£ 535 /i         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY

                            W ASH INGTCN. O C 20-160
                                    EPA-SAB-DWC-90-015
  April 26, 1990
  Honorable William K. Reilly
  Admi nis tra to r
  U.S. environmental Protection Agency
  401 tl Street, S . W.
  Washington,  D.C.   20460
  Subject:  Science Advisory Board's review of the documen'
  "Reaction Kinetics and Reaction Products of Chlorine and
  Chioramines in the Digestive Tract"
  Dear Mr.  Reilly,


       The  Toxicology Subcommittee of  the  Science Advisory  Board's
  Drinking  Water Committee met  in Washington, D.C.  December  8,  1939
  to review the document produced for  the  Office of  Drinking Water
  "Reaction Kinetics and Reaction Products of Chlorine  and
  Chloramines in the Digestive  Tract".

       The  document  reviewed  focuses  on  the  extrapolation  of
  information about  reactions between  commonly  used  disinfectants
  and saliva and gastric juices  at high  dose  levels  to  predict  the
  reactions of  the much lower doses commonly  found  in disinfected
  drinking water.  The Subcommittee agrees that the  mechanisms
  involved at low doses differ  from those  of  high doses and thus  ±
  simple linear relationship  should not  be used for  extrapolation.
  Using  current methods the toxicity  of  the  disinfectants  may  no-
  be distinguishable from  the  toxicity of  the by-products,  and  -_ - ; s
  the' toxicity  of the by-products should be  studied separately.
  Thus,  studies are  needed  for  the character  and the toxicity  of
  the by-products at low dose  levels  both  for chlorine  and for
  chloramines used as disinfectants.   In addition  several
  components of a major research program are  recommended.

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     We  appreciate  the  opportunity  to  conduct  this particular
scientific  review.   We  ask  that  the  Agency  formally  respond to
the scientific  advice  provided herein.
                    Sincerely,
                     /         Q  /9/   a
                    JjjAfyw^  C.. L^^
                   I\_/*'  n         —•—"
                    Raymand  C.  Lo£nr
                    Chairman
                    Executive  Committee
                    William  H.  Graze
                    Chairman
                    Drinkiog Water  Committee
                         -
                    Ve r ne A.  Ray
                    Chai rman
                    Toxicology Subcommittee

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         FPA       U.S. Environmental        Washington, DC
                     Protection Agency        EPA-SAB-DWC-90-OL5
                of the
               Committee
                 of the
                             and
       of           and                in the
                   Tract
A      ADVISORY BOARD REPORT                          1990

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                      1.0

     The Toxicology Subcommittee of the Science Advisory Board's
Drinking Water Committee net in Washington, D.C., on December 8,
1939 to review the document produced for the Office of Drinking
Water entitled "Reaction Kinetics and Reaction Products of
Chlorine and Chloramines in the Digestive Tract", written by Dr.
Frank E. Scully, Jr.  (Old Dominion University) and Dr. William
'white  (University of Vermont) .

     The document focuses on the extrapolation of information
about reactions of saliva and gastric juices with disinfectants
commonly found in disinfected drinking water at high dose levels
to predict the reactions that may occur of much lower dose
levels.  The Subcommittee agrees that the mechanisms involved at
low dose levels differ  from those as high dose levels, and that a
simple  linear relationship therefore, should not be used for
extrapolation.  Further, the toxicity of the disinfectants may
not be  distinguishable  from the toxicity of the by-products, and
thus the toxicity of  the by-products should be studied
separately.  Consequently» studies are needed for the
characterization and  the toxicity of the by-products at low dose
levels  both  for chlorine and  for chloramines used as
disinfectants.  Although chlorine reacts quickly, chloramine
tends  to be  more stable in saliva and gastric juices.  Due to the
stability  of chloramine in saliva there is some potential for
adsorption in the mouth, esophagus, and stomach.  Therefore, scne
toxicological effects of chloramine may be attributable to the
parent  compound.

      The Subcommittee recommends that this problem  area receive
more  research  support.  The  particular research  recommended  hers
should include  both ia_vivo  and  in^jnJbrjD studies.   Specific
research  efforts  recommended include verifying  the  differences
between rat and human saliva,  performing studies on the by-
products  formed and determining  the  reaction  chemical  by-product^
that  nay be formed.

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c. Do the findings only apply to oxidants or     other chemicals
     Implicated?

d.     the toxicology of disinfectants be distinguished from the
     toxicology of in_vlvo by-products at typical drinking water
     exposure levels?

e. Are further kinetic         needed to quantify rates of
     decomposition that would be biologically significant?  If
     so, what chemical by-products  (in__vivo.) studies should be
     conducted to identify biologically significant products?

f.  Could the Committee suggest in vivo toxicological studies
     that would help to specify and quantify the toxicology of
     biologically active species produced jn^vivo?

     The study of reaction kinetics of          oxidants such as
disinfectants is complex for several reasons.  First, it is
difficult to quantify     reactions           mouth and stomach
    leaky reaction           Second,           and stomach
dynamic systems and ingestion of food or      the smell of  food
generates acidic fluids that can change reaction kinetics
dramatically.  For       and other  reasons  discussed below, the
existing knowledge in this area is  not complete.  Because of the
importance of this information in regulating disinfectants  and
disinfection by-products, the Committee recommends that studies
be conducted to provide the missing information.
          3.0            OF                   THE

      In  the  report that follows several         raised by
 Office of  Drinking Water are addressed,  followed  by a
 conclusion from     Committee in Section 3.6.   It is important to
 recognize,  however,  that the issues tend to  overlap and     not
 necessarily  independent,

 3.1  How do kinetic considerations of chlorine and chloramine
                     with endogenous           affect the
                          of available      on the toxicity of t'r.e
                         themselves?

      Available information                    chlorine      not
 survive  long        In saliva to be available for            and
 to produce any direct systemic effects of toxicological

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significance.  It is possible that very high doses of chlorine
(» 100 ppm)  might be high enough to provide some      chlorine,
but       are no      to         that     resulting
concentrations would be sufficient to         significant
toxlcological effects.  Thus     Subcommittee concurs that in the
procedure of extrapolating the data obtained from animals
administered high doses of chlorine, linear extrapolation may not
be justified.

     On     other hand, chloramlne has sufficient stability in
saliva so that there is the potential for some chloramine
absorption via the buccal mucosa, esophagus, and stomach.
Therefore, some of the toxicological effects produced by
chloramine may be attributable to the        compound..

     The report reviewed here does raise concerns about the
potential role of secondary products formed from
disinfectants.  As discussed in the report, there Is reason to
believe that the nature of       products will vary, depending on
of disinfectant concentration.  Thus,     toxlcological hazards
of           the disinfectants will vary, depending on.the
amounts and  nature of  the products  formed within discrete ranges
disinfectant concentration.  It  is possible that products may be
formed at low       which     not'observed at high       and that
these     more toxic or less toxic than those          at high
doses.  Consequently,  the Committee            avoiding the
assumption of a simple linear relationship between production of
these secondary products and disinfectant dose.  Studies should
be made of the actual  dose-response relationships of the reaction
products, to the extent possible.

3.2       consideration of  chlorine and chloramine reactivity
          with endogenous compounds affect  the characterization
          of risk  associated with  the  use of these chemicals  as
          disinfectants?

          formation of           products in the  mouth, esophagus
and          following the  ingestlon of chlorine  or chloramine
could  contribute  to the potential  hazards  associated  with  the use
of these  disinfectants.   However,  the  impact on  the  risk
characterization  cannot be  predicted  on  the basis  of  current
 information.  -The  nature  of by-products  formed,  the  variability
of their  formation     destruction with  varying  concentrations  of
disinfectant,  and their toxicology will      to  be explicitly

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considered.  It is doubtful that these problems can be adequately
dealt with using the currently available model studies that were
discussed in the report.  Specifically, the model discussed
dissipation of residual disinfectant but was able to identify
reaction products only in the most general of terms.

     As mentioned above, there is some possibility that some
portion of a chloramine dose could be systemically absorbed.  In
this case, the biologically available absorbed dose would have to
be known and its systemic concentration correlated with the
resulting toxicity caused by all components to determine whether
the chloramine itself or by-products are of greater concern.
Further, if the carcinogenic or non-carcinogenic toxic effect :_ 3
observed only at very high levels of exposure, it is not always
the case that it can be scaled down linearly to low doses.  At
high doses chloramine levels may overwhelm the ability of the
endogenous compounds in saliva or gastric juice, and of exogenous
compounds such as food, to react with the chloramine.  At lower
dose levels the small amounts of chloramine would not be absorbed
to the  same degree and the chloramine would be unlikely to have
much toxicological significance. This plausible non-linear
mechanism argues against using a simple linear extrapolation  for
the dose-response relationship in every case.

3.3  Can the toxicity of disinfectant be distinguished from the
          toxicity of in vivo by-products at typical drinking
          water exposure levels?

     In general, the bioassay systems cannot distinguish
differences between toxic  effects produced by the parent
disinfectant compound and  those produced by secondary products
generated  either by chemical or biochemical processes.  However,
insight into potentially toxic products generated chemically  or
biochemically could allow  for the more complete prediction  of
toxiqity.

     To pursue this avenue,  we must  increase  our understanding  z~
these  by-products by studying them separately.  However,  in order
to  do  this, the by-products  must be  synthesized  in  quantities
sufficient  for toxicological testing.  Endpoints of toxicity  ir.
these  by-product  toxicity  studies might correlate with those  see-
in  toxicity studies with the disinfectant  agent.   In such a case.
the toxicity  could  be  attributed to  the secondary  by-product.

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However, It should be            that high levels of primary
disinfectant     be producing by-products, concentrations of by-
products, and toxicity endpoints that are different from those
that result at lower level         This could be     to
differences in distribution, metabolic pathway kinetics
chemical characteristics of the primary disinfectant in reaction
with body fluids or tissues.  At typical drinking water levels,
(i.e. low concentration of primary disinfectant) it is likely
that such low levels of secondary products are formed that it may
be impossible technically to find and prove the involvement of
secondary products in toxicity.

3.4  What mass balance studies are needed to show which
          competitive kinetic rates     important in the
          formation     decomposition of biologically significant
          by-products?

     Before comparative kinetic studies are undertaken,
reactions     by-products that are important must be identified.
Because  these disinfectants     both oxidants and chlorine
substitution agents, the stoichiometry of the reactions must be
studied.  Disinfectants that both oxidize     form new products
by substitution typically result in different products as a
function of disinfectant dose and substrate concentration.
Products and reactions important at low concentrations     becor.e
oxidized         unimportant at high doses.  It is therefore
recommended that reactions  and by-products produced be identified
as a function of halogen concentration.

     After the  important by-products and  the reactions producing
them have been  identified,  further kinetic studies are needed  to
quantify rates  of  formation    decomposition for those that are
biologically significant.        studies  will likely be different
for  chlorine and chloramine, as discussed below.

3.4.1'  Chlorination

     The report being  reviewed here already has  identified that,
with     large  concentration of reducing                 in the
digestive tract, chlorine  at normal dose  levels  is  reduced to
chloride.  The  issue is  the formation  of  biologically  significant
by-products  and their            decomposition.  The  first
question is,           by-products                     at  low
doses  of chlorine  to compete with the  reduction reactions

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removing free chlorine to chloride?  Secondly, are the toxic by-
products        by either halogenation or oxidation reactions
stable enough to be biologically active?  The report did not
identify the likely additional reducing        present in_viyo.
These reducing        include reduced sulfur functionality,                 {
nitrite, iodide and ammonia.  The Committee recommends further              |
studies on chlorination          only if studies      that stable
toxic by-products     produced.

3.4.2  Chloramination

     The reactions which need further study following
chlorination of drinking water         reactions of chloramines:
NHjCl and organic-N-Cl.   These compounds are much less likely to            :
be reduced to chloride, as mentioned above.  The overall effect             ;
of reducing        in human saliva     gastric fluid on reducing            .
NH2C1 and organic-N-Cl can be easily studied by measuring oxidant
demand.  Products of reactions with cells and secretions lining             ]
    gastrointestinal tract     less easily modelled.  The                   i
question which needs additional study is the extent of formation
of toxic  (perhaps non-oxidant) by-products from NH2C1
organic-N-Cl reactions and potential direct systemic toxicity  of
these compounds should they survive unreduced.  The major  gaps  In
the      are the reaction kinetics of       chloramines,
especially under gastric fluid chloride and pH levels, and the
reactions with the cells lining the gastrointestinal tract.
Additional chloramine kinetic                          on  both
oxidation and substitution  reactions, to fill the  existing data
gaps.   Also studies need to be made on  interactions with nitrite,
ammonia,  iodide             sulfur            found in the
digestive tract but not are discussed in the  report.

3.5  Are ilLJfJLvo toxicological studies        to help specify  and
          quantify the toxicologically  active species produced in


     Performing in_^ivo studies may be  difficult.  On the other
hand,  it  will be difficult  to  define the risk from water
disinfection       on the  risk from one or  even  a  few such active
by-products         of unknowns regarding  relative concentratlcr.5
under  realistic conditions      possible interactions.

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for reactions at low doses that could be different both
qualitatively and quantitatively from       which occur at high
doses.  Chlorine     react so quickly that           not
significant toxicological effects at low       linearly relatable
to       at              Chloramine is              at the
degree at low       as it is at high         At
chloramine            overwhelm the ability of     endogenous
          in saliva or gastric juice     of     exogenous
               as food to react with it.  Further, it is possible
that toxic           are created at low       which become
subsequently destroyed at high doses.          of this possible
difference in     reactions  (with possible differences in
toxicity),     Subcommittee does not recommend that high-to-low
dose extrapolation be used for these compounds.  To properly
assess their toxic potential, it is necessary to conduct studies
throughout the concentration range encountered in disinfected
waters.

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                              ROSTER
                      SCIENCE  ADVISORY  BOARD
                     TOXICOLOGY
                                  8,  1989
ACTING CHAIRMAN
Dr. Verne Ray
     Medical Research Laboratory
     Pfizer, inc.
     Groton, CT  06340
Dr. Richard Bull
     College of Pharmacy
     Washington State University
     Pullman, WA  99164-6510

Dr. Gary Carlson
     Department, of Pharmacology     Toxicology
     School of Pharmacy
     Purdue University
     West  Lafayette, IN  4790?

Dr. Donald Johnson
     Department of Environmental  Sciences     Engineering
     School of Public Health
     University of North Carolina
     Chapel Hill, NC  27599

Dr David Kaufman
     Department of Pathology
     University of North Carolina
     Brinkhous-Builitt, Room  515
     Chapel Hill, NC  27514

Dr, Thomas Tephly
     Department of Pharmacology
     The Bowen science  Building
     University of Iowa
     Iowa  City,  IA   52242

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EXECUTIVE SECRETARY

Dr. C. Richard
     Science          Board
             A-101F
     Washington^ D.C.  20460
STAFF_SECRETARY

Darlene A. Sewell
     Science Advisory Board
     USEPA   A-101F
     Washington, D.C.  20460
S TA FF_D IRECTOR

Dr. Donald G.Barnes
     Science Advisory Board
            A-101
     Washington, D.C.  20460

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