Ward
Penberthy
04/
30/
2003
01:
12
PM
To:
lharris@
socplas.
org
cc:
(
bcc:
Mary
Dominiak/
DC/
USEPA/
US)
Subject:
Follow­
up
Questions
Regarding
FMG
LOI
Commitments
In
the
March
14,
2003
FMG
Letter
of
Intent
there
are
commitments
to
a
variety
of
environmental
monitoring
and
product
testing
activities.
We
would
like
to
understand
precisely
what
work
is
being
undertaken
and
would
appreciate
some
clarification
about
some
of
the
LOI
items.
After
we
understand
the
specifics
of
the
LOI
commitments,
we
will
be
in
a
better
position
to
identify
testing
issues
that
are
adequately
dealt
with
in
the
LOIs
vs.
items
that
may
need
to
be
addressed
in
the
ECA
discussions
commencing
on
June
6.

To
that
end,
could
you
please
provide
a
detailed
description
of
the
testing
activities
that
are
described
in
the
LOI?
In
particular,
EPA
requests
clarification
on
the
following
items:

LOI
page
7
item
2
3)
"
as
necessary
....
conduct
ground
and
surface
water
analysis
and
assess
results
using
the
water
screening
levels..."

What
criteria
will
be
used
to
determine
if
it
is
"
necessary"
to
collect
water
samples?

How
many
samples
will
be
analyzed
from
each
location
and
what
is
the
sampling
strategy?

What
test
method
(
standard)
will
be
used
to
analyze
the
samples
(
e.
g.,
ASTM,
EPA,
OECD,
other

specify)?
Will
PFOA
precursors
and/
or
other
constituent
components
of
the
product
mixtures
be
analyzed
for
in

addition
to
APFO/
PFOA?
If
so
which
ones?
What
is
the
accuracy
and
precision
of
the
test
method?

Has
the
test
method
been
validated?

Do
you
have
a
consolidated
written
description
of
the
procedures
that
will
be
followed
with
this

testing?
If
so,
please
provide
a
copy.
If
these
procedures
have
already
been
identified
in
a
submission
to
the
Agency
(
ie.
to
AR226
or
8(
e)),
please
identify
the
submission.
What
is
the
timing
of
this
work?

LOI
page
10
item
4
1)
and
2)
"
analyze
representative
articles
of
commerce
containing
or
made
with
dry
fluoropolymer
resins
for
the
presence
of
APFO"
and
"
for
products
coated
or
manufactured
with
liquid
dispersions,
analyze
representative
articles
of
commerce
for
presence
of
APFO"

How
will
representative
products
be
selected?
What
criteria
will
be
used
to
determine
which
products

are
"
representative"?
How
many
samples
of
each
representative
product
will
be
analyzed
and
what
is
the
sampling

strategy?
Will
the
number
of
articles
analyzed
be
sufficient
to
make
a
judgement
about
the
overall
contribution

of
fluoropolymer
treated
articles
to
PFOA
in
the
environment?
What
test
method
(
standard)
will
be
used
to
analyze
the
samples
(
e.
g.,
ASTM,
EPA,
OECD,
other

specify)?
Will
PFOA
precursors
and/
or
other
constituent
components
of
the
product
mixtures
be
analyzed
for
in

addition
to
APFO/
PFOA?
If
so
which
ones?
What
is
the
accuracy
and
precision
of
the
test
method?

Has
the
test
method
been
validated?

What
is
the
reporting
criteria
for
the
constituent
components
that
will
be
reported?

Do
you
have
a
consolidated
written
description
of
the
procedures
that
will
be
followed
with
this

testing?
If
so,
please
provide
a
copy.
If
these
procedures
have
already
been
identified
in
a
submission
to
the
Agency
(
ie.
to
AR226
or
8(
e)),
please
identify
the
submission.
What
is
the
timing
of
this
work?

LOI
Addendum
III
item
4)
"
monitor
groundwater
and
surface
water
for
APFO
in
the
vicinity
of
the
facility"

How
many
samples
will
be
analyzed
and
what
is
the
sampling
strategy?

What
specific
facilities
are
anticipated
to
be
covered
by
the
Addendum?

What
is
the
basis
for
selecting
these
facilities
as
opposed
to
monitoring
all
facilities?

What
test
method
(
standard)
will
be
used
to
analyze
the
samples
(
e.
g.,
ASTM,
EPA,
OECD,
other

specify)?
Will
PFOA
precursors
and/
or
other
constituent
components
of
the
product
mixtures
be
analyzed
for
in

addition
to
APFO/
PFOA?
If
so
which
ones?
What
is
the
accuracy
and
precision
of
the
test
method?

Has
the
test
method
been
validated?

Do
you
have
a
consolidated
written
description
of
the
procedures
that
will
be
followed
with
this

testing?
If
so,
please
provide
a
copy.
If
these
procedures
have
already
been
identified
in
a
submission
to
the
Agency
(
ie.
to
AR226
or
8(
e)),
please
identify
the
submission.
What
is
the
timing
of
this
work?

We
would
appreciate
a
response
by
May
5,
2003.
Please
call
me
at
202
564
­
8171
if
you
have
any
questions
or
need
to
discuss
further.
Thanks
for
your
continued
help
on
these
matters.
