Page 1 of 6  1  Halohydantoins Case Overview Reregistration Case Number 3055 A. Chemical Overview This Reregistration Eligibility Document ( RED) covers a group of active ingredients that are collectively known as the Dihalodialkylhydantoins or Halohydantoins. The following active ingredients are covered by the RED.

Common Name: Dihalodialkylhydantoins or Halohydantoins Chemical Name CAS# MW OPP Chemical Code 1 Bromo 3 Chloro 5,5 16079 88 2 241.5 6315 Dimethylhydantoin ( C5 H6 Br Cl N2 O2)

BromoChloro 5,5 32718 18 6 241.5 6315 Dimethlyhydantoin ( C5 H6 Br Cl N2 O2)

1,3 Dibromo 5,5 77 48 5 286 6317 Dimethylhydantoin ( C5 H6 Br2 N2 O2)

1,3 Dichloro 5,5 118 52 5 197 28501 Dimethylhydantoin ( C5 H6 Cl2 N2 O2)

1,3 Dichloro 5 Ethyl 89415 87 2 211 128826 5 Methylhydantoin ( C6 H8 Br Cl N2 O2)

Basic Manufacturers: Albemarle Corporation Ameribrom, Inc./ Dead Sea Bromine Group Bio Lab, Inc./ Great Lakes Chemical Corporation Lonza Inc. Page 2 of 6  2  Chemical Characterization Structurally, the halohydantoins consist of a central organic hydantoin ring moiety ( either dimethylhydantoin or ethylmethylhydantoin) to which halogen atoms ( bromine and/ or chlorine) can be attached at both the 1 and 3 positions on the hydantoin ring.

In concentrated form, the halohydantoins are very stable. Upon usage, which involves dilution in water or a water system, the halohydantoins rapidly decompose to release chlorine and/ or bromine and dimethylhydantoin ( DMH) and, for certain products, ethylmethylhydantoin( EMH). These released halogens react with water to form either hypochlorous or hypobromous acid, which is the actual biocidal agent. Accordingly, the halohydantoins are essentially delivery systems for hypochlorous and hypobromous acid.

The two key advantages of halohydantoins over inorganic forms of chlorine and bromine are that they are less hazardous to handle and store ( because of the corrosive nature of the inorganic forms of chlorine and bromine) and the fact that the bound form allows for a slower and more manageable release of the halogen atoms when they are placed in water. The latter characteristic helps to maintain a more consistent halogen level in the water source where they are added.

B. Use Profile The halohydantoins are used for microbial control in water and water systems. In particular, the halohydantoins are used as disinfectants in commercial and residential swimming pools, spas and hot tubs; as sanitizers for treatment of toilet bowl water in homes; and for controlling bacterial and fungal contamination in a variety of industrial water systems such as industrial cooling water systems, pulp and paper mill process water, wastewater treatment systems, air washer water systems, sewage systems, industrial processing water, irrigation systems, and ornamental ponds.

The only food use for the halohydantoins is as a slimicide in the manufacture of food contact paper and paperboard. The 1998 Antimicrobial Regulation Technical Corrections Act ( ARTCA) gave the U. S. Food and Drug Administration ( FDA) jurisdiction for regulating dietary residues of food contact slimicides under Section 409 of the Federal Food, Drug and Cosmetic Act ( FFDCA). In addition, EPA is responsible for registering the slimicide product under FIFRA. The FDA regulation that permits the halohydantoins to be used as slimicides in the manufacture of food contact paper and paperboard is in 21 C. F. R. Part 176.300. Page 3 of 6  3  SUPPORTED USE SITES:

Indoor Food No use sites identified Indoor Non Food Hydrostatic Sterilizer Water Systems Pasteurizer/ Warmer/ Cannery/ Retort Water Systems Transportation Cleaning Indoor Residential Toilet Bowls and Urinals Bathroom Premises/ Hard Surfaces Aquatic Non Food Residential Swimming Pool Water Systems Air Conditioner Hot Tubs & Spas.

Aquatic Food Pulp and Paper Mill Water ( food contact paper)

Aquatic Nonfood Ornamental Ponds/ Aquaria Irrigation Systems Aquatic Non Food Industrial Air Washer Water Systems ( includes air scrubbing and washing) Evaporative Condenser Water Systems Pulp and Paper Mill Systems Sewage/ Wastewater Treatment Systems Commercial/ Industrial Water Cooling Tower Systems Heat Exchanger Water Systems Industrial Processing Water Photo Processing Water Secondary Oil Recovery Injection Water Oil Recovery Drilling Muds And Packer Fluids Recirculating Cooling Water ( Greenhouses & Nurseries) Page 4 of 6  4  APPLICATION RATES: Indoor Non Food For recirculating cooling water systems the typical rate of application ranges from 0.1 to 0.75 lbs per 1,000 gallons of water with 5 70 ppm Halohydantoins with 0.5  5 ppm Halogen by method of PLS, PS feeders, PL and PU. End Use pack size ranges from 25 to 2,200 lb. for briquettes, tablets and in granular form. The end use pack size for gels range from 22 oz to 400 pounds.

For transportation cleaning, 1 to 5 ppm of Halohydantoins with 1 to 3 ppm Halogen is used at a typical rate of .025 to 0.1 lbs per 1,000 gallons of water. PLS or PS feeder is used for Briquettes and tablets in end use pack sizes that range from 20 to 50 pounds.

Indoor Residential For toilet bowls and urinals, 1 to 5 ppm of Halohydantoins with 2 to 10 ppm of Halogen is used by method of PLS at a typical rate of 17 to 25 grams per month in briquettes and tablet form.

For bathroom premises and hard surfaces, 588 ppm of Halohydantoins with 1,125 ppm of Halogen is used at a typical rate of 0.45 ounces per every 3 gallons of water applied by method of mop, BR, and W. Product is in granular and tablet form in end use pack sizes ranging from 1 to 50 pounds.

Aquatic Non food Residential For residential and commercial pools, 50 to 300 ppm of Halohydantoins with 1 to 4 ppm of Halogen is used at a weekly rate of 0.5 to 2.5 pounds per 10,000 gallons of water. Product is dispensed through a PLS/ PS feeder in tablet, briquettes and granular form from end use packs sizes that range from 20 to 50 pounds.

For residential and commercial spas, 30 to 100 ppm of Halohydantoins with 2 to 6 ppm of Halogen is used at a weekly rate of 0.1 to 0.5 pounds per 1,000 gallons of water. Product is dispensed through a PLS/ PS feeder in tablet, briquettes and granular form from end use packs sizes that range from 1 to 50 pounds.

For use in air conditioner and dehumidifier basin/ drip pans, one ore more 20 gram tablets are placed in the basin or drip pan from end use pack sizes are in 25 and 50 pounds.

Aquatic Food For Pulp & Paper w/ food contact, 5 to 25 ppm of Halohydantoins with 1 to 5 ppm of Halogen is used at a typical rate of 0.16 to 2.0 pounds per ton of paper. A PLS/ PS feeder Page 5 of 6  5  or PU is used to dispense product in briquette, granular, powder, tablet and gel form. End Use pack size ranges from 25 to 2,200 lb. for briquettes, tablets and in granular form. The end use pack size for gels range from 22 oz to 400 pounds.

Aquatic Non Food For Decorative Waters without fish, 50 to 260 ppm of Halohydantoins with 1 to 3 ppm of Halogen is used at a weekly rate of 0.5 to 1.4 pounds per 10,000 gallons of water. A PLS/ PS feeder is used to dispense product in briquette, granular, tablet and gel form. End use pack size ranges from 22oz to 400 pounds for gel and 20 to 50 pounds for all other forms.

For irrigation and automatic water distribution systems ( not for use on food crops) 8 to 24 ppm of Halohydantoins with 5 to 15 ppm of Halogen is used at a typical rate of 15 to 45 grams per 1,000 gallons of water. A PLS/ PS feeder, PU, or PL is used to dispense product in granular, powder and tablet form. End use pack sizes are in 3 and 25 pounds.

Aquatic Non Food Industrial For Recirculating cooling systems, 5 to 70 ppm of Halohydantoins with 0.5 to 5 ppm of Halogens used at a typical rate of 0.1 to 0.75 pounds per 1,000 gallons of water dependent on level of biological control. A PLS/ PS feeder, PU, or PL is used to dispense product in granular, briquettes, tablet and gel form. End use pack sizes range from 22 oz to 400 pounds for gel form and 25 to 2,200 pounds for all other forms.

For once through cooling systems, 5 to 35 ppm of Halohydantoins with 0.5 to 5 ppm of Halogen is used at a typical rate of 0.1 to 0.3 pounds per 1,000 gallons of water. A PLS/ PS feeder, PU, or PL is used to dispense product in granular, briquettes, tablet and gel form. End use pack sizes range from 22 oz to 400 pounds for gel form and 25 to 2,200 pounds for all other forms For Pulp and Paper, 5 to 25 ppm of Halohydantoins with 1 to 5 ppm of Halogen is used at a typical rate of 0.16 to 2.0 pounds per ton of paper. A PLS/ PS feeder or PU is used to dispense product in granular, powder, tablet and gel form. End use pack sizes range from 22 oz to 400 pounds for gel form and 25 to 2,200 pounds for all other forms.

For sewage and wastewater treatment systems, 5 to 35 ppm of Halohydantoins with 0.5 to 5 ppm of Halogen is used at a typical rate of 0.1 to 0.75 pounds per 1,000 gallons of water. A PLS/ PS feeder, PU, or PL is used to dispense product in briquette, granular, tablet and gel form. End use pack sizes range from 22 oz to 400 pounds for gel form and 25 to 2,200 pounds for all other forms.

For photo processing, 1 to 5 ppm of Halohydantoins with 1 to 3 ppm of Halogen is used at a typical rate of 0.006 to 0.02 pounds per 1,000 gallon of water. A PLS/ PS feeder is used to dispense product in granular, briquettes and tablet form. End use pack sizes range from 1 to 50 pounds. Page 6 of 6  6  For secondary oil recovery injection water, 300 ppm of Halohydantoins with 280 ppm of Halogen is used at a typical rate of 2.3 pounds per 1,000 gallons of water. A PLS/ PS feeder is used to dispense product in granular and tablet form. End use pack sizes range from 25 to 2,200 pounds.

For oil recovery drilling muds& Packer Fluids, 940 ppm of Halohydantoins with 1,800 ppm of Halogen is used at a typical rate of 15 pounds per 1,000 gallons of water. A PLS/ PS feeder is used to dispense product in granular and tablet form. End use pack sizes range from 25 to 2,200 pounds For recirculating cooling water for greenhouses and nurseries, 8 to 24 ppm of Halohydantoins with 5 to 15 ppm of Halogen is used at a typical rate of 15 to 45 grams per 1,000 gallons of water. A PLS/ PS feeder is used to dispense product in granular, powder and tablet form. End use pack sizes are in 3 and 25 pounds.

TARGET PESTS: Slime forming bacteria and fungi; human pathogens in swimming pools, spas, hot tubs, toilet bowls and urinals; mollusks and algae.

FORMULATION TYPES: Powder, granular, tablets ( including nuggets), briquettes and gel. Each formulation is designed to best serve a certain type of application with the product form influencing the dissolution rate.

ACUTE TOXICITY AND CHEMICAL CLASS:

Halohydantoins are classified as moderately toxic after acute oral administration. They are markedly irritating to lung tissues upon inhalation with potential systematic absorption and tissue damage. On contact they are corrosive to peripheral tissue  eyes, skin and mucous membrane. Halohydantoins are toxic to aquatic organisms. They are considered strong oxidizing agents.

C. Regulatory History In 1987, EPA issued a Data Call In ( DCI) for antimicrobial products, which covered the halohydantoins. In response to this DCI, generic toxicology, environmental fate and ecotoxicity data were submitted. Generic data were developed on the breakdown products, dimethylhydantoin ( DMH) and ethylmethylhydantoin ( EMH). The primary reason for developing generic data on DMH and EMH is that these ring structures represent the persistent component of the halohydantoins. A secondary reason for evaluating the hydantoin moieties rather than the entire halohydantoin molecule is that the corrosive properties of the released halogens would limit the amount of chemical that could be administered to laboratory animals; thereby precluding a meaningful evaluation of the hydantoin moieties. The Agency also determined that data developed on DMH was applicable to EMH and vice versa. The basis for this decision was the similarity of the chemical structure of these two chemicals and the similarity of results from studies conducted on both the DMH and EMH compounds.


UNITED STATES ENVIRONMENTAL PROTECTION AGENCY WASHINGTON, D. C. 20460 OFFICE OF WATER MEMORANDUM June 24, 2004 SUBJECT: 2003 National Coordinators Workshop Feedback for the 304( m) Planning Process for the 2004/ 2005 Plan FROM: Patricia Harrigan, USEPA/ OW/ OST ( 202) 566 1666 ( harrigan. patricia@ epa. gov)

TO: Public Record for the Effluent Guidelines Program Plan for 2004/ 2005 EPA Docket Number OW 2003 0074 ( www. epa. gov/ edockets/)

The purpose of this memorandum is to describe suggestions and issues identified by pretreatment coordinators attending the November, 2003 National Coordinators Workshop hosted by the Association of Metropolitan Sewerage Agencies. EPA solicited feedback from workshop attendees during roundtable discussions and will consider these suggestions during development of the final Effluent Guidelines Program Plan for 2004/ 2005.

Additional feedback triggered by this workshop was sent to EPA through an email discussion chain. That feedback is documented in a separate memo titled " Additional Feedback from State Pretreatment Coordinators to the 304( m) Planning Process for the 2004/ 2005 Plan."

Overview As outlined in the preliminary Effluent Guidelines Program Plan for 2004/ 2005 published on December 31, 2003 in the Federal Register ( 68 FR 75515), EPA is using four major factors to determine whether to revise a set of existing effluent guidelines. These four factors are:

Factor 1: Consideration of the extent to which the pollutants discharged by an industry category pose adverse impacts ( including potential risks) to human health or the environment.

Factor 2: Identification of an applicable and demonstrated technology, process change, or pollution prevention alternative that can effectively reduce the pollutants discharged by the industry category and thereby substantially reduce any potential risk to human health or the environment associated with those pollutants.

Factor 3: Evaluation of the cost, performance, and affordability of the technology, process change, or pollution prevention measures identified using the second factor. Page 2 of 3

Factor 4: Evaluation of implementation and efficiency considerations. Under this factor, EPA would consider whether existing effluent guidelines could be revised, for example, to eliminate inefficiencies or impediments to technological innovation, or to promote innovative approaches such as water quality trading, including within plant trading. This factor might also prompt EPA to decide not to revise effluent guidelines for an industry category where the pollutant source is already being addressed by another regulatory program, such as EPA's stormwater requirements, or by non regulatory programs that may more effectively address the problem.

This memo consolidates suggestions received in response to 7 questions posed by Deborah Nagle, chief of the Industrial Branch in EPA's Office of Wastewater Management. These suggestions are not formal comments, but EPA wanted to record them here for the public record. An excerpt from the summary report is attached to this memo. The complete summary report can be viewed at http:// www. amsa cleanwater. org/ meetings/ 03pret/ ppt/ 2003prceed. pdf.

Centralized Waste Treatment ( 40 CFR 437): Several attendees noted issues with the Centralized Waste Treatment ( CWT) ELG, including the belief that the limits are so low that matrix interference puts detection limits above discharge limits. More generally, respondents mentioned the need for further guidance on general implementation of the CWT rule.

Hospitals ( 40 CFR 460): Attendees identified this point source category, along with healthcare in general, as one which could provide opportunities for multi media pollutant reductions.

Metal Finishing ( 40 CFR 433): Attendees identified this point source category as one which could provide opportunities for multi media pollutant reductions. The workshop attendees noted significant technological improvements in this sector.

Organic Chemicals, Plastics, and Synthetic Fibers ( 40 CFR 414): Attendees identified this point source category as one which could provide opportunities for multi media pollutant reductions. The workshop attendees noted significant technological improvements in the organic chemical sector, with better overall treatment ( stripping, improved filtration ahead of carbon).

Pharmaceutical Manufacturing ( 40 CFR 439): This ELG was commonly mentioned as one requiring assistance in applying. Responders specifically noted that biotech companies should not be included in the scope, as their wastestreams are basically clean and relatively minor. Attendees also identified this point source category as one which could provide opportunities for multimedia pollutant reductions.

Pulp, Paper, and Paperboard ( 40 CFR 430): Attendees identified this point source category as one which could provide opportunities for multi media pollutant reductions. Page 3 of 3 New Point Source Categories: The overwhelming response was that there is no need to introduce new categorical standards or regulations. Most attendees believed that local limits were more than effective to control pollutants. Many also believed that resources should be spent on guidance on existing ELGs as opposed to creating new ones that are already controlled on the local level. However, printers and fiberglass manufacturers were identified as point source categories which could provide opportunities for multi media pollutant reductions. Dentists were identified as a sector with innovative approaches to minimize pollutant releases. Dye manufacturers were also identified as a sector with innovative approaches to minimize pollutant releasesm with their practice of evaporating wastes.

General for All Effluent Guidelines: Generally, any concentration based ELG was thought to impede adoption of water conservation practices. POTWs expressed interest in converting to mass limits to allow for greater water conservation, but would still like to retain the ability to choose whichever method is more appropriate. Attachment: Combined Roundtable Discussions at 2003 National Pretreatment Coordinators Workshop Excerpted from Summary Report Combined Roundtable Discussions Workshop attendees were seated at tables of 10 people, given introductory presentations, and then asked to comment on each of the three topics through a series of discussion questions.

The first topic discussed was the issue of effluent guidelines implementation. Deborah Nagle, Chief, Industrial Branch, OWM, posed a series of questions regarding implementation issues which were then discussed in at each roundtable.

The questions posed and a summary of what was discussed are outlined as follows:

1. Identify any current Effluent Guideline/ pretreatment standard that you find you need assistance in applying. Specifically, for that guideline or industrial sector:

What specific issues are you grappling with?

What tools could aid your permit writing for these facilities?

Several attendees noted issues with the Centralized Waste Treatment ( CWT) ELG, including the belief that the limits are so low that matrix interference puts detection limits above discharge limits. More generally, respondents mentioned the need for further guidance on general implementation of the CWT rule.

Another ELG commonly mentioned was the Pharmaceutical rule, specifically noting that biotech companies should not be included as their wastestreams are basically clean and relatively minor.

2. Should EPA consider new categorical guidelines for any industrial operations that are currently not regulated by a categorical guideline or revise existing guidelines? What problem would a categorical guideline or study address?

The overwhelming response was that there is no need to introduce new categorical standards or regulations. Most attendees believed that local limits were more than effective to control pollutants. Many also believed that resources should be spent on guidance on existing ELGs as opposed to creating new ones that are already controlled on the local level. 3. What industry sectors may provide an opportunity for multimedia pollutant reductions?

Among those sectors listed by the attendees that could provide opportunities for multimedia pollutant reductions were pulp and paper, organic chemicals, printers, pharmaceuticals, health care, metal finishers, and fiberglass manufacturers and plastics.

4. What industry sectors reflect innovative approaches to minimize pollutant releases?

Responses to this question included BMPs for dentists, the use of wash down waters as dilution for next batches by dye manufacturers, the practice of " evaporating" wastes as opposed to discharging them. One attendee mentioned that finalization of the Pretreatment Streamlining Rule would greatly increase opportunities for innovation.

5. What current industry sectors reflect significantly improved treatment technologies since adoption of the categorical standards ( e. g., water use or pollutant treatment)?

The workshop attendees noted significant technological improvements in the organic chemical sector, with better overall treatment ( stripping, improved filtration ahead of carbon) , and the metal finishing sector. It was also noted that ISO standards drive categorical standards through pollution prevention actions.

6. Provide specific examples where a categorical guideline may impede adoption of water conservation or pollution reduction technologies. Generally, any concentration based ELG was thought to impede adoption of water conservation practices. POTWs expressed interest in converting to mass limits to allow for greater water conservation, but would still like to retain the ability to choose whichever method is more appropriate.

7. To the extent possible, discuss whether your recommended reforms ( above) would increase or decrease water pollution discharges or sludge quality:

Identify the number of these facilities ( per industrial sector) that you have.

The roundtable notes did not reflect any discussion on this question.