March
14,
2003
Mr.
Stephen
L.
Johnson
Assistant
Administrator
for
Prevention,
Pesticides
and
Toxic
Substances
US
Environmental
Protection
Agency
(
7101M)
1200
Pennsylvania
Avenue
NW
Washington,
DC
20460
Re:
Letter
ofIntent
for
the
Telomer
Research
Program
Dear
Mr.
Johnson:

The
parties
to
this
letter,
as
members
of
the
Telomer
Research
Program
(
TRP)
1
which
comprise
the
major
telomer
producers,
have
prepared
this
Letter
ofIntent
(
LOl)
to
address
questions
raised
by
the
US
Environmental
Protection
Agency
(
EPA)
about
the
possible
association
of
perfluorooctanoic
acid
(
PFOA)
with
telomer­
based
products.
The
purpose
of
this
letter
is
to
affirm
our
commitment
to
responding
to
the
concerns
ofthe
EPA
and
to
provide
a
summary
of
(
i)
the
actions
the
parties
are
pursuing
in
2003,
(
ii)
additional
product
stewardship
measures
that
the
TRP
members
will
implement,
(
iii)
information
that
the
TRP
will
provide
the
EPA,
and
(
iv)
work
conducted
to
date.

The
TRP
is
evaluating
telomer
products
sold
in
the
United
States
to
determine
whether
they
contribute
to
significant
human
or
environmental
exposure
to
PFOA.
Our
evaluation
has
six
key
components.

1.
Analysis
of
products
and
articles
2.
Analysis
of
"
aged"
products
and
"
in
use"
articles
3.
Characterization
ofpotential
release
of
PFOA
from
telomer­
based
product
manufacture
4.
Characterization
ofpotential
release
of
PFOA
from
telomer­
treated
article
manufacture
5.
Analysis
of
possible
biodegradation
of
telomer­
based
polymeric
products
6.
Evaluation
of
the
ultimate
fate
and
disposal
routes
for
telomer­
treated
articles
in
the
United
States
EPA
has
expressed
a
concern
to
our
industry
about
reports
oflow
but
widespread
levels
of
PFOA
in
human
blood.
We
recognize
that,
although
there
is
no
evidence
of
a
health
effect
at
the
levels
found,
the
presence
of
PFOA
in
blood
is
a
concern
for
EPA.
Telomers
are
not
made
from
PFOA,
nor
is
PPOA
added
during
the
manufacture
or
use
oftelomer
products.
Questions
have
arisen
about
the
potential
for
telomers
to
transform
to
PFOA
under
various
conditions.
We
believe
the
potential
for
such
transformation
is
small,
any
PFOA
levels
that
may
result
from
this
potential
conversion
would
be
small,
and
the
overall
contribution
oftelomer
products
to
human
exposure
to
PFOA
consequently
would
be
negligible.
However,
the
TRP
members
commit
to
`
The
companies
participating
in
the
TRP
include
Asahi
Glass,
Clariant
GmbIl,
Daikin
Industries
and
E.
I.
duPont
de
Nemours
&
Company.
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
2
verifying
that
these
assumptions
are
true
and
have
set
forth
below
a
program
of
research
to
meet
this
responsibility.

Fluorotelomers
are
used
in
a
number
of
specialized
products
including:
water
and
oil
repellents
and
barriers
for
carpets,
clothing,
upholstery,
and
paper;
mold
releases
forplastic
and
rubber
molding;
aqueous
film
forming
foams
(
AFFF
firefighting
agents);
and
wetting
agents
for
floor
polish,
inks
and
a
range
of
similar
applications.
There
is
only
one
TRP
member
company
(
DuPont)
that
manufactures
both
the
basic
telomer
chemicals
and
end­
use
products
in
the
United
States.
One
additional
TRP
member
(
Daikin)
is
a
manufacturer
who
imports
the
basic
telomer
chemicals
and
processes
them
into
end­
use
products
in
the
United
States.
The
other
TRP
companies
(
Asahi
Glass
and
Clamant)
are
importing
end­
use
telomer
products
to
the
United
States.
Approximately
90%
of
the
volume
of
telomer
products
goes
to
industrial
users,
who
apply
them
to
carpets,
textiles
and
paper
at
the
mill
sites,
coat
them
on
various
surfaces
(
e.
g.,
molding
machines),
or
mix
them
into
polishes,
inks
and
other
products.

As
supplied
to
those
industrial
users,
telomer­
based
products
may
contain
PFOA
as
an
impurity
in
trace
amounts.
Given
the
known
worldwide
production
of
telomers,
the
levels
of
PFOA
that
would
be
placed
in
commerce
per
year,
based
on
this
understanding,
is
expected
to
be
relatively
small.
We
are
not
sure
how
that
amount
ofPFOA
is
formed,
but
this
information
may
suggest
that
there
is
some
potential
for
telomers
to
transform
to
PFOA.
We
are
now
trying
to
determine
whether
there
are
relevant
routes
by
which
telomers
may,
in
fact,
transform
to
PFOA
and
to
what
degree
these
transformations
take
place.
An
important
element
of
this
LOl
is
our
evaluation
of
this
question.

Investigating
the
amount
of
PFOA
from
telomer
products
is
made
more
challengingby
direct
inputs
of
PFOA
from
other
sources
into
the
environment
and
by
environmental
loadings
from
legacies
attributable
to
widespread
use
ofdiscontinued
surfactants
and
oil­
and
waterrepellent
chemistries.

In
all
of
the
projects
described
in
the
commitment
section
of
this
LOT,
the
TRP
members
intend
to
deliver
data
that
will
meet
EPA's
guidelines
forinformation
quality.
2
Even
where
we
are
conducting
relatively
short­
term
screening
analyses,
we
intend
to
meet
appropriate
EPA
standards.
Our
commitment
to
data
quality
will
not
compromise
our
efforts
to
supply
the­
EPA
with
information
in
an
expeditious
manner.

The
TRP
is
committed
to
conducting
a
proactive
program
to
develop
additional
data
on
environmental
fate
of
our
products,
better
characterize
routes
ofexposure,
strengthenproduct
stewardship
and
risk
communication
practices,
and
take
additional
measures
to
reduce
or
prevent
exposure
wherever
new
data
suggest
that
such
changes
are
needed.

2
EPA
has
issued
Information
Quality
Guidelines,
in
conformance
with
the
Data
Quality
Act
and
guidance
issued
by
the
Office
of
Management
and
Budget.
TRP
also
will
consider
EPA
Order
#
5360.1
I
82
(
Quality
System)
for
further
guidance
on
how
to
document
QAIQC
measures.
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
3
TRP
Voluntary
Commitment
The
members
of
the
TRP
are
working
together
to
complete
the
assessments
described
below
related
to
telomer
products.
TRP
will
provide
periodic
briefings
to
EPA
staff
to
summarize
recent
results
from
these
telomer­
related
studies.
These
briefings
are
expected
to
occur
at
least
monthly
in
2003.
In
addition,
the
TRP
will
provide
new
documents,
other
materials
and
final
study
reports
to
EPA
as
soon
as
they
become
available.

1.
Product
and
Article
Analysis
The
TRP
has
contracted
with
an
outside
research
laboratory
to
analyze
for
the
presence
of
PFOA
in
the
major
end­
use
telomer
products
in
commerce
and
articles
treated
with
those
products.
TRP
will
provide
EPA
with
a
description
of
the
scope
and
rationale
for
analysis
of
PFOA
in
telomer­
based
polymeric
products
and
telomer­
treated
articles
during
March
2003.
TRP
analytical
experts
have
developed
the
appropriate
sampling
and
analysis­
plans­
as
well
as
analytical
standards
for
the
work.
Draft
plans
for
the
"
Product
and
Article
Analysis"
study
and
"
Sampling
Guidance"
were
provided
to
the
EPA
on
February
14,
2003
for
review
and
comment.
The
screening
study
will
begin
in
March
2003;
the
final
report
is
expected
by
June
/
July
2003.
The
results
will
be
provided
to
EPA
as
soon
as
they
are
available.

This
analysis
will
address
three
major
use
categories:
carpets,
textiles
and
paper.
The
primary
products
that
our
members
market
for
these
applications
are
polymer&(
approximately
85%
ofwhat
the
TRP
members
manufacture
and
sell).
The
products
to
be
tested
are
those
that
the
respective
TRP
member
companies
manufacture
as
actual
items
of
commerce.
While
there
are
many
potential
telomer
polymeric
products,
a
relatively
small
number
represent
the
primary
product
classes
in
commerce
(
12
products).
As
a
result,
the
TRP
will
provide
EPA
with
a
comprehensive
initial
picture
of
exposure
potential
by
focusing
on
these
major
end­
use
polymers
and
the
corresponding
articles
of
commerce.
The
treated
articles
to
be
tested
are
actual
carpet,
textile,
and
paper
substrates
treated
under
representative
mill
conditions
with
the
subject
telomerbased
polymeric
products.

The
chemical
identities
of
these
particular
polymers,
volumes,
and
their
relative
market
share,
are
Confidential
Business
Information
(
CBI).
The
TRP
members
intend
to
provide
the
Agency
with
specifics
about
each
polymer
to
be
tested,
such
as
its
structure,
CAS
number,~
chemical
name,
2002
use
and
volume
in
commerce,
through
company­
specific
submissions.
This
information
will
be
supplied
to
the
EPA
by
March
24,
2003.
TRP
companies
will
also
provide
EPA
(
under
CBI)
specifics
such
as
structures,
CAS
numbers,
chemical
names,
2002
uses
and
volumes
in
commerce
of
all
other
telomer
products
used
in
the
United
States
(
including
nonpolymeric
products)
by
May2003.

2.
Analysis
of
"
Aged"
Products
and
"
In
Use"
Articles
The
TRP
members
will
examine
transformation
of
end­
use
telomer
products
for
potential
PFOA
generation
that
might
occur
through
storage
ofthe
product
over
time
or
through
normal
use
of
treated
articles.
TRP
will
develop
a
plan
by
April
2003for
conducting
PFOA
"
aging"
and
"
in
use"
analyses
ofthe
specific
products
and
treated
articles
that
are
the
subject
oftheTRPsponsored
work
in
Item
1
above.
For
these
analyses,
"
aged"
means
the
likely
conditions
our
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
4
products
will
see
under
normal
storage
and
distribution.
"
Tn­
use"
means
the
conditions
treated
articles
will
see
under
normal
distribution
and
use.
Study
protocols,
analytical
methods
and
appropriate
test
conditions
will
be
developed
for
this
work
during
the
second
quarter
2003
as
this
reflects
a
new
area
of
research
for
the
TRP.
Results
of
this
study
are
expected
to
be
complete
in
the
third
quarter
2003.
The
study
protocols
will
be
designed
to
achieve
expeditious
results
while
determining
whether
or
not
PFOA
releases
arise
from
real­
world
conditions,
consistent
with
EPA's
quality
guidelines
I
procedures.

3.
Characterizing
Potential
Release
ofPFOA
from
Telomer­
Based
Product
Manufacture
In
February
2003,
the
TRP
presented
to
EPA
a
general
description
of
the
process
chemistry
employed
in
telomer
manufacturing
and
processing
operations.
As
a
follow
up,
the
TRP
will
prepare
and
submit
a
generalized
process
schematic
and
description
to
the
EPA
by
end
of
March
2003.
However,
each
TRP
member
company
uses
unique
processes
in
its
manufacturing
operations.
Each
member
company
will
provide
the
location
of
each
US­
based
TRP
member
telomerprocessing
and
manufacturing
facility
by
March
24,
2003
and
meet
separately
with
the
Agency
to
explain
its
overall
individual
process,
focusing
on
its
operations
in
the
United
States.
Each
member
company
will
also
share
information
about
potential
release
of
PFOA
or
exposure
points
from
its
US­
based
processes
by
the
end
of
April
20Q3~
The
companies
will
define
action
plans
by
the
end
of
May
2003
to
investigate
the
potential
forPFOA
release
and
exposure.
The
members
of
TRP
are
available
to
begin
discussions
immediately
and
will
call
individually
to
schedule
these
briefings.

In
addition
to
the
TRP­
sponsored
studies
described
above,
DuPont,
which
is
the
only
fully
integrated
US
telomer
producer,
makes
the
commitments
set
forth
in
Appendix
I.

4.
Characterizing
Potential
Release
ofPFOAfrom
Telomer­
Treated
Article
Manufacture
The
TRP
members
will
examine
the
potential
for
PFOA
releases
or
occupational
exposures
at
US
facilities
that
manufacture
telomer­
treated
articles.
In
order
to
conduct
research
on
articles
of
commerce
efficiently,
we
believe
this
information
is
best
assembled
through
a
release
estimate
model
analysis
directed
at
manufacture
of
the
three
primary
telomer­
treated
article
types
 
carpet,
textiles
and
paper
 
that
are
addressed
in
other
TRP
workstreams.
The
TRP
will
conduct
a
study
to
determine
the
estimates
of
potential
release
ofPFOA.
In
this
analysis
we
will
attempt
to
identify
potential
release
points,
exposure
pathways,
and
ultimate
environmental
compartments
(
air,
land,
water)
for
potential
PFOA
emissions
from
telomertreated
article
manufacturing
processes.
It
is
our
expectation
that
this
analysis
will
be
complete
by
June
I
July
2003.
The
final
reports
from
this
analysis
will
be
provided
to
the
EPA
no
later
than
August
/
September
2003.

While
the
release
estimate
studies
are
underway,
the
TRP
will
proceed
to
develop
and
demonstrate
the
required
sampling
and
analytical
methods
for
PFOA
in
the
mill
simulations
described
below.
We
expect
this
work
to
be
completed
in
the
third
quarter
2003.
The
release
estimate
analysis
will
be
used
to
first
design
and
then
conduct
mill
simulations
ofthe
potential
release
of
PFOA
from
telomer­
treated
article
manufacturing
operations.
A
contract
laboratory
capable
of
simulating
the
actual
mill
environment
under
defined
and
known
conditions
will
be
used
to
verify
the
data
generated
in
the
above
release
estimate
study.
The
mill
simulations
are
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
5
expected
to
begin
during
the
third
quarter
2003.
The
results
from
the
analysis
and
simulations
will
be
used
to
estimate
the
potential
occupational
and
environmental
exposure
to
PFOA
from
the
specified
telomer­
treated
article
manufacturing
processes.
This
work,
along
with
the
Product
and
Article
Analysis
in
Item
1
of
this
letter,
is
expected
to
provide
a
more
comprehensive
picture
to
aid
in
the
understanding
of
the
potential
occupational
and
environmental
exposure
to
PFOA
from
telomer­
treated
article
manufacturing
processes.

S.
Biodegradation
Analysis
The
TRP
will
gather
information
about
whether
and
how
telomers
might
degrade
to
PFOA
through
biodegradation
under
environmentally
relevant
conditions.
The
TRP
will
conduct
further
biodegradation
studies;
see
"
Continuation
of
TRP
Research
Activities"
for
method
development
studies
with
the
8­
2
Telomer
Alcohol
to
test
for
the
potential
generation
of
PFOA.
These
studies
will
follow
appropriate
OECD
protocols
for
the
telomer­
based
polymeric
products
used
in
the
Product
and
Article
Analysis
(
Itemi).
These
screening
tests
will
provide
useful
data
on
the
potential
for
biodegradation
to
PFOA
from
major
end­
use
telomer­
based
polymeric
products.
TRP
will
develop
the
study
approach,
protocols
and
rationale,
and
submit
these
to
the
US
EPA
by
April
2003
for
review
and
comment.
Then
in
the
second/
third
quarter
2003,
we
will
conduct
the
biodegradation
analysis
of
the
telomer­
basedpolymeric
products
selected
forthe
study
above.
Initial
results
are
expected
beginning
in
July
2003.
Final
reports
will
be
submitted
to
EPA
as
soon
as
they
become
avallable.

6.
Analysis
ofIncineration
The
TRP
has
begun
to
compile
information
on
the
ultimate
fate
and
disposal
routes
(
incineration
versus
landfill)
of
the
telomer­
based
polymeric
products
and
articles
treated
in
the
United
States.
The
results
ofthis
study
will
be
provided
to
EPA
by
July
2003.
Concurrently,
TRP
will
examine
information
available
on
types
of
incineration
tests
that
may
be
applicable
and
will
provide
this
information
to
EPA
by
the
end
ofthe
second
quarter
2003.

Related
Activities
Information
Exchange
Over
the
last
several
years
the
TRP
member
companies
have
prepared
and
collected
numerous
studies
and
reports
about
telomers.
Many
ofthese
documents
are
drawn
from
the
public
literature,
but
some
represent
unpublished
reports.
In
addition,
we
have
unpublished
reports
that
have
been
produced
for
the
TRP.
Both
the
published
and
unpublished
documents
include
summaries
from
TRP
and
non­
TRP
studies
on
physical­
chemical
properties,
toxicology,
pharmacokinetics,
and
environmental
fate
and
effects.

To
expedite
the
flow
of
information,
TRP
will
provide
the
EPA
with
a
listing
of
the
documents
in
the
TRP
database
by
March
24,
2003.
Copies
of
the
documents
will
follow
as
soon
as
they
can
be
compiled
but
no
later
than
April
15,
2003.
If
EPA
requests
companyspecific
information,
the
company
will
supply
the
information
to
EPA
with
appropriate
confidential
business
information
claims,
as
provided
for
underEPA
regulations.
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
6
In
addition,
TRP
will
provide
new
documents,
other
materials
and
final
study
reports
to
EPA
as
soon
as
they
become
available.
Individual
companies
will
also
submit
documents,
information,
and
final
study
reports
to
EPA
related
to
their
own
studies
on
products
sold
in
the
US
market
as
soon
as
they
become
available.
Tn
addition,
TRP
will
continue
to
provide
periodic
briefings
to
EPA
staff
to
summarize
recent
results
from
these
telomer­
relatcd
studies.
These
briefings
are
expected
to
occur
at
least
monthly
in
2003.
TRP
will
also
provide
EPA
advance
notice
of
upcoming
studies
and
reports.

Product
Stewardshipfor
Customers
The
TRP
members
are
committed
to
the
continued
safe
manufacture
and
use
of
telomerbased
products.
The
TRP
acknowledges
that
it
is
equally
important
to
continue
to
establish
and
support
responsible
occupational
health
and
environmental
practices
in
the
use
of
telomer
products.

TRP
member
companies
have
in
place
product
stewardship
practices
with
their
customers
related
to
the
application,
use
and
occupational
exposure
to
telomer­
based
products,
and
have
each
adopted
workplace
health
and
safety
practices
to
minimize
occupational
exposure.
These
activities
are
essential
parts
of
long­
standing
product
stewardship
programs
and
are
ongoing.

Further
efforts
on
occupational
product
stewardship
programs
will
focus
on
technical
support
and
assistance
to
telomer­
based
product
users
(
customers)
to
assist
them
in
keeping
their
occupational
safety
and
health
programs
current.
Accordingly,
the
TRP
members'
product
stewardship
role
is
to
provide
the
necessary
information,
assist
in
the
understanding
of
the
information,
and
provide
support
to
customers
using
telomer­
based
products.

The
TRP
has
no
single
unified
product
stewardship
program.
As
a
result,
the
TRP
member
companies
plan
to
have
additional
product
stewardship
programs
in
place
by
July
2003.
These
programs
will
be
developed
with
reference
to
the
Responsible
Care
guidelines
outlined
in
SOCMA
Management
Practices
/
Product
Stewardship
Code.
Each
member
company
will
provide
documented
evidence
for
their
respective
programs
to
EPA
by
July
2003.

In
addition,
the
TRP
believes
the
development
and
distribution
of
a
"
Safe
Handling
and
Use"
handbook
would
be
a
valuable
tool
for
our
customers.
This
handbook
would
amplify
the
basic
information
contained
in
MSDS
to
provide
additional
information
about
telomers
and
suggestions
for
overall
occupational
exposure
reduction
measures
for
our
customers'
consideration
In
developing
such
a
product,
we
would
focus
on
ways
to
make
it
userfriendly
and
practical.
This
TRP
handbook
will
be
developed
for
customer
review
by
August
2003.

Continuation
ofTRP
Research
Activities
The
TRP
has
had
a
research
program
underway
for
two
years,
which
has
focused
primarily
on
the
8­
2
TelomerAlcohol.
Many
of
these
efforts
will
be
producing
important
results
in
2003.
In
light
of
EPA's
expressed
interest
in
the
potential
formation
of
PFOA
from
telomer­
based
products,
the
TRP
is
reconsidering
the
priority
of
new
work
on
the
8­
2
Telomer
Alcohol.
The
TRP
intends
to
complete
the
majority
of
the
projects
that
are
already
underway.
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
7
Relative
to
some
of
our
current
work
efforts,
we
very
clearly
understand
there
is
concern
within
the
EPA
that
it
has
taken
too
long
to
clarify
whether
there
is
biodegradation
of
our
products
to
PFOA.
Much
of
this
time
is
attributable
to
our
efforts
to
develop
`
4C­
labeled
material
that
could
be
used
in
the
biodegradation
studies.
TRP
now
has
a
supply
of
this
material.
We
anticipate
the
quality
and
significance
of
the
data
we
obtain
with
this
`
4C­
labeled
material
will
provide
information
valuable
enough
to
justify
the
time
and
effort
spent.

Appendix
2
describes
the
8­
2
Telomer
Alcohol
workstreams
the
TRP
has
completed
to
date
as
well
as
those
underway.
The
results
from
the
completed
studies
either
have
been
submitted
to
the
US
EPA's
Administrative
Record
226
(
AR­
226)
or
will
be
submitted
as
soon
as
the
final
report
is
completed.
Appendix
3
contains
a
list
and
schedule
of
the
reports
from
the
TRP
work
on
the
8­
2
Telomer
Alcohol,
including
those
reports
that
will
be
provided
to
EPA
during
the
remainder
of
2003.
Final
study
reports
from
TRP­
sponsored
studies
will
be
submitted
to
EPA
as
soon
as
they
become
available.

We
believe
the
actions
described
in
this
letter
represent
a
responsive
and
responsible
commitment
by
the
TRP
member
companies
to
help
address
EPA's
expressed
interest
in
the
potential
for
PFOA
exposure
from
telomer­
based
products.
We
have
made
these
commitments
as
tangible
as
possible,
including
specific
timelines.
For
convenience,
we
have
summarized
these
commitments
and
timelines
in
Appendices
4
and
5.

The
TRP
members
appreciate
the
opportunity
to
work
with
EPA
on
this
important
matter
and
agree
that
communicating
the
progress
on
our
efforts
and
sharing
of
information
is
important.
Accordingly,
we
will
continue
to
communicate
with
EPA
when
important
information
arises.

In
closing,
we
would
like
to
emphasize
that
the
TRP
is
committed
to
the
continued
safe
manufacture,
processing
and
use
of
telomer
chemistry.
We
look
forward
to
working
with
EPA
in
the
future
to
achieve
these
goals.

Respectfully
submitted,

TRP
Member
Companies
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
Sc&­

Signature:
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Clariant
Gnibll
Clariant
GmbIl
Signature:
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Name:
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Title:
_______________________________

Daikin
America,
Inc.

Signature:
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Name:
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Cbemkal.
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Mr.
Stephen
L.
Johnson
March
14,
2003
Page
9
APPENDIX
1
E.
I.
duPont
de
Nemours
Company
(
DuPont)
Telomer
Manufacturing
Facility
Commitment
DuPont
manufactures
telomers
in
the
United
States
at
the
following
sites:

°
Chambers
Works
in
Deepwater,
New
Jersey
°
Washington
Works
in
Parkersburg,
West
Virginia
DuPont
Commits
to
the
following
with
respect
to
manufacturing
operations
at
these
sites:

1)
Develop
site
specific
plans
to
assess
levels
ofPFOA
in
air
and
water
from
manufacturing
operations
around
each
site;
development
of
plans
will
begin
not
later
than
30
days
after
the
date
ofthis
letter.

2)
Conduct
site­
specific
air
dispersion
modeling
for
applicable
manufacturing
operations,
using
the
EPA
approved
Industrial
Source
Complex
Short
Term
3
(
ISCSTS)
model,
as
described
in
EPA's
Guideline
on
Air
Ouality
Models
(
40
C.
F.
R.
Part
51,
Appendix
W),

and
assess
the
results
using
the
air
screening
levels
established
in
West
Virginia.

3)
Conduct
ground
and
surface
water
analyses
at
each
site,
and
assess
the
results
using
the
water
screening
levels
established
in
West
Virginia.

4)
Use
the
West
Virginia
screening
levels
to
determine
what
additional
actions,
if
any,
may
need
to
be
taken,
after
reviewing
the
information
with
EPA.

Six
months
after
this
Letter
is
submitted,
reports
will
be
submitted
foreach
site
on
progress
made
with
respect
to
environmental
assessments.

In
addition
to
the
environmental
assessment
comniitments
made
above,
DuPont
will,
by
April
1,
2003,
provide
EPA
with
applicable
existing
industrial
hygiene
air
monitoring
data
forPFOA
from
DuPont
operations
at
Chambers
Works.
Also
by
April
1,
2003,
the
DuPont
telomers
business
will
provide
EPA
with
summary
data
on
existing
employee
blood
monitoring
results
(
taking
steps
to
preserve
confidentiality)
from
telomer
manufacturing
operations
and
PFOA
recycle
operations
at
Chambers
Works.
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
10
APPENDIX
2
Summary
of
TRP
Research
Activities
on
8­
2
Telomer
Alcohol
8­
2
Telomer
Alcohol
Studies
**
Work
Complete
Work
Underway
2001
I
2002
j
2003
O.
cute
Fish:
Fathead
Minnow
~.
cuteInvertebrate:
Daphn!
a
magna
~.
cute&
Chronic
Algae
(
72
Hour)

~
cutePlant
Seedling
(
21
Day)
Chronic
Nematode
(
3
Day)

UVNisible
Absorption
Spectrum
vapor
Pressure
Method
Development
&
Material
Handling
Prepare
Cold
Standards
for
Synthesis
Route
complete
Prepare
"
C
Material
as
Standard
complete
 
 
Cold
Synthesis
Demonstration
complete
14C
Synthesis
and
Preparation
of
Study
Material
complete
 
 
_
___________
 
 
 
*
*
The
results
from
the
completed
studies
either
have
been
submitted
to
EPA's
Administrative
Record
226
(
AR­
226)
or
will
be
submitted
as
soon
as
the
final
report
is
completed.
~.
cuteOral
Toxicity
Repeated­
Dose
Range­
Finding
Oral
Toxicity
Study
StudyDescription
I
STATUS
I1Qj2QI3QI4OI1Q~
2Q~
3Qj4QI1QI2QI3QI4QI
Bacterial
Reverse
Mutation
Subchronic
90
Day
Oral
Gavage
(
Rat)
with
90­
Day
Recovery
complete
Bone
Marrow
Erythrocyte
Micronucleus
Test
(
Rat)
complete
complete
Hydrolytic
~
Complete
cy
complete
I
I
~.
dsorption­
Desorption:
Analytical
Method
~
dsorption­
Desorption:
Soil,
Sediment
&
Sludge
(
14C)
complete
~
erobicBiodegradation
(
cold
material,
screening,
method
~
evelopment
&
standards
preparation)
complete
~
erobicBiodegradation
(
14C)
in
progress
~
tmosphericDegradation!
Indirect
Photolysis
in
Air
complete
Long­
Range
Transport
Properties
(
Air
/
Water)
in
progress
complete
in
progress
III
~.
cuteEarthworm
(
14
Day~
complete
complete
complete
Chronic
Daphnia
Magna
(
21
Day)
complete
Hater
Solubility
&
Water
Analytical
Method
complete
complete
in
progress
Sorption
Properties
rat.'
complete
I
complete
complete
Pilot
Experiments!
Interim
Results
complete
complete
Chemical
Synthesis
Development
&
Demonstration
(
cold)
in
prc~
ress
Develop.
Demonstrate
&
Document
Analytical
Methods
complete
complete
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
11
APPENDIX
3
TRP
Final
Report
Schedule
(
8­
2
Telomer
Alcohol
Studies)

The
Telomer
Research
Program
(
TRP)
plans
to
submit
final
study
reports
to
the
US
EVA,
according
to
the
schedule
below.
TRP
will
be
keep
EPA
apprised
of
any
modifications
to
the
reporting
schedule.
[
Note:
Most
of
the
TRP
studies
listed
below
were
focused
on
8­
2
Telomer
Alcohol
(
C8F17CH2CH2OH;
CAS
#
678­
39­
7),
a
primary
fluorotelomer
intermediate.]

January
2003
(
submitted)

 
Acute
Oral
Toxicity
 
Fixed
Dose
Method
 
In
vivo
Rat
Micronucleus
Assay
 
Salmonella­
K
coli/
Mammalian­
Microsome
Reverse
Mutation
Assay
March
2003
Submitted
 
Acute
Aquatic
Toxicity
Tests:
Fish
(
Zebrafish),
Daphnia
magna,
Algae
(
Scenedesmus
subspicatus)
o
Limit
Test
with
the
Saturated
Solution
o
Limit
Test
with
the
Water
Accommodated
Fraction
(
WAF)

 
Microbial
Respiration
Inhibition
Test
with
Activated
Sludge
Forthcoming
 
Physical­
Chemical
Properties
of
8­
2
TelomerAlcohol:
Ultraviolet
/
Visible
Absorption
Spectrum,
Vapor
Pressure,
Water
Solubility
and
Sorption
Properties
 
Hydrolytic
Stability
of
8­
2
Telomer
Alcohol
as
a
Function
of
pH
 
Atmospheric
Degradation
ofthe
Fluorinated
Alcohol,
C8F17C112CH2011
 
Terrestrial
Toxicity
Studies:
Earthworm,
Nematode,
Plants
 
Repeated
Dose
Oral
Toxicity
Gavage
RangeFinding
Study
in
Rats
 
Subehronic
Toxicity
90­
day
Oral
Gavage
Study
in
Rats
 
Bioconcentration
in
Carp
[
Note:
This
study
was
conducted
for
Japan
METI
and
provided
to
the
TRP.
TRP
did
not
fund
the
study
directly
but
arranged
for
the
translation
into
English.]

 
University
ofToronto
Year
1
Progress
Report
on
Fluorotelomer
Alcohols
May
/
June
2003
 
Aerobic
Ready
Biodegradation
of
14C­
Labeled
8­
2
Telomer
Alcohol
(
Modified
OECD
301D)

­­
with
transformation
products
and
mass
balance
 
Chronic
Toxicity
Study
(
21­
day
Daphnia)

Future
Submissions
in
2003
(
studies
not
yet
underway)

 
Adsorption
/
Desorption
of
8­
2
Telomer
Alcohol
using
a
Batch
Equilibrium
Method
 
Qtr
3
I
2003
 
Long­
Range
Transport
Properties
(
Air!
Water)
 
Qtr
4
/
2003
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
12
APPENDIX
4
TRP
Conunitment
Summary
In
this
Letter
ofIntent
to
the
US
EPA,
the
Telomer
Research
Program
(
TRP)
outlines
six
areas
of
commitment
and
agrees
to
provide
EPA
with
documents
/
submissions
on
specific
plans
and
activities
to
follow
through
on
these
items.
The
commitment
items
and
dates
are
summarized
below.

1.
Product
andArticle
Analysis
Note:
The
products
to
be
tested
are
those
that
the
respective
TRP
member
companies
manufacture
as
actual
items
of
commerce.
The
treated
articles
to
be
tested
are
actual
carpet,
textile,
and
papersubstrates
treated
under
representative
mill
conditions
with
the
subject
telomer­
basedpolymericproducts.

 
Description
ofscope
and
rationale
for
analyzing
for
PFOA
in
telomer­
based
polymeric
products
and
telomer­
treated
articles.
This
study
will
cover
representative
polymeric
products
in
commerce
and
the
major
end­
use
applications
(
carpet,
textiles,
and
paper).
Complete
in
March
2003.

 
Information
from
individual
companies
under
CBI
about
each
telomer­
based
polymeric
product
to
be
tested
in
this
study
(
CAS
number,
chemical
name
or
structural
representation
if
no
CAS
number,
product,
2002
use
and
volume)
 
to
EPA
by
March
24,
2003.

 
Description
of
other
telomer­
based
products
(
including
non­
polymeric
products)
and
applications
in
the
United
States
not
included
in
the
Product
and
Article
Analysis,
including
CAS
number,
chemical
name
or
structural
representation
if
no
CAS
number,
product
and
2002
use
and
volume
in
commerce
 
to
be
provided
by
individual
companies
under
CBI
by
May
2003.

 
Submit
draft
study
plans
for
Product
and
Article
Analysis
and
Sampling
Guidance
to
EPA
forreview
and
comment
 
completed
on
February
14,
2003.

 
Conduct
analytical
and
sample
method
development
 
by
March
/
April
2003;
conduct
product
and
article
analysis
 
by
MayI
June
2003.

 
Submit
final
report
from
screening
study
on
Product
and
Article
Analysis
 
by
June
/
July
2003.

2.
Analysis
of"
Aged"
Products
and
"
In
Use"
Articles
Note:
For
these
analyses,
"
aged"
means
the
storage
and
distribution
ofproducts.
"
In­
use"
means
the
distribution
and
use
of
the
treated
articles.

 
Develop
plan
for
conducting
PFOA
"
aging"
and
"
in
use"
analytical
studies
in
initial
enduse
segments
of
carpet,
textiles,
and
paper
 
by
April
2003.
Address
specific
issues
such
as
residual
monomers,
leaching,
degradation,
"
walk
off,"
volatilization,
and
light
exposure.

 
Develop
appropriate
study
protocols,
analytical
methods
and
appropriate
test
conditions
to
conductthese
tests
during
Qtr
2
I
2003.
Conduct
"
aging"
and
"
in
use"
analyses
of
the
specific
products
and
treated
articles
(
carpet,
textiles,
paper)
in
the
TRP­
sponsored
work
under
Item
1
above,
once
protocols
and
methods
are
available
 
expected
to
be
completed
by
Qtr
3
/
2003.
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
13
3.
Characterizing
Potential
Release
ofPFOA
from
Telom
er­
Based
Product
Manufacture
 
Prepare
general
description
of
the
process
chemistry
employed
in
telomer
manufacturing
and
processing
operations
 
by
end
of
March
2003.

 
Provide
the
location
of
each
US
TRP
member
telomer
manufacturing
and
processing
facility
 
by
March
24,
2003.

 
Describe
specific
telomermanufacturing
process
chemistry
by
member
companies
and
information
about
potential
releases
of
PFOA
and
exposure
routes
from
these
processes
(
US
operations)
 
by
end
ofApril
2003.

 
Develop
action
plans
(
by
TRP
member
companies)
to
investigate
the
potential
for
PFOA
release
and
exposure
 
by
end
of
May
2003.

4.
Characterizing
Potential
Release
ofPFOA
from
Telomer­
Treated
Article
Manufacture
 
Develop
estimates
of
potential
release
ofPFOA
related
to
manufacture
of
the
primary
article
types
(
carpet,
textiles
and
paper)
 
by
June
I
July
2003.
The
release
scenarios
to
be
developed
will
cover
potential
occupational
and
environmental
exposure
related
to
the
potential
release
of
PFOA
from
article
manufacture.

 
Provide
EPA
with
results
of
release
estimations
of
PFOA
 
by
August
/
September
2003.

 
Develop
and
demonstrate
required
sampling
and
analytical
methods
for
PFOA
determination
in
the
mill
simulations
 
in
Qtr
3
/
2003.

 
Conduct
mill
simulations
of
the
potential
releases
of
PFOA
from
telomer­
treated
article
manufacture
to
quantify
the
potential
occupational
and
environmental
exposure
related
to
PFOA
from
article
manufacture
 
begin
during
Qtr
3
/
2003.

5.
Biodegradation
Analysis
 
Develop
study
approach,
protocols
and
rationale
for
conducting
biodegradation
analyses
oftelomer­
based
polymeric
products
used
in
the
Product
and
Article
Analysis
(
Item
1
above)
 
provide
to
EPA
by
April
2003
for
review
and
Comment.

 
Conduct
biodegradation
studies
for
potential
generation
ofPFOA
from
polymeric
products
used
in
the
Product
and
Article
Analysis
 
during
Qtr
2­
3
/
2003.

 
Submit
results
of
polymer
biodegradation
analyses
as
they
become
available
 
expected
to
begin
in
July
2003.

6.
Analysis
ofIncineration
 
Compile
information
on
telomer­
based
polymeric
products
and
uses
to
understand
the
ultimate
fate
and
disposal
routes
(
landfill
versus
incineration)
fortelomer­
treated
articles
in
the
United
States
 
provide
to
EPA
by
July
2003.

 
Review
information
on
types
ofincineration
tests
that
may
be
applicable
and
provide
this
information
to
EPA
by
end
of
Qtr
2
/
2003.
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
14
Related
Activities
Information
Exchange
 
Listing
of
documents
in
the
TRP
database
 
submit
list
to
EPA
by
March
24,
2003.
The
documents
will
follow
as
soon
as
they
can
be
compiled,
but
no
later
than
April
15,
2003.
The
documents
are
TRP
and
non­
TRP
reports
on
physical­
chemical
properties,
toxicology,
pharmacokinetics,
and
environmental
fate
and
effects.

 
TRP
will
provide
new
documents,
other
materials,
and
final
study
reports
to
EPA
as
soon
they
become
available.
Individual
companies
will
also
submit
documents,
information,
and
final
study
reports
to
EPA
related
to
their
own
studies
on
products
sold
in
the
US
market,
as
soon
as
they
become
available.

 
TRP
will
continue
to
provide
periodic
briefings
to
EPA
staff
to
summarize
current
results
from
these
telomer­
related
studies.
These
briefings
are
expected
to
occur
at
least
monthly
in
2003.
TRP
will
provide
EPA
advance
notice
forupcoming
studies
and
report
timing.

Product
Stewardshipfor
Customers
 
TRP
member
companies
will
have
additional
product
stewardship
programs
in
place
by
July
2003
developed
with
reference
to
the
Responsible
Care
guidelines
outlined
in
the
SOCMA
Management
Practices
/
Product
Stewardship
Code.
Each
company
will
provide
documented
evidence
for
their
respective
programs
 
by
July
2003.

 
Develop
TRP
Safe
Handling
and
Use
Handbook
 
for
customer
review
by
August
2003.

Continuation
of
TRP
Research
Activities
 
Proceed
with
studies
on
8­
2
Telomer
Alcohol
in
areas
of
physical­
chemical
properties,
toxicity,
pharmacokinetics,
and
environmental
fate
and
effects
(
see
Appendix
2).

 
Describe
the
method
development
and
preliminary
biodegradation
studies
conducted
on
8­
2
Telomer
Alcohol
(
types
ofstudies
and
rationale)
 
by
March
2003.

 
Submit
results
from
biodegradation
analysis
of
8­
2
Telomer
Alcohol
with
both
cold
and
`
4C­
labelecl
material
 
by
March
21,
2003
(
DuPont
preliminary
screening
cold
study)
and
June
/
July
2003
(
TRP
14C­
labeled
study).

 
Submitfinal
study
reports
from
all
TRP­
sponsored
studies
to
EPA
as
soon
as
they
become
available.

 
A
schedule
ofTRP
final
report
submissions
for
the
8­
2
Telomer
Alcohol
studies
is
provided
in
the
LOl
Appendix
3.
An
updated
list
will
be
provided
to
EPA
monthly
in
2003.
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
15
APPENDIX
5
TRP
Commitment
Summary
(
Chronological
Order)

March
2003
1.
Product
and
Article
Analysis:
Description
of
scope
and
rationale
for
analyzing
for
PFOA
in
telomer­
based
polymeric
products
and
telomer­
treated
consumer
articles.
This
initial
study
covers
representative
polymeric
products
in
commerce
and
the
major
end­
use
applications
(
carpet,
textiles,
paper).
Draft
study
plans
were
provided
to
EPA
in
February
2003
for
review.
2.
Product
and
Article
Analysis:
Information
from
individual
companies
under
CBI
about
each
telomer­
based
polymeric
product
to
be
tested
in
this
study
(
CAS
number,
chemical
name
or
structural
representation
if
no
CAS
number,
product,
2002
use
and
volume
in
commerce).
3.
Characterize
Potential
Release
ofPFOA
from
Telomer­
Based
Product
Manufacture:
Provide
general
description
of
the
process
chemistry
employed
in
telomer
manufacturing
and
processing
operations.
Provide
Location
of
each
US
TRP
member
telomer
manufacturing
and
processing
facility.
4.
Biodegradation
Studies
(
8­
2
Telomer
Alcohol):
Description
ofthe
method
development
and
preliminary
biodegradation
studies
conducted
on
8­
2
TelomerAlcohol
(
types
of
studies
and
rationale).
5.
Biodegradation
Studies
(
8­
2
Telomer
Alcohol):
Deliver
results
from
biodegradation
analysis
of
8­
2
Telomer
Alcohol
with
cold
material
(
DuPont
preliminary
screening
study).
6.
Information
Exchange:
Submit
list
of
documents,
other
materials
and
final
study
reports
contained
in
the
TRP
database;
documents
to
follow
when
compiled
(
April).

April
2003
1.
Product
and
Article
Analysis:
Conduct
analytical
and
sample
method
development.
2.
Analysis
of
"
Aged"
Products
and
"
In
Use"
Articles:
Submit
plan
forconducting
PFOA
"
aging"
and
"
in
use"
analytical
studies
in
initial
end­
use
segments
of
carpet,
textiles,
and
paper.
Address
specific
issues
such
as
residual
monomers,
leaching,
degradation,
"
walk
off,"
volatilization,
and
light
exposure.
3.
Characterize
Potential
Release
ofPFOA
from
Telomer­
Based
Product
Manufacture:
Description
of
specific
telomer
manufacturing
process
chemistry
by
member
companies
and
information
about
potential
releases
ofPFOA
and
exposure
routes
from
these
processes
(
US
operations).
4.
Biodegradation
Analysis
(
Polymeric
Products):
Provide
for
EPA
review
the
study
approach,
protocols
and
rationale
forbiodegradation
analysis
of
polymeric
products
in
the
Product
and
Article
Analysis
(
Item
1).
5.
Information
Exchange:
Provide
copies
ofdocuments
and
other
materials
from
the
TRP
database.
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
16
May
2003
1.
Product
and
Article
Analysis:
Description
of
other
telomer­
based
products
(
including
nonpolymeric
products)
and
applications
in
the
United
States
not
included
in
the
Product
and
Article
Analysis,
including
CAS
number,
chemical
name
or
structural
representation
if
no
CAS
number,
product,
2002
use
and
volume
in
commerce
 
to
be
provided
by
individual
companies
under
CBI.
2.
Product
and
Article
Analysis:
Conduct
product
and
article
analyses
and
compile
results.
3.
Characterize
Potential
Release
ofPFOA
from
Telomer­
Based
Product
Manufacture:
TRP
member
companies
will
develop
action
plans
to
investigate
the
potential
for
PF&
A
release
and
exposure.

June
2003
1.
Analysis
of
"
Aged"
Products
and
"
In
Use"
Articles:
Develop
appropriate
analytical
methods
and
study
protocols
to
conduct
these
analyses.
TRP
will
need
to
define
appropriate
"
aging"
and
"
in
use"
conditions
to
conduct
these
tests.
2.
Characterize
Potential
Release
ofPFOA
from
Telomer­
Treated
Article
Manufacture:
Develop
estimates
of
potential
release
of
PFOA
related
to
the
manufacture
oLthree
primary
article
types
(
carpet,
textiles
and
paper).
The
release
scenarios
to
be
developed
will
cover
occupational
and
environmental
exposure
related
to
potential
release
of
PFOA
from
article
manufacture.
3.
Analysis
of
Incineration:
Review
information
on
types
of
incineration
tests
that
may
be
applicable
and
provide
a
summary
to
EPA.

July
2003
1.
Product
and
Article
Analysis:
Submit
final
report
from
screening
study
on
Product
and
Article
Analysis
2.
Characterize
Potential
Release
ofPFOA
from
Telomer­
Treated
Article
Manufacture:
Develop
and
demonstrate
required
sampling
and
analytical
methods
for
PFOA
determination
in
the
mill
simulations.
3.
Biodegradation
Studies
(
8­
2
Telomer
Alcohol):
Deliver
results
from
biodegradation
analysis
of
8­
2
Telomer
Alcohol
with
14C­
labeled
material
(
TRP
study).
4.
Biodegradation
Analysis
(
Polymeric
Products):
Conduct
biodegradation
analysis
for
PFOA
ofpolymeric
products
used
in
the
Product
and
Article
Analysis
under
Item
1.
5.
Analysis
of
Incineration:
Compile
information
on
telomer­
based
polymeric
products
and
uses
to
understand
the
ultimate
fate
and
disposal
routes
(
landfill
versus
incineration)
for
telomer­
treated
articles
in
the
United
States.
6.
Product
Stewardship
for
Customers:
TRP
member
companies
will
have
additional
product
stewardship
programs
in
place
developed
with
reference
to
for
ResponsibleCare
guidelines
outlined
in
the
SOCMA
Management
Practices
/
Product
Stewardship
Code.

August
2003
1.
Characterize
Potential
Release
ofPFOA
from
Telomer­
Treated
Article
Manufacture:
Submit
results
of
release
estimations
of
PFOA
from
article
manufacture.
Mr.
Stephen
L.
Johnson
March
14,
2003
Page
17
2.
Biodegradation
Analysis
(
Polymeric
Products):
Submit
results
of
biodegradation
analyses
for
PFOA
in
polymeric
products.
3.
Product
Stewardship
for
Customers:
Provide
TRP
Safe
Handling
and
Use
Handbook
to
customers
for
review.

September
2003
1.
Analysis
of
"
Aged"
Products
and
"
In
Use"
Articles:
Conduct
"
aging"
and
"
in
use"
analyses
of
the
specific
products
and
treated
articles
(
carpet,
textiles,
paper)
in
TRPsponsored
work
under
Item
1,
once
methods
and
protocols
are
available
study
conducted.
2.
Characterize
Potential
Release
ofPFOA
from
Telomer­
Treated
Article
Manufacture:
Initiate
mill
simulations
of
the
potential
release
of
PFOA
from
telomer­
treated
article
manufacture
to
estimate
the
potential
occupational
and
environmental
exposure
of
PFOA
from
article
manufacture.
Continue
mill
simulations
into
Qtr
4
/
2003.
