  SEQ CHAPTER \h \r 1 

UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

WASHINGTON D.C., 20460

OFFICE OF

PREVENTION, PESTICIDES AND

TOXIC SUBSTANCES



									PC Code: 018101

DP Barcodes: D336717

									

									Date: March 19, 2007

MEMORANDUM					

SUBJECT:	Tier I Drinking Water Assessment for Chlormequat Chloride in
Support of Reregistration Eligibility Decision

TO:		Tracy Perry, Chemical Risk Manager

		Special Review Branch	

		Special Review and Reregistration Division

		

		Elissa Reaves, Risk Assessor

		Donald Wilbur, Risk Assessor

		Reregistration Branch II

		Health Effects Division

FROM:	Marietta Echeverria, Environmental Scientist

		Environmental Risk Branch IV

		Environmental Fate and Effects Division

THROUGH:	R. David Jones, Ph.D., Senior Agronomist

		Environmental Risk Branch IV

		Environmental Fate and Effects Division

APPROVED	

BY:		Elizabeth Behl, Branch Chief

		Environmental Risk Branch IV

		Environmental Fate and Effects Division

	Attached is the drinking water exposure assessment for chlormequat
chloride in support of the reregistration eligibility decision (RED). 
This assessment considers all registered outdoor uses including bedding
plants and ornamentals in shadehouses and nurseries.  If additional
refinements are necessary, please contact Marietta Echeverria at
703-305-8578 or echeverria.marietta@epa.gov.	



								

Tier I Drinking Water Exposure Assessment for the Reregistration
Eligibility Decision (RED) for Chlormequat Chloride 

						

				

Chlormequat Chloride [2-chloroethyltrimethyl ammonium chloride]

CAS No. 000999-81-5

Prepared by:

	Marietta Echeverria, Environmental Scientist

Environmental Risk Branch IV

	U. S. Environmental Protection Agency

Office of Pesticide Programs

Environmental Fate and Effects Division

Environmental Risk Branch IV

1200 Pennsylvania Ave., NW

Mail Code 7507P

Washington, DC 20460

Reviewed by:

R. David Jones, Ph.D, Senior Agronomist

Elizabeth Behl, Branch Chief

Environmental Risk Branch IV

Environmental Fate and Effects Division

	

Executive Summary

	This document reports the drinking water exposure assessment for
2-chloroethyltrimethyl ammonium chloride (chlormequat chloride) that has
been conducted to support the human health risk assessment for the
rergistration eligibility decision (RED).  Chlormequat chloride is a
plant growth regulator used on bedding plants and containerized
ornamentals in greenhouses, shadehouses, and nurseries.  Foliar spray
applications and drench applications (greenhouse uses only) are allowed
on the label.  Tier 1 surface water and groundwater modeling was
conducted for the labeled shadehouse or container nursery use (EPA Reg.
No. 241-74), which represents the highest use rate of all labeled uses
with an annual application rate of 33.3 lbs. a.i./A/year.  The
recommended estimated drinking water concentrations (EDWCs) for the
human health risk assessment are in Table 1.  There were no identified
major degradates of chlormequat chloride in the laboratory studies. 
However, all transformation products greater than 10% of the applied may
not have been identified in the aerobic soil and aerobic aquatic
metabolism studies.  

	

Table 1.  Tier I EDWCs for chlormequat chloride for ground boom spray
applications (EPA Reg. No. 241-74)

Drinking Water Source (Model)	Use rate (lbs ai/A/year)	EDWC (ppb)

Surface water (FIRST)

 - Acute (peak)

 - Chronic (annual mean)	

33.3

	

2574

91

Groundwater (SCI-GROW)	33.3	24

Problem Formulation

	This is a Tier I drinking water assessment that uses modeling and
available monitoring data to estimate the groundwater and surface water
concentrations in drinking water sources (pre-treatment) resulting from
pesticide use on sites that are vulnerable.  This initial tier screens
out chemicals with low potential risk and allows OPP to focus resources
on more refined risk assessments for chemicals which potentially present
more significant risks. This drinking water assessment reports potential
exposure concentrations for the human health dietary risk assessment and
provides a description of how those concentrations were determined. 

Previous Assessments

EFED completed a Tier I drinking water assessment for the only
registered outdoor use of chlormequat chloride (on ornamentals and
bedding plants in nurseries and shadehouses) in August 2006 (018101
D322925 DWA).  This assessment relies on the previous assessment. 
During the registration process the maximum use pattern decreased from
49.5 lbs ai/A/year to 33.3 lbs ai/A/year.  This assessment is based on
the maximum rate of the registered uses of Cycocel® (EPA Reg. No.
241-74; 33.3 lbs ai/A/year).  The previous assessment only considered
exposure to parent chlormequat chloride.  However, since there were
unidentified residues in the metabolism studies that may be of risk
concern, a total toxic residue approach that assumes all uncharacterized
extractable residues are of equal toxicity to chlormequat chloride was
used to estimate exposure in the current assessment.  This results in an
increase in aerobic soil metabolism half-life of ~200% for surface water
modeling and ~27% for groundwater modeling. 

Analysis

Use Characterization

Chlormequat chloride is a plant growth regulator (PGR) for use on
bedding plants and containerized ornamentals in greenhouses,
shadehouses, and nurseries as the formulated product Cycocel® (EPA Reg.
No. 241-74).  In open production areas not under cover, Cycocel® use is
restricted to containerized ornamentals only.  Application to
field-grown ornamentals is not allowed by the label.  The label allows
foliar spray applications and drench applications.  Drench applications
are only allowed for the indoor greenhouse uses.  This assessment does
not consider the indoor greenhouse uses because environmental exposures
are expected to be limited to greenhouse discharge which is regulated
under the National Pollutant Discharge Elimination System (NPDES).

For the outdoor (shadehouse and nursery) uses, spray volume providing
thorough plant coverage will vary with plant size and foliage coverage
and application rates will vary according specific crop type.  However,
the label states that a single application cannot exceed a rate of 3.7
lbs. ai/A, and the total annual rate can not exceed 33.3 lbs ai/A/year. 
The label also limits the number of applications to 3 per crop cycle. 
For this assessment, 3 production cycles per year are assumed, resulting
in a maximum of 9 applications per year.  The interval between repeat
applications to the same crop can range from 5 to 21 days.  Table 2
summarizes the maximum application rates used in this assessment.

Table 2. Maximum use patterns for Cycocel on bedding plants and
containerized ornamentals

Uses	App. type	Max app. Rate (lbs ai/A)	Max # of app./ year	Min app.
Interval (days)

Bedding plants, containerized ornamentals	Foliar spray; mechanized
ground boom sprayer	3.7	9	5

Environmental Fate and Transport Characterization

	There are a number of data gaps in the chlormequat chloride
environmental fate and transport dataset.  In the absence of data,
assumptions made regarding chlormequat chloride were compared to and
supported by the environmental fate and transport data of
didecyl-dimethylammonium chloride (DDAC, PC code 69149, CAS No.
007173-51-5).  DDAC and chlormequat chloride are both quaternary
ammonium compounds that have been classified according to the Agency’s
PR Notice 88-2 (February 26, 1988) as Group I, alkyl or hydroxyalkyl
(straight chain) substituted quaternary ammonium compounds.

	Chlormequat chloride has variable mobility in the environment.  Batch
equilibrium studies resulted in Freundlich sorption coefficients ranging
1.13 – 9.12 ml/g with corresponding 1/N values ranging 0.511 – 0.955
(MRIDs 46715228, 46715229).  Even though chlormequat chloride is a
cation, the correlation between cation exchange capacity (CEC) and
sorption was not significant in the batch equilibrium studies.  In a
supplemental aged column leaching study 0.3-0.5 % of the applied
radioactivity was found in the leachate after 48 hours of leaching with
4 pore volumes of 0.01 M CaCl2 in a loamy sand soil (MRID 46715230).  In
another supplemental aged column leaching study 2.5% of the applied
radioactivity was found in the leachate following 45 days of leaching
with 0.5 inches of distilled water daily through a 15 inch column filled
with a clay loam soil (MRID 124061).   In a supplemental unaged column
leaching study < 0.1 % of applied radioactivity was found in the
leachate after leaching with 20 inches of distilled water at a rate not
exceeding 1 inch/hour through a 15 inch column filled with a sand, sandy
loam, silt loam and clay loam soil (MRID 124062).  In both of these
studies distilled water was used which could lead to dispersion of clays
that could affect soil structure.

Depending on soil, site and meteorological conditions chlormequat
chloride may be transported off-site via runoff, leaching and/or
erosion.  

	Overall, the major route of dissipation for chlormequat chloride
appears to be microbial degradation.  A supplemental aerobic soil
metabolism study showed that chlormequat chloride degraded with
half-lives of 30-43 days in two sandy loam and two silt loam soils (MRID
46715225).  In the study, up to 43.7% and 10.7% of the applied
radioactivity in the soil extracts was unaccounted for in two soils.  No
attempt was made to identify these transformation products and it is not
known whether or not the residues consisted of one or more components. 
Consequently, all transformation products detected at >10% of the
applied may not have been identified.  Using a total residue approach
that assumes all uncharacterized extractable residues are of equal
toxicity to chlormequat chloride results in half-lives of 32 – 132
days.  A supplemental aerobic aquatic metabolism study showed that
chlormequat chloride degraded with total system half-lives of 5-9 days
in a river water-sandy loam sediment and pond water-silt loam sediment
system (MRID 46715227).  There were no available acceptable data for
degradation of chlormequat chloride by hydrolysis or photolysis. 
Comparison to DDAC data, however, suggests that chlormequat chloride may
be hydrolytically and photolytically stable (MRID 411758-01, 411758-02).
 There are also no data for chlormequat chloride under anaerobic
conditions.  DDAC has, however, been shown to be persistent under
anaerobic conditions (MRID 422538-02).  Table 3 summarizes the
registrant-submitted environmental fate and transport properties of
chlormequat chloride.	

	Major degradates (excluding CO2) were not identified in the available
metabolism studies.  In the aerobic aquatic metabolism study, an
unidentified polar compound reached a maximum of 4.8 and 13.4 % in the
total systems.  Choline-chloride was also detected in the aerobic
aquatic metabolism study at a maximum of 2.0 and 5.5% in the total
systems.

	

  SEQ CHAPTER \h \r 1 Table 3.  Summary of environmental chemistry and
fate properties of chlormequat chloride  tc "Table 7  Summary of
Environmental Chemistry and Fate Properties of Flurprimidol " \f D  

Parameter	Value	Reference/Comments

Selected Physical/Chemical Parameters

PC code	018101

	CAS No.	999-81-5

	Physical state	Liquid	Product chemistry

Chemical name	2-chloro-N,N,N-trimethylethylethanammonium chloride salt
Product chemistry

Chemical formula	C5H13Cl2N	Product chemistry

Molecular weight	158.1 g/mol	Product chemistry

Water solubility	106 mg/L	Product chemistry

Density	1.14 g/mL	Product chemistry

Boiling point	Not reported	Product chemistry

Vapor pressure (20 °C)	7.5 x 10-8 mm Hg	Product chemistry

log KOW	2.51	Product chemistry

Persistence

Hydrolysis t1/2



	pH 5

	pH 7

	pH 9	No data	Likely stable per comparison to DDAC (MRID 411758-01)

Photolysis t1/2in water	No data	Likely stable per comparison to DDAC
(MRID 411758-02)

Photolysis t1/2 in soil	No data	Likely stable per comparison to DDAC
(MRID 411758-02)

Soil metabolism aerobic t1/2

[Total residues]1	43.4, 29.7, 31.5, 43.0 d

[43.4, 32.9, 36.3, 132.3 d]	MRID 46715225

Soil metabolism anaerobic t1/2	No data	Likely stable per comparison to
DDAC (MRID 422538-02)

Aquatic metabolism aerobic t1/2	4.9, 8.7 d	MRID 46715227

Aquatic metabolism anaerobic t1/2	No data	Likely stable per comparison
to DDAC (MRID 422538-02)

Mobility

Batch equilibrium 	Soil Type	Kf2	1/N	Koc3	MRIDs 46715228, 46715229

	Loamy sand	1.25	0.511	55



Sandy loam	4.57	0.691	291



Silt loam	1.13	0.702	81



Sand	1.73	0.543	93



Sandy loam	2.14	0.768	89



Loam	9.12	0.849	912



Silt loam	8.08	0.955	385









Column leaching – aged residues	0.3-0.5 % applied radioactivity in
leachate after 48 hours of leaching with 4 pore volumes of 0.01 M CaCl2
in a loamy sand soil; 

2.5% of applied radioactivity in leachate following 45 days of leaching
with 0.5 acre-inches of distilled water daily in a clay loam soil; 
MRIDs 46715230, 124061

Column leaching - unaged	< 0.1 % of applied radioactivity in leachate
after leaching with 20 acre-inches of distilled water at a rate < 1
inch/hr in a sand, sandy loam, silt loam and clay loam soil.	MRID 124062

Laboratory volatility	NA

	Field Dissipation

Terrestrial field dissipation	No data

	Aquatic field dissipation	NA

	Bioaccumulation

Accumulation in fish, BCF	No data

	1. Total residue approach assumes uncharacterized extractable residues
are of similar toxicity as parent chlormequat chloride.

2. Units of (mg/kg)/(mg/L)1/N, where 1/N is the Freundlich exponent.

3. Approximation calculated from the Freundlich coefficient, per
standard EFED guidance.

Drinking Water Exposure Modeling

	Tier 1 modeling was used to estimate the drinking water exposure for
use in the dietary risk assessment of chlormequat chloride.  The
following is a description of the models used, the selection of the
model input parameters, and a characterization of the output from these
simulations.

Models

	Tier 1 EDWCs for surface water were generated using FIRST, dated August
5, 2001.  FIRST is a screening model designed by the Environmental Fate
and Effects Division (EFED, 2001a) of the Office of Pesticide Programs
to estimate the concentrations found in drinking water from surface
water sources for use in human health risk assessment.  As such, it
provides upper bound values on the concentrations that might be found in
drinking water due to the use of a pesticide.  FIRST is a single-event
model (one runoff event), but can account for spray drift from multiple
applications.  FIRST is hardwired to represent the Index Reservoir, a
standard water body used by the Office of Pesticide Programs to assess
drinking water exposure (Office of Pesticide Programs, 2002).  It is
based on a real reservoir, Shipman City Lake in Illinois, which is known
to be vulnerable to pesticide contamination. The single runoff event
moves a maximum of 8% of the applied pesticide into the reservoir.  This
amount can be reduced due to degradation on the field and the effects of
binding to soil in the field.  FIRST also uses a Percent Cropped Area
(PCA) factor to adjust for the area within the watershed that is planted
to the modeled crop.  A PCA of unity (the most protective) was applied
in this assessment because there is no PCA for nurseries and shadehouses
and these uses are not included in the “all agricultural land”
classification on which the default PCA of 0.87 was based.

	Tier 1 EDWCs for groundwater were generated with SCIGROW 2.3, dated
July 29, 2003 (EFED, 2001b).  SCIGROW is a regression model used as a
screening tool for ground water used as drinking water.  SCIGROW was
developed by regressing the results of Prospective Ground Water studies
against the Relative Index of Leaching Potential (RILP).  The RILP is
function of aerobic soil metabolism and the soil-water partition
coefficient.  The output of SCIGROW represents the concentrations that
might be expected in shallow unconfined aquifers under sandy soils.

Modeling Approach and Input Parameters

	Tables 4 and 5 summarize the model input parameter values used in FIRST
and SCIGROW, respectively.  These parameters were selected in accordance
with EFED’s input parameter guidance (Environmental Fate and Effects
Division, 2002).

	For the surface water and groundwater assessments, the maximum
application rate, 3.7 lb a.i./A/application, was used and the maximum
number of applications per year was assumed to be 9 (3 applications per
crop cycle and 3 crop cycles per year).  Based on registrant-submitted
data for chlormequat chloride, an aerobic soil metabolism and aerobic
aquatic metabolism half-life of 100 and 12.6 d (the upper 90th
percentile confidence bound on the mean) was used for surface water
modeling with FIRST.  It was assumed that chlormequat chloride was
stable to photolysis.   For groundwater modeling with SCIGROW, the
median of the four values, 39.9 d, was used as the aerobic soil
metabolism input.  The soil-water partitioning coefficient used in FIRST
and SCIGROW was 1.1 ml/g and 55 ml/goc, respectively, the lowest
non-sand Kd/Koc of seven values.  The lowest Koc value was used in
SCIGROW because there was greater than 3-fold variability in the
available data. 

Table 4. FIRST (v 1.0) input parameter values for chlormequat chloride
applied by ground boom spray

Parameter	Value	Source	Comments

Application Rate (lb a.i./A)	3.7	EPA Reg. No. 241-74

	Number of Applications	9	EPA Reg. No. 241-74

	Interval between Applications (d)	5	EPA Reg. No. 241-74

	Soil Partitioning Coefficient (Kd; ml/g)	1.1	MRIDs 46715228, 46715229 
lowest non-sand value 

Aerobic Soil Metabolism t1/2 (d)	100	MRID 46715225	90th percentile upper
confidence bound on the mean (43.4, 32.9, 36.3, 132.3 d) based on total
residues1

Wetted in?	No	foliar applied

	Depth of Incorporation (inches)	0	foliar applied

	Method of Application	ground spray	EPA Reg. No. 241-74

	Percent Cropped Area 	1	Most protective	No PCA for nurseries

Solubility in Water (mg/L)	106	Product chemistry data

	Aerobic Aquatic Metabolism t1/2 (d)	12.6	MRID 46715227 	90th percentile
upper confidence bound on the mean (4.9, 8.7 d)

Aquatic Photolysis t1/2 (d)	0	--	Assumed stable to photolysis (no data)

		1. Total residue approach assumes all unidentified extractable
residues are of similar toxicity to parent chlormequat chloride.

	

Table 5.  SCIGROW 2.3 input parameter values for chlormequat chloride
applied by ground boom.

Parameter	Value	Source	Comments

Maximum Application Rate (lb a.i./A/application)	3.7	EPA Reg. No. 241-74

	Maximum Number of Applications per Year	9	EPA Reg. No. 241-74

	Aerobic Soil Metabolism Half-life (days)	39.9	MRID 46715225 	median
values (43.4, 32.9, 36.3, 132.3 d) based on total residues1

Organic Carbon Partition Coefficient (Koc, ml/goc)	55	MRID 46715228,
46715229 	lowest value; > 3-fold variability in Koc data 

1. Total residue approach assumes all unidentified extractable residues
are of similar toxicity to parent chlormequat chloride.

Modeling Results

	The FIRST and SCI-GROW output files are located in Appendix A.  Based
on the results of these simulations, EFED recommends an acute surface
water EDWC of 2574 µg/L and a chronic EDWC of 91 µg/L for use in the
human health risk assessment.  These recommendations are based on the
use of chlormequat chloride to ornamentals in nurseries or shadehouses
at an annual application rate of 33.3 lb a.i./A/year.  The recommended
EWDC for groundwater is 23.6 µg/L and is also based on the use of
chlormequat chloride to ornamentals in shadehouses and nurseries at the
previously stated rate. 

Monitoring Data

	There were no national-scale monitoring data available for this
assessment.  

Drinking Water Treatment

There is no available information on the drinking water treatment
effects on chlormequat chloride.

conclusions

	The estimated concentrations provided in this assessment were generated
from Tier 1 models and are conservative estimates of chlormequat
chloride concentrations in untreated drinking water.  Major sources of
uncertainty include the inadequate identification of degradates in the
metabolism studies, assumptions regarding application intervals, the
appropriate PCA for nursery/shadehouse ornamentals, and the
applicability of the standard Tier 1 models to the nursery/shadehouse
use.  

	In the aerobic soil and aerobic aquatic metabolism studies all
transformation products greater than 10% of the applied may not have
been identified.  A total residue approach, which conservatively assumed
that all unidentified extractable residues are of similar toxicity to
parent chlormequat chloride, was used for modeling.  

	The application interval was assumed to be 5 days (which is the minimum
permitted by the label) for all 9 applications.  Since there are only 3
allowed applications per crop cycle, it is likely that the interval
between applications of subsequent crop cycles will be greater than 5
days, and thus the 5-day interval was likely a protective assumption. 
Also, since there is no standard PCA for nurseries/shadehouses, this
assessment is based on the assumption that an entire 178-ha watershed
consists of containerized nursery/shadehouse ornamentals all of which
are treated simultaneously with chlormequat chloride, again a likely
conservative assumption.  Finally, the standard Tier 1 models used in
this assessment were developed to simulate pesticide applications in
open agricultural fields and not specifically for containerized
ornamentals in nurseries/shadehouses.  The impact of rainfall and
corresponding pesticide transport is likely dampened due to the use of
containers and/or shade covers relative to open agricultural fields,
which also leads to a protective assessment.   

	If dietary risks require refinement, higher tiered models and modeling
scenarios can be utilized upon request.

Appendix A:   Input/Output Modeling Files

FIRST File

RUN No.   1 FOR chlormequat chlo ON   nurseries     * INPUT VALUES * 

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

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

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

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

  3.700( 29.106)   9   5       1.1*******   GROUND( 6.4) 100.0      .0

   FIELD AND RESERVOIR HALFLIFE VALUES (DAYS) 

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

   METABOLIC  DAYS UNTIL  HYDROLYSIS   PHOTOLYSIS   METABOLIC  COMBINED

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

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

    100.00        2          N/A       .00-     .00    12.60     12.60

   UNTREATED WATER CONC (MILLIGRAMS/LITER (PPM)) Ver 1.1.0 DEC 12, 2005

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

        PEAK DAY  (ACUTE)      ANNUAL AVERAGE (CHRONIC)      

          CONCENTRATION             CONCENTRATION            

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

              2.574                       .091

SCIGROW File 

                          SCIGROW

                          VERSION 2.3

            ENVIRONMENTAL FATE AND EFFECTS DIVISION

                 OFFICE OF PESTICIDE PROGRAMS

             U.S. ENVIRONMENTAL PROTECTION AGENCY

                        SCREENING MODEL

                FOR AQUATIC PESTICIDE EXPOSURE

 

 SciGrow version 2.3

 chemical:chormequat chloride

 time is  3/ 9/2007  12:43:57

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

  Application      Number of       Total Use    Koc      Soil Aerobic

  rate (lb/acre)  applications   (lb/acre/yr)  (ml/g)   metabolism
(days)

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

      3.700           9.0          33.300      5.50E+01       39.9

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

 groundwater screening cond (ppb) =   2.36E+01 

 ***********************************************************************
* 

References

Environmental Fate and Effects Division.  2001a.  FIRST (F)IFRA (I)ndex
(R)eservoir (S)creening (T)ool. Tier 1 Model for Drinking Water
Exposure: User's Manual.     HYPERLINK
"http://www.epa.gov/oppefed1/models/water/first_users_manual.htm" 
http://www.epa.gov/oppefed1/models/water/first_users_manual.htm 

Environmental Fate and Effects Division.  2001b.  SCI-GROW - (S)creening
(C)oncentration (I)n (GRO)und (W)ater: User's Manual.     HYPERLINK
"http://www.epa.gov/oppefed1/models/water/scigrow_users_manual.htm" 
http://www.epa.gov/oppefed1/models/water/scigrow_users_manual.htm 

Environmental Fate and Effects Division.  2002.  Guidance for Selecting
Input Parameters in Modeling the Environmental Fate and Transport of
Pesticides, Version II. U. S. Environmental Protection Agency.
Washington, D.C.      HYPERLINK "http://www.epa.gov/oppefed1/models/" 
http://www.epa.gov/oppefed1/models water/input_guidance2_28_02.htm/ 

Office of Pesticide Programs. 2000.  Part A. Guidance for Use of the
Index Reservoir in Drinking Water Assessments.     HYPERLINK
"http://www.epa.gov/oppfead1/trac/science/reservoir.pdf" 
http://www.epa.gov/oppfead1/trac/science/reservoir.pdf 

         

  PAGE   

  PAGE   

  PAGE   2 

  PAGE   3 

  PAGE   4 

