U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
PFOA
ECA
Monitoring
Technical
Workgroup
Meeting
Summary,
7/
9/
03
61
participants;
Attendance
list,
agenda,
and
presentation
materials
in
docket
at
OPPT­
2003­
0012­
0146.

The
meeting
included
four
sections:
°
EPA
presentation
listing
the
scope
of
the
Letter
of
Intent
(
LOI)
environmental
sampling
and
monitoring
activities
and
the
preliminary
EPA
data
needs
and
monitoring
objectives
°
Industry
presentations
clarifying
issues
from
the
June
23,
2003
workgroup
meeting
°
Discussion/
Questions
°
Identification
of
workgroup
next
steps;
determination
of
workgroup
assignments
I.
EPA
Presentation
Lawrence
Libelo
of
EPA
presented
a
summary
of
EPA's
understanding
of
industry
LOI
environmental
sampling
and
monitoring
commitments,
and
expressed
EPA's
understanding
of
current
data
gaps
and
monitoring
objectives.
EPA
defined
the
overall
ECA
program
objective
as
the
determination
of
how
PFOA
and
PFOA
precursors
are
released
into
the
environment;
their
fate
and
transport
upon
release;
and
the
routes
and
levels
of
human
and
environmental
exposure.
EPA
indicated
that
it
viewed
the
objective
of
a
monitoring
program
as
providing
information
on
releases
and
routes
of
exposure
in
sufficient
detail
to
understand
the
contributions
of
PFOA
from
various
possible
sources,
and
to
inform
a
cumulative
assessment
of
the
exposure.

Industry
responded
at
several
points
during
the
EPA
characterization
of
its
understanding
of
the
industry
LOI
commitments
to
offer
corrections
and
clarifications.
In
connection
with
proposed
LOI
monitoring
at
APFO
user
sites,
the
Fluoropolymer
Manufacturers
Group
(
FMG)
stated
that
there
is
ongoing
monitoring
at
the
Washington
Works,
WV
site
as
part
of
State
permit
requirements,
and
that
the
preliminary
report
for
the
Decatur,
AL
3M/
Dyneon
sites
is
anticipated
by
August
1,
2003.
In
response
to
EPA's
statement
that
the
LOI
includes
no
environmental
monitoring
at
dispersion
processor
sites,
FMG
stated
that
its
proposed
material
balance
of
dispersion
processors
will
establish
how
much
APFO
goes
out
in
products
and
through
recycling
and
disposal,
and
that
the
question
of
monitoring
would
be
more
relevant
once
the
material
balance
work
was
completed.

In
its
presentation,
EPA
characterized
the
industry
LOI
commitments
for
telomer
sites
as
process
modeling,
with
no
environmental
monitoring
at
processing
or
use
sites.
The
Telomer
Research
Program
(
TRP)
clarified
that
it
has
committed
to
monitoring
at
manufacturing
sites
as
referenced
in
Appendix
#
1
of
the
LOI
commitment.

Substantial
discussion
surrounded
EPA's
description
of
its
understanding
of
the
objectives
of
the
LOI
monitoring
commitments.
EPA
characterized
the
FMG
monitoring
as
having
a
"
health
impact"
objective,
being
grounded
in
determining
whether
environmental
PFOA
levels
would
exceed
the
interim
screening
levels
established
by
the
West
Virginia
C­
8
Assessment
of
Toxicity
Team
(
CATT)
(
OPPT­
2003­
0012­
0015).
EPA's
objectives
of
RECEIVED
OPPT
NCIC
2003
August
6
9:
13AM
OPPT­
2003­
0012­
0158
U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
2
identifying
and
understanding
PFOA
sources
and
pathways
would
utilize
a
sampling
scheme
based
on
analytical
capabilities.
EPA
indicated
that
air
modeling
by
itself
would
not
be
sufficient
for
these
purposes,
and
that
actual
monitoring
of
vapor,
particulate,
and
water
phase
may
be
needed.
With
respect
to
the
proposed
telomer
processor
modeling,
EPA
noted
that
processing
engineering
modeling
would
not
determine
environmental
concentrations.
EPA
also
questioned
whether
biota,
sludge,
or
air
sampling
may
be
needed
at
most
locations.

DuPont
disagreed
with
the
"
health
impact"
characterization
of
the
West
Virginia
monitoring
program,
stating
that
the
monitoring
efforts
were
not
based
entirely
on
screening
levels.
They
noted
that
all
levels
measured
were
well
below
the
CATT
limits,
and
that
sampling
continued
out
to
the
point
where
PFOA
levels
were
decreasing.
DuPont
indicated
that
water
samples
taken
from
a
2­
mile
radius
area
established
that
PFOA
levels
were
lower
than
levels
in
samples
from
the
1
mile
area,
and
that
sampling
ended
at
that
point.
Similarly,
they
indicated
that
the
air
modeling
used
in
West
Virginia
was
based
on
measured
stack
samples,
that
the
model
predictions
correlated
with
the
water
sampling
findings,
and
that
no
validated
method
exists
for
sampling
air
in
the
community,
given
the
low
PFOA
concentrations
that
would
be
anticipated.
During
the
ensuing
discussion
of
possible
air
sampling,
FMG
indicated
that
it
might
be
possible
to
use
local
point
source
personal
hygiene
sampling
in
the
workplace
and
then
expand
to
place
detectors
out
in
the
community
to
produce
data
that
could
be
compared
to
the
modeling
predictions.

Responding
to
EPA's
questions
about
the
absence
of
soil
and
sludge
sampling,
FMG
stated
that
it
had
submitted
adsorption/
desorption
data
to
the
docket
for
review,
and
indicated
that
the
rapid
desorption
results
combined
with
the
Ohio
soil
samples
appeared
to
validate
their
proposal
for
no
additional
soil
monitoring.
FMG
noted
that,
based
on
those
samples,
the
models
were
good
predictors,
and
observed
that
the
West
Virginia/
Ohio
modeling
results
were
used
to
locate
appropriate
sites
for
sample
well
drilling
at
the
new
Fayetteville,
NC
facility.

In
summarizing
its
rationale
of
the
need
for
monitoring,
EPA
indicated
that
existing
blood
analyses
suggest
widespread
exposure,
and
existing
monitoring
data
show
measurable
levels
of
PFOA
and
possible
PFOA
precursors
in
water,
soil,
sediment,
air,
municipal
sludge,
and
biota.
EPA
noted
that
monitoring
could
help
to
define
the
presently
unknown
sources
and
pathways
of
PFOA
and
PFOA
precursors,
and
proposed
that
screening
level
monitoring
be
focused
on
(
1)
worst
case
scenarios;
(
2)
manufacturing,
processing
and
use
monitoring;
and
(
3)
sampling
of
all
environmental
media.
EPA
stated
that
the
scope
of
monitoring
should
be
sufficient
to
identify
background
levels
of
concentration
and
exposure;
should
include
enough
sites
to
ensure
that
worst
case
sites
and
processes
have
been
identified;
and
should
collect
the
appropriate
data
to
allow
extrapolation
to
other
plant
sites
and
areas.
EPA
suggested
that
the
scope
would
include
all
manufacturing
sites,
selected
processor
sites,
and
a
representative
number
of
end
user
sites
from
all
processes,
and
that
monitoring
should
analyze
for
known
or
suspected
precursors
as
well
as
for
PFOA.
In
response
to
a
question,
EPA
clarified
that
the
elements
identified
as
"
data
needs"
in
the
Preliminary
Framework
document
(
OPPT­
2003­
0012­
0056)
and
in
its
presentation
materials
were
points
of
negotiation.
EPA
noted
that,
as
stated
in
U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
3
the
Preliminary
Framework
document,
these
items
present
a
framework
for
the
development
of
data
that
the
Agency
believes
would
be
appropriate
to
address
the
outstanding
PFOA
source
and
exposure
questions
identified
in
the
Federal
Register
notice,
not
a
predetermined
list
of
needs
automatically
defining
the
outcome
of
the
ECA
process.

EPA
acknowledged
that
monitoring
is
part
of
the
larger
matrix
of
PFOA­
related
information.
EPA
noted
that
monitoring
is
proposed
for
verification
of
laboratory
work
and
modeling,
and
observed
that
such
studies
can
produce
unexpected
results.
Monitoring
could
be
used
to
determine
what
additional
testing
may
be
necessary.

II.
Industry
Presentations
FMG
FMG
summarized
their
LOI
commitments
for
monitoring
and
related
activities
at
APFO
manufacturing,
fluoropolymer
manufacturing,
and
dispersion
processing
sites.
FMG
indicated
that
the
current
US
APFO
manufacturer
will
conduct
water
monitoring
and
air
dispersion
modeling
on
an
ongoing
basis,
while
the
prior
US
manufacturer
is
conducting
broad­
based
monitoring
on
an
ongoing
basis,
and
that
all
results
will
be
reported
to
the
EPA.
FMG
stated
that
the
monitoring
programs
at
these
sites
are
comprehensive
and
sufficient.

With
respect
to
fluoropolymer
manufacturing
sites,
FMG
stated
that
75%
of
existing
manufacturing
sites
in
the
US
that
continue
to
use
APFO
are
covered
in
the
scope
of
the
monitoring
proposals
by
industry.
With
regard
to
biota
sampling
at
those
sites,
FMG
stated
that
studies
indicate
that
bio­
concentration
factors
are
low
and
that
the
fish
testing
submitted
by
3M
indicates
no
significant
levels,
leading
to
FMG's
decision
not
to
monitor
biota.
FMG
noted
that
it
did
not
propose
market
basket
surveys
because
previous
surveys
produced
few
detectable
results,
which
were
not
detected
when
the
samples
were
re­
analyzed.
FMG
also
provided
information
on
the
Association
of
Plastics
Manufacturers
in
Europe
(
APME)
study
of
absorption/
desorption
of
PFOA
to
soil,
which
was
submitted
to
EPA
on
July
7,
2003.
FMG
stated
that
the
results
of
the
Little
Hocking
Water
Association
soil
investigation
were
consistent
with
the
APME
study,
and
recommended
on
the
basis
of
those
factors
that
there
was
no
need
to
conduct
soil
testing.

Concerning
dispersion
processor
sites,
FMG
described
their
LOI
commitment
to
develop
a
dispersion
processor
material
balance
as
including
water
and
air
sampling
at
selected
sites
representing
metal
coaters/
formulators,
glass
cloth
coaters,
additives,
and
other
types
by
processing
temperature.
The
selection
criteria
were
based
on
the
principal
volume
users
and
included
analysis
and
comparison
of
operating
conditions.
FMG
stated
that
the
material
balance
report
would
be
submitted
to
EPA
by
the
end
of
2003.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
4
TRP
TRP
restated
their
LOI
commitment
as
the
development
of
site­
specific
plans
on
its
US
operations
to
assess
levels
of
PFOA
in
air
and
water
from
manufacturing
operations
around
each
site;
conduct
site­
specific
air
dispersion
modeling
for
applicable
manufacturing
operations
and
assess
the
results
using
the
air
screening
levels
established
in
WV;
and
conduct
ground
and
surface
water
analyses
at
each
site
and
assess
the
results
using
the
water
screening
levels
established
in
WV.
TRP
reported
the
status
of
each
of
these
areas.

TRP
indicated
that
their
LOI
approach
to
monitoring
focused
on
relevant
releases
and
exposures
during
the
life­
cycle
of
telomer­
based
products
and
articles;
that
their
focus
on
fate
and
monitoring
studies
was
based
on
release
and
exposure
analyses
and
considerations;
and
that
consideration
of
additional
testing
would
be
an
iterative,
step­
wise
approach
triggered
by
improved
knowledge
gained.

TRP
presented
diagrams
on
the
telomer
product
application
process
and
demonstrated
areas
where
potential
environmental
releases
could
occur.
This
information
will
form
the
basis
for
their
mill
pilot
study
design.
TRP
stated
that
the
processing
equipment
is
uniform
across
industries,
has
been
used
for
many
years
and
is
well
understood.
TRP
characterized
the
typical
mass
balance
analysis
as
the
amount
used
being
equal
to
the
amount
on
the
finished
article
plus
air,
water
and
solid
waste
emissions
or
releases
during
product
manufacture.
TRP
stated
that
PFOA
releases
to
water,
air
and
solid
waste
could
be
estimated
for
each
user
site,
including
predicted
environmental
concentrations
for
air
and
water,
and
that
information
could
be
used
to
predict
overall
US
releases.

TRP
stated
that
its
mill
pilot
study
would
represent
real
commercial
processing
and
provide
a
controlled
realistic
scientific
study
to
verify
the
release
model.
The
pilot
production
line
would
be
free
from
other
contamination
sources.
The
pilot
facility
equipment
was
described
as
an
industry
standard
scale­
down
of
actual
mill
equipment
used
industry­
wide
for
research
and
development.
Sampling
would
be
conducted
on
the
application
bath
before
and
after
application,
exhaust
air,
and
treated
articles.
Analysis
will
include
total
organic
fluorine
and
PFOA.

III.
Discussion/
Questions
Parties
asked
whether
the
sampling
proposed
by
EPA
was
intended
to
progress
until
a
non­
detect
finding
was
reached.
EPA
responded
that
its
intention
would
be
to
collect
a
sufficient
number
of
samples
to
obtain
a
background
against
which
to
interpret
the
results.

All
workgroup
participants
agreed
on
the
stated
PFOA
ECA
program
objective,
but
had
differing
opinions
regarding
the
role
that
monitoring
would
play.
Some
participants
felt
that
pchem
properties
and
degradation
pathway
analysis
should
determine
whether
monitoring
is
used.
Some
parties
indicated
that
monitoring
would
be
needed
to
understand
partitioning,
to
determine
U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
5
types
and
rates
of
degradation,
and
to
determine
whether
the
precursor
or
something
else
is
mobile.

Certain
interested
parties
asked
why
monitoring
of
disposal
sites
had
not
been
proposed..
EPA
stated
that
monitoring
in
the
vicinity
of
disposal
sites
as
well
as
near
manufacturing
and
use
sites
should
be
considered.

Several
questions
were
asked
regarding
the
adequacy
of
models
for
making
predictions
involving
these
chemicals.
EPA
stated
that
these
are
non­
conventional
chemicals
that
have
unusual
properties
and
have
been
shown
to
behave
differently
than
many
conventional
models
would
predict.
Because
of
this,
EPA
observed
that
some
additional
sampling
data
may
be
necessary
in
order
to
validate
model
predictions.

One
issue
raised
by
interested
parties
but
not
addressed
by
the
workgroup
was
the
perceived
need
for
human
blood
sampling
in
the
vicinity
of
manufacturing
facilities
to
determine
the
existence
of
"
hot
spots"
with
higher
blood
levels
than
levels
found
in
the
general
population.
Some
interested
parties
stated
that
blood
monitoring
is
key
to
the
determination
of
pathways
of
transmission
to
humans.
EPA
noted
that
blood
sampling
was
not
within
the
purview
of
the
ECA
workgroup
process
and
should
be
brought
up
in
the
plenary
session.

Some
interested
parties
expressed
a
desire
for
sampling
at
distinct
sites
where
only
fluoropolymers
or
telomers,
but
not
both,
were
manufactured.
Parties
indicated
that
doing
sampling
and
analysis
at
distinct
sites
could
better
identify
which
processes
are
contributing
to
PFOA
contamination
than
sampling
at
a
site
used
for
both
purposes.

Parties
pressed
for
an
EPA
analysis
of
and
response
to
conclusions
drawn
by
industry
from
a
market
basket
study
conducted
by
3M.
Several
parties
expressed
differences
of
opinion
regarding
the
interpretation
of
the
results
of
the
study,
and
indicated
that
additional
studies
might
be
warranted.

Parties
asked
questions
concerning
the
FMG
dispersion
mass
balance
analysis,
including
the
number
and
size
of
job
shops
to
be
sampled,
the
number
of
sintered
vs
unsintered
shops,
and
the
method
of
sampling.
FMG
stated
that
15
shops
are
proposed
to
be
sampled
from
primarily
sintered
operations.
Interested
parties
had
concerns
for
smaller
shops
and
questioned
the
degree
of
emission
controls
compared
to
the
larger
shops.
FMG
stated
they
are
aware
of
the
emissions
issue,
and
that
their
intent
is
to
characterize
the
industry.
FMG
stated
that
sampling
would
be
by
the
Exygen
method,
and
that
the
chain
of
custody
and
control
follow
the
procedures
of
the
WV
multi­
media
consent
order.
FMG
added
that
water
sampling
would
be
for
PFOA
in
process
water,
POTW
connected
and
POTW
outfalls.

Interested
parties
raised
questions
regarding
the
proposed
TRP
mill
pilot
study
including
consideration
of
equipment
contamination,
contract
lab
participation,
and
representation
of
the
3
application
methods.
TRP
stated
that
all
mill
equipment
would
be
determined
to
be
contaminant­
U.
S.
Environmental
Protection
Agency
Meeting
Summary
August
1,
2003
6
free
prior
to
use.
TRP
is
using
a
contract
laboratory
that
is
used
throughout
industry
for
emissions
analysis.
The
primary
focus
of
the
pilot
study
will
be
on
the
spray
and
pad
application
methods.

Parties
raised
questions
regarding
the
potential
environmental
releases
from
solid
wastes,
as
well
as
air
and
water
releases.
TRP
stated
that
solid
wastes
are
expected
to
be
the
major
component
of
waste.
TRP
anticipates
that
fugitive
emissions
would
be
from
the
drier
and
samples
would
be
collected
from
the
stack.
Concerning
a
question
about
drum
heels
 
the
residue
remaining
in
a
shipping
container
 
TRP
stated
that
normal
handling
practices
are
the
use
of
returnable
totes
for
materials
and
that
all
materials
are
pumped
into
mix
tanks
for
use.

IV.
Identification
of
workgroup
next
steps;
determination
of
workgroup
assignments
The
workgroup
selected
Phil
Oshida
of
EPA
to
present
a
summary
of
the
workgroup
activities
to
the
Plenary
session.

°
The
workgroup
participants
concluded
that
technical
subgroups
were
necessary
to
consider
telomer
and
fluoropolymer
monitoring
issues
separately;
to
come
to
a
common
understanding
of
the
goal
to
be
served
by
monitoring
within
the
overall
goal
of
the
PFOA
ECA
process;
to
formulate
questions
specifically
to
be
answered
by
monitoring;
and
to
bring
those
questions
back
to
the
main
workgroup.
The
first
meeting
will
convene
one
to
two
times
prior
to
the
next
workgroup
meeting
in
September.
The
workgroup
participants
suggested
that
the
meeting
take
place
for
an
entire
day
as
many
issues
need
discussion
and
the
previous
workgroup
meetings
were
not
adequate
to
accomplish
significant
progress.
°
EPA
committed
to
the
development
of
a
time­
line
for
the
subgroup
activities
to
be
circulated
to
interested
parties.
Interested
parties
wishing
to
participate
will
identify
themselves
to
EPA.
°
The
entire
monitoring
workgroup
will
convene
during
the
week
of
September
15,
2003.
