53 18.46 18.08 17.07 16.33 10.72 0.419355 18.1 17.98 17.58 16.64 15.9 10.39 0.451613 17.17 17.08 16.76 15.93 15.27 10.03 0.483871 15.53 15.45 15.17 14.36 13.74 9.694 0.516129 15.25 15.19 14.89 14.27 13.72 9.225 0.548387 14.67 14.6 14.45 14.07 13.64 8.96 0.580645 13.61 13.57 13.33 12.63 12.1 7.997 0.612903 12.65 12.59 12.3 11.78 11.3 7.803 0.645161 12.52 12.48 12.24 11.64 11.16 7.728 0.677419 12.44 12.41 12.17 11.55 11.05 7.21 0.709677 10.95 10.91 10.69 10.28 9.931 6.991 0.741935 10.93 10.87 10.65 10.17 9.749 6.903 0.774194 10.75 10.72 10.54 10.05 9.628 6.886 0.806452 10.54 10.5 10.27 9.716 9.274 6.221 0.83871 9.316 9.275 9.087 8.601 8.231 5.754 0.870968 8.776 8.722 8.571 8.214 7.847 5.231 0.903226 8.725 8.677 8.52 8.086 7.741 5.206 0.935484 7.58 7.536 7.367 6.997 6.81 5.177 0.967742 6.75 6.713 6.64 6.389 6.113 4.515 0.1 29.52 29.347 29.034 28.089 27.043 17.075 Average of yearly average s: 10.1203 7 Inputs generated by pe4. pl  8 August 2003 Data used for this run: Output File: MCPBORg1 Metfile: w24232. dvf PRZM scenario: ORsnbeansC. txt EXAMS environment file: pond298. exv Chemical Name: MCPB_ OR_ snapbean_ NEW_ gro und Description Variable Name Value Units Comm ents Page 85 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Molecular weight mwt 228.6 g/ mol Henry's Law Const. henry 3.42E 09 atm m^ 3/ mol Vapor Pressure vapr 4.00E 07 torr Solubility sol 600 mg/ L Kd Kd 0.85 mg/ L Koc Koc mg/ L Photolysis half life kdp 2.6 days Halflife Aerobic Aquatic Metabolism kbacw 156 days Halfife Anaerobic Aquatic Metabolism kbacs 68 days Halfife Aerobic Soil Metabolism asm 78 days Halfife Hydrolysis: pH 7 0 days Halflife Method: CAM 1 integer See PRZM manual Incorporatio n Depth: DEPI 0 cm Application Rate: TAPP 1.68 kg/ ha Application Efficiency: APPEF F 0.99 fraction Spray Drift DRFT 0.01 fraction of application rate applied to pond Application Date Date 3 Jan dd/ mm or dd/ mmm or dd mm or dd mmm Record 17: FILTRA IPSCND 1 UPTKF Record 18: PLVKR T PLDKR T FEXTR C 0.5 Flag for Index Res. Run IR Pond Flag for runoff calc. RUNOF F none none, monthly or total( average of entire run) Page 86 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) APPENDIX C: Terrestrial Bird and Mammal TREX Version 1.1 Model Results Page 87 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) TREX ( Version1.1)

As part of the terrestrial assessment, EFED modeled exposure concentrations of MCPB to non target animals following the proposed application rates provided by the registrant. For terrestrial birds and mammals, estimates of initial levels of MCPB residues on various food items, which may be contacted or consumed by wildlife, were determined using the Kenega Fletcher nomogram followed by a first order decline model TREX 1.1. Upper bound Kenega Fletcher values were used for RQ calculations Page 88 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) 1. Upper Bound Kenaga Residues for RQ Calculations Birds and Mammals TREX Version 1.1 Model ( May 25, 2005)

INPUT VALUES Chemical Name: MCPB Use Peas Formulation MCPB sodium salt Application Rate 1.5 lbs a. e./ acre Half life 35 days Application Interval 1 days Maximum # Apps./ Year 1 Length of Simulation 1 year Concentration of Concern 0.00 ( ppm) Name of Concentration of Concern Avian acute LC50 Endpoints Avian Bobwhite quail LD50 ( mg/ kg bw) 257 Bobwhite quail LC50 ( mg/ kg diet) Bobwhite quail NOAEL ( mg/ kg bw) 0 Bobwhite quail NOAEC ( mg/ kg diet)

Mammals LD50 ( mg/ kg bw) 832 LC50 ( mg/ kg diet) 0 NOAEL ( mg/ kg bw) 4.56 NOAEC ( mg/ kg diet) 91.2 EECs ( ppm) Kenaga Values Short Grass 360 Tall Grass 165 Broadleafplants/ sminsects 202.5 Fruits/ pods/ seeds/ lg insects 22.50 Page 89 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Avian Results Upper Bound Kenaga Avian Body % body wgt Adjusted Class Weight consumed LD50 Small 20 114 182 Mid 100 65 232 Large 1000 29 327 EEC equivalent dose ( mg/ kg bw) Avian Classes and Body Weights small mid large 20 g 100 g 1000 g Short Grass 410 234 104 Tall Grass 188 107 48 Broadleaf plants/ sm insects 231 132 59 Fruits/ pods/ lg insects 26 15 7 Dose based RQs ( daily dose/ LD50) Avian Acute RQs 20 g 100 g 1000 g Short Grass 2.26 1.01 0.32 Tall Grass 1.03 0.46 0.15 Broadleaf plants/ sm insects 1.27 0.57 0.18 Fruits/ pods/ lg insects 0.14 0.06 0.02 Page 90 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Mammalian Results Upper Bound Kenaga Mammalian Body % body wgt Adjusted Adjusted Class Weight consumed LD50 NOAEL 15 95 1829 17 Herbivores/ 35 66 1480 14 insectivores 1000 15 640 6 15 21 1829 10 Grainvores 35 15 1480 14 1000 3 640 6 EEC equivalent dose ( mg/ kg bw) Mammalian Classes and Body weight Herbivores/ insectivores Granivores 15 g 35 g 1000 g 15 g 35 g 1000 g Short Grass 342 238 54 Tall Grass 157 109 25 Broadleaf plants/ sm Insects 192 134 30 Fruits/ pods/ seed/ lg insects 21 15 3 5 3 1 Dose based RQs ( daily dose/ LD50 or NOAEL) 15 g mammal 35 g mammal 1000 g mammal Acute Chronic Acute Chronic Acute Chro nic Short Grass 0.19 19.94 0.16 17.12 0.08 9 Tall Grass 0.09 9.14 0.07 7.85 0.04 4.12 Broadleaf plants/ sm insects 0.11 11.22 0.09 9.63 0.05 5.06 Fruits/ pods/ lg insects 0.01 1.25 0.01 1.07 0.01 0.56 Seeds ( granivore) 0.00 0.47 0 0.24 0.00 0.11 Page 91 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) 2. . Mean Kenaga Residues for Risk Characterization only Birds and Mammals TREX model version 1.1 Avian Results Mean Kenaga Residues Avian Body % body wgt Adjusted Class Weight consumed LD50 Small 20 114 182 Mid 100 65 232 Large 1000 29 327 EEC equivalent dose ( mg/ kg bw) Avian Classes and Body Weights small mid large 20 g 100 g 1000 g Short Grass 145 83 37 Tall Grass 62 35 16 Broadleaf plants/ sm insects 77 44 20 Fruits/ pods/ lg insects 12 7 3 Dose based Rqs ( daily dose/ LD50) Avian Acute RQs 20 g 100 g 1000 g Short Grass 0.8 0.36 0.11 Tall Grass 0.34 0.15 0.05 Broadleaf plants/ sm insects 0.42 0.19 0.06 Fruits/ pods/ lg insects 0.07 0.03 0.01 Dietary based RQs ( EEC/ LC50 or NOAEC) RQs Acute Chronic Short Grass Tall Grass Broadleaf plants/ sm Insects Fruits/ pods/ lg insects Page 92 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Mammalian Results Mean Kenaga Residues Mammalian Body % body wgt Adjusted Adjusted Class Weight consumed LD50 NOAEL 15 95 1829 19 Herbivores 35 66 1480 15 insectivores 1000 15 640 7 15 21 1829 19 Grainvores 35 15 1480 15 1000 3 640 4 EEC equivalent dose ( mg/ kg bw) Mammalian Classes and Body weight Herbivores/ insectivores Granivores 15 g 35 g 1000 g 15 g 35 g 1000 g Short Grass 121 84 19 Tall Grass 51 36 8 Broadleafplants/ sm Insects 64 45 10 Fruits/ pods/ seeds/ lg insects 10 7 2 2 2 0 Dose based RQs ( daily dose/ LD50 or NOAEL) 15 g mammal 35 g mammal 1000 g mammal Acute Chronic Acute Chronic Acute Chronic Short Grass 0.07 6.44 0.06 5.53 0.03 2.91 Tall Grass 0.03 2.73 0.02 2.34 0.01 1.23 Broadleaf plants/ sm insects 0.04 3.41 0.03 2.93 0.02 1.54 Fruits/ pods/ lg insects 0.01 0.53 0 0.46 0.00 0.24 Seeds ( granivore) 0.00 0.12 0 0.1 0.00 0.08 APPENDIX D: TerrPlant and AgDrift Model and Results Page 94 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) TERRPLANT MODEL Version 1.0 Terrestrial plant exposure characterization employs runoff and spray drift scenarios contained in OPP's Terrplant model. Exposure calculations are based on a pesticide's water solubility and the amount of pesticide present on the surface soil within the first inch of depth. For dry areas, the loading of pesticide active ingredient or acid equivalent from runoff to an adjacent non target area is assumed to occur from one acre of treatment to one acre of non target area. For terrestrial plants inhabiting semi aquatic ( wetland) areas, runoff is considered to occur from a larger source area with active ingredient loading originating from 10 acres of treated area to a single acre of non target wetland. Default spray drift assumptions are 1% for ground applications and 5% for aerial, forced air ( i. e., air pressure within a spray tank that forces the spray liquid through the boom nozzles), and chemigation applications. Predicted EECs resulting from spray drift and aerial applications are derived for non granular applications only. Terrestrial Plant EECs and Acute Non Endangered RQs ( 8/ 8/ 01; version 1.0)) Chemical: MCPB Input Values Application Rate ( lb a. e./ acre) 1.5 Estimated Environmental Concentrations ( EECs) for NON GRANULAR formulation applications ( lbs a. i./ acre) Risk Quotients ( RQs) for NON GRANULAR formulation applications Runoff Value ( 0.01, 0.02, or 0.05 if chemical solubility < 10, 10

100, or > 100 ppm,

respectively) 0.05 Application Method Total Loading to Adjacent Areas ( EEC = Sheet Runoff + Drift) Total Loading to Semiaquatic Areas ( EEC = Channelized Runoff +

Drift) DRIFT EEC ( for ground:

application rate x 0.01)

( for aerial: application rate x 0.05) Emergence RQs,

Adjacent Areas RQ = EEC/ Seedling Emergence EC25 Emergence RQs,

Semi aquatic Areas RQ = EEC/ Seedling Emergence EC25 Drift Rqs RQ = Drift EEC/ Vegetative Vigor EC25 Emergence Minimum Incorporation Depth ( inches) 0 Monocot Dicot Monocot Dicot Monocot Dicot Ground Unincorp. 0.0900 0.765 0.0150 4.50 5.63 38.25 47.81 0.94 10 Seed Emerg Monocot EC25 ( lb a. e./ acre) 0.02 Seed Emerg Dicot EC25 ( lb a. e./ acre) 0.016 Aerial, Airblast, Spray Chemigation 0.1200 0.525 0.0750 6 7.50 26.25 32.81 4.69 50 Veg Vigor Monocot EC25 ( lb a. e./ acre) 0.016 Veg Vigor Dicot EC25 ( lb a. e./ acre) 0.002 Terrestrial Plant EECs and Acute Endangered RQs ( 8/ 8/ 01; version 1.0) Chemical: MCPB Input Values Application Rate ( lb a. e./ acre) 1.5 Estimated Environmental Concentrations ( EECs) for NON GRANULAR formulation applications ( lbs a. i./ acre) Risk Quotients ( RQs) for NON GRANULAR formulation applications Runoff Value ( 0.01, 0.02, or 0.05 if chemical solubility < 10, 10

100, or > 100 ppm,

respectively) 0.05 Application Method Total Loading to Adjacent Areas ( EEC =

Sheet Runoff + Drift) Total Loading to Semi aquatic Areas ( EEC =

( Channelized Runoff +

Drift) DRIFT EEC ( for ground:

application rate x 0.01) ( for aerial: application rate x 0.05) Emergence RQs,

Adjacent Areas RQ = EEC/ Seedling Emergence EC05 or NOAEC Emergence RQs,

Semiaquatic areas RQ = EEC/ Seedling Emergence EC05 or NOAEC Drift Rqs RQ =

EEC/ Vegetative Vigor EC05 or NOAEC Minimum Incorporation Depth ( inches) 0 Monocot Dicot Monocot Dicot Monocot Dicot Ground Unincorp. 0.0900 0.7650 0.0150 9.00 9.00 76.50 76.50 Seed Emerg Monocot EC05 or NOAEC ( lb a. e./ acre) 0.01 Seed Emerg Dicot EC05 or NOAEC ( lb a. e./ acre) 0.01 Aerial, Airblast, Spray Chemigation 0.1200 0.5250 0.0750 12.00 12.00 52.50 52.50 Veg Vigor Monocot EC05 or NOAEC ( lbs a../ acre)

Veg Vigor Dicot EC05 or NOAEC ( lb a. e./ acre)  Page 97 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) AGDRIFT Model ( Version 2.01)

The AgDRIFT model ( Version 2.01) was used to refine the spray drift exposure estimate for terrestrial plants. Downwind spray drift buffers were developed for possible use in mitigating risks for endangered terrestrial plants that grow in close proximity to agricultural and non agricultural fields that may be treated with liquid spray applications of MCPB. The model was used to estimate spray buffer distances for ground and aerial application to reach the NOAEC and EC 25 doses for the most sensitive monocot and dicot species in the seedling emergence and the vegetative vigor studies. The standard toxicity level EFED uses for calculating risk quotients for non endangered terrestrial plants is the EC 25. For endangered plants, the NOAEC ( or EC 05 if a NOAEC value is not available) is used. Seedling emergence endpoints are representative of exposure through soil to germinating plants, while vegetative vigor endpoints are representative of foliar exposure. The terrestrial plant measurement endpoints used in the model are specified in Table D 1.

Aerial Application The most important factors affecting drift from aerial applications are spray droplet size, release height, and wind speed. The aerial part of the AgDRIFT model predicts mean dissipation distances based on the inputs provided. For aerial applications, the model contains three tiers of increasing complexity. However, only Tier 1 Aerial Model was used to estimate spray buffer distances for an initial screening .

Tier I Aerial Modeling The AgDRIFT Tier I model for aerial application limits the input parameters to droplet size only. The output of the Tier I AgDRIFT model provides distances required to dissipate spray drift to the NOAEC and EC 25 levels.

An analysis of the results indicates exceedance of the Acute Risk LOC for non endangered monocots and dicots located adjacent to treated areas, in semi aquatic areas, and as a result of spray drift.. The Endangered Species LOC was exceeded for monocots and dicots located in dryland and semi aquatic areas adjacent to treated areas and for dicots as a result of spray drift.

In spite of the uncertainty in the magnitude of the EC 25 values used to calculate the RQs for MCPB, other data in the vegetative vigor studies indicate the potential for risk to non target dicots from spray drift alone. Using the spray drift model AgDrift, the distances were calculated at which exposure would be equivalent to the lowest application rates tested in the vegetative vigor study which led to adverse effects. This Tier 1 AgDrift assessment assumed a fine to medium droplet size spectrum, and an aerial application. Table D .2.. shows these rates for each crop, the fraction of the applied, and the distance at which that deposition would occur. Page 98 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) TABLE D. 2. Input and Output Parameters AGDRIFT to Estimate Distance of Deposition of MCPB Equivalent to Rates Tested in Vegetative Vigor Study Crop input parameter initial average disposition ( lb ae/ acre) input parameter active rate lb ae/ acre output parameter fraction of the applied output parameter Distance of Deposition Cabbage 0.08 1.5 0.0533 177 Lettuce 0.039 1.5 0.026 361 Soybean 0.17 1.5 0.1134 85 Tomato 0.08 1.5 0.0533 177 Highly active herbicides, such as the growth regulators, present the greatest drift hazard because extremely small amounts can cause severe problems. Even if only a small surface area of the plant is exposed to MCPB, or a seedling is exposed to MCPB as it breaks through the soil surface, there is a possibility that the plant may be severely damaged or die as a result. In the vegetative vigor test, effects observed included mortality ( one cucmber plant, two radish plants), leaf necrosis, decreased plant size, leaf curl, and stem tumors. Such damage, even if only minor, may be sufficient to prevent the plant from competing successfully with other plants for resources and water.

. However, since the vegetative vigor tests could not determine a no effect application rate for MCPB, the effectiveness of these buffers to eliminate risk to plants cannot be evaluated. APPENDIX E: Ecological Effects Data Page 100 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Ecological Effects Data 71 1 Avian Acute Oral Bobwhite Quail. MRID 42560801 ( Acceptable). In a 14 day oral gavage study, MCPB sodium was determined to be moderately toxic to bobwhite quail with an LD 50 of 282 mg ai/ kg ( 95% confidence interval 241 330 mg ai/ kg). The NOEL was not determined due to abnormal effects at the lowest test level. The study is scientifically sound and follows the guideline protocols. Study design: 10 birds, five males and five females were assigned to each treatment level, including the controls. Observations for mortality and sublethal effects were made once a day for 14 days post dosing. Body weights were measured at test initiation, and on days 3, 7, and 14. Average estimated feed consumption was determined for each group for days 0 3, 4 7, and 8 14. Reported results: Bobwhite were exposed to six nominal concentrations of MCPB: 0, 147, 215, 316, 464 and 681 mg ai/ kg. There were 10 mortalities ( 100%) at the 681 level, 9 at 464 level, 6 at 316 level, 2 at 215 level and 1 at 147 level. Signs of toxicity were observed at all test groups. Birds in the 681mg/ kg group appeared lethargic, and exhibited dyspnea ( gasping), loss of righting reflex and diarrhea. Birds in the other treatment groups exhibited lethargy and diarrhea. Gross necropsis were performed on all 28 birds that died and all showed abnormalities such as; white areas and or white film on the heart, liver, gizzard, gallbladder, crop or intestines. Also clear fluid from the beak was observed.

71 2 Avian Acute Dietary Bobwhite Quail. MRID 42560802 ( Acceptable). In an 8 day dietary study, MCPB sodium was determined to be practically non toxic to bobwhite quail with an LC 50 > 5000 ppm ai ( nominal concentration). The NOEL was 1250 ppm ai ( nominal concentration). The study is scientifically sound and generally followed guideline protocols. Study design: Ten birds were assigned to each treatment level, including five vehicle control groups. Reported Results: Bobwhite were exposed to five nominal concentrations of MCPB NA: 312, 625, 1250, 2500 and 5000 ppm. There were no mortalities at any test level or in control groups. There were no clinical signs of toxicity at any test level. The gross necropsis revealed abnormal findings in 2 birds. Three white spots were present on the liver of 1 bird in the 1250 ppm ai group and a dark red spot was found on the liver at the 5000 ppm ai group.

Mallard. MRID 42560803 ( Acceptable). In an 8 day dietary study, MCPB sodium was determined to be practically non toxic to mallard ducklings with an LC 50 > 5000 ppm ai ( nominal concentration). The NOEL was 1250 ppm ai ( nominal concentration). The study is scientifically sound and generally followed guideline protocols. Study design: Ten birds were assigned to each treatment level, including five vehicle control groups. Reported Results: Mallard were exposed to five nominal concentrations of MCPB NA: 312, 625, 1250, 2500 and 5000 ppm. There were no mortalities at any test level or in control groups. There were no clinical signs of toxicity at any test level. The gross necropsis revealed no abnormal findings.

72 1 Freshwater Fish Acute Page 101 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Rainbow Trout. MRID 42532608 ( Acceptable). In a 96 hour flow through test, MCPB sodium was determined to be moderately toxic to rainbow trout with an LC 50 of 4.3 mg ai/ L. The NOEC was determined to be 1.0 mg ai/ L. The study is scientifically sound and meets guideline protocols. Study design: Six concentrations of chemical and dilution water control were used, each with two replicates of ten fish. Observations for mortality and sublethal effects were made daily throughout the exposure period. Reported results: The mean measured concentrations of MCPB NA were: 0( control), 8.0, 4.9, 2.8, 1.8, 1.0, and 0.60 mg ai/ L. Sublethal effects ( eg. Loss of equilibrium and darkening) were observed in surviving fish at the 4.9, 2.8, and 1.8 mg ai/ L; there were no other abnormal effects at any other test levels. There was 100% mortality at the 8.0 mg ai/ L level within 48 hours, 70% mortality at 4.9 mg ai/ L level by 96 hours, and 5% at 2.8 mg ai/ L at 96 hours.

Bluegill Sunfish. MRID 42532601 ( Acceptable). In a 96 hour flow through test, MCPB sodium was determined to be slightly toxic to bluegill sunfish with an LC 50 of 14 mg ai/ L. The NOEC was determined to be 8.9 mg ai/ L. The study is scientifically sound and meets guideline protocols. Study design: Six concentrations of chemical and dilution water control were used, each with two replicates of 10 fish. Observations for mortality and sublethal effects were made daily throughout the exposure period. Reported results: The mean measured concentrations of MCPB NA were: 0( control), 29, 16, 8.9, 56.4, 3.5 and 2 mg ai/ L. Sublethal effects ( eg. Loss of equilibrium and darkening) were observed in surviving fish at the 16 mg ai/ L level; There were no other sublethal abnormal effects at any other test levels. There was 100% mortality at the 25 mg ai/ L within 72 hours, and 75% mortality at the 16 mg ai / L level by 96 hours. There was a single mortality at the 3.5 mg ai/ L level, but this was not considered treatment related as there were no mortalities at the next highest level ( 8.9 mgai/ L).

72 2 Freshwater Invertebrate Acute Daphnia. MRID 42532602 ( Acceptable). In a 48 hour flow through test, MCPB sodium was determined to be slightly toxic to daphnids with an EC 50 of 55 mg ai/ L ( 95% confidence interval of 49  63 mg ai/ L). The NOEC was determined to be 20 mg ai/ L. The study is scientifically sound and meets guideline protocols. Study design: Five concentrations of chemical and dilution water control were used, each with two replicates of 20 daphnids. Observations for mortality and sublethal effects were made daily throughout the exposure period. Reported results: The mean measured concentrations of MCPB NA were: 0( control), 87, 51, 33, 20, and 12 mg ai/ L. Sublethal effects ( e. g. lethargy an carapace) were observed in all surviving daphnids at 87 and 51 mg ai/ L, and in 15% of the daphnids at 33 mg ai/ L. There was 95% mortality at the 87 mg ai/ L and 45% mortality at 51 mg ai/ L by the end of the test period. 81 1 Acute Mammalian Oral Rat. MRID 144801 ( Acceptable). In an acute oral study, MCPB acid was determined to have a low toxicity ( Toxicity Category III) to rats with LD 50' s of 4.7 ( 3.8  6.0) g/ kg for males and females combined. The study is scientifically sound and meets guideline protocols.

Rat. MRID 116340 ( Acceptable). In an acute oral study, MCPB acid was determined to have a low toxicity Page 102 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) ( Toxicity Category III) to rats with LD 50' s of 1570 ( 912  2700) mg/ kg in males and 1700 ( 969  2981) mg/ kg in females. The study is scientifically sound and meets guideline protocols.

82 1 Mammalian Chronic Dog. MRID 116345 ( Supplemental). In a 90 day feeding study, MCPB acid was determined to produce reproductive effects ( testicular and prostate atrophy; curtailment of spermatogenic activitiy) in dogs with a LOEL of 1600 ppm and the NOEL of 480 ppm. This study was considered supplemental because little data was provided on the concentration and stability of the test material in the diet and the pathological examination was insufficient.

Dog. MRID 42883603 ( Acceptable). In a 13 week feeding study, MCPB acid was determined to produce sublethal and reproductive effects ( reduced testes weights; physiological changes in clinical chemistry) in dogs with a LOAEL of 44 mg/ kg/ day and a NOAEL of 25 mg/ kg/ day. The study is scientifically sound and meets the guideline protocols.

Rat. MRID 42883602 ( Acceptable). In a 13 week feeding study, MCPB acid did not produce any toxicologically significant effects to rat; consequently, the NOAEL was determined to be 158 mg/ kg/ day, the highest dose tested. The study is scientifically sound and meets the guideline protocols.

83 3 Mammalian Developmental Rat. MRID 40865402 ( Acceptable). In a developmental toxicity study, MCPB acid produced maternal toxicity and developmental toxicity in Sprague Dawley rats at 100 mg ai/ kg/ day ( LOAEL). The NOAEL for both was 25 mg ai/ kg/ day. The study is scientifically sound and meets guideline protocols.

Rabbit. MRID 40865401 ( Acceptable). In a developmental toxicity study, MCPB acid produced maternal toxicity ( death) at 20 mg ai/ kg/ day ( LOAEL) in New Zealand white rabbits. The NOAEL for maternal toxicity was 5 mg ai/ kg/ day the NOAEL for developmental toxicity was 20 mg ai/ kg/ day. The study is scientifically sound and meets guideline protocols.

83 4 Mammalian Reproduction  MCPA Rat. MRID 40041701 ( Acceptable). In a 2 generation reproduction study, MCPA acid produced maternal and offspring toxicity at 22.5 mg ai/ kg/ day ( LOAEL) in Crl: CD ( SD) rats. The NOAEL for maternal and offspring toxicity was 7.5 mg ai/ kg/ day. There were no treatment related developmental effects to the fetuses. The study is scientifically sound and meets guideline protocols.

122 1( b) Vegetative Vigor  Tier I Page 103 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Corn and Oats. MRID 42560804 ( Acceptable). In a Tier I vegetative vigor test, corn and oats had < 25% detrimental effects. The NOECs for the corn and oats were 1.5 lb ai/ acre and 1.3 lb ai/ acre, respectively. The study is scientifically sound and meets the guideline protocols.

122 2 Aquatic Plant Algae Blue green algae. MRID 42532603 ( Acceptable). In a Tier I toxicity test with blue green algae, the EC 50 for cell density was > 2.1 mg ai/ L. Tier II testing was not required for this species because the NOEC exceeded the maximum label rate of 1.5 lb ai/ acre. The study is scientifically sound and meets the guideline protocols.

Green algae. MRID 42532605 ( Acceptable). In a Tier I toxicity test with green algae, the 120 hour EC 50 for cell density was 0.42 mg ai/ L. The study is scientifically sound and meets the guideline protocols.

Marine diatom. MRID 42532606 ( Acceptable). In a Tier I and II toxicity test with the marine diatom, the 120 hour EC 50 for cell density was 1.5 mg ai/ L. The study is scientifically sound and meets the guideline protocols.

Diatom. MRID 42532609 ( Acceptable). In a Tier I and II toxicity test with the diatom, the 120 hour EC 50 for cell density was 0.71 mg ai/ L with a 95% confidence limit of ( 0.11  4.6), The NOEC was .048mg ai/ L. The study is scientifically sound and meets the guideline protocols 123 1( a) Seedling Emergence  Tier II Monocots ( 5 species) and Dicots ( 5 species). MRID 42560804 ( Acceptable). In a Tier II seedling emergence study, mortality and morphological abnormalities were observed in all species tested ( cabbage, corn, cucumber, lettuce, oats, onion, ryegrass, radish, soybean, and tomato) with shoot length being the most sensitive parameter tested and cabbage the most sensitive species ( EC 25 0.017 lb ai/ acre, NOEC 0.012 lb ai/ acre). The study is scientifically sound and meets guideline protocols.

123 1( b) Vegetative Vigor  Tier II Monocots ( 3 species) and Dicots ( 5 species). MRID 42560804 ( Acceptable). In a Tier II vegetative vigor study, mortality and morphological abnormalities were observed in all species tested ( cabbage, cucumber, lettuce, onion, ryegrass, radish, soybean, and tomato) with shoot weight being the most sensitive parameter tested and tomato the most sensitive species ( EC 25 0.0017 lb ai/ L). There is uncertainty in the vegetative vigor EC 25 values for dicots, because they were extrapolated below the lowest dose tested in the study. Furthermore, the NOEC values reported in the original study were reported as being higher than the EC 25 values. Further extrapolation of the data needs to be done to derive EC 05 values from the dose response curves for the vegetative vigor study. The study is scientifically sound and meets guideline protocols.

123 2 Aquatic Plant Acute Page 104 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Duckweed. MRID 42532604 ( Acceptable). In a 14 day toxicity test with duckweed, the EC 50 for frond production was 0.23 mg ai/ L and the EC 50 for frond biomass was 1.7 mg ai/ L. The study is scientifically sound and meets guideline protocols.

141 1 Acute Honey Bee Contact Honey Bee. MRID 42532607 ( Acceptable). In a 48 hour acute contact study with the honey bee, the LD 50 was > 25

g/ bee classifies MCPB as relatively non toxic to honey bees. . The study is scientifically sound and meets guideline protocols. Design and Dose: Three replicates of 25 bees each were used for each treatment and the controls. One treatment level ( 25

g/ bee) was used. Reported results: There was 15% mortality ( 11) bees in the treated bees after 48 hours. No other significant effects were reported. APPENDIX F: Data Requirements Page 106 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Appendix F: Data Requirement Tables for MCPB TABLE of Environmental Fate Data Requirements Guideline # Data Requirement MRID # Study Classification Is more data needed?

161 1 Hydrolysis 42574301 Acceptable no 161 2 Photodegradation in Water 42574302 Acceptable no 161 3 Photodegradation on Soil 43829901 Invalid no 161 4 Photodegradation in Air N/ A no 162 1 Aerobic Soil Metabolism 43247601 Acceptable no 162 2 Anaerobic Soil Metabolism 43015501 Acceptable no 162 3 Anaerobic Aquatic Metabolism No study submitte d no 162 4 Aerobic Aquatic Metabolism No study submitte d ( not at this time)

163 1 Leaching Adsorption/ Desorption 42693701 43466401 Acceptable no 163 2 Laboratory Volatility N/ A 163 3 Field Volatility N/ A 164 1 Terrestrial Field Dissipation No study submitte d yes 164 2 Aquatic Field Dissipation N/ A 164 3 Forestry Dissipation N/ A 165 4 Accumulation in Fish N/ A 165 5 Accumulation aquatic non target N/ A 166 1 Ground Water small prospective N/ A 166 2 Groundwater  small retrospective N/ A 201 1 Droplet Size Spectrum N/ A 202 1 Drift Field Evaluation N/ A Page 107 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) TABLE of Ecological Toxicity Data Requirements Guideline # Data Requirement MRID # Classification Is more data needed?

71 1 Avian acute oral LD50 ( bobwhite quail) 42560801 Acceptable No 71 2 Avian acute dietary LC50 ( bobwhite quail) ( mallard duck) 4.25608e+ 15 Acceptable Acceptable No 71 4 Avian reproduction ( bobwhite quail) ( mallard duck) N/ A Yes 72 1 Freshwater fish acute LC500 ( rainbow trout) ( bluegill sunfish) 42532608 42532601 Acceptable Acceptable No 72 2 Freshwater invertebrate acute EC50 ( daphnia) 42532602 Acceptable No 72 3a Estuarine/ marine fish acute LC50 ( sheepshead minnow) N/ A Yes 72 3b Estuarine/ marine invertebrate acute EC50 ( eastern oyster) N/ A Yes 72 4a Freshwater fish early life stage ( fathead minnow) N/ A Yes 72 4b Freshwater invertebrate life cycle ( daphnia) N/ A Yes 72 4d Estuarine/ marine life cycle ( mysid) N/ A Yes 72 5 Freshwater fish full life cycle N/ A Yes 72 7 Aquatic Field Study N/ A Yes 81 1 Acute mammalian oral LD50 ( rat) 144801 Acceptable No 82 1( a) 82 1( b) Mammalian chronic ( dog) ( rat) 1.16345e+ 11 Acceptableminimum Acceptableminimum No 83 1( a) 83 1( b) Mammalian Chronic N/ A Yes 83 3 Mammalian Developmental ( rat) ( rabbit) 408654 Acceptable Acceptable No 83 4 MCPB Mammalian Reproduction N/ A Yes 83 4 MPCA Mammalian Reproduction 40041701 Acceptable No 123 1( a) Seedling Emergence  Tier II 42560804 Acceptable No 122 1( b) Vegetative Vigor  Tier I 42560804 Acceptable No 123 1( b) Vegetative Vigor  Tier II 42560804 Acceptable No Guideline # Data Requirement MRID # Classification Is more data needed?

Page 108 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) 122 2 Aquatic plant algae ( green algae) ( blue green algae) ( diatom) ( marine diatom) 42532605 42532603 42532609 42532606 Acceptable Acceptable Acceptable Acceptable No 123 2 Aquatic plant acute EC50 ( duckweed) 42532604 Acceptable No 141 1 Acute honey bee contact LD50 42532607 Acceptable No 141 2 Honey Bee Residue on Foliage N/ A Yes 141 5 Honey Bee Field Testing for Pollinator N/ A Yes APPENDIX G: Environmental Fate Bibliography Page 110 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Environmental Fate Bibliography Das, Y. T. 1992. Hydrolysis of [ 14C] MCPB in aqueous solutions buffered at pH 5, 7 and 9. Unpublished study performed by Innovative Scientific Services, Inc., Piscataway, NJ and sponsored by Rhône Poulenc Agrochemie, Lyon Cedex, France. ISSI Study Number 92010; Rhone Poulenc Study Number 92 06. September 23, 1992. MRID 42574301 Das, Y. T. 1992. Photodegradation of [ 14C] MCPB in aqueous solutions buffered at pH 5, 7 and 9 under artificial sunlight. Unpublished study performed by Innovative Scientific Services, Inc., Piscataway, NJ and sponsored by Rhône Poulenc Agrochemie, Lyon Cedex, France. ISSI Study Number 92011; Rhone Poulenc Study Number 92 07. September 23, 1992. MRID 42574302 Robson, M. M. 1993. Determination of adsorption/ desorption characteristics of 4( 2 methyl, 4 chlorophenoxy) butyric acid ( MCPB) in soil. Unpublished study performed by Hazleton UK, North Yorkshire, England. HUK Study No. 68/ 127. Study sponsored by Rhône Poulenc Agriculture, Essex, England. February 10, 1993. MRID 42693701 Goodyear, A. 1993. ( 14C) MCPB: anaerobic soil metabolism. Unpublished study performed by Hazleton UK, North Yorkshire, England, and sponsored by MCPB Task Force, c/ o Rhône Poulenc Agricultural Limited, Essex, England. Laboratory Study No. 68/ 131 and Report No. 68/ 131 1015. MRID 43015501 Howard, P. H. and W. M. Meylan. 1997. Handbook of Physical Properties of Organic Chemicals. Lewis Publishers, New York. p. 121.

John, A., et al. 1994. MCPB: aerobic soil metabolism. Unpublished study performed and sponsored by MCPB Task Force, c/ o Rhône Poulenc Agricultural Limited, Essex, England. Laboratory Project and Study ID: P 93/ 194. MRID 43247601 John, A. E., M. K. Jones and P. Lowden. 1994. MCPB: Fresh and aged leaching study in five soils. Laboratory Project ID. P 92/ 333. Unpublished study performed and submitted by Rhône Poulenc Agriculture Limited, Essex, England. Laboratory Project ID: P 92/ 333. MRID 43466401 Ferreira, E. M., A. E. John, P. Lowden, and D. J. Austin. 1992. MCPB soil photolysis study. Laboratory Project ID: P92/ 126. Unpublished study performed and submitted by Rhône Poulenc Agriculture Limited, Ongar, Essex, England. MRID 43829901 Podall, H. 2002. CBI Product Chemistry Review. March 8, 2002.

Tomlin, C. D. S., ed. 1997. The Pesticide Manual  # 65 MCPB Sodium Salt. British Crop Protection Council, 11th ed, Farnham, Surrey, UK. p. 254.

WSSA ( Weed Science Society of America). 1994. Herbicide Handbook. Ahrens W. H., Ed., Champaign, IL. p. 352. APPENDIX H: Ecotoxicity Bibliography Page 112 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Ecotoxicity Bibliography Bettencourt, M. J. 1992. MCPB Sodium  Acute toxicity to rainbow trout ( Oncorhynchus mykiss) under flow through conditions. Unpublished study performed by Springborn Laboratories, Inc., Wareham, MA and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. SLI Report Number 92 7 4228. MRID 42532608 Bettencourt, M. J. 1992. MCPB Sodium  Acute toxicity to bluegill sunfish ( Lepomis macrochirus) under flow through conditions. Unpublished study performed by Springborn Laboratories, Inc., Wareham, MA and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. SLI Report Number 92 8 4263. MRID 42532601 Christensen, K. P. 1992. MCPB Sodium  Determination of effects on seed germination, seedling emergence and vegetative vigor of ten plant species. Unpublished study performed by Springborn Laboratories, Inc., Wareham, MA and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. Study Number HWA 656 172. July 14, 1993. MRID 42560804 Corley, J. and D. L. Kunkel. 1999. MCPB: Magnitude of the residue on pea ( reregistration). Unpublished study performed by Environmental Toxicology Laboratory, University of California, Davis, CA and sponsored by Rutgers University, North Brunswick, NJ. Study Number 05470.94 CAR23. MRID 44754101 Dalgard, D. W. 1993. 13 Week dietary toxicity study with MCPB in dogs. Unpublished study performed by Hazleton Washington, Inc., Vienna, VA and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. SLI Report Number 92 8 4263. MRID 42883603 Dexter, A. G., J. L. Gunsolus, and W. S. Curran. 1994. Herbicide Mode of Action and Sugarbeet Injury Symptoms. North Dakota State University of Agriculture and Applied Science, Fargo, ND.

Ferrell, J. A., G. E. MacDonald, B. J. Brecke, A. C. Bennett, and J. Tredaway Ducar. 2005. Florida's Organo Auxin Herbicide Rule  2005. University of Florida, Institute of Food and Agricultural Sciences, Gainesville, FL.

Heimann, M. F. and R. C. Newman. 1997. Plant injury due to turfgrass broadleaf weed herbicides. University of Wisconsin  Cooperative Extension, Madison, WI.

Hoberg, J. R. 1992. MCPB Sodium  Toxicity to the freshwater blue green alga, Anabaena flosaquae Unpublished study performed by Springborn Laboratories, Wareham, MA and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. Study Number 10566.0392.6230.420. MRID 42532603 Hoberg, J. R. 1992. MCPB Sodium  Toxicity to the green alga, Selenastrum capricornutum. Unpublished study performed by Springborn Laboratories, Wareham, MA and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. Study Report Number 92 8 4361. MRID 42532605 Page 113 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Hoberg, J. R. 1992. MCPB Sodium  Toxicity to the freshwater diatom, Navicula pelliculosa Unpublished study performed by Springborn Laboratories, Wareham, MA and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. Study Number 10566.0392.6230.440. MRID 42532609 Hoberg, J. R. 1992. MCPB Sodium  Toxicity to the marine diatom, Skeletonema costatum. Unpublished study performed by Springborn Laboratories, Wareham, MA and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. Study Report Number 92 8 4372. MRID 42532606 Hoberg, J. R. 1992. MCPB Sodium  Toxicity to the duckweed, Lemna gibba. Unpublished study performed by Springborn Laboratories, Wareham, MA and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. Study Report Number 92 8 4368. MRID 42532604 Holsing, G. 1969. Acute Oral  Rats  MCPB Technical. Unpublished study performed by TRW, Inc. and sponsored by Rhodia, Inc. Project Report Number 517 102. MRID 116340 Kynoch, S. 1985. Acute oral toxicity to rats of MCPB Technical Acid. Unpublished study performed by Huntingdon Research Center. MRID 144801 Lingenfelter, D. D. and N. L. Hartwig. 2003. Introduction to Weeds and Herbicides. Penn State College of Agricultural Sciences  Agricultural Research and Cooperative Extension. Pp. 1  20.

MacKenzie, K. 1986. Two generation reproduction study with MCPA in rats. Unpublished study performed by Hazleton Laboratories America, Inc., Madison, WI. Laboratory Study Number 6148 100. MRID 40041701 Maggi, V. L. 1992. Acute contact toxicity of MCPB sodium salt to honey bees ( Apis mellifera). Unpublished study performed by California Agricultural Research, Inc., Kerman, CA and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. Laboratory Study Number CAR 169 92. MRID 42532607 Pedersen, C. A. and B. R. Helsten. 1992. MCPB Sodium: 14 Day acute oral LD 50 study in bobwhite quail. Unpublished study performed by BioLife Associates, Ltd., Neillsville, WI and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. Study Number BLAL 108 016 03. MRID 42560801 Pedersen, C. A. and B. R. Helsten. 1992. MCPB Sodium: 8 Day acute dietary study in bobwhite quail. Unpublished study performed by BioLife Associates, Ltd., Neillsville, WI and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. Study Number BLAL 108 014 01. MRID 42560802 Pedersen, C. A. and B. R. Helsten. 1992. MCPB Sodium: 8 Day acute dietary study in mallard ducklings. Unpublished study performed by BioLife Associates, Ltd., Neillsville, WI and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. Study Number BLAL 108 015 04. MRID 42560803 Page 114 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Putt, A. E. 1992. MCPB Sodium  Acute toxicity to daphnids ( Daphnia magna) under flowthrough conditions. Unpublished study performed by Springborn Laboratories, Wareham, MA and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. Study Report Number 92 7 4351. MRID 42532602 Trutter, J. A. 1993. 13 Week dietary toxicity study with MCPB in rats. Unpublished study performed by Hazleton Washington, Inc., Vienna, VA and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. Study Number HWA 656 174. MRID 42883602 Tyl, R. W. 1988. Developmental toxicity evaluation of MCPB administered by gavage to CD ( Sprague Dawley) Rats. Unpublished study performed by Bushy Run Research Center, Export, PA and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. Study Report Number 51 532. MRID 40865402 Tyl, R. W. and T. L. Neeper Bradley 1988. Developmental toxicity evaluation of MCPB administered by gavage to New Zealand White Rabbits. Unpublished study performed by Bushy Run Research Center, Export, PA and sponsored by Rhône Poulenc Agrochemie, Research Triangle Park, NC. Study Report Number 51 547. MRID 40865401 Page 115 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) APPENDIX I: Locates Endangered Species Page 116 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Unique Taxa Count by State for Selected Crops Reporting for > 1 Acres Cowpeas and southern peas, dry ( 53), Peas, dry edible ( 55), Cowpeas and southern peas, green ( 78), Peas, green, excluding cowpeas ( 81), Peas, all ( 312)

Cowpeas and southern peas, dry Bird Fish MammalAmphibian Crustacean Reptile Arachnids Insects Plant Snails Clam Affected Counties: 27 17 14 13 12 13 12 14 1 2 Affected States: 5 3 4 5 2 2 0 2 3 1 2 Affected Species: 15 11 10 4 5 4 5 33 1 6 Cowpeas and southern peas, green Bird Fish MammalAmphibian Crustacean Reptile Arachnids Insects Plant Snails Clam Affected Counties: 162 60 52 18 2 61 6 65 4 37 Affected States: 12 9 12 4 2 9 0 3 12 2 10 Affected Species: 16 17 8 4 2 12 2 56 4 31 Peas, all Bird Fish MammalAmphibian Crustacean Reptile Arachnids Insects Plant Snails Clam Affected Counties: 408 152 188 37 22 91 52 204 8 60 Affected States: 39 22 36 5 5 12 1 14 37 5 20 Affected Species: 48 39 38 10 11 21 1 27 350 10 37 Peas, dry edible Bird Fish MammalAmphibian Crustacean Reptile Arachnids Insects Plant Snails Clam Affected Counties: 64 28 13 3 9 2 Affected States: 7 6 6 2 0 0 0 0 4 1 0 Affected Species: 5 6 4 2 4 4 Peas, green, excluding cowpeas Bird Fish MammalAmphibian Crustacean Reptile Arachnids Insects Plant Snails Clam Thursday, June 09, 2005 Page 1 of 20 Page 117 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Peas, green, excluding cowpeas Bird Fish MammalAmphibian Crustacean Reptile Arachnids Insects Plant Snails Clam Affected Counties: 196 65 123 11 6 29 33 137 2 32 Affected States: 35 18 29 4 2 9 0 10 32 2 17 Affected Species: 21 19 23 5 4 13 19 130 3 24 Thursday, June 09, 2005 Page 2 of 20 Page 118 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) Grand Summary Bird Fish MammalAmphibian Crustacean Reptile Arachnids Insects PlantSnails Clam Total Counties: 408 152 188 37 22 91 1 52 204 8 60 Total States: 39 22 36 5 5 12 1 14 37 5 20 Unique Species Totals: 48 39 38 10 11 21 1 27 350 10 37 Species Affected:

FROG, MOUNTAIN YELLOW LEGGED Rana muscosa Amphibian TREEFROG, PINE BARRENS Hyla andersonii Amphibian TOAD, HOUSTON Bufo houstonensis Amphibian TOAD, ARROYO SOUTHWESTERN Bufo californicus (= microscaphus) Amphibian FROG, CALIFORNIA RED LEGGED Rana aurora draytonii Amphibian SALAMANDER, CALIFORNIA TIGER Ambystoma californiense Amphibian SALAMANDER, DESERT SLENDER Batrachoseps aridus Amphibian SALAMANDER, FLATWOODS Ambystoma cingulatum Amphibian SALAMANDER, SANTA CRUZ Ambystoma macrodactylum croceum Amphibian LONG TOED SALAMANDER, RED HILLS Phaeognathus hubrichti Amphibian SPIDER, KAUAI CAVE WOLF Adelocosa anops Arachnid TERN, CALIFORNIA LEAST Sterna antillarum browni Bird SPARROW, FLORIDA GRASSHOPPER Ammodramus savannarum floridanus Bird SHEARWATER, NEWELL'S Puffinus auricularis newelli Bird TOWNSEND'S CAHOW Pterodroma cahow Bird THRUSH, LARGE KAUAI Myadestes myadestinus Bird CURLEW, ESKIMO Numenius borealis Bird PLOVER, PIPING Charadrius melodus Bird PLOVER, WESTERN SNOWY Charadrius alexandrinus nivosus Bird CROW, HAWAIIAN (' ALALA) Corvus hawaiiensis Bird CREEPER, HAWAII Oreomystis mana Bird CRANE, WHOOPING Grus americana Bird CONDOR, CALIFORNIA Gymnogyps californianus Bird TERN, INTERIOR ( POPULATION) Sterna antillarum Bird COOT, HAWAIIAN (= ALAE KEO Fulica americana alai Bird HAWK, HAWAIIAN ( IO) Buteo solitarius Bird CARACARA, AUDUBON'S CRESTED Polyborus plancus audubonii Bird THRUSH, SMALL KAUAI ( PUAIOHI) Myadestes palmeri Bird Thursday, June 09, 2005 Page 3 of 20 Page 119 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) RAIL, CALIFORNIA CLAPPER Rallus longirostris obsoletus Bird RAIL, LIGHT FOOTED CLAPPER Rallus longirostris levipes Bird RAIL, YUMA CLAPPER Rallus longirostris yumanensis Bird GNATCATCHER, COASTAL Polioptila californica californica Bird CALIFORNIA STORK, WOOD Mycteria americana Bird STILT, HAWAIIAN (= AE'O) Himantopus mexicanus knudseni Bird GOOSE, HAWAIIAN ( NENE) Branta (= Nesochen) sandvicensis Bird TERN, ROSEATE Sterna dougallii dougallii Bird KITE, EVERGLADE SNAIL Rostrhamus sociabilis plumbeus Bird ' AKIA POLA'AU ( HEMIGNATHUS Hemignathus munroi Bird MUNROI)

OWL, NORTHERN SPOTTED Strix occidentalis caurina Bird PALILA Loxioides bailleui Bird DUCK, HAWAIIAN ( KOLOA) Anas wyvilliana Bird VIREO, BLACK CAPPED Vireo atricapilla Bird VIREO, LEAST BELL'S Vireo bellii pusillus Bird PELICAN, BROWN Pelecanus occidentalis Bird ' O'U ( HONEYCREEPER) Psittirostra psittacea Bird PETREL, HAWAIIAN DARK RUMPED Pterodroma phaeopygia sandwichensis Bird OWL, MEXICAN SPOTTED Strix occidentalis lucida Bird ' AKEPA, HAWAII Loxops coccineus coccineus Bird ' AKIA LOA, KAUAI ( HEMIGNATHUS Hemignathus procerus Bird PROCERUS)

NUKU PU'U Hemignathus lucidus Bird FALCON, NORTHERN APLOMADO Falco femoralis septentrionalis Bird WOODPECKER, RED COCKADED Picoides borealis Bird JAY, FLORIDA SCRUB Aphelocoma coerulescens Bird ' O'O, KAUAI (=' A'A) Moho braccatus Bird WARBLER ( WOOD), Dendroica chrysoparia Bird GOLDEN CHEEKED EAGLE, BALD Haliaeetus leucocephalus Bird MURRELET, MARBLED Brachyramphus marmoratus marmoratus Bird FLYCATCHER, SOUTHWESTERN Empidonax traillii extimus Bird WILLOW MOORHEN, HAWAIIAN COMMON Gallinula chloropus sandvicensis Bird MUSSEL, DWARF WEDGE Alasmidonta heterodon Clam MUSSEL, SCALESHELL Leptodea leptodon Clam RIFFLESHELL, NORTHERN Epioblasma torulosa rangiana Clam STIRRUP SHELL Quadrula stapes Clam COMBSHELL, SOUTHERN Epioblasma penita Clam (= PENITENT MUSSEL)

Thursday, June 09, 2005 Page 4 of 20 Page 120 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) MOCCASINSHELL, ALABAMA Medionidus acutissimus Clam FANSHELL Cyprogenia stegaria Clam FATMUCKET, ARKANSAS Lampsilis powelli Clam MUSSEL, WINGED MAPLELEAF Quadrula fragosa Clam KIDNEYSHELL, TRIANGULAR Ptychobranchus greeni Clam SLABSHELL, CHIPOLA Elliptio chipolaensis Clam SPINYMUSSEL, TAR RIVER Elliptio steinstansana Clam ROCK POCKETBOOK, OUACHITA Arkansia wheeleri Clam (= WHEELER'S PM)

PIGTOE, CUMBERLAND Pleurobema gibberum Clam (= CUMBERLAND PIGTOE MUSSEL PIGTOE, DARK Pleurobema furvum Clam PIGTOE, FINE RAYED Fusconaia cuneolus Clam PIGTOE, FLAT (= MARSHALL'S Pleurobema marshalli Clam MUSSEL)

PIGTOE, HEAVY (= JUDGE TAIT'S Pleurobema taitianum Clam MUSSEL)

PIGTOE, OVAL Pleurobema pyriforme Clam PIGTOE, ROUGH Pleurobema plenum Clam CLUBSHELL, OVATE Pleurobema perovatum Clam HEELSPLITTER, INFLATED Potamilus inflatus Clam CLUBSHELL Pleurobema clava Clam BANKCLIMBER, PURPLE Elliptoideus sloatianus Clam PIGTOE, SOUTHERN Pleurobema georgianum Clam THREERIDGE, FAT Amblema neislerii Clam PEARLYMUSSEL, PINK MUCKET Lampsilis abrupta Clam PEARLYMUSSEL, ORANGE FOOTED Plethobasus cooperianus Clam PEARLYMUSSEL, HIGGINS' EYE Lampsilis higginsii Clam POCKETBOOK, FAT Potamilus capax Clam POCKETBOOK, FINE LINED Lampsilis altilis Clam POCKETBOOK, SHINY RAYED Lampsilis subangulata Clam MUCKET, ORANGE NACRE Lampsilis perovalis Clam MOCCASINSHELL, GULF Medionidus penicillatus Clam CLUBSHELL, SOUTHERN Pleurobema decisum Clam PIGTOE, SHINY Fusconaia cor Clam HEELSPLITTER, CAROLINA Lasmigona decorata Clam SHRIMP, ALABAMA CAVE Palaemonias alabamae Crustacean SHRIMP, VERNAL POOL TADPOLE Lepidurus packardi Crustacean SHRIMP, VERNAL POOL FAIRY Branchinecta lynchi Crustacean SHRIMP, SQUIRREL CHIMNEY CAVE Palaemonetes cummingi Crustacean SHRIMP, SAN DIEGO FAIRY Branchinecta sandiegonensis Crustacean Thursday, June 09, 2005 Page 5 of 20 Page 121 of 136 ( Draft Errors Only Phase I 10/ 20/ 05) SHRIMP, RIVERSIDE FAIRY Streptocephalus woottoni Crustacean SHRIMP, CONSERVANCY FAIRY Branchinecta conservatio Crustacean SHRIMP, CALIFORNIA FRESHWATER Syncaris pacifica Crustacean SHRIMP, LONGHORN FAIRY Branchinecta longiantenna Crustacean ISOPOD, MADISON CAVE Antrolana lira Crustacean AMPHIPOD, KAUAI CAVE Spelaeorchestia koloana Crustacean SALMON, CHUM ( HOOD CANAL Oncorhynchus (= Salmo) keta Fish SUMMER POPULATION)

SALMON, ATLANTIC Salmo salar Fish SALMON, CHINOOK ( CALIFORNIA Oncorhynchus (= Salmo) tshawytscha Fish COASTAL ESU)

SALMON, CHINOOK ( CENTRAL Oncorhynchus (= Salmo) tshawytscha Fish VALLEY SPRING RUN)

SALMON, CHINOOK ( LOWER Oncorhynchus (= Salmo) tshawytscha Fish COLUMBIA RIVER)

SALMON, CHINOOK ( PUGET SOUND) Oncorhynchus (= Salmo) tshawytscha Fish SALMON, CHINOOK ( SACRAMENTO Oncorhynchus (= Salmo) tshawytscha Fish RIVER WINTER RUN)

SALMON, CHINOOK ( SNAKE RIVER Oncorhynchus (= Salmo) tshawytscha Fish FALL RUN)

SALMON, CHINOOK ( SNAKE RIVER Oncorhynchus (= Salmo) tshawytscha Fish SPRING/ SUMMER)

SALMON, CHINOOK ( UPPER Oncorhynchus (= Salmo) tshawytscha Fish COLUMBIA RIVER SPRING)

STEELHEAD, UPPER COLUMBIA Oncorhynchus (= Salmo) mykiss Fish RIVER POPULATION SALMON, CHUM ( COLUMBIA RIVER Oncorhynchus (= Salmo) keta Fish POPULATION)

CHUB, MOHAVE TUI Gila bicolor mohavensis Fish SALMON, COHO ( CENTRAL Oncorhynchus (= Salmo) kisutch Fish CALIFORNIA COAST POP)

SALMON, COHO ( OREGON COAST Oncorhynchus (= Salmo) kisutch Fish POPULATION)

SALMON, COHO ( SOUTHERN Oncorhynchus (= Salmo) kisutch Fish OR/ NORTHERN CA COAST)

SALMON, SOCKEYE ( SNAKE RIVER Oncorhynchus (= Salmo) nerka Fish POPULATION)

STEELHEAD, SOUTHERN Oncorhynchus (= Salmo) mykiss Fish CALIFORNIA POPULATION SAWFISH, SMALLTOOTH Pristis pectinata Fish STEELHEAD, SOUTH CENTRAL Oncorhynchus (= Salmo) mykiss Fish CALIFORNIA POP SALMON, CHINOOK ( UPPER Oncorhynchus (= Salmo) tshawytscha Fish WILLAMETTE RIVER)