U.
S.
Environmental
Protection
Agency
Meeting
Summary
July
2,
2003
PFOA
ECA
Monitoring
Technical
Workgroup
Meeting
Summary,
6/
23/
03
56
participants;
Attendance
list
in
docket
at
OPPT­
2003­
0012­
0126.

The
meeting
included
three
sections:
I.
Presentations
on
the
scope
of
all
industry
LOI
environmental
sampling
and
monitoring
commitments.
II.
Discussion/
Questions
III.
Identification
of
workgroup
next
steps;
determination
of
workgroup
assignments
for
workgroup
and
plenary
meetings
on
July
9
and
10,
2003.

I.
LOI
Commitments
­
Summary
of
Industry
Presentations
The
presentations
on
industry
LOI
commitments
for
monitoring
included
APFO
(
ammonium
perfluorooctanoate)
user
sites,
APFO
manufacturing
sites,
dispersion
processor
sites,
telomer
manufacturing
sites,
and
telomer
use
sites.
The
slide
presentations
are
available
in
the
docket
at
OPPT­
2003­
0012­
0126.

APFO
User
Sites
The
FMG
presentation
described
their
LOI
monitoring
commitments
at
APFO
user
sites
with
respect
to
water
monitoring
and
air
modeling
for
3
pre­
determined
sites
(
DuPont
Washington
Works,
Parkersburg,
WV
and
the
Daikin
and
Dyneon/
3M
plants,
Decatur,
AL),
utilizing
a
phased
approach
where
continued
actions
would
be
determined
by
results
of
the
first
phase.
FMG
reported
that
monitoring
studies
were
underway
at
the
Daikin
and
Dyneon/
3M
sites,
and
that
interim
reports
for
the
Dyneon/
3M
plant
are
projected
for
September
15,
2003.
FMG
indicated
that
reports
from
the
DuPont
site
have
already
been
submitted.

FMG
noted
that
the
monitoring
commitments
were
based
on
the
terms
contained
in
the
multimedia
consent
order
for
the
Washington
Works
plant
signed
by
DuPont
in
November
2001.
Pursuant
to
that
order,
the
C8
Assessment
of
Toxicity
Team
(
CATT)
was
formed
to
determine
risk­
based
human
health
protective
screening
levels
in
air,
water,
and
soil,
to
provide
health
risk
information
to
the
public,
and
to
determine
ecological
health
protective
screening
level
in
surface
water.
The
CATT
team
determined
screening
levels
of
150
ppb
for
water,
240
ppm
for
soil,
1
µ
g/
m3
for
air,
and
an
Aquatic
Life
Advisory
Concentration
level
of
1,360
ppb.

A
Groundwater
Investigation
Steering
Team
(
GIST)
was
also
formed
to
assess
the
presence
and
extent
in
drinking
water,
groundwater,
and
surface
water.
The
scope
of
this
team
included
the
Washington
Works
as
well
as
3
nearby
landfills.

Water
monitoring
included
surface
water
at
rivers
and
creeks
upstream
and
downstream
as
well
as
on­
site,
plant
outfalls,
and
groundwater
under
existing
sites.
The
CATT
screening
levels
were
used
to
assess
results
of
site
studies
and
to
determine
if
additional
action
was
necessary.
The
sampling
included
studies
of
wells
in
a
1
mile
radius
and
a
2
mile
radius
around
the
Washington
U.
S.
Environmental
Protection
Agency
Meeting
Summary
July
2,
2003
2
Works,
WV
site.
FMG
reported
that
the
results
of
testing
were
well
below
the
CATT
levels
and
that
samples
at
the
2
mile
radius
showed
decreased
concentrations
compared
to
the
1
mile
radius.

Air
modeling
was
conducted
according
to
the
Industrial
Source
Complex
Short
Term
Model
(
ISCST3
)
model.
A
site
specific
model
was
used.
The
procedure
included
EPA's
Guideline
on
Air
Quality
Models
40
CFR
Part
51.
Certain
site­
specific
information
was
used
as
the
model
input,
including
a
measured
emission
rate
of
APFO;
the
stack
location,
height,
and
diameter;
gas
exit
temperature;
gas
flow
rate
(
exit
velocity);
and
detailed
plant
layout/
plot
plan.
Air
modeling
data
was
provided
for
2000,
2002
and
projected
values
for
2003
were
generated
for
both
WV
and
Ohio
from
the
Washington
Works
facility.

FMG
indicated
that
ongoing
water
monitoring
will
be
conducted
at
the
Washington
Works
plant
and
3
landfills
in
WV,
monthly
at
plant
outfalls
and
quarterly
at
monitoring
wells.
These
requirements
are
being
integrated
into
permits
for
each
facility.
Monitoring
at
public
water
systems
of
the
Little
Hocking
Water
Association,
Tuppers
Plains­
Chester
Water
District,
and
Lubeck
are
sampled
quarterly.
Off­
site
residential
wells
will
be
sampled.
GIST
is
developing
a
plan
to
conduct
periodic
monitoring
of
locations
in
both
WV
and
OH.

FMG
maintained
that
key
lessons
learned
to
date
indicate
that
air
modeling
may
help
predict
locations
of
higher
ground
water
concentrations;
that
because
of
low
surface
water
concentrations
and
low
bioconcentration
factors,
fish
testing
is
not
justified;
and
that
soil
sampling
is
unnecessary
because
the
data
indicate
that
the
tendency
for
adsorption
onto
soils
is
very
low.

APFO
Manufacturing
Sites
FMG
noted
that
there
is
only
one
plant
in
the
United
States
currently
manufacturing
APFO
 
the
new
DuPont
facility
in
Fayetteville,
NC
 
and
that
3M
is
continuing
to
monitor
its
discontinued
manufacturing
sites
in
Cottage
Grove,
MN
and
Decatur,
AL.

The
3M
monitoring
plan
includes
site
description,
ground
water,
and
plant
effluent
at
the
Cottage
Grove
site;
and
site
description,
ground
water,
plant
effluent,
and
environmental
sampling
(
surface
water,
sediments,
and
fish)
at
the
Decatur
site.
A
summary
table
was
presented
detailing
the
monitoring
activity
and
reporting
deadlines
for
the
next
5
years
at
both
facilities.

FMG
presented
further
monitoring
commitments
for
APFO
manufacturing
which
included
prestartup
water
testing,
air
dispersion
modeling
predictions
and
ongoing
annual
monitoring
at
the
DuPont
Fayetteville,
NC
facility.
Emissions
would
include
APFO
plus
APFO
acid
fluoride,
emissions
at
capacity
rates,
and
scrubber
efficiency
validated
via
stack
testing
currently
underway.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
July
2,
2003
3
FMG
indicated
that
it
considers
air
modeling
to
be
preferable
to
monitoring
because
airborne
monitoring
is
not
practical
or
time­
efficient.
FMG
indicated
that
monitoring
is
slow
due
to
low
aerial
concentrations,
that
concentrations
fluctuate
with
time
and
manufacturing
activity,
and
that
detection
methods
are
not
sensitive
enough
for
real
time
monitoring.
FMG
reported
that
the
model
correlates
with
surface
exposure
in
WV.

APFO
Dispersion
Processor
Sites
FMG
presented
information
on
its
Dispersion
Processors
Mass
Balance
(
DPMB),
which
is
intended
to
account
for
the
amount
of
APFO
fluoropolymer
in
various
compartments
in
industry
as
either
being
recycled,
destroyed,
emitted,
or
contained
in
downstream
products
(
commercial
products
in
dry
powder,
pellets
and
dispersion
forms).
Dispersions
make
up
a
significant
fraction
of
APFO
use.
Almost
all
remaining
material
(
75%)
is
accounted
for
by
recycle,
destruction,
air
and
water
emissions
and
landfill.

FMG
defined
a
dispersion
as
a
water/
polymer
mixture
of
10e7
molecular
weight
polymers
that
do
not
easily
dissolve
in
water.
These
aqueous
dispersions
are
formulated
into
coatings
that
are
applied
to
the
surface
of
other
products.
There
is
a
small
amount
of
APFO
present
in
the
liquid
dispersion
as
sold
by
the
fluoropolymer
manufacturers.

FMG
reported
that
the
plan
for
the
dispersion
processors
mass
balance
includes
a
process
description
questionnaire,
use
and
consumption
data,
application
descriptions,
and
the
use
of
validated
sampling
and
analytical
methods.
Because
processors
are
typically
small
companies
with
highly
proprietary
systems,
a
third
party
environmental
consultant
will
conduct
and
complete
the
questionnaires,
collect
samples
of
process
emissions
(
water/
air),
collect
samples
of
input
raw
materials,
and
oversee
analysis
by
a
qualified
outside
laboratory.
FMG
indicated
that
data
will
be
reported
only
in
the
aggregate
by
market
segments
to
protect
proprietary
process
and
product
information.
FMG
indicated
that
the
laboratory
has
been
selected
and
a
contract
is
in
preparation,
a
statement
of
work
for
the
third
party
environmental
consultant
is
in
draft
form,
and
the
report
to
EPA
is
targeted
by
the
end
of
2003.

Telomer
Sites
The
TRP
reported
that
monitoring
at
telomer
manufacturing
sites
will
take
place
at
the
Washington
Works
and
the
Chambers
Works
sites.
Rather
than
monitoring
at
facilities
that
process
or
use
telomer­
based
polymer
products
to
treat
paper,
carpet,
and
textile
products,
however,
the
TRP
indicated
that
it
would
use
a
mill
pilot
study
to
characterize
emissions
from
processes
and
plants
typical
of
each
market,
and
that
it
would
not
commit
to
further
testing
until
the
results
of
the
mill
study
were
understood.
The
mill
pilot
study
is
expected
to
be
conducted
from
September
to
the
end
of
2003.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
July
2,
2003
4
TRP
indicated
that
another
part
of
the
LOI
commitment
includes
release
and
exposure
assessments
adjacent
to
telomer
manufacturers
and
customer
use
facilities,
and
that
an
action
plan
needs
to
be
developed
to
investigate
the
potential
for
PFOA
release
and
exposure
in
US
manufacturing.
TRP
stated
that
release
estimates
and
analytical
method
development
are
underway.

The
TRP
noted
that,
at
the
June
6,
2003
meeting,
it
had
proposed
inclusion
of
the
8­
2
telomer
alcohol
in
its
LOI
commitments,
and
clarified
that
TRP
intended
to
add
the
alcohol
to
the
mill
work
and
develop
a
valid
method
for
alcohol
analysis.

II.
Discussion/
Questions:

Interested
parties
raised
a
number
of
questions
following
the
industry
presentations.
With
respect
to
the
absence
of
proposals
to
sample
soil
at
APFO
user
sites,
parties
questioned
the
conclusion
that
there
was
a
low
adsorption
of
PFOA
to
soil.

Concerning
the
dispersion
processor
mass
balance
project,
parties
asked
whether
the
survey
would
identify
downstream
controls
in
use,
including
scrubbers,
incinerators,
and
the
like;
FMG
responded
that
they
would
be
included.
FMG
reported
that
no
raw
data
from
the
survey
would
be
submitted
to
anyone
because
of
confidentiality
issues
with
the
processors
and
antitrust
and
FTC
prohibitions
on
revealing
proprietary
information.
FMG
indicated
that
only
the
third
party
contractor
would
have
access
to
the
raw
data.
FMG
stated
that
there
are
only
about
15
to
17
facilities
included
in
their
matrix,
and
that
there
may
be
only
2
to
3
facilities
in
any
given
cell,
making
it
difficult
for
the
contractor
even
to
report
aggregated
data
without
revealing
proprietary
information.
They
noted
that
for
some
companies,
fluoropolymer
processing
is
only
a
small
part
of
their
overall
business,
and
that
some
processors
are
"
job
shops,"
not
dedicated
production
facilities.
EPA
expressed
concern
that
in
the
absence
of
receiving
the
raw
data,
it
would
not
be
able
to
assess
the
information
being
provided.

In
response
to
questions
about
monitoring
at
telomer
manufacturing
sites
and
about
the
components
of
the
pilot
mill
study
to
characterize
telomer
processing
and
use
facilities,
TRP
clarified
that
all
of
the
telomer
chemical
products
included
in
the
testing
are
polymers,
acrylates
and
methacrylates,
in
aqueous
dispersions.
TRP
responded
to
comments
concerning
the
ideal
nature
of
the
mill
pilot
study
by
observing
that
the
study
will
utilize
lab
scale
equipment
known
to
replicate
real­
life
production
processes.
TRP
noted
that,
if
real
manufacturing
facilities
were
used,
it
would
be
impossible
to
distinguish
whether
any
PFOA
found
on­
site
was
being
derived
from
telomers
or
could
be
attributed
to
past
use
of
other
products
with
inherent
PFOA
contamination.
TRP
stated
that
using
the
mill
study
would
allow
for
controls
in
order
to
determine
a
mass
balance
and
to
definitively
determine
the
source
of
any
PFOA
found.
TRP
indicated
that
the
lab
scale
equipment
was
used
throughout
the
mill
industries
as
an
accepted
study
technique.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
July
2,
2003
5
Responding
to
questions
about
whether
the
telomer
application
processes
were
similar
for
all
three
of
the
market
segments
TRP
proposed
to
study,
TRP
indicated
that
telomer
applications
take
place
using
dedicated
pieces
of
equipment
that
apply
the
products
in
the
same
order
at
the
same
time
in
the
process.
TRP
clarified
that
it
would
conduct
mill
studies
for
each
of
the
three
market
segments,
using
only
the
most
common
application
method,
immersion.

Asked
how
the
evaluation
of
groundwater
would
be
conducted
in
a
mill
study,
TRP
responded
that
the
primary
potential
route
to
groundwater
through
the
mill
is
the
aqueous
bath
going
down
the
drain,
and
the
mill
study
would
measure
how
much
was
taken
up
by
the
coated
products
and
average
how
much
went
down
the
drain.
Questioned
on
how
air
releases
would
be
evaluated
in
a
mill
study,
and
how
releases
and
exposures
could
be
mapped,
TRP
answered
that
the
mill
study
would
look
first
for
pathways
to
the
various
environmental
compartments,
rather
than
analyzing
for
the
presence
of
PFOA
or
PFOA
precursors
in
those
compartments
with
no
indication
that
the
process
could
result
in
there
release
to
those
media.
Parties
indicated
concerns
with
the
adequacy
of
the
mill
pilot
study
approach,
including
whether
this
small
scale
process
would
allow
for
the
detection
of
low
concentration
materials,
and
questioned
the
TRP's
decision
to
determine
whether
or
not
to
perform
higher
tier
testing
on
the
findings
of
the
mill
study.

Parties
raised
several
issues
with
respect
to
the
adequacy
of
the
monitoring
programs
described
by
industry,
noting
that
the
monitoring
at
the
Washington
Works
plant
did
not
include
data
elements
that
appeared
in
the
EPA
Preliminary
Framework
document,
such
as
sediments
and
biota.
Parties
also
questioned
why
other
manufacturing
sites
were
not
included
in
the
sampling
and
monitoring
programs.
The
use
in
the
monitoring
program
of
the
screening
levels
set
by
the
WV
CATT
process
was
questioned.
Parties
expressed
concern
that
the
use
being
proposed
for
the
levels
was
not
appropriate,
and
that
the
levels
themselves
were
not
determined
in
an
open,
public
process
and
exceeded
internal
control
levels
previously
set
by
DuPont.
Parties
also
raised
the
question
of
doing
market
basket
sampling
of
food
products
and
of
doing
targeted
human
blood
sampling
in
the
vicinity
of
facilities.
EPA
noted
that
blood
sampling
would
be
beyond
the
scope
of
this
ECA
process,
as
announced
in
the
Federal
Register
notice,
and
indicated
that
EPA
has
approached
CDC
to
request
the
inclusion
of
PFOA
and
other
perfluorinated
chemicals
in
the
National
Health
and
Nutrition
Examination
Survey
(
NHANES).
Industry
observed
that
a
previous
market
basket
survey
had
identified
PFOA
in
very
few
of
the
samples
collected,
and
that
it
did
not
believe
that
additional
food
sampling
would
be
warranted
on
the
basis
of
those
earlier
results.

When
asked
why
the
monitoring
program
relied
on
air
modeling
rather
than
air
monitoring,
the
industry
responded
that
monitoring
outside
the
plant
was
not
feasible
because
there
is
no
validated
method
able
to
detect
the
diluted
air
concentrations
that
might
exist
in
a
community.
The
industry
clarified
that
the
air
modeling
method
did
employ
measured
emission
data
points
at
plant
stacks
to
inform
the
calculation
of
modeled
air
estimates
in
the
community.
Other
parties
expressed
their
belief
that
air
measurement
methodologies
could
be
developed
and
used
to
allow
U.
S.
Environmental
Protection
Agency
Meeting
Summary
July
2,
2003
6
for
air
monitoring
in
communities,
and
questioned
the
absence
of
air
model
validation
for
the
WV
modeling
used
as
the
basis
of
the
LOI
commitment.

Parties
asked
whether
the
soil
could
be
acting
as
a
sink
for
previously
released
PFOA
and
other
perfluorinated
compounds.
Questions
were
also
raised
about
whether
the
surfactant
properties
and
uses
of
PFOA
might
speed
the
movement
of
other
chemicals
through
the
aquifer.
Parties
also
asked
whether
testing
for
the
presence
of
other
perfluorinated
compounds
should
be
done,
not
just
PFOA.

III.
Next
Steps
A:
Review
of
LOI
information
by
all
workgroup
participants.
Clarification
questions
on
the
LOI
presentations
are
due
to
Mary
Dominiak
by
COB
on
6/
27.
B:
Summary
of
Workgroup
meeting
to
be
distributed
in
one
week.
C:
Participants
to
submit
questions,
comments,
and
major
topics
to
discuss
at
the
next
workgroup
meeting
to
Mary
Dominiak
by
COB
on
7/
7.
D:
List
of
questions
proposed
for
workgroup
meeting
to
be
e­
mailed
to
participants
on
7/
8
or
available
in
hard
copy
at
the
meeting
on
7/
9.
E:
Be
considering
workgroup
spokesperson
for
plenary
meeting
on
7/
10.
