Ward
Penberthy
04/
30/
2003
01:
04
PM
To:
stephen.
h.
korzeniowski@
usa.
dupont.
com
cc:
(
bcc:
Mary
Dominiak/
DC/
USEPA/
US)
Subject:
Follow­
up
Questions
Regarding
TRP
LOI
Commitments
In
the
TRP
Letter
of
Intent
dated
March
14,
2003
there
are
commitments
to
a
variety
of
environmental
fate,
incineration
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
various
testing
activities
that
are
described
in
the
LOI?
In
particular,
EPA
requests
clarification
on
the
following
items:

LOI
page
3
item
1.
Product
and
Article
Analysis
How
will
representative
products
and
articles
be
selected?
What
criteria
will
determine
which

products
and
articles
are
"
representative"?
Will
the
number
of
products
and
articles
analyzed
be
sufficient
to
make
a
judgement
about
the
overall

contribution
of
telomer
products
and
articles
to
PFOA
in
the
environment?
What
are
the
chemical
identities
of
the
products?

We
have
received
test
methods
from
TRP
for
both
products
(
chemicals)
and
articles
­­
Has
either

method
ever
been
used
before?
Can
you
update
us
on
the
validation
status
and
accuracy
and
precision
of
each
test
method?

Will
PFOA
precursors
such
as
free
telomer
alcohols
be
analyzed
for
in
addition
to
PFOA?
If
so,
which

ones?
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
3
item
2
Aged
Products
and
In
Use
Articles
How
many
products
and
articles
will
be
analyzed?

How
will
representative
products
and
articles
be
selected?

Will
the
number
of
products
and
articles
analyzed
be
sufficient
to
make
a
judgement
about
the

overall
contribution
of
telomer
products
and
articles
to
PFOA
in
the
environment
through
this
pathway?
What
are
the
chemical
identities
of
the
products?

How
will
products
and
articles
be
"
aged"?

What
test
method
will
be
used
to
analyze
the
samples?
(
Will
it
be
the
same
test
method
as
in
item

1?)
What
is
the
test
method's
validation
status
and
its
accuracy
and
precision?

Will
PFOA
precursors
such
as
free
telomer
alcohols
be
analyzed
for
in
addition
to
PFOA?
If
so,
which

ones?
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
4
Releases
of
PFOA
from
Telomer
Treated
Article
Manufacture
How
many
samples
will
be
analyzed?

How
will
representative
articles
be
selected?

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

of
telomer
treated
articles
to
PFOA
in
the
environment?
What
test
method
will
be
used
to
analyze
the
samples?
(
will
it
be
the
same
test
method
as
in
item
1?)

What
is
the
accuracy
and
precision
of
the
test
method?

Will
PFOA
precursors
such
as
free
telomer
alcohols
be
analyzed
for
in
addition
to
PFOA?
If
so,

which
ones?
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
5
Biodegradation
Analysis
How
many
products
will
be
studied
and
how
will
they
be
selected
?

What
are
the
chemical
identities
of
the
products

What
test
method
will
be
used?

What
is
the
accuracy
and
precision
of
the
test
method?

Will
PFOA
precursors
such
as
free
telomer
alcohols
be
analyzed
for
in
addition
to
PFOA?
If
so,
which

ones?
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
5
Incineration
Analysis
How
many
products
and
articles
will
be
analyzed?

How
will
representative
products
and
articles
be
selected?

What
are
the
chemical
identities
of
the
products?

What
test
method
will
be
used
to
analyze
the
samples?

Has
the
test
method
ever
been
validated?

What
is
the
accuracy
and
precision
of
the
test
method?

Will
PFOA
precursors
such
as
free
telomer
alcohols
be
analyzed
for
in
addition
to
PFOA?
If
so,
which

ones?
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.
