RICHARD
J.
OTTEN
Registration
and
Regulatory
Services
PMB
239,
7474
Creedmoor
Road,
Raleigh,
NC
27613
PHONE:
919­
846­
7860
FAX:
919­
846­
2775
Email:
dgminc@
bellsouth.
net
November
7,
2002
Mr.
Mark
Howard
Reregistration
Branch,
SRRD
(
H7508W)

U.
S.
Environmental
Protection
Agency
Ariel
Rios
Building
1200
Pennsylvania
Ave.,
N.
W.

Washington,
DC
20460
RE:
4­
CPA
Mini­
SMART
Meeting
October
24,
2002
Dear
Mr.
Howard:

The
following
comments
respond
to
the
various
questions
from
EPA
reviewers
during
the
meeting
cited
above:

1)
Based
on
usage
during
the
past
several
years,
estimated
future
use
of
4­
CPA
to
inhibit
root
development
of
sprouting
mung
beans
will
be
less
than
20
pounds
per
year.

2)
Both
LaChoy
and
Chun
King
bean
sprouts
are
now
produced
at
the
Archibald,
Ohio
facility
using
the
same
procedure.

3)
This
facility
produces
canned
bean
sprouts
only.
No
sprouts
for
the
fresh
market
are
grown
with
this
procedure.

4)
Currently,
there
are
only
three
laboratory
employees
who
are
exposed
to
4­
CPA
during
measuring,
mixing
and
use.
No
change
is
expected
in
the
future.

5)
Depending
on
the
temperatures
of
incoming
water,
it
takes
five
to
six
days
total
to
grow
the
bean
sprouts.
The
beans
are
first
soaked
for
five
to
eight
hours
in
the
solution
of
4­
CPA.
Then,
the
beans
are
rinsed
with
water,
placed
in
the
growing
bins,
in
growth
chambers
and
irrigated
(
sprayed)
every
70
minutes.
After
about
five
days,
the
bins
are
flooded
with
water
to
float
the
beans
and
sprouts
to
the
packing
area.
Immediately
edible
sprouts
are
separated
from
non­
edible
other
plant
parts
and
canned.
If
you
desire
more
detail,
please
review
the
information
provided
to
the
Case
Manager
several
years
ago.

6)
ConAgra
does
not
have
consumption
data
that
is
different
from
figures
used
by
EPA
several
years
ago.

7)
As
expressed
during
our
meeting,
the
lower
residue
tolerance
of
0.2
ppm
should
be
used
in
any
dietary
exposure
calculations,
rather
than
the
previously
published
tolerance
of
2.0
ppm.

8)
Since
EPA's
evaluation
several
years
ago,
there
has
been
no
change
in
the
way
rinse
and
wastewater
are
being
handled.
Water
goes
directly
to
the
POTW.
(
Publicly
Owned
Treatment
Works)
Any
residual
water
on
the
unused
bean
hulls
goes
to
the
local
landfill.

9)
Likewise,
there
has
been
no
change
in
the
way
solid
waste
is
being
treated.
Solids
are
separated
mechanically
from
any
associated
liquids
and
sent
to
the
local
landfill.

10)
Information
on
the
residue
levels
detected
and
the
breakdown
of
4­
CPA
is
in
EPA's
files
and
referred
to
in
the
previous
RED.
The
studies
were
run
in
1995.
Nothing
has
changed
to
our
knowledge.
Please
contact
me
if
these
data
need
to
be
resubmitted.

Please
contact
me
if
other
information
is
desired
at
this
time.

Sincerely,

Richard
J.
Otten
Regulatory
Consultant
for
ConAgra
Foods
RJO/
ama
