Mary
Dominiak
09/
04/
2003
04:
46
PM
To:
Mary
Dominiak/
DC/
USEPA/
US@
EPA
cc:
(
bcc:
Mary
Dominiak/
DC/
USEPA/
US)
Subject:
Materials
for
9­
9­
03
PFOA
ECA
Telomer
Degradation
Subgroup
conference
call
You
are
receiving
this
message
because
you
have
expressed
an
interest
in
receiving
information
concerning
the
Agency's
enforceable
consent
agreement
(
ECA)
process
on
perfluorooctanoic
acid
(
PFOA)
and
the
fluorinated
telomers,
OPPT­
2003­
0012.
If
you
no
longer
wish
to
receive
this
information,
please
reply
to
dominiak.
mary@
epa.
gov
requesting
that
you
be
removed
from
this
notification
list.

****************************************************************************************
TO:
PFOA
ECA
Technical
Workgroup
and
Plenary
Meeting
Attendees
Attached
please
find
a
tentative
agenda,
a
list
of
anticipated
attendees,
and
two
EPA
documents
for
use
in
the
second
meeting
of
the
PFOA
ECA
Technical
Expert
Subgroup
on
Telomer
Degradation,
a
teleconference
meeting
scheduled
for
Tuesday,
September
9,
2003,
from
10:
00
to
1:
00
EDT.
The
physical
meeting
facilities
are
at
EPA
East
Building,
1201
Constitution
Avenue,
NW,
Washington,
DC,
Room
4225.

A
limited
number
of
conference
lines
are
available
for
this
call,
and
have
been
arranged
for
the
convenience
of
Subgroup
members
who
are
not
able
to
attend
the
meeting
in
person
in
Washington,
DC.
Priority
for
the
conference
lines
must
be
given
to
Subgroup
members,
who
appear
on
the
list
of
anticipated
attendees
attached
to
the
draft
agenda.
Call­
in
information
appears
on
the
draft
agenda.

The
two
EPA
documents
include
EPA
comments
on
the
Biodegradation
Approach
Proposal
presented
by
the
Telomer
Research
Group
(
TRP)
at
the
Subgroup
meeting
on
August
14,
2003
(
included
in
the
docket
as
part
of
document
OPPT­
2003­
0012­
0181);
and
a
table
comparing
the
EPA
and
TRP
proposals
for
the
elucidation
of
degradation
pathways
and
the
identification
of
degradation
products.

If
you
have
any
questions
or
experience
any
difficulty
in
opening
the
attached
files,
please
contact
me.

Sincerely,

Mary
F.
Dominiak
U.
S.
Environmental
Protection
Agency
EPA
East,
Mail
Code
7405M
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
Phone:
202­
564­
8104
Fax:
202­
564­
4775
Courier
deliveries:
1201
Constitution
Ave.,
NW,
Room
4410;
564­
4760
Telomer
Degradation
ECA
draft
agenda
090420
EPA­
TRP
Degradation
Proposal
Compariso
EPA
comments
on
8­
14­
03
TRP
biodeg
propos
U.
S.
Environmental
Protection
Agency
Draft,
September
4,
2003
Technical
Subgroup
on
Degradation
Test
Methods
for
Telomers
Tentative
Agenda
­
Second
Meeting
(
Teleconference)

Tuesday,
September
9,
2003
10:
00
AM
to
1:
00
PM
Meeting
Location
­
Room
4225
in
EPA
East.
Fifteen
(
15)
teleconference
lines
are
available
for
anticipated
attendees
who
are
unable
to
attend
in
person.

The
call­
in
number
is
202­
275­
0199.
The
access
code
is
3824#.

Please
note
that
the
number
of
conference
lines
available
is
limited,
and
priority
must
be
given
to
anticipated
attendees.
Organizations
with
multiple
remote
attendees
are
requested
to
consolidate
their
participants
to
the
extent
possible,
so
that
multiple
participants
at
the
same
remote
location
could
use
a
single
call­
in
line.

 
Review
of
Action
Items
from
8/
14/
2003
meeting:

TRP:
review
applicability
of
SCAS
test;
consider
degradation
products
for
testing
or
alternative
proposal
to
screen
for
degradants,
measurement
of
rate
constants,
and
consider
extending
the
length
of
the
test
EPA:
comment
on
TRP
proposal,
review
TRP
logic
for
not
testing
water
and
air,
analytical
chemistry
issues,
degradation
products
issues,
and
consider
whether
we
can
begin
drafting
an
ECA
for
soil
testing
 
Discussion
of
TRP
Action
Items
­
TRP
S
Discussion
of
EPA
Action
Items
­
EPA
S
Next
Steps
U.
S.
Environmental
Protection
Agency
Draft,
September
4,
2003
Anticipated
Attendees
for
September
9,
2003
Telomer
Degradation
Subgroup
Meeting
Rich
Purdy
Treye
Thomas,
CPSC
John
Heinze,
Environmental
Health
Research
Foundation
Volker
Koch,
Clariant
Hiroyuki
Iwai,
Daikin
Satoshi
Komatsu,
Daikin
Ed
Lampert,
Daikin
Yukiko
Nishiyama,
Daikin
Randy
Roussel,
Daikin
Maggie
Martin,
Daikin
Bob
Buck,
DuPont
Bill
Berti,
DuPont
John
Gannon,
DuPont
Steve
Korzeniowski,
DuPont
W.
Michael
McCabe
(
DuPont)
Bill
Hardie,
W.
L.
Gore
Richard
Baillie,
W.
L.
Gore
Erin
Russell,
Clariant
David
Lynch,
EPA/
EETD
Bob
Boethling,
EPA/
EETD
Andy
Mamantov,
EPA/
EETD
Greg
Fritz,
EPA/
EETD
Laurence
Libelo,
EPA/
EETD
Ward
Penberthy,
EPA/
CCD
Eric
Weber,
EPA/
ORD
Tim
Collette.
EPA/
ORD
Ed
Heithmar,
EPA/
ORD
Rich
Leukroth,
EPA/
CCD
Wendy
Hoffman,
EPA/
EETD
Cathy
Fehrenbacher,
EPA/
EETD
Barbara
Leczynski,
EPA/
CCD
Mary
Dominiak,
EPA/
CCD
(
Observer:
Barbara
Smyser,
CPS
[
TRP])
(
Observer:
Katie
Smythe,
RAND
[
TRP])
U.
S.
Environmental
Protection
Agency
September
4,
2003
EPA
Comments
on
Telomer
Research
Program
(
TRP)
Biodegradation
Approach
Proposal
(
14
Aug
03)

Objective
The
TRP
Biodegradation
Approach
Proposal
presents
a
plan
in
which
the
environmental
partitioning
and
transformations
of
telomer
based
telomeric
products
and
telomer
based
polymers
are
investigated.
Initially
two
telomer­
based
products
and
two
telomer­
based
polymers
isolated
from
them
will
be
studied,
followed
by
studies
on
10
additional
representative
telomerbased
polymeric
products.

Page
Comment
3
The
stated
objective
is
to
determine
if
telomer­
based
products
and
polymers
biodegrade
to
PFOA,
but
it
should
be
to
determine
if
they
degrade
(
via
biodegradation
or
any
other
process)
to
PFOA
or
any
other
transformation
products
of
potential
concern.

Some
release
information
has
been
provided
to
the
agency,
however
all
relevant
releases
have
yet
to
be
verified.
This
verification
is
important
because
incorrect
release
assumptions
could
result
in
important
media­
specific
tests
not
being
run
12
Uses/
applications
EPA
is
evaluating
the
use
information
with
respect
to
chemical
selection
under
a
proposed
ECA
Physical­
Chemical
Properties
13
What
are
the
sources
of
p­
chem
properties
for
the
two
polymers
to
be
tested?
Are
they
measured
or
estimated?

E­
Fate
Testing
Decision
Tree:
STP
18
The
figure
is
somewhat
confusing.
Does
an
"
Aerobic
sewage
treatment
test"
need
to
be
done
regardless
of
whether
a
test
substance
shows
significant
sludge
adsorption
or
sedimentation?
This
is
the
interpretation
of
the
figure,
since
there
is
no
high,
low,
yes
or
no
on
the
down
arrow
from
sludge
adsorption.

Instead
of
"
Inherent
biodegradability"
the
box
should
say
"
Semi­
Continuous
Activated
Sludge
(
SCAS)
test".
Since
there
are
no
exits
from
this
box,
it
is
assumed
to
mean
that
the
biodegradation
information
is
simply
noted
and
its
use
is
undefined.
It
is
acceptable
that
negative
results
in
a
SCAS
test
run
for
an
agreed
upon
number
of
cycles
 
which
will
be
many,
in
order
to
ensure
that
the
negative
results
have
meaning
 
could
be
used
to
U.
S.
Environmental
Protection
Agency
September
4,
2003
2
avoid
the
need
for
a
simulation
test
such
as
OECD
303A;
except
that
according
to
the
flow
chart
it
will
be
run
regardless.

If
the
intent
is
not
to
require
an
aerobic
sewage
treatment
test
if
sludge
adsorption
is
high,
then
EPA
disagrees
with
the
approach.
Biodegradation
can
occur
in
treatment
regardless
of
whether
a
substance
is
strongly
adsorbed.
Degradation
can
be
aerobic
or
anaerobic.
Even
"
aerobic"
treatment
processes
can
have
anaerobic
zones
(
e.
g.
settled
sludge
in
the
secondary
clarifier).
Etc
Also,
it
will
be
particularly
important
to
establish
mutually
agreeable
thresholds;
e.
g.
for
what
is
a
"
high
HLC"
and
what
is
high
sludge
adsorption.
There
are
many
such
thresholds
in
the
TRP
scheme.

It
is
preferable
to
have
a
testing
scheme
in
which
one
simply
does
the
simulation
test
straightaway,
perhaps
after
determining
basic
p/
chem
properties
but
not
triggered
by
results
in
any
of
them.
Such
a
simulation
test
would
require
measuring
parent
and
products
in
sludge,
effluent,
and
off­
gases.
It
and
any
other
testing
for
soil
or
water
fate
would
be
done
independently
of
results
in
the
other
tests.
Neither
a
SCAS
nor
Zahn­
Wellens
test
would
be
done
because
it
would
not
yield
additional
useful
information.
Such
an
approach
is
simple
and
does
not
require
a
complex
flow
chart.

It
appears
that
this
flow
chart,
(
especially,
the
significance
of
an
arrow's
lacking
a
yes,
no,
high
or
low
descriptor),
indicates
some
testing
would
be
done
automatically.
In
this
context
the
flow
chart
seems
better
described
as
an
assessment
logic
than
a
testing
tree,
which
is
what
the
title
says.

The
use
of
HLC
alone
as
a
determining
factor
for
triggering
inherent
biodegradability
testing
in
this
scheme
suggests
a
high
level
of
confidence
that
high
HLC
values
will
not
also
sorb.
How
would
such
a
chemical
be
handled?

There
will
be
some
discharge
of
a
chemical
to
surface
waters
even
though
it
sorbs
strongly
to
sludge
as
solids
carry
over
from
the
final
clarfier.
Most
STPs
operate
in
the
80­
90
%
solids
removal
efficiency
range.

E­
Fate
Testing
Decision
Tree
:
Soil
19
The
scheme
seems
to
indicate
that
the
soil
test
would
be
done
regardless
of
whether
there
is
high
or
low
sorption
or
HLC.
TRP
should
more
clearly
separate
the
assessment
logic
(
which
shows
what
information
comes
from
what
test
and
what
it
may
mean)
from
the
list
of
tests
and
what
if
anything
triggers
a
given
test.
Part
of
the
problem
is
that
the
flow
chart
is
called
a
testing
decision
tree
and
fate
testing
logic.
U.
S.
Environmental
Protection
Agency
September
4,
2003
3
Is
testing
for
biodegradation
in
groundwater
triggered
if
releases
to
soil
of
a
nonsorbing
chemical
are
expected?

E­
Fate
Testing
Decision
Tree
:
Air
20
Where
do
hydroxyl
radical
and
ozone
oxidation
fit
into
the
grand
scheme?
Is
it
intended
that
"
indirect
photolysis"
includes
these
processes?

How
is
wet/
dry
deposition
potential
determined?

How
is
indirect
photolysis
(
hydroxy
radical
oxidation)
rate
determined?

Indirect
photolysis
in
air
testing
should
be
conducted
regardless
of
the
UV/
Vis
absorption
test
results.

The
assumption
of
no
air
releases
should
not
be
accepted
without
verification.
Possible
routes
include
volatilization
from
aeration
in
STP?

What
is
the
HLC
value
to
determine
if
the
potential
for
volatilization
is
significant?
How
is
HLC
value
determined?

For
LRTP
assessment
EPA
suggests
review
and
consideration
of
the
OECDrecommended
"
benchmark
chemicals
approach,"
the
selected
benchmarks
would
provide
the
needed
context
for
any
estimates
of
LRTP.
A
Draft
OECD
guidance
document
is
now
available.

E­
Fate
Testing
Decision
Tree
:
Water
21
How
will
it
be
determined
whether
a
substance
forms
a
film
at
the
water/
air
interface?
Which
test
guideline/
method?

Does
the
absence
of
yes,
no,
high
or
low
from
the
down
arrow
under
"
forms
film"
mean
that
sorption
will
be
determined
regardless
of
the
outcome
of
photolysis
tests
(
if
done)?
Analogous
question
for
the
down
arrow
from
sediment
adsorption/
sedimentation.

Which
river
die­
away
test?
The
conditions
of
OECD
308
"
Aerobic
and
anaerobic
transformations
in
aquatic
sediments
systems"
subsume
the
basic
conditions
of
a
typical
river
die­
away
test.
It
appears,
therefore,
there
is
no
reason
to
do
a
river
die­
away
test
if
OECD
308
is
done.

OECD
308
should
be
done
if
there
is
any
potential
for
entry
via
water,
regardless
of
whether
there
is
film
formation
or
adsorption/
sedimentation.
U.
S.
Environmental
Protection
Agency
September
4,
2003
4
Routes
into
the
Environment
24
Soil
could
also
receive
releases
from
air
deposition.
Can
the
assumption
of
no
direct
discharges
to
water
be
confirmed?
The
chemical
bound
to
soil
in
surface
runoff
does
not
appear
to
be
considered
and
it
should
be
as
a
potential
route
of
entry
into
the
environment.

Are
the
results
from
the
incineration
testing
considered
in
this
proposal?

Environmental
Entry
Point:
STP
26
The
slide
says
that
water
and
sediment
are
not
expected
to
be
significant
compartments
if
there
is
major
adsorption
to
sludge,
but
what
about
the
possibly
substantial
fraction
of
sludge
solids
that
don't
settle
and
are
discharged
with
effluent
to
receiving
waters?
This
is
likely
to
vary
with
the
plant
and
how
well
it's
operating.
This
is
one
reason
why
the
OECD
308
test
should
be
done
regardless
of
the
extent
of
sludge
adsorption.

Sediments
could
be
a
compartment
for
polymer
bound
to
sludge
released
in
effluent
and
deposited
to
sediments.
Sludge
volume
is
often
reduced
and
stabilized
via
anaerobic
digestion.
OECD
311
addresses
this
biodegradation
process
and
it
is
appropriately
part
of
the
testing
plan.

Environmental
Entry
Point:
Landfill
28
Chemical
substances
may
leach
or
migrate
from
landfilled
articles
or
off­
spec
polymers/
products.
Therefore,
it
is
incorrect
to
say
categorically
that
leaching
to
ground
water
beneath
landfills
is
not
expected.
We
would
expect
very
little
such
migration
but
this
should
be
subject
to
some
sort
of
screening
test
since
the
environmental
behavior
of
these
compounds
is
largely
unknown.

How
does
the
article
testing
fit
in?

Would
acid
leachate
conditions
have
an
effect
on
these
chemicals?

29
How
will
high
or
low
HLC
and
Koc
be
defined?

Analytical
Measurement
Limitations
34
What
is
the
sensitivity
of
TOF
analysis
and
how
will
it
be
used
in
material
balance?
U.
S.
Environmental
Protection
Agency
September
4,
2003
5
Proposed
Study
Plan
35
EPA
is
reviewing
criteria
for
the
selection
of
chemicals
to
be
tested
under
a
proposed
ECA
Study
Proposal:
Inherent
biodegradability
in
Sludge
36
EPA
does
not
believe
that
a
Zahn­
Wellens
test
provides
more
favorable
conditions
than
in
a
typical
STP.
The
TRP
should
provide
hard
evidence
to
support
their
assertion.

Various
things
have
been
written
about
Zahn­
Wellens
vs.
STPs
and
other
tests,
over
the
years.
Gerike
and
Fischer
(
1979)
say
it
".....
is
meant
to
represent
an
industrial
sewage
treatment
plant;
i.
e.
it
was
designed
to
evaluate
the
removability
of
industrial
chemicals
released
by
point
discharge...."
Nyholm
(
1990)
says
"
If
the
result
from
a
SCAS
test
is
negative,
and
toxic
effects
can
be
ruled
out,
environmental
persistence
is
considered
likely
and
there
is
usually
no
need
to
carry
out
a
simulation
test.
The
Zahn­
Wellens
test,
although
powerful,
does
not
offer
the
same
possibilities
for
adaptation
over
a
long
period
of
time,
and
a
negative
result
in
this
test
does
not
rule
out
biodegradability
in
adapted
environments."
Painter
(
1995)
points
out
that
the
cell
density
in
Zahn
­
Wellens
is
much
higher
than
in
ready
tests
(
at
1000
mg/
L),
but
then
indicates
that
there
is
no
other
organic
matter
added,
and
the
duration
is
only
28
days
as
in
ready
tests.
He
says
that
SCAS
"...
is
much
more
conducive
to
biodegradation
than
the
other
tests
since
the
concentration
of
sludge
is
higher
at
1­
4
g/
L
[
similar
to
STPs],
domestic
or
synthetic
sewage
is
fed
daily
with
the
test
compound,
and
the
duration
can
be
three
months
or
more."
It
seems
better
to
characterize
Zahn­
Wellens
as
a
crude
STP
simulation
test,
as
do
Blok
and
Balk
(
1994).

It
is
also
not
wise
to
generalize
so
broadly
about
STP
conditions.
There
are
typical
STPs,
but
there
are
also
extended
aeration
systems,
facultative
lagoons,
etc.
EPA
must
consider
all
of
this.

In
general,
it
is
believed
that
the
environment
has
more
degradation
power
than
most
laboratory
screening
tests,
and
this
probably
also
applies
to
tests
using
natural
grab
samples.

Aerobic
Sewage
Treatment
Study:
Proposal
for
Discussion
40
"
Need
to
understand
sorption
to
sludge
and
sedimentation
in
advance
of
the
study"
 
how?
By
conducting
Activated
Sludge
Sorption/
Desorption
Isotherm
tests?

The
test
needs
to
analyze
volatiles
and
the
aqueous
phase.
Also
assess
the
potential
for
solids
carry
over
into
effluent.
U.
S.
Environmental
Protection
Agency
September
4,
2003
6
How
will
relevant
concentrations
be
determined?
What
is
the
influence
of
the
sensitivity
of
analytical
methods
used
on
determining
initial
test
chemical
concentrations?

41
In
order
to
meet
EPA's
data
needs
the
endpoints
should
include
analysis
of
sludge
for
TOF,
PFOA
and
other
degradation
products,
analysis
of
aqueous
phase
for
TOF,
[
F­],
PFOA,
and
other
degradation
products,
and
analysis
of
volatiles
for
TOF,
PFOA
and
other
degradation
products.

Technical
Hurdles:
Activated
Sludge
Sorption
42
EPA
suggests
that
it
may
be
possible
to
develop
reliable
methods
for
extraction
of
degradation
products.

Aerobic
and
Anaerobic
Transformations
in
Soil:
Proposal
for
Discussion
45
Consider
flow­
through
design
for
soil
biodegradation
testing.
Test
duration
should
be
long
enough
to
establish
half­
life
or
one
year,
which
ever
is
shorter.
Include
measurement
of
degradation
rates
and
half­
lives
and
analysis
of
degradation
products
including
PFOA.

46
The
soil
study
is
arguably
the
most
important
biodegradation
study
to
be
done,
based
on
the
expected
partitioning
characteristics
of
the
test
substances.
There
should
be
more
test
materials,
possibly
including
degradation
products.
What
if
the
STP
and/
or
SCAS
studies
suggest
possible
formation
of
relevant
breakdown
products?
In
this
case
the
products
could
also
enter
soil,
e.
g.
via
land
spreading
of
sludge.
Therefore,
soil
degradation
testing
may
be
triggered
by
results
of
other
fate
tests.
U.
S.
Environmental
Protection
Agency
Draft,
September
4,
2003
Comparison
of
EPA
and
TRP
Proposals
for
Elucidation
of
Degradation
Pathways
and
Identification
of
Degradation
Products
Test
Substances:

EPA:
Telomer
products
will
be
specified,
individual
representative
test
substances.
Examples
include
telomer
iodides,
telomer
alcohols,

telomer
esters
of
(
meth)
acrylates,
telomer
sulfonates,
telomer
phosphates
TRP:

From
among
the
12
representative
substances
proposed
by
TRP,
two
telomer
based
products
and
two
telomer
based
polymers
isolated
from
them.

EPA
Proposed
Test
TRP
Proposed
Test
EPA
Proposed
Analytical
TRP
Proposed
Analytical
Semicontinuous
Activated
Sludge
(
SCAS)
Test
OECD
302A
Inherent
Biodegradation
Zahn­

Wellens
OECD
302
B
?
Semicontinuous
Activated
Sludge
(
SCAS)
Test
OECD
302A
?
Identification
of
major
degradation
products
including
PFOA
Trap
and
analyze
volatiles
Mass
balance
Sludge:
PFOA
Aqueous:
Fluoride
[
F­]

No
volatiles
analysis
Simulation
Test­
Aerobic
Sewage
Treatment
(
Activated
Sludge
Units)

OECD
303A
Simulation
Test­
Aerobic
Sewage
Treatment
(
Activated
Sludge
Units)

OECD
303A
ID
major
degradation
products
including
PFOA
Trap
and
analyze
volatiles
Mass
balance
Sludge:
TOF,
PFOA
Aqueous:
TOF,
PFOA,
[
F­]

No
volatiles
analysis
U.
S.
Environmental
Protection
Agency
Draft,
September
4,
2003
Aerobic
and
Anaerobic
Transformations
in
Soil
OECD
307
Aerobic
and
Anaerobic
Transformations
in
Soil
OECD
307
Inherent
Biodegradability
in
Soil
OECD
304A
ID
major
degradation
products
including
PFOA
Trap
volatiles
Determine
rates
and
half­
lives
Duration
up
to
1
year
Mass
balance
PFOA
Duration
120
days
Aerobic
and
Anaerobic
Transformations
in
Aquatic
Sediment
Systems
OECD
308
*
Aerobic
and
Anaerobic
Transformations
in
Aquatic
Sediments
OECD
308
ID
major
degradation
products
including
PFOA
Trap
volatiles
Determine
rates
and
half­
lives
Duration
up
to
1
year
Mass
balance
To
be
determined
Anaerobic
Biodegradability
of
Organic
Compounds
in
Digested
Sludge:
Measurement
of
Gas
Production,
OECD
311
*
Anaerobic
Biodegradation
of
Organic
Compounds
in
Sludge
ID
major
degradation
products
including
PFOA
Trap
volatiles
Determine
rates
and
half­
lives
Duration
to
be
determined
Mass
balance
To
be
determined
(
Covered
under
OECD
308)
*
Modified
River
Die
Away
NA
To
be
determined
U.
S.
Environmental
Protection
Agency
Draft,
September
4,
2003
UV/
Visible
Absorption
OPPTS
830.7050
*
UV/
Visible
Absorption
NA
NA
Direct
Photolysis
in
Water
OPPTS
835.2210
*
Direct
Photolysis
in
Water
To
be
determined
To
be
determined
Indirect
Photolysis
Screening
Test
OPPTS
835.5270
*
Indirect
Photolysis
in
Water
To
be
determined
To
be
determined
None
*
Indirect
Photolysis
in
Air
NA
To
be
determined
None
*
Direct
Photolysis
in
Air
NA
To
be
determined
None
*
Indirect
Photolysis
in
Soil
NA
To
be
determined
*
Part
of
TRP
E­
Fate
testing
decision
tree
but
not
part
of
proposed
study
plan.
