FMG
LOI
 
Addendum
III,
Item
4
May
7,
2003
DuPont
Response
Page
1
FMG
LOI
Response
from
DuPont
to
EPA
Questions
re
Addendum
III,
Item
4
"
monitor
groundwater
and
surface
water
for
APFO
in
the
vicinity
of
the
facility"
specific
to
APFO
manufacturing
facility
i)
How
many
samples
will
be
analyzed
and
what
will
be
the
sampling
strategy?

There
is
only
one
DuPont
manufacturing
APFO
manufacturing
site,
as
listed
below.
At
this
site,
in
January
2003,
groundwater
was
sampled
from
four
monitoring
wells
and
a
combined
surface
and
wastewater
sample
was
collected
from
the
site
NPDES
outfall
(
Outfall­
002).
These
samples
were
collected
in
order
to
establish
baseline
conditions
at
the
facility.
Sampling
strategy
was
based
upon
site
coverage
and
accessibility
to
the
wells.
Confirmatory
sampling
was
conducted
in
March
2003.
The
same
sampling
plan
will
be
repeated
on
an
annual
basis.

Results
and
more
details
on
the
sampling
plan
are
provided
in
Attachment
1,
entitled
"
Workplan
to
Monitor
PFOA
in
Water,
DuPont
Fayetteville
Works",
dated
May
2003
and
Attachment
2,
entitled
"
January
2003
Baseline
C­
8
Sampling
DuPont
Fayetteville
Works",
dated
March
2003.

ii)
What
specific
facilities
are
anticipated
to
be
covered
in
the
Addendum?

The
only
DuPont
APFO
manufacturing
facility
is
DuPont
Fayetteville
Works
22828
NC
Highway
87
West
Fayetteville,
North
Carolina
28306
i)
What
is
the
basis
for
selecting
these
facilities
as
opposed
to
monitoring
all
facilities?

The
Fayetteville
facility
is
the
only
facility
where
DuPont
manufactures
APFO.

i)
What
test
method(
standard)
willbeusedto
analyzethesamples(
e.
g.,
ASTM,
EPA,
OECD,
other?)

The
test
method
used
to
analyze
the
water
samples
is
the
same
method
being
used
to
analyze
water
samples
from
West
Virginia
and
Ohio.
Ammonium
perfluorooctanoate
(
APFO)
forms
perfluorooctanoic
acid
(
PFOA)
in
aqueous
solution.
PFOA
is
extracted
from
water
using
C18
solid
phase
extraction
(
SPE)
cartridges.
Quantitation
of
PFOA
is
accomplished
by
LC/
MS/
MS
analysis
using
selected
reaction
monitoring
(
SRM).
Levels
of
PFOA
found
are
mathematically
FMG
LOI
 
Addendum
III,
Item
4
May
7,
2003
DuPont
Response
Page
2
converted
and
reported
as
APFO.
The
analytical
procedure
is
described
in
more
detail
in
Attachment
3,
Exygen
Research
Method
Number
01M­
008­
046
Revision
1,
entitled
"
Method
of
Analysis
for
the
Determination
of
Ammonium
Perfluorooctanoate
(
APFO)
in
Water
Revision
1",
dated
January
xx,
2003,
referred
to
hereafter
as
the
"
Exygen
SOP".

iv)
WillPFOAprecursorsand/
orotherconstituentcomponentsoftheproductmixtures
be
analyzed
for
in
addition
to
APFO/
PFOA?
If
so,
whichones?

The
analysis
is
for
APFO
only
since
the
only
precursor,
the
acid
fluoride,
converts
to
APFO.

v)
What
is
the
accuracy
and
precision
of
the
test
method?

See
Attachment
3
Exygen
SOP
and
also
page
28
of
Attachment
4,
entitled
"
Groundwater
Investigation
Quality
Assurance
Project
Plan
for
Washington
Works
Plant",
dated
January
2002,
which
is
described
in
response
to
item
vii)
below.

vi)
Has
the
test
method
been
validated?

The
test
method
(
as
described
in
Attachment
3)
is
the
same
as
that
being
used
for
samples
collected
for
testing
in
West
Virginia.
Over
25%
of
the
data
collected
since
December
2001
has
undergone
third
party
quality
assurance
review.
The
quality
assurance
review
was
conducted
by
Environmental
Standards,
Inc.
in
Valley
Forge,
Pennsylvania,
with
guidance
from
the
Region
III
Modifications
to
National
Functional
Guidelines
for
Organic
Data
Review
[
United
States
Environmental
Protection
Agency
(
USEPA),
1994].

In
addition,
Exygen
has
received
certification
from
the
State
of
West
Virginia
to
conduct
PFOA
analysis.

vi)
Doyouhaveaconsolidatedwrittendescriptionoftheproceduresthatwillbe
followedwiththistesting?

As
stated
on
page
1
of
Attachment
2,
the
procedures
followed
for
water
sampling
and
testing
are
similar
to
those
followed
for
sampling
and
testing
of
groundwater
and
surface
water
at
the
DuPont
Washington
Works,
West
Virginia
facility.
See
Attachment
4,
"
Groundwater
Investigation
Quality
Assurance
Project
Plan
for
Washington
Works
Plant",
with
focus
on
Sections
4.0
 
15.0.

A
similar
document
is
being
prepared
for
the
Fayetteville
facility
and
will
be
forwarded
to
EPA
when
complete.

(
1)
If
so,
please
provide
a
copy.

See
Attachment
4.
FMG
LOI
 
Addendum
III,
Item
4
May
7,
2003
DuPont
Response
Page
3
(
2)
IftheseprocedureshavealreadybeenidentifiedinasubmissiontotheAgency(
i.
e.,
toAR226or8(
e)),
pleaseidentifythesubmission.

N/
A
vi)
What
is
the
timing
of
this
work?

Baseline
sampling
is
completed.
Sampling
will
continue
annually,
with
the
next
sampling
event
being
targeted
for
January
2004.
FMG
LOI
 
Addendum
III,
Item
4
May
7,
2003
DuPont
Response
Page
4
List
of
Attachments
In
Response
to
Questions
on
Addendum
III,
Item
4
of
the
FMG
LOI
Attachment
No.
Title
No.
of
Pages
1
Workplan
to
Monitor
PFOA
in
Water1
DuPont
Fayetteville
Works
2
January
2003
Baseline
C­
8
Sampling5
DuPont
Fayetteville
Works
3
Exygen
Method
of
Analysis
for
the
28
Determination
of
Ammonium
Perfluorooctanoate
(
APFO)
in
Water
Revision
1
4
Groundwater
Investigation
Quality
49
Assurance
Project
Plan
for
Washington
Works
Plant
