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 ESTABLISHMENT AND REVIEWS OF
ORIGINAL KEPONE ACTION LEVELS
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ESTABLISHMENT & REVIEWS  OF  ORIGINAL KEPONE ACT-ION LEVELS

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        ESTABLISHMENT & REVIEWS OF ORIGINAL KEPONE ACTION LEVELS


                           Table of Contents


1.   Introduction:  Evolution of the Problem and Brief Chronology
     of EPA Response

2.   Considerations in Establishing Current Action Levels

     a.   Toxicological Considerations

     b.   Analytical and Residue Chemistry Considerations

3.   New Considerations in Revising or Continuing Current Action Levels

4.   Results of Reassessment and Recommendations

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                             INTRODUCTION:

 I.  Evolution of the Problem and Brief Chronology of EPA Response

    In mid-1975, the Atlanta Center for Disease Control, in conjunction
with Virginia t discovered that several Life'Science Products Company (LSPC)
workers were seriously ill due to massive occupational exposure to Kepone.
Kepone residues from .02 to 60 parts per million ("PP^T were found in both
blood and sebum samples from all 28 hospitalized LSPC workers, in addition
to one worker's wife who had also been hospitalized.

    Kepone levels of 0.1 to 4 parts per billion (ppb) were found in the
James River.  Kepone residues ranging between 0.1 and 20 ppm were found
in fish and shellfish in the James River, some from samples as far as
40 miles away.  Bottom sediments, soils, and sludge were also tested with
positive results.  Filters gathered between March of 1974, and April 1975,
from the State air sampler station located approximately 200 yards from
LSPC operation contained residues ranging from 0.2 to 50 micrograms per
cubic meter of air.  Tap water from the Hopewell water supply was also
tested; fortunately, no detectable levels of Kepone were discovered there.
As a result of the water media samplings, Governor Godwin of Virginia
closed the James River to fishing the following day.

    On August 20, EPA Region III issued an order to LSPC under the authority
of the Federal Insecticide, Fungicide and Rodenticide Act, to stop the
sale or use. of Kepone, as well as its removal from the premises.  On
February 3, 1976, a similar order was 'issued to the Baltimore facility
of Allied Chemical Corporation.

    EPA's Environmental Research Laboratory in Gulf Breeze, Florida,
(ERL/GB) has established the cleansing ability (depuration) of trans-
planted seed oysters.  Data obtained from the State and corroborated by
ERL/GB indicate the James River seed oysters depurate Kepone.  The James
River supplied 90 per cent of all the seed oysters in Virginia, of which
50 per cent of that amount is exported.  Seed oysters are transplanted to
various growing areas and reach marketable size in two to three years.

    In February 1976, EPA recommended to the FDA "action levels" or allow-
able temporary levels of pesticide residues used as enforcement guides,
of 0.3 parts per million (ppm) of Kepone in the edible portion of shell-
fish (oysters and clams) 0.1 ppm in finfish, and 0.4 ppm in crabs.  EPA
also recommended a 0.03 ppm action level in processed oyster stew.  These
recommendations were made using classical estimate procedures for threshold
effects described in the next section of this paper.  At that time, EPA
committed itself to further consideration of this action level for possible
revision if new data warranted it.

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i.  Considerations in Establishing Current Action Levels

     There are at least three major considerations in adoption of action
levels.  First, toxicological, i.e., human safety, considerations are
overriding.  Second, there are analytical and residue chemistry considera-
tions, which are necessary to establish or confirm analytical method(s)
to enforce the action level.  A third consideration is economic loss,
i.e., what percentage of the fish and shellfish production will be rendered
unfit by the action level.

     A.  Toxicological Considerations

     The procedure used by the Toxicology Branch of EPA-OPP's
Registration Division to develop recommended action levels for
Kepone in finfish, shellfish and blue crabs was analogous to
the procedure used for establishing the acceptability of pesticide
tolerances.  The following data were reviewed when the Kepone
action levels were originally recommended and were rereviewed
for this reassessment:
  1 .   Acute Studies
      a.  Oral  LD5g - Feb. 9, 1959

      b.  Dermal LD50 - Feb. 9, 1959

  2.   Subacute Studies

      a.  21-Day Oral - Rat - Feb. 9, 1959

      b.  90-Day Oral - Rat - Feb. 9, 1959
                                                          t
  3.  Chronic Studies

      a.  2-yr. Rat Feeding - July 1961

      b.  2-yr. Dog Feeding - Feb. 1962

      c.  Mouse Reproduction - 1965

      d.   NCI Verbal  Oncogenic Report  -  Fall 1975

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     The initial correspondence in our files dates back to 1958 and sons
reports are undated.  Therefore the dates given above are approximations
in some cases.

In summary, the original review of the data indicated that:

     1.  Kepone is not acutely toxic and would be placed in  toxicity
         Category II for labeling purposes.  This category classification
         qives no indication of the subacute and chronic toxicity of
         the chemical.

     2.  There is evidence that Kepone is a cumulative toxin at relatively
         low levels  (approx. 5 ppm in rats) and that .within  a three
         month period 5 ppm produced a 10 ppm fat residue and 80 ppm
         produced a  400 ppm fat residue.

     3.  Tremors, characteristic of chlorinated hydrocarbons, occurred
         at 25 ppm in chronic feeding study.  Testicular atrophy and
         estrogenic  effects were evident at this level in rats and mice
         resulting in sterility in both sexes.  Females appear more
         susceptable to Kepone in all mammalian species tested.  Ten
         ppm is hepatotoxic in females.

     4.  In a two-year  rat study, 10 and 25 ppm may have produced
         hepatocarcinoma in both sexes.  Preliminary information from
         flCI lends credence to this suspicion.  Kepone produced a 24%
         incidence in female rats and approximately 80% in both sexes
         in mice at  levels from 5 to 40 ppm.  It appears that Kepone
         must be considered as a highly suspect carcinogen.

     5.  At 1 ppm in the rat a slight increase in proteinuria was noted
         and the severity increased with dose.  Therefore the MEL of
         1 ppm in rats  reported by Allied Chem. is questionable.

     6.  Preliminary analysis of Kepone residues in shell fish and fin
         fish indicated levels near and above the questionable rat NEL.
The recommended Kepone action levels for fin fish, shell fish and crabs
were developed in the following manner using a method analogous to
tolerance acceptability calculations.

     A.  Determination of Maximum Permissible Intakes (MPI)

         1.  Using  the questionable  1 ppm  "no effect level" from the
             two year rat feeding study and several safety factors
             (SF) a MPI was calculated for a 60 kg human.  (1 ppm in
             rat diet = 0.050 mg/kg  body weight/day)

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        Safety Factor     SF Value (Rat)     MPI (Man, 60K)

                          mq/kg bd. wt/day   mg/day
100
500
1000
2000
0.0005
0.0001
0.00005
0.000025
0.03
0.006
0.003
0.0015
    2.  Sample calculations:

        a.  Determination of safety factor value
                                              •
            0.050 mg/kg/day = 0.00005 mg/kg/day
             1000



        b.  Determination of MPI

            0.00005 mg/kg/day X 60 kg =  0.003 mg/day

B.  Determination of Food Factors (FF)  for each  of the  food  items
    in the daily diet of man.   (FF = % in daily  diet)

    1.  Fin Fish (Fresh and Frozen, edible weight)

        a.  Per capita consumption 1973*
            5.1 Ibs/yr X453.6 gr = 2313  gr/yr

        b.  Per capita consumption/day
            2313 T 365 = 6.34 gr

        c.  % of 1500 gr total  daily diet
            6.34 f 1500 = 0.42%

    2,  Shell  Fish (Fresh and Frozen, edible weight)

        a.  Per capita consumption 1973*.
            2.1 Ibs/yr X 453.6 gr = 952.6 gr

        b.  Per capita consumption/day
            952.6 gr ± 365 = 2.61 gr

        c.  % of 1500 gr total  daily diet
            2.61 * 1500 = 0.17%

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    3.  Blue Crabs

        a.  Per capita consumption 1969**
            0.213 Ibs/yr X 453.6 gr = 96.6 gr/yr

        b.  Per capita consumption/day
            96.6 - 365 = 0.26 gr

        c.  % of 1500 gr total  daily diet
            0.26 f 1500 =0.02%
               Consumption,  Prices,  Expenditures  Supolement  for
         TahlP Q   nni7   n'  Re      ••'°-  138'  US°A-Eco.  Res.  Ser.
          iaole 9,  p.  17,  Dec.
       **
           USDC Nat. Marine  Fisheries Ser. Circular 361  (1969).
C.  Determination of the Theoretical  Maximal  Residue Contribution
    (TMRC) of the recommended action levels to the cl.n'ly diet,
    assuming that the maximum allowed residue will be present
    in the food when consumed.

    1.  Fin Fish (action level 0.1  ppm= 0.0001 mg/kg of diet)
        0.0042  X 1500 gr X 0.0001  mg = 0.0006 mg

    2.  Shell Fish (action level  0.3 ppm = 0.0003 mg/kg of diet)
        0.0017  X 1500 gr X 0.0003  mg = 0.0008 mg

    3.  Blue Crabs (action level  0.4 ppm = 0.0004 mg/kg of diet)
        0.0002  X 1500 gr X0.0004 mg = 0.0001 mg

D.  Comparison of TMRC with the MPI to determine acceptability
    of recommended action level (SF = 1000).

    Food Item     Action Level     TMRC             MPI
                  ppm              mg/Total Diet    mg/day
    Fin Fish      0.1              0.0006  .         0.003
    Shell  Fish    0.3              0.0008  l         0.003
  •  Blue Crabs    0.4              0.0001           0.003
                                 T=0.0015

    In each case the recommended  action level produces a TMRC lower
    than the MPI derived with a 1000SF and leaves room for additional
    action levels for other food  items if the necessity arises  (total
    TMRC = 0.0015 mg/day vs 0.003 mg/day).

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     b.  Analytical  and  Residue  Chemistry  Considerations

      The only  previous  tolerance  actions  on  Kepone  were  a  temporary
tolerance of 0.1 ppm on  potatoes  (expired)  and  a current  tolerance
of 0.01 ppm on  bananas.   The  banana  tolerance represents  analytical
sensitivity and was  based  on  the  Registration Division's  Chemistry
Branch's assurance to  Toxicology  Branch  that  there  would  be no  real
residues in edible parts.

     (a) The Regulatory  method  for bananas  (PP# OE0919),  was published
in the Pesticide Analytical M. anual (PA4 ) Vol  II,  and validated  on
banana peel and pulp.  The method's  estimated sensitivity is 0.005 ppm.
The principle of this  method  involves  isopropanol/benzene extraction,
fuming sulfuric acid  cleanup, base partitioning,  and '1C or  EC gas liquid
chromatography  (GLC).  The procedure  is  said  to be  applicable for certain
other fruits, vegetables, milk  with  modifications for oily  samples.

     (b) HERL method(s):   The HERL procedure  is actually  a  system
of alternative  extraction, cleanup,  determinative,  and  confirmatory
procedures have been  used  in  various  combinations.   For fish and
shellfish, the  basic  procedure  was:   extraction of  lOg  sample with
25% toluene/Et  acetate,  cleanup  by micro Florisil column  or gel
permeation, or  base  partitioning.  Measurement  is by GLC  with any
of 5 optional GC columns and  any  of  4  detectors.   Some  analyses
have been confirmed  by GC/Mass  spectrometry with  chemical ioniza-
tion.

     The sensitivity of  the overall  procedure appeared  to-be about
0.01 ppm in fish and  shellfish,  judging  from  the  residue  values
reported.  However,  based  on  conversation  with  Dr. "ioseman, Analyti-
cal Branch, HERL,  this sensitivity may not  always be attainable.
Raw data (chromatogram)  has been  requested  from HERL so that it will
be possible to  gauge  the minimum  response  in  relation to  background.
The alternative procedures were  used  to  provide additional  assurance
through comparison of  results.   Reasonable  agreement on replicate
samples by the  alternative procedures  was  obtained  on most  samples
and there is no reason to  question accuracy of  results.

     (c)  FDA multiresidue methods:   Kepone had not  been  sought in
any FDA regulatory program, including  the  Total Diet Study.  Its
behavior has not been  sufficiently studied  in the PAl (FDA) mul-
tiresidue method for  chlorinated  hydrocarbons.   Preliminary studies
indicate that it is  not  detected  by  the  method, either  because  it is
not eluted from the  Florisil  column  or does not have a  favorable
partitioning co-efficient  in  the  acetonitrile/hexane partitioning
step.   FDA Headquarters  was then  devising  a method  to be  used by
the District Laboratories  in  the  current Kepone situation.   It
seemed likely that they  would go  with  some  version  of the current
multiresidue method  to minimize  impact on  their pesticide program.

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     (d)  Other methods:   There  have  been a few reports in the literature
of other methods  for  Kepone  but  these  appeared to be of limited interest
(Arant, F.S.J Econ.  Ent..  60:925-7,  1967)

3.  Residues in fish  and  shellfish  in  James River area (HERL data)

Fin fish examined were  fresh water  or  anadromous species only.  Kepone
residues ranged from 0.01-0.2 ppm  in  bottom feeders and trace to 3 ppm
in predator  fish.  These  residue values apparently are based on the
whole gutted fish.   Any action level  adopted would be on a similar
basis because the FDA Manual describes the fish sample to be "headed,
gutted, and  scaled."  Separate analyses were made by HERL on entrails
and liver with correspondingly higher  residue findings.

No data were presented  on salt water  food fishes (flounder, striped
bass, blues, seatrout)  which might  be  expected within the sampling
area.  This  omission  has  some practical significance in regards to
setting action levels.  Consumer hazards  arising from fresh water
fish could be controlled  (without  action  levels) by imposing fishing
restrictions on local waters, the  salt water acting as an effective
barrier to migration  from the quarantined area.   The risks from
consumption  of the migratory salt  water food fishes taken after
residence in the  James  estuary would  have to be controlled by an
action level implemented  in  a national surveillance program since
the fish might be taken elsewhere  in  Chesapeake Bay or long the
East Coast.  Levels  found in clams  and oysters were comparable and
ranged from  0.2 to 0.8  ppm.   No  analyses  of crabs were made.

The available data (total of about  26 samples) did not permit any
statistical  evaluation  as to distribution of residue levels in fish
or shellfish populations  within  the contaminated area during the
period of sampling.   Neither was the  sampling adequate to indicate
residue decline rate.  Both  factors are important considerations
in selecting an action  level because  they determine the extent of
economic loss, i.e..  a  given action level renders x% of the fish
population violative  at a given  time.

We had little or  no  information  on  any alterations Kepone may
undergo in water  or  marine organisms.   A rat metabolism study
indicates it is fairly  stable in mammals.  The related compound
Mirex  is known to degrade under  sunlight  or UV light to Kepone
and further  Cl 9  and Cl  10 degradation products of Kepone.*  On
the basis of present  information,  Kepone  per se must be considered
the residue  of concern  in fish and  the action level should reflect
this.

*G.W.  Ivie,  H.W.  Dorough, E.G. Alley,  J.  Ag Food Chem 22 no. 6, 1974

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  4.   New Considerations for Revising or Continuing Action Levels
       Current Action Levels
Subsequent to the above review the Toxicology  Branch  received  the  NCI
Carcinogenesis Bioassay'Report on Technical  Grade  Chlordecone  (Kepone).
A summary of the results, provided by MCI, confirming the  suspicion
raised by the two year rat study follows:

     "A carcinogenesis bioassay of technical grade chlordecone (Kepone)
     was conducted using Osborne-Mendel  rats and B5C3F1  mice.   Chlordecone
     was administered in the diet for 80'weeks at  two dose levels, with
     the rats sacrificed at 112 weeks and the  mice at 90 weeks.  The
     starting dose levels were 15 and 30 ppm for male rats, 30-and 60 ppm
     for female rats, 40 ppm for male mice and 40  and 80 ppm for female
     mice.  As these dose levels were" not well tolerated,  the  dose levels
     were reduced during the course of the experiment such that the
     average dose  levels were  as follows:  8 and 24 ppm for male rats,
     18 and 26 ppm for  female  rats, 20 and 23 ppm for'male mice and
     20 and 40 ppm for  female  mice.  Clinical signs of toxicity were
     observed in both species,  including generalized  tremors and
     dermatologic  changes.  A  significant increase (P  .05) was found
     in the incidence of hepatocellular carcinomas of high dose level
     rats and of mice at both  dose levels of chlordecone.  The incidences
     in the high dose groups were 7% and 22% for'male and female rats
     (compared with  0 in controls for both sexes) and 88% and 47% for
     male and female mice  (compared with 16% for male controls and 0
     in females);  for the  low  dose groups of mice the incidences were
     81%.for males and  52% for females.  In addition, the time to
     detection of  the first hepatocellular carcinoma  observed at death
     was shorter for treated than control mice and, in both sexes and
     both species, it appeared inversely related to the dose.  In
     chlordecone-treated mice  and rats extensive hyperplasia of the
     liver was also  found.  The incidence of tumors other than in the
     liver for chlordecone-treated.groups did not appear significantly
     different from  that in controls."

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   More recent food consumption values were used for finfish and shellfish
   than in the first recommendation; therefore, the figures presented than
   differ slightly from previous derived quantities.   The differences do
   not change the recommended action levels for each food item previously
   developed.  With the exception of the NCI carcinogenesis Bioassay
   Report, summarized below, no new toxicological  data has been received
   by the Toxicology Branch since the original  recommendation.
In the previous evaluation it was concluded^that an action level  of 0.02 ppm
for fish, clams and oysters could be supported with available analytical
methods.  This represented a bottom line figure subject to increase by
toxicology and economic impact considerations.  The figures which sub-
sequently issued were 0.4, 0.3, 0.1 ppm on crabs, oysters and fin fish,
respectively.

Given the present state of the methodology for Kepone, a 0.02 ppm
action level could still be supported if new toxicology information
requires such a reduction from present action levels.  That is, residues
on the order of 0.02 ppm can be measured when analytical procedures are
carefully controlled.  However, experience gained with the methods during
the intensive 1976 sampling program, including an interlaboratory quality
assurance (check sample) study, suggests that a level of 0.05 ppm should
be the lowest level at which any regulatory action should be taken.

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Detailed Considerations

1.  Commodity definition

It is important that action levels clearly specific the sample
to which it applies.  The following corresponds to  those used for tolerances
and are found in  FDA PAM Vol.  I, Sec. 141.12.

    (a) fin fish  and eel discard head,  tail, fins,  scales,  inedible
        bones and entrails, analyze with  skin  (e.-.cept  fish  with
        inedible  skin)

      (b) oysters, clams: examine homogeneous mixture  of
         -.eats  and liquor,  (exclude shell liquor.)

      (c) crabs: Discard  shell  and  viscera,  examine  edible
         portion  including  fatty deposits in wing tins.
         (for soft crabs use whole crab)

2.  Chemical entity measured

Although certain  rearrangements of Kepone-Mirex have  been reported,
there is still  no information  on significant metabolites occurring
in marine  organisms and  the residue of  concern is Kepone per se.
It is measured  against reference standard (EPA £ 7) in tetrahydrate
form  (corrected to anhydrous Kepone.)


3.  Improvements  in methodology

Significant advancements have  been made in Kepone methodology in
1976.  The advancements, however,  may  be  characterized as refine-
ments and  validation of  available  methods rather than any breakthroughs
Several analytical workshops between EPA  (KTP, Gulfbreeze,  and RD),
FDA, Virginia State laboratories,  and Maryland were instrumental in
eliminating numerous and troublesome optional  extraction, cleanup,
and determinative steps  employed  in the various labs  in early 1976.
From these meetings there emerged  a more  or  less standardized analyt-
ical method and useful agreement on sample preparation and use of re-
ference standards.

The method of choice for fish, shellfish, and  crabs is based on the
Allied Chemical Co. method  as  described in PAH Vol. II for bananas.
A modification  of this method  was  devised by Chemistry Branch, RD,
and used in the analyses of 60 fish samples  for the State of Va.
A paper on this method was  presented by Mr.  Watts,  CUM at a symposium
in Williamsburg VA. in May.

FDA was not successful  in  incorporating Kepone into their multi-
residue schemes.  They have  devised for  their  regulatory program a
modification  of the same method  (PAM  II), described above (see
program circular  7320.79A,  attach. C).  It is  this method which
will  be used  to enforce  Kepone action  levels  and it would be adequate
to enforce an action  level  of  0.05 ppm. Principle:  isopropanol/
benzene extraction, fuming  sulfuric acid  cleanup, base partitioning,
and GC/EC  detection.

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 Analysis of 1976 residue data on fish, shellfish, and crabs

 Through the soring, summer, and fall of 1976 several major sampling
 programs were carried out. The first of these was coordinated by the
 Virginia Division of Consolidated Laboratory Services. The cooperat-
 ing laboratories were RTP-EPA; Gulfbreeze-EPA, Registration Divison
 (CHM)-EPA, Annapolis-EPA, FDA Baltimore District and Virginia Insti-
 tute of Marine Sciences (VIMS). Sampling in this program was mainly
 in the lower bay and tributaries." The State of Maryland established
 a Kepone Task Force and conducted sampling, mostly in the upper bay.

 The FDA initiated a program calling for analyses of 304 samples of
 Kepone (and Mirex) through October 29, 1976. These samples were to
.be collected from commercial markets, with primary emphasis on Bay
 fish, but also some sampling of migrant bluefish along the east
 coast and some in the fire ant areas (Gulf Coast) to investigate
 possible Kepone residues from Mirex usage.

 Much of the data from these programs seems to have been freely
 interchanged, but we are not aware of any comprehensive summary of
 the 1976 sampling program. Such a summary could provide a base for
 predicting the level of residues likely to occur in Say fish pop-
 ulations in 1977, and. most importantly, what Percentage of the
 catch would fall within action levels.

 Certain statements in the files indicate that such statistical
 analyses may have already -been made. Example: Gov. Godwin "among
 all species of finfish tested	 samples above action level ranged
 from 7 to 16 ," (Richmond News Leader 10/13/76). Also, the National
 Fisheries Institute and Virginia Seafood Council (letter of 10/14/76,
 L.J. Weddig, Exec., Dir. in letter to J. Blanchard) says 14.2  of
 all species were above action level.

 Attachment A is a statistical evaluation of the distribution of residues
 in fish, shellfish, and crabs. The evaluation is based on all the
 data available to us as of 12/23/76.  It includes all of the
 residue data generated in the 1976 FDA regulatory program, data
 from the Maryland Kepone Task Force, and data from the program

 coordinated by the Virginia Division of Consolidated Laboratory
 Services, including 60 analyses made by our CHM laboratory,
 RTP, and Gulfbreeze.  The Virginia data may be incomplete.

 The data base includes a total of about 470 analyses of various
 portions of 25 species taken from various locations.

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4.  Results of Reassessment and Recommendations
                    t
    The Toxicology and Chemistry Branches have rereviewed all data on
which the original action level recommendations were made and have also
taken into consideration data received since those recommendations were
forwarded.  The latter include additional residue data and an NCI Chlordecone
Carcinogenesis Bioassay report.  The review confirms the original action
level recommendations, 0.1 onm finfish, 0.3 ppm shellfish, 0.4 ppm crab.

    The toxicological review was "calculated on the original basis of a
1000-fold safety factor applied to the rat chronic feeding study data.
Some minor variations from the original were seen in the Toxicology Branch
calculations due to the use of more recently developed dietary intake
figures in the calculations.  Because of the demonstrated carcinogenic
potential  of Kepone in two species of test animals, the lack of a clear
cut "no-effect level" in the two year rat feeding study, and the evidence
that Kepone is a cumulative toxin, no recommendation is made to revise' the
established Kepone action levels at the present time.

    The major recommendation change from the Chemistry Branch Review,  in
light of additional experience with the analytical method, is to adopt
0.05 ppm (as opposed to 0.02 ppm) as the baseline enforcement action level
subject to modification by toxicological or benefit/risk parameters.
Acceptance of 0.02 ppm would require extremely careful control on the
analytical method.

    As part of the evaluation of current action levels, an independent
study of risks and benefits was performed by scientists in the Office of
Special Pesticide Reviews (attached).  Emphasis was placed on the identi-
fication,  articulation and measurement of variables, either health or
economic related, which are affected by alternative regulatory options.
Specifically, the paper presents an analysis of the human health impacts
which might be associated with maximum Kepone exposure (residues equaling.
the current action levels) from Chesapeake Bay finfish, shellfish and
blue crabs.  Health impacts were evaluated using tv/o currently accepted
models for cancer assessment—> the "one-hit model" and the "log-probit
model'—under several alternative patterns of human seafood consumption.
In an attempt to tie a measure of benefit to the seafood sector affected
by Kepone action levels, the study also examined the total protein pro-
duction for human consumption arising from Chesapeake Bay fisheries  as
well as other economic characteristics.   The information contained in the
Office of Special Pesticide Review's study will be used as input into
the decision process regarding recommendations for Kepone action levels.
                                                                       (3.

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                                                         Attachment A
                 Surnnary And Analysis Of The Currently

                 Available Kepona Residue Pata
Introduction
     Samples of Fin Fish and Shell Fish fron the Virginia  and Maryland
Haters of the Chesapeake Cay and its Tributary Rivers have been collected
1n several najor sampling programs conducted by the States Maryland and
Virginia and the Food and Drug, Administration and the Environmental
Protection Aqency.  To our knov/ledge no complete summary of all the Kepone
Residue analysis from these programs is availably yet.  However, the analy-
tical results from over 600 samples collected in these programs were pro-
vided to us by Or, Paul Cornel iussen of FDA and Dr. Jack Blnnchard of FPA.
Of these samples adequate information concerning species,  collection point
and bow ths sample was prepared for analysis v/as available for 470 of these
samples.  These 470 samples represented about 25 different species of marine
life.  A discussion of these residue data are presented here.

     Samples collected from the Janes River (up-stream from the Janes P.iver
Bridge) were considered separately from the Chesapeake Bay (including the
Hampton Roads area).  This was done because of the high levels found in the
Janss River samoles and because the State of Virqinia has  banned .fishing in the
Jake's River.  Consideration of data was further divided into fin fish; clams,
oysters conch and muscles; and crabs, because it is on these commodities that
the current action levels havo been established.

     In general the data for these samples showed markedly non-normal dis-
tribution such that approximately 70* of the reported values are below their
respective arithmetic means.  The third moments about the  mean (a measure
of skewnass:  it equals 0 for a normal curve and less than 0.5 for approxi-
mately random distributions) ranged from 4 to 5 for most of the distributions.
Because of the non-nornal distribution of ' these data the statical inferences
that can  be drawn  are United.  However, the conclusions that can be drav/n
are discussed below.
              ke Bayt   Residue data  and adequate background information for
 193 samples representing 16  species of fin fish taker, from the Chesapeake
 and its tributary rivers (except  the Janes) w
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        g the shad, the residue levels reported ranged from 0 to O.ftC. pr;^
and aypj-gged 0.056 ppm with a standard deviation of 0,114 pom,,  The- shad
averr. pd 0.117 ppm with a standard deviation of 0.223 ppm.  However,, be-
cause of the non-normal distribution of the data no definitive conclusion
can be reached as to whether this difference is significant.  (See Con-
culslon below).  156 or 30% of the reported values were below the mean.
Only 8* of the samples collected exceeded the current n.l ppm action level.
Approximately 5X exceeded the 0.2 ppm level.  Mo definitive conclusion as
to what percentage of fish caught in the Bay would be expected to exceed
the 0.1 ppm love! can be made.  However, these data appear to indicate that
about £-10% of the fish caught niay be over the current action level.

    James River:  Residue data and adequate background Information for 51
samples representing 10 species of F1n F1sh taken from the James River were
available.  Residue levels reported ranged from 0 to 3.1 ppm.  The average
value for all James River F1n Fish was .931 ppm with a standard deviation of
1.85 ppm.  Again almost 70% of the reported values were below the mean.  55%
of all sample exceeded the current 0.1 ppm action level, and approximately
T/3 of the samples exceeded the 1 ppm level.  The residue levels reported
for the 25 shad samples taken from the James River were no higher than other
species, in fact their average residue level was only 0.503 ppm.  The data
tend to indicate that the average residue level 1n F1n F1sh taken from the
Games River would approach 1.0 ppm.

 Clams, Oysters. Conch, and Mussels

     Chesapeake  Bay:  Residue data for 110 samples of these shell fish taken
 from the bay were considered.  Residue levels reported ranged from 0 to Q.7G
 ppm.  The average value was 0.046 ppm with a standard deviation of 0.111 ppm.
 Again the distribution of residue values was badly skev/ed with 742 of all
 reported values below the mean.  Only 2 samples or about 2% bore residues
 above the current 0.3 ppm action level.  The data appear to indicate that
 residue levels  1n these shell fish taken from the Bay are comparable to the
 levels in Fin  Fish.

     James River:  Residue data for 55 samples of these shell fish taken from
 the  James River are available.  The reported residue levels ranged from 0 to
 0.51  ppm.  The  average residue level was 0.209 ppm with a standard deviation
 of 0.128  ppm.   22£ of  these samples exceeded the current 0.3 ppm action level,
 The  data  tend  to indicate that the levels 1n this class of shell fish taken
 from the  James River will be  less than the corresponding levels in Fin Fish.

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    Chesapeake Bay:  Residue data and adequate background information are
available for*48 sairples of crabs.  The edible portions of both hard and soft
crabs were included,  Ths soft crab data was included in these data because
of the limited number of samples available.  The reported reside values ranged
from 0 to 3.44 ppn.  Trie residues averaged .261 ppro with a standard deviation
of 0.551 ppm.  Again almost 70S of the reported values were below the mean.
However* 192 of sa/nples were above the current 0.4 ppn action level and 13?
were above the 0.5 ppro level.  These data tend to indicate that average resi-
due levels in crab neat frosn crabs taken from the bay will approach 0.3 ppn
and that about 20* of the crabs B*y exceed the current action level.
    Jaoes River:  Only five samples of crabs taken from the James River are
available.  Residue values ranged froro 2.04 to 3.10 ppro and averaged 2.G9 ppm.

    In conclusion tJie data demonstrate a markedly non-normal distribution;
thus i indicating that there were additional pararncters effecting the Kepone
residue levels in fish than wera included in cur analysis.  The first para-
meter considered v*as geographical location „ but further dividing of the data
into sraaller areas for consideration provided little improvement in tha dis-
tribution of residues.  Because Kepona is a persistent compound the length
of time a specimen is exposed (generally its age) would be expected to be an
important factor.  However, inforration as to age or even weight of samples
was only available for a portion of the data, and thus could not be included
in our considerations.  Also the season of the year a sample was taken in
sonc species could significantly effect the resulting residue levels.

    Thus, tha data indicate that the inferences that can.be drawn frora these
data are vsry limited because it can not bo demonstrated that the undefined
parameters effecting the distribution of residues will  be consant for any
subsequent sailings.  Perhaps, when a coprplete sionary of all  the samples
collected in the various state and federal sampling programs is  available a
better delineation of parameters affecting, residue levels will  be possible,
and wore definitive predictions regarding residue levels can be drawn.

    Additional Keponn residue samples wars collected by the Food and Drug
Administration, from the waters of the Atlantic Ocean and the Gulf of Mexico.
The residue data frcci the analyses of these samples arc also available.   Hcw-
   r t|-iesc data wero not included in this evaluation, because of the much
lower exnosurs of these samples to Kepone residues.

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    Chesapeak« Bay:  Residue data and adequate background information arc
available for~48 sairples of crabs.  The edible portions of both hard and soft
crabs were Included.  The soft crab data was Included 1n these data because?
of the limited number of samples available.   The reported reside values ranged
from 0 to 3.44 ppn.  The residues averaged .261 ppm with a standard deviation
of 0.551 ppm.  Again almost 70S of the reported valups were below the mean.
However. 192 of sa/nples were abova the current 0.4 ppn action level and 133?
were above the 0.5 ppro level.  These data tend to Indicate that average resi-
due levnls In crab neat from crabs taken from the bay will approach 0.3 ppn
and that about 20* of the crabs my exceed the current action level.

    Janes River:  Only five samples of crabs taken from the James River are
available.  Residue values ranged from 2.04 to 3.10 ppro and averaged. 2.59 ppm.

    In conclusion tJie data demonstrate a markedly non-normal distribution;
thust indicating that there wore additional  pararnetcrs effecting the Kapone
residue levels In fish than wera Included 1n our analysis.  The first para-
meter considered was geographical location,,  but further dividing of the data
Into sraaller areas for consideration provided little improvement 1n tha dis-
tribution of residues.  Because Kepona Is a  persistent compound the length
of time a specimen 1s exposed (generally its age) would be expected to be en
Important factor.  However, 1nforrot1on as to ngr: or even weight of samples
was only available for a portion of the data, omJ thus could not be included
in our considerations.  Also the season of tho year a sample was taken 1n
sonc species could significantly effact th>» resulting residue levels.

    Thus, the data indicate that tha Inferences that can be drawn fron these
data are vsry limited because it can not bo  demonstrated that the undefined
parameters effecting tha distribution of residues will  be consant for any
subsequent sailings.  Perhaps, when a conplate summary of all  the samples
collected 1n the various state and federal sampling program is  available a
better delineation of parameters affecting,residue levels will  ba possible,
and wsr*? definitive predictions regarding reside levels can be drawn.

    Additional Kepom» residue sainples wera collected by th«>  Food  and Drug
Administration, from the waters of the Atlantic Ocean and tho Gulf of Mexico.
The residue data frcci the analyses of these  samples arc also available.  Kcw-
   r these"data wero not Included 1n this evaluation, because of  the nuch
      exposure of these samples to Kepone residues.

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