Mary
Dominiak
09/
12/
2003
12:
12
PM
To:
mary
dominiak
cc:
cc:
Subject:
PFOA
ECA
Expert
Subgroup
Meeting
Summaries,
8/
14­
15/
03,
8/
19­
21/
03
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
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you
be
removed
from
this
notification
list.

****************************************************************************************
TO:
PFOA
ECA
Technical
Workgroup
and
Plenary
Meeting
Attendees
Attached
are
summaries
of
the
PFOA
ECA
Technical
Expert
Subgroup
meetings
held
on
August
14,
15,
19,
20,
and
21,
2003.

Copies
of
these
summaries
have
been
submitted
to
the
docket.
If
you
have
any
comments
on
the
accuracy
of
the
summaries,
please
direct
them
to
me.
If
corrections
to
a
meeting
summary
are
necessary,
we
will
place
the
comments
together
with
a
corrected
version
of
the
summary
in
the
docket.
The
materials
that
were
used
and
distributed
at
these
meetings,
including
agendas,
attendance
lists,
and
presentation
documents,
appear
in
the
docket
at
OPPT­
2003­
0012­
0181.

The
summary
for
the
PFOA
ECA
Telomer
Degradation
Technical
Expert
Subgroup
meeting
notes
that
a
clarification
conference
call
was
scheduled
for
September
3,
2003.
This
teleconference
meeting
was
subsequently
rescheduled
for
September
9,
2003,
and
notification
of
the
call,
together
with
meeting
materials,
were
provided
in
an
email
transmission
from
me
dated
September
4,
2003.
These
materials
also
appear
in
the
docket
at
OPPT­
2003­
0012­
0192.
Additional
materials
transmitted
by
the
Telomer
Research
Project
(
TRP)
on
the
morning
of
the
meeting
were
forwarded
to
members
of
this
notification
list.
These
materials
appear
in
the
docket
at
OPPT­
2003­
0012­
0193.
The
agenda,
attendance
form,
and
revised
presentation
materials
used
during
the
meeting
appear
in
the
docket
at
OPPT­
2003­
0012­
0194.
A
summary
of
the
teleconference
meeting
will
be
available
at
the
PFOA
ECA
Telomer
Technical
Workgroup
meeting
scheduled
for
September
16,
2003,
and
will
subsequently
appear
in
the
docket.

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
8­
21­
03
Summary,
Fluoropolymer
Monitoring
Subgr
8­
14­
03
Summary,
Telomer
Incineration
Subgro
8­
15­
03
Summary,
Telomer
Monitoring
Subgro
8­
19­
03
Summary,
Fluoropolymer
Incineration
Subgr
8­
20­
03
Summary,
Fluoropolymer
Aged
Articles
Subg
8­
14­
03
Summary,
Telomer
Degradation
Subgro
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
PFOA
ECA
Telomer
Incineration
Technical
Subgroup
Meeting
Summary,
8/
14/
03
40
participants;
Attendance
list
and
presentation
materials
in
docket
at
OPPT­
2003­
0012­
0181.

The
meeting
included
three
sections:
I.
Telomer
Research
Project
(
TRP)
presentation
of
Incineration
Testing
Proposal
II.
Discussion
III.
Identification
of
subgroup
next
steps
I.
TRP
presentation
TRP
presented
a
proposal
to
the
technical
subgroup
on
incineration
test
methods
for
telomers.
The
presentation
included
information
on
TRP's
approach
to
investigate
the
incineration
of
telomer­
based
substances
to
quantitatively
determine
emission
levels
of
PFOA.
The
proposal
included
the
identification
of
representative
materials
for
testing;
description
of
experimental
apparatus;
review
of
relevant
incineration
test
conditions;
sampling
and
analysis
considerations;
study
materials
characterization;
and
discussion
of
next
steps.
The
presentation
can
be
found
in
the
docket
at
OPPT­
2003­
0012­
0181.

TRP
defined
the
objectives
of
the
desk
study
as
the
understanding
of
U.
S.
waste
disposal
methods
for
waste
carpet,
textile
and
paper
and
applicable
incineration
uses;
and
the
review
of
U.
S.
incinerator
conditions
to
understand
typical
operating
temperatures.
The
TRP
group
concluded
that
carpet
is
largely
landfilled
or
recycled,
and
that
less
than
1%
of
total
carpet
waste
is
incinerated.
Based
on
these
conclusions,
TRP
considered
carpet
eliminated
as
a
possible
testing
component.
TRP
proposed
conducting
investigations
on
textile
products,
including
medical
textiles,
and
paper.

TRP
summarized
the
operating
conditions
of
Municipal
Waste
Combustors
(
MWC)
secondary
chambers
at
a
temperature
range
of
982NC
to
1093NC.
TRP
further
stated
that
operation
at
temperatures
above
982NC
is
to
ensure
complete
combustion
of
organic
compounds
prior
to
passing
through
the
boiler.
TRP
proposed
conducting
thermogravimetric
analysis
to
determine
the
temperature
required
for
complete
gasification.

TRP
identified
the
testing
materials
as
paper
and
textile
products
including
medical
textiles.
Representative
samples
from
each
of
the
two
product
types
will
be
prepared
using
a
composite
mixture
of
the
LOI
telomer­
based
polymeric
products,
in
a
concentrated
solid
form,
and
in
equal
proportions
by
product
and
class.

TRP
described
the
laboratory
apparatus
to
be
utilized
for
the
experiment
as
being
similar
to
the
equipment
used
by
the
University
of
Dayton
in
conducting
the
3M
studies.
Proposed
experimental
conditions
will
be
at
temperature
levels
of
900NC
and
1000NC
with
a
2
second
residence
time.
Three
replicates
will
be
used
for
each
testing
temperature
and
a
blank
will
be
run
under
each
experimental
condition.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
2
TRP
indicated
that
sampling
and
analysis
would
include
monitoring
exhaust
gas
parameters
for
flow
rate,
oxygen,
carbon
dioxide,
and
carbon
monoxide.
The
exhaust
samples
will
be
collected
on
suitable
sorbent
cartridge(
s)
and/
or
in
aqueous
solution
trap(
s)
for
off­
line
LC/
MS/
MS
analysis
at
a
qualified
commercial
laboratory.
TRP
stated
that
PFOA
determination
will
require
adaptation
and
validation
of
available
methods.

TRP
stated
that
the
study
materials
characterization
was
to
include
elemental
analysis
for
determination
of
carbon,
hydrogen,
nitrogen,
chlorine,
fluorine
and
oxygen
by
difference,
as
well
as
the
PFOA
content.

Lastly
the
TRP
group
suggested
discussion
of
the
next
steps
of
the
process.

II.
Discussion
Members
of
the
groups
discussed
the
proposed
use
of
composite
samples
for
analysis.
TRP
stated
that
the
use
of
composite
"
neat
chemicals"
is
a
conservative
approach
that
would
yield
higher
concentrations
than
those
seen
through
the
use
of
the
coated
products.
TRP
explained
that
compositing
was
the
most
timely,
cost
efficient
manner
to
answer
the
question
of
PFOA
formation.
Participants
also
questioned
what
the
possible
next
steps
would
be
in
the
event
that
PFOA
was
detected
in
the
composite
samples.
Concerns
are
that
the
contribution
by
the
individual
components
would
be
unknown
based
on
the
current
testing
scheme.
TRP
suggested
focusing
on
the
proposed
testing
and
would
consider
going
back
and
looking
at
the
individual
components
at
a
later
date.

The
group
suggested
the
inclusion
of
a
"
spiked"
sample
with
PFOA
to
validate
the
detection
and
analysis
methods.
TRP
stated
their
intent
to
conduct
a
fluorine
mass
balance
analysis
would
eliminate
the
need
for
such
a
spike.

The
subcommittee
members
discussed
the
proposed
incineration
conditions
for
testing.
Typical
MWC
operating
temperatures
were
established
to
be
between
982NC
and
1093NC;
however,
participants
cited
that
some
incinerators
that
meet
medical
standards
operate
primary
zones
at
only
650NC.
Discussions
involved
what
the
appropriate
temperatures
for
analysis
should
be
and
what
merit
might
be
found
in
testing
at
a
lower
temperature
(
700NC).
TRP
expressed
the
belief
that
the
proposed
900NC
and
1000NC
would
adequately
simulate
current
MWC
conditions
of
complete
gasification
of
the
sample
in
chamber
1
and
complete
transport
to
chamber
2.
Other
interested
parties
suggested
the
lower
temperatures
would
better
inform
possible
PFOA
sources
from
those
incinerators
operating
under
medical
standards
of
650NC.
Parties
noted
that
the
goal
of
the
TRP
experiments
is
determining
99.99%
destruction,
while
the
goal
of
medical
incinerators
is
the
removal
of
pathogens
and
visible
wastes.
The
group
decided
to
continue
this
discussion
once
EPA
has
time
to
review
literature
on
MWCs
more
closely.
TRP
will
begin
development
of
a
protocol
while
leaving
the
temperatures
blank
for
the
interim.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
3
Interested
parties
expressed
concerns
regarding
the
replication
of
combustion
conditions
with
regards
to
mixing
conditions
in
municipal
incinerators.
TRP
stated
that
the
issue
would
be
directly
addressed
by
the
"
worst
case"
scenarios,
and
that
the
mixing
of
trash
would
lead
to
nondetection
in
the
off­
gas.

Group
members
discussed
the
ability
to
evaluate
the
results
and
to
put
them
into
perspective.
The
suggestion
was
made
to
generate
an
exposure
assessment
that
would
serve
to
quantify
and
put
the
findings
into
context.
TRP
agreed
to
perform
an
exposure
assessment
as
part
of
the
ECA
work.

The
participants
agreed
that
the
proposed
work
was
acceptable
and
that,
with
more
detailed
documentation
of
specific
testing
and
analytical
methods,
a
draft
proposal
suitable
for
incorporation
into
an
ECA
would
be
possible.
The
TRP
group
agreed
to
provide
a
draft
testing
protocol
for
discussion
at
the
next
Telomers
Technical
Workgroup
meeting
on
September
16,
2003.
EPA
agreed
to
begin
parallel
work
on
the
language
for
an
ECA
proposal
document
that
will
be
paired
with
the
TRP
testing
proposal.

III.
Identification
of
subcommittee
next
steps
°
EPA
concluded
that
the
LOI
chemicals
are
satisfactory;
however,
EPA
may
identify
additional
possible
products
or
markets
by
the
September
16,
2003
meeting.
°
EPA
will
begin
work
on
a
draft
proposal
suitable
for
incorporation
into
an
ECA.
°
EPA
will
review
the
TRP
testing
proposal
and
bring
back
comments
at
the
Telomer
Technical
Workgroup
meeting
on
September
16,
2003.
°
TRP
will
conduct
a
Thermogravimetric
Analysis
for
determination
of
gasification
temperature.
°
TRP
will
provide
a
Draft
Testing
Protocol
by
Friday,
September
12,
2003,
for
review
prior
to
the
Telomer
Technical
Workgroup
meeting
on
September
16,
2003.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
PFOA
ECA
Telomer
Degradation
Technical
Subgroup
Meeting
Summary,
8/
14/
03
37
participants;
Attendance
list
and
presentation
materials
in
docket
at
OPPT­
2003­
0012­
0181.

The
meeting
included
three
sections:
I.
Telomer
Research
Project
(
TRP)
presentation
of
Biodegradation
Testing
Proposal
II.
Discussion
III.
Identification
of
subgroup
next
steps
I.
TRP
presentation
TRP
presented
a
proposal
to
the
technical
subgroup
on
degradation
for
telomers.
The
presentation
included
information
on
TRP's
approach
to
determining
whether
telomer­
based
polymeric
polymers
biodegrade
to
PFOA.
The
proposal
included
a
statement
of
objectives
and
approach;
technical
review
and
discussion
of
environmental
fate
testing
logic
and
experimental
design;
summary
and
conclusions;
and
discussion
of
next
steps.
The
presentation
can
be
found
in
the
docket
at
OPPT­
2003­
0012­
0181.

TRP
detailed
the
approach
to
be
conducting
studies
designed
to
address
partitioning
and
biotransformation
in
relevant
environmental
compartments.
The
initial
step
is
conducting
laboratory
studies
that
are
simple,
focus
on
relevant
releases,
and
inform
the
question
of
whether
telomer­
based
polymeric
products
and
polymers
have
the
potential
to
transform
to
PFOA.
Results
of
the
studies
will
be
used
to
determine
the
need
for
longer­
term
studies.

TRP
defined
the
factors
for
determining
the
relevant
environmental
compartments
as
use/
applications,
physical­
chemical
properties,
and
emissions/
point
of
entry.
TRP
detailed
that
the
areas
of
carpet,
textiles,
and
paper
were
to
be
considered
for
emissions/
point
of
entry
into
the
environment
through
Sewage
Treatment
Plants
(
STPs),
soil
(
land­
applied
sludge
and
landfill),
air,
and
water
(
STP
discharge
and
other
discharges
to
water).

TRP
utilized
a
decision
tree
approach
to
detail
the
rationale
for
specific
environmental
fate
testing
dependent
on
the
point
of
entry
and
pathways
of
transport
into
the
environment.
The
tree
detailed
possible
pathways
for
environmental
entry
points
of
STPs,
soil,
air,
and
water.

TRP
narrowed
the
analysis
of
environmental
pathways
to
include
STP
analysis
for
"
down
the
drain"
disposal,
sludge,
and
wastewater;
and
soil
analysis
to
include
land­
applied
sludge
from
STPs
and
landfill
disposal
of
treated
articles.
TRP
stated
that
water
would
not
be
considered
due
to
no
direct
discharge
to
water;
incinceration
would
be
addressed
in
a
separate
ECA
workstream;
and
air
would
be
addressed
by
the
TRP
mill
release
and
pilot
study
work.

TRP
presented
their
proposed
study
plans
to
include
Inherent
Biodegradation
in
Sludge
(
Zahn­
Wellens,
OECD
302B)
as
an
amendment
to
the
LOI
commitment,
Aerobic
Sewage
Treatment
Study
(
OECD
303A),
and
Soil
Aerobic/
Anaerobic
Biodegradation
Study
(
OECD
304
and
307)
for
2
telomer­
based
products
and
2
telomer­
based
polymers.
The
purpose
is
to
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
2
characterize
the
products
and
isolated
polymers
before
conducting
testing
of
the
10
remaining
telomer­
based
polymer
products.
TRP
detailed
the
technical
hurdles
associated
with
each
of
the
proposed
testing
procedures.

TRP
concluded
that
the
study
approach
is
a
step­
wise
progression
based
on
relevant
routes
into
the
environment
and
building
upon
knowledge
gained;
considers
feasible
and
workable
biotransformation
and
partitioning
studies
that
address
the
central
question
posed
by
EPA;
is
based
on
modification
of
available
biodegradation
test
methods;
utilizes
available
analytical
method;
takes
into
consideration
the
ability
to
conduct
work
in
a
timely
manner;
and
is
consistent
with
and
additive
to
the
TRP
Letter
of
Intent
(
LOI).

Lastly
the
TRP
group
suggested
discussion
of
the
next
steps
of
the
process.

II.
Discussion
Members
of
the
group
discussed
the
possibility
of
substituting
the
Semi­
Continuous
Activated
Sludge
test
(
SCAS)
for
the
proposed
Zahn­
Wellens
Inherent
Biodegradability
test.
Discussions
detailed
the
belief
that
the
SCAS
test
is
a
much
more
powerful
test
that
would
better
address
biodegradation.
It
was
noted
that
problems
are
often
associated
with
the
SCAS
with
regards
to
the
testing
method.
The
group
suggested
that
TRP
review
the
recommendation
for
the
SCAS
test
and
provide
comments
at
the
next
meeting.

Subgroup
participants
raised
a
concern
about
possible
human
metabolism
of
PFOA
from
inhalation
of
particles.
The
question
was
raised
regarding
whether
these
types
of
exposures
were
significant.
TRP
suggested
that
the
pharmocokinetics
study
of
the
telomer
8­
2
alcohol
and
the
articles
analysis
should
help
identify
any
transformations
that
could
occur.

Members
of
the
group
asked
about
consideration
of
the
Anaerobic
Sludge
Digestion
Study.
The
response
was
that
the
test
has
been
considered;
however,
the
belief
is
that
the
Inherent
Biodegradability
test
would
serve
as
a
worst
case
indicator
of
PFOA
generation.

Participants
questioned
whether
the
telomer
8­
2
alcohol
and
other
degradation
products
were
being
considered
for
analysis.
The
group
suggested
inclusion
of
the
telomer
8­
2
alcohol
and
identification
of
degradation
products
in
the
studies.
The
group
felt
identification
of
products
other
than
PFOA
was
important
information
to
have.
Suggestions
were
made
to
use
traps
to
obtain
the
volatiles
and
use
GC/
MS
analysis
for
screening
of
potential
degradants.
The
group
suggested
that
TRP
consider
the
suggestions
and
provide
comments
at
the
next
meeting.

The
group
discussed
the
adequacy
of
the
duration
time
for
the
Inherent
Biodegradation
test.
A
test
duration
of
28
days
is
the
standard
for
this
test;
however,
participants
asked
if
that
time
could
be
extended
to
60
days.
The
comment
was
that
extension
to
60
days
would
not
be
relevant
to
the
STP
setting,
as
a
standard
detention
time
in
STPs
is
6
to
10
days.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
3
The
group
raised
the
question
of
the
determination
of
rate
constants
for
these
studies.
The
group
felt
that
the
current
proposal
would
yield
no
rate
constants
for
future
use.
The
group
suggested
that
TRP
consider
the
suggestions
and
provide
comments
at
the
next
meeting.

III.
Identification
of
subgroup
next
steps
°
TRP
will
consider
EPA's
request
to
conduct
the
SCAS
test
in
place
of
the
Zahn­
Wellens
test,
determine
whether
more
work
can
be
done
in
the
areas
of
rate
constants,
consider
inclusion
of
the
Telomer
8­
2
alcohol
and
possible
identification
of
degradation
products.
°
A
copy
of
the
Clariant
hydrolysis
study
will
be
made
available
for
review
by
EPA.
°
TRP
will
provide
the
testing
information
on
the
radiolabeled
biodegradation
study
by
the
end
of
August.
°
EPA
will
review
the
soil
study
and
other
proposals
and
determine
if
any
are
ready
for
drafting
a
proposal
suitable
for
incorporation
into
an
ECA.
°
EPA
will
review
the
proposal
and
submit
any
comments
to
TRP
within
2
weeks.
A
conference
call
is
scheduled
for
Sept
3,
2003
for
clarification
of
any
questions
based
on
the
comments.
°
The
technical
subgroup
will
try
to
set
aside
time
during
the
Telomer
Technical
Workgroup
meeting
on
September
16,
2003
for
discussion
of
issues.
°
EPA
to
review
proposed
chemicals
and
make
a
determination
if
chemicals
other
than
those
stated
in
the
LOI
are
necessary
for
evaluation.
EPA
is
still
awaiting
some
product
information
in
order
to
finish
the
review.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
PFOA
ECA
Telomer
Monitoring
Technical
Subgroup
Meeting
Summary,
8/
15/
03
45
participants;
Attendance
list
and
presentation
materials
in
docket
at
OPPT­
2003­
0012­
0181.

The
meeting
included
three
sections:
I.
Telomer
Research
Project
(
TRP)
presentation
of
Monitoring
Proposal
II.
Discussion
III.
Identification
of
subgroup
next
steps
I.
TRP
presentation
TRP
presented
a
proposal
to
the
technical
subgroup
on
environmental
monitoring
for
telomers.
The
presentation
included
information
on
TRP's
approach
to
understanding
and
characterizing
current
PFOA
releases
from
carpet,
textile,
and
paper
industrial
manufacture,
uniquely
attributable
to
telomer­
based
polymeric
products,
in
order
to
provide
information
on
potential
PFOA
environmental
and
occupational
exposures.
The
presentation
included
a
review
of
the
telomer
product
application
process,
mass
balance
overview,
mill
release
model
information,
and
mill
monitoring
pilot
study
information.
The
presentation
can
be
found
in
the
docket
at
OPPT­
2003­
0012­
0181.

TRP
provided
a
brief
review
of
the
telomer
product
application
process
to
demonstrate
the
usefulness
of
the
proposed
mass
balance
analysis.
Product
manufacture
includes
the
wet
application
of
telomer­
based
polymer,
the
drying
of
the
article,
and
trimming
of
wastes
from
the
treated
article.
The
mass
balance
will
focus
on
accounting
for
the
amount
of
material
on
the
treated
article,
the
amount
left
in
the
application
bath
for
wastewater
treatment
disposal,
the
amount
driven
off
during
the
drying
process,
and
the
amount
to
landfill
from
article
trimming.

TRP
detailed
the
use
of
mill
release
modeling
to
predict
the
total
US
environmental
releases
and
concentrations.
Processing
variables
including
average
daily
product
usage
and
number
of
total
user
locations,
combined
with
the
mass
balance
information,
will
serve
to
allow
determination
of
PFOA
releases
to
air,
water,
and
solid
wastes
at
each
user
site.
TRP
stated
this
information
is
critical
to
defining
the
fitness
of
purpose
for
PFOA
sampling
and
analysis
methods.

TRP
defined
the
mill
monitoring
pilot
study
as
a
controlled,
realistic
study
to
verify
the
release
model
with
measured
data
including
a
pilot
production
line
which
is
free
of
other
contaminations.
The
analysis
would
begin
with
a
Total
Organic
Fluorine
(
TOF)
analysis
to
verify
the
overall
mass
balance.
Chemical­
specific
determination
of
PFOA
and
telomer
8­
2
alcohol
would
require
development
and
validation
of
sampling
and
analysis
methods.

TRP
explained
that
the
mill
monitoring
pilot
study
represents
real
commercial
processing
by
utilization
of
industry­
standard,
scaled­
down
versions
of
actual
mill
equipment
that
is
used
industry­
wide
for
research
and
development.
Sampling
would
include
the
application
bath,
exhaust
air,
treated
article
and
work
area
air.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
2
In
response
to
issues
surrounding
CBI
identification
of
telomers
for
testing,
TRP
proposed
preparation
of
a
representative
acrylic
polymer
of
known
composition
and
residual
raw
material
profile,
to
be
used
on
treated
polyester
textile
fabric
as
the
beginning
experiment.
Analysis
of
TOF
would
be
performed
to
see
if
meaningful
measurements
in
air,
water,
and
treated
substrates
could
be
demonstrated
to
achieve
the
mass
balance.
TRP
would
use
this
analysis
as
the
basis
for
validation
of
the
mill
monitoring
pilot
work
and
would
begin
analysis
of
proposed
articles
in
the
areas
of
carpet,
textiles
and
paper.

TRP
summarized
by
stating
that
the
studies
would
address
environmental
and
occupational
exposures
to
PFOA
from
telomer­
based
polymeric
products
used
in
carpet,
textile
and
paper
processes
including
air,
water,
solid
and
land.

Lastly
the
TRP
group
suggested
discussion
of
the
next
steps
of
the
process.

II.
Discussion
The
facilitator
of
the
subgroup
suggested
that
the
group
consider
what
the
purpose
of
the
subgroup
is
and
form
questions
that
monitoring
should
answer.
The
discussions
produced
questions
to
be
considered
by
the
Telomer
Monitoring
Subgroup
and
questions
that
can
be
taken
back
to
the
larger
Monitoring
Technical
Workgroup
for
discussion.

Members
of
the
subgroup
compiled
questions
they
determined
should
be
addressed
within
the
Monitoring
Technical
Subgroup:
°
How
telomers
get
into
the
environment
°
Will/
do
telomers
break
down
to
PFOA
(
will
monitoring
help
us?)
°
Do
telomers/
PFOA
enter
into
biota?
°
Precursors
­
difficult
to
monitor
for.
Persistent
­
how/
will
they
be
transported?
How
do
they
behave?
°
Release
and
exposure
data
of
PFOA
in
air,
surface
water,
groundwater,
sediment
&
soil
°
Look
at
processing
sites
of
telomers
°
Look
at
manufacturing
sites
of
telomers
°
Separate
chemical
vs
engineering
uses
(
use
analytical
chemistry
at
sites
to
distinguish
branch
chain
vs
straight
chains)
°
Can
we
attribute
analyte
to
a
specific
source?
°
Do
we
need
to
involve
other
industries
to
identify
sources
of
PFOA
in
the
environment?
(
e.
g.,
carpet
mills)
°
Can
we
go
through
processes
of
products
to
eliminate
or
identify
source
of
PFOA?
(
e.
g.,
telomer
alcohol)
°
Talk
to
other
interested
parties
to
see
what
their
contributions
are?
°
What
happens
to
product
once
disposed
of?
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
3
°
Biodegradation
of
telomers
­
does
it
happen
on
site?
Need
to
validate
model
(
e.
g.,
does
it
change
with
distance
from
plant?)
°
Sources/
Pathways
­
How
will
monitoring
data
be
used?
(
e.
g.,
for
experiment
at
a
specific
plant
or
use
in
broader
range­
finding
study?)
°
Generate
emission
factors/
rates
to
get
estimate
of
environmental
loading.
°
Is
the
focus
on
future
sources
or
on
past
environmental
exposures?
How
do
we
aggregate
or
disaggregate
this
information?
°
Make
sure
to
quantify.
What
exposures
of
PFOA
are
from
telomers?
°
Question
of
disposal
sites,
exposures
from
FPOA
from
past
uses
(
risk
assessment
issue)
°
Is
there
a
way
to
monitor
whether
PFOA
is
in
biota
other
than
human
blood
monitoring?
°
Monitoring
vs.
Modeling.
When
is
monitoring
necessary
vs.
use
of
models?

Members
compiled
questions
they
determined
should
be
taken
back
to
the
Monitoring
Technical
Workgroup
for
discussion:
°
Is
water
being
contaminated
on­
site
and
off­
site?
°
Does
it
move
to
the
soil
on­
site
and
off­
site?
°
How
much
moves
to
air?
°
How
much
does
volume
compare
(
e.
g.,
straight
PFOA
telomers
vs
other
industries)

Members
of
the
group
agreed
that
monitoring
needs
to
be
done,
but
could
not
agree
on
who
should
be
doing
it.
The
suggestion
was
made
to
recommend
to
the
Monitoring
Workgroup
that
users
be
invited
to
participate
in
the
conversations.
The
recommendation
would
then
be
brought
to
the
Plenary.
The
group
decided
to
continue
discussions
at
the
next
scheduled
subgroup
meeting.

III.
Identification
of
subgroup
next
steps
°
Take
questions
to
the
Monitoring
Technical
Workgroup
on
September
16,
2003.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
PFOA
ECA
Fluoropolymer
Incineration
Technical
Subgroup
Meeting
Summary,
8/
19/
03
30
participants;
Attendance
list
and
presentation
materials
in
docket
at
OPPT­
2003­
0012­
0181.

The
meeting
included
three
sections:
I.
Fluoropolymer
Manufacturing
Group
(
FMG)
presentation
of
Incineration
Testing
Proposal
II.
Discussion
III.
Identification
of
subgroup
next
steps
I.
FMG
presentation
FMG
presented
a
proposal
to
the
technical
subgroup
on
incineration
test
methods
for
fluoropolymers.
The
presentation
included
information
on
FMG's
approach
to
addressing
the
question
of
whether
fluoropolymer
incineration
is
a
potential
source
of
PFOA
in
the
environment.
The
proposal
included
the
identification
of
representative
materials
for
testing;
review
of
relevant
incineration
conditions;
presentation
of
key
elements
of
the
proposed
testing
program;
and
discussion
of
next
steps.
The
presentation
can
be
found
in
the
docket
at
OPPT­
2003­
0012­
0181.

FMG's
discussion
of
representative
materials
identified
the
4
main
classes
of
products
as
dry
melt
resins
(
FEP,
PFA,
THV,
ETFE,
and
HTE);
dry
non­
melt
resins/
gums
(
PFTE);
dry
nonmelt
resins/
gums
(
fluoroelastomers);
and
aqueous
dispersions
(
PTFE,
FEP,
PFA,
and
THV).
FMG
stated
that
the
4
classes
of
products
covered
the
range
of
the
12
fluoropolymer
families.
Each
class
of
materials
would
be
a
composite
mixture
as
solids,
in
equal
proportions
according
to
the
number
of
companies
that
produce
the
various
products.

FMG
provided
a
detailed
literature
review
of
relevant
Municipal
Waste
Combustor
(
MWC)
operating
conditions.
The
presentation
summarized
the
standard
operating
conditions
of
MWCs
as
typically
operating
secondary
chambers
at
greater
than
1000NC
with
a
residence
time
of
2
seconds.
FMG
stated
that
over
90%
of
municipal
solid
wastes
are
combusted
at
982NC
for
2
seconds.
The
proposed
operating
conditions
for
incineration
evaluations
were
conservatively
identified
as
900NC
with
a
2­
second
residence
time.

FMG
detailed
the
key
elements
of
the
proposed
testing
program
including
the
overall
test
program
objective,
phases
of
testing,
testing
materials,
experimental
apparatus,
experimental
conditions,
and
sampling
and
analysis.

Lastly
the
FMG
group
suggested
discussion
of
the
next
steps
of
the
process.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
2
II.
Discussion
Members
of
the
technical
subgroup
discussed
the
proposed
4
classes
of
products
and
how
they
related
to
the
end
uses.
The
products
are
to
be
representative
of
the
world
of
fluoropolymer
products
and
are
composites
of
the
individual
products
streams.

The
topic
of
a
tiered
or
phased
approach
was
discussed
in
the
event
that
PFOA
should
appear
in
the
preliminary
testing
results.
Participants
discussed
the
application
of
the
proposed
screening
approach
and
questioned
what
the
next
step
would
be
should
PFOA
be
identified.
The
conclusion
was
that
the
initial
screening
testing
would
be
conducted
and
subsequent
results
be
presented
to
the
group
for
evaluation.
Results
would
be
presented
in
the
form
of
an
exposure
assessment.
Possible
next
steps
would
be
the
identification
of
individual
contributions
of
products
in
the
composite
and
their
likelihood
for
incineration.

Temperature
of
operation
for
the
testing
was
another
topic
for
discussion.
FMG
proposed
900NC
operating
temperature
based
on
current
operating
conditions
of
MWCs.
Comparisons
were
made
to
the
conditions
used
for
the
3M
incineration
testing
protocol
used
for
PFOS
analysis.
It
was
clarified
that
the
conditions
of
the
3M
study
were
based
on
thermogravimetric
analysis
of
the
PFOS
material
until
99.99%
destruction
was
observed.
EPA
suggested
that
such
analyses
be
conducted
for
determination
of
this
level
of
destruction.
FMG
stated
that
information
on
required
decomposition
kinetics
of
PFOA
will
be
reported
as
a
DuPont
document.

The
issue
of
the
use
of
aqueous
dispersions
by
processing
sites
was
discussed.
There
was
concern
that
emissions
from
afterburners
and
ovens
were
not
being
addressed
in
the
incineration
testing
proposal.
FMG
stated
that
their
LOI
commitments
of
a
material
balance
around
aqueous
dispersion
customer
facilities,
decomposition
kinetics
information,
and
articles
of
commerce
testing
will
support
the
assumption
of
complete
destruction
of
PFOA
during
drying
of
aqueous
dispersions.

The
group
discussed
the
phases
of
the
testing
program
to
clarify
any
issues
regarding
the
progression
of
work.
Questions
were
posed
regarding
the
development
of
other
test
methods
and
the
format
for
data
reporting
and
development.
The
FMG
group
clarified
other
method
development
as
the
inclusion
of
Total
Organic
Fluorine
(
TOF)
in
their
analysis.
A
method
for
verification
would
be
necessary
for
this
item.
FMG
addressed
the
question
of
data
reporting
by
agreement
to
include
an
exposure
assessment
as
part
of
the
testing
report.
The
exposure
assessment
would
serve
to
quantify
the
presence
of
PFOA
in
the
environment
from
incineration.

FMG
stated
the
credentials
of
Dr.
Phil
Taylor
of
the
University
of
Dayton.
Dr.
Taylor
was
the
technical
lead
on
the
incineration
testing
conducted
on
behalf
of
3M,
which
serves
as
the
model
for
the
FMG
testing
proposal.
FMG
will
be
utilizing
Dr.
Taylor's
expertise
to
conduct
the
incineration
testing
proposed.
Members
of
the
group
expressed
concerns
regarding
containers
for
transport
of
samples
for
analysis.
FMG
stated
that
the
utilization
of
the
University
of
Dayton
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
3
personnel
would
provide
an
additional
level
of
confidence
to
the
experiment
due
to
their
extensive
experience
in
sample
collection
and
analysis.

The
participants
agreed
that
the
proposed
work
was
generally
acceptable
and
that,
with
more
detailed
documentation
of
specific
testing
and
analytical
methods,
a
draft
proposal
suitable
for
incorporation
into
an
ECA
would
be
possible.
The
FMG
group
agreed
to
provide
a
draft
testing
protocol
for
discussion
at
the
next
Fluoropolymers
Technical
Workgroup
meeting
on
September
17,
2003.
EPA
agreed
to
begin
parallel
work
on
the
draft
proposal
for
an
ECA
document
that
will
be
paired
with
the
FMG
testing
proposal.

III.
Identification
of
subgroup
next
steps
°
EPA
will
begin
work
on
a
draft
incineration
testing
proposal
for
incorporation
into
an
ECA.
°
FMG
will
provide
a
Draft
Testing
Protocol
by
Friday,
September
12,
2003
for
review
prior
to
the
Fluoropolymer
Technical
Workgroup
meeting
on
September
17,
2003.
°
Decomposition
Kinetics
of
PFOA
information
will
be
forthcoming.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
PFOA
ECA
Fluoropolymer
Aged
Articles
Technical
Subgroup
Meeting
Summary,
8/
20/
03
38
participants;
Attendance
list
and
presentation
materials
in
docket
at
OPPT­
2003­
0012­
0181.

The
meeting
included
three
sections:
I.
Fluoropolymer
Manufacturers
Group
(
FMG)
presentation
of
Aged
Articles
of
Commerce
Test
Proposal
II.
Discussion
III.
Identification
of
subgroup
next
steps
I.
FMG
presentation
FMG
presented
a
proposal
to
the
technical
subgroup
on
aged
articles
of
commerce
for
fluoropolymers.
The
presentation
included
information
on
FMG's
approach
to
determining
whether
PFOA
is
emitted
from
fluoropolymer­
containing
articles
as
they
age
during
use.
The
proposal
included
statement
of
goals
and
objectives,
reiteration
of
aged
article
selection
criteria,
identification
of
selected
aged
articles,
testing
methodologies
to
be
employed,
and
discussion
of
next
steps.
The
presentation
can
be
found
in
the
docket
at
OPPT­
2003­
0012­
0181.

FMG
reiterated
their
selection
criteria
for
aged
articles
from
the
3
main
fluoropolymer
classes
of
melt/
extrusion,
polymer
drying,
and
liquid
dispersion
products/
articles.
Articles
were
considered
based
upon
consumer
and
industrial
applications,
high
and
low
heat
processing,
potential
volume,
and
potential
human
exposures.

FMG
provided
additional
selection
criteria
for
aqueous
dispersions,
non­
melt
resins/
gums,
and
melt/
extrusion
products
by
considering
repeated/
long­
term
use
and
human
exposure
during
use.
FMG
provided
sample
selection
trees
to
demonstrate
the
rationales
behind
the
articles
selected
for
testing.
Plenum
cables,
membranes
for
apparel,
and
household
cookware
were
selected
based
on
the
additional
considerations
of
repeated/
long­
term
use
and
human
exposure
during
use.

FMG
detailed
the
testing
methodologies
to
be
used
as
FDA
Simulated
Aging
Protocols.
Extraction
protocols
were
chosen
based
on
life
cycle
analysis
of
articles
as
well
as
time,
temperature
and
solvent.
The
proposed
validation
of
analytical
methods
would
be
by
LC/
MS/
MS
using
the
solvents
of
water,
ethanol,
corn
oil,
and
ethyl
acetate.

FMG
proposed
the
next
steps
of
the
process
to
be
the
verification
of
existing
validated
analytical
methods;
development
of
protocols
by
determining
appropriate
times
and
temperatures;
completion
and
review
of
the
Study
Plan
with
EPA
and
Interested
Parties;
and
beginning
the
Study
Plan
after
January
1,
2004.

Lastly
the
FMG
group
suggested
discussion
of
the
next
steps
of
the
process.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
2
II.
Discussion
Members
of
the
technical
subgroup
questioned
the
assumption
that
PFOA
is
destroyed
or
driven
off
during
melt/
extrusion
and
non­
melt
resins/
gums
processing,
and
during
aqueous
dispersion
drying.
FMG
stated
that
information
available
on
PFOA
demonstrated
rapid
degradation
at
temperatures
above
250NC
and
that
fluoropolymer
processing
takes
place
at
temperatures
exceeding
300NC.
FMG
noted
that
test
data
on
frying
pans
show
no
PFOA
detection
and
that
thermokinetic
information
is
forthcoming.
Based
on
the
questions
raised
regarding
degradation
of
PFOA,
FMG
committed
to
assembling
a
summary
of
all
degradation
product
data
for
future
discussion.

Workgroup
participants
discussed
the
selection
criteria
for
aged
articles
of
commerce
testing.
Questions
were
raised
regarding
why
the
plenum
cables,
membranes
for
apparel,
and
household
cookware
were
chosen
as
opposed
to
items
such
as
tubing
for
industrial
food
applications,
barrier
creams,
medical
tubing,
etc.
The
question
was
posed
as
to
if
any
quantitative
analysis
was
performed
when
selecting
the
articles
for
testing.
FMG
stated
that
samples
were
chosen
based
on
the
same
considerations
as
the
articles
of
commerce
with
the
addition
of
repeated/
long­
term
use
and
human
exposure
potential.
Professional
judgment,
combined
with
considerations
of
production
volume
and
application
quantity,
were
how
the
products
were
selected.
Selected
products
are
intended
to
represent
the
families
of
fluoropolymers
for
each
class.
It
was
noted
that
barrier
creams
were
no
longer
produced
by
any
of
the
signatories
of
the
FMG
Letter
of
Intent
(
LOI).

Discussions
regarding
solvent
selection
included
suggestions
of
use
of
such
solvents
as
saliva,
acid,
chloroform,
etc.
to
accurately
evaluate
substances
likely
to
come
in
contact
with
the
articles.
FMG
stated
that
the
fluoropolymers
by
design
are
resistant
to
thermal
and
water
insult
as
a
characteristic
of
their
intended
use,
and
that
solvent
selection
is
difficult.
It
is
known
that
PFOA
is
readily
soluble
in
water,
therefore,
that
is
one
of
the
solvents
suggested
for
evaluation.
Subgroup
members
suggested
saliva
as
a
possible
solvent
to
take
into
account
the
possibility
of
children
chewing
on
apparel
and
possibly
being
exposed.
Another
suggestion
was
the
use
of
chloroform
as
a
solvent
due
to
prior
success
with
swelling
and
extraction
of
fluoropolymers.
FMG
agreed
to
take
these
suggestions
into
consideration.

The
workgroup
participants
posed
the
question
of
having
accelerated
aging
evaluations
take
into
consideration
possible
generation
of
PFOA
through
abrasion
of
products.
Suggestions
were
made
to
evaluate
the
chewing
action
of
a
child
as
a
possible
test
to
simulate
the
chewing
of
apparel
by
children.
Another
suggestion
was
subjecting
the
articles
to
high
heat
and
solvents
to
test
the
possible
release
of
PFOA.
FMG
agreed
to
evaluate
the
possible
simulation
of
chewing
as
a
creative
use.

Several
members
of
the
workgroup
suggested
determination
of
the
PFOA
content
in
the
article
for
comparison
with
the
extraction
techniques
proposed.
FMG
stated
that
this
worst
case
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
3
estimate
would
be
covered
by
the
articles
of
commerce
testing
already
approved
as
part
of
the
LOI
process.
Results
of
these
evaluations
would
inform
the
group
to
the
possible
PFOA
content
in
the
articles.
The
suggestion
was
made
that
samples
be
taken
at
regular
intervals
during
the
aging
process
and
evaluated
to
answer
the
question
of
content
throughout
the
experiment.

Interested
parties
had
concerns
regarding
the
purity
of
PFOA
being
used
and
the
possible
formation
of
PFOA
or
precursors
during
the
aging
process.

Members
of
the
workgroup
discussed
the
Mabury
degradation
study
where
analysis
of
PTFE
demonstrated
the
formation
of
PFOA
and
other
analogs.
The
validity
of
the
testing
was
disputed
due
to
the
possible
contamination
of
samples
from
the
tubing
used
on
the
experimental
apparatus,
and
the
lack
of
validation
of
data
quality.

The
subject
of
a
possible
mass
balance
analysis
during
the
experimental
aging
was
discussed.
Participants
felt
that
periodic
analysis
during
aging
would
determine
the
where
and
how
of
vapor
and
substrate.
FMG
proposed
evaluating
samples
during
regular
intervals
throughout
the
proposed
10
day
aging
studies
which
would
definitively
determine
if
PFOA
is
generated
during
aging.

III.
Identification
of
subcommittee
next
steps
°
FMG
will
revisit
the
discussions
from
the
meeting
and
provide
a
presentation
in
advance
of
the
Fluoropolymer
Technical
Workgroup
meeting
on
September
17,
2003.
°
FMG
will
assemble
a
summary
all
degradation
products
data
for
future
discussion.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
PFOA
ECA
Fluoropolymer
Monitoring
Technical
Subgroup
Meeting
Summary,
8/
21/
03
46
participants;
Attendance
list
and
presentation
materials
in
docket
at
OPPT­
2003­
0012­
0181.

The
meeting
included
three
sections:
I.
Fluoropolymer
Manufacturers
Group
(
FMG)
presentation
of
Monitoring
Proposal
II.
Discussion
III.
Identification
of
subgroup
next
steps
I.
FMG
presentation
FMG
presented
a
proposal
to
the
technical
subgroup
on
environmental
monitoring
for
fluoropolymers.
The
presentation
included
information
on
FMG's
approach
to
understanding
the
role
of
environmental
sampling
and
monitoring
in
characterizing
the
manufacturing
contributions
to
PFOA
levels
in
the
environment.
The
presentation
included
the
statement
of
objective;
discussion
of
various
models
for
PFOA
detection
in
air,
soil,
groundwater,
and
water;
comparison
of
model
versus
field
measurements;
and
statement
of
conclusions.
The
presentation
can
be
found
in
the
docket
at
OPPT­
2003­
0012­
0181.

FMG
stated
the
overall
objective
of
the
ECA
process
as
the
enhancement
of
understanding
of
sources
of
PFOA
in
the
environment
and
the
pathways
by
which
human
exposure
to
PFOA
is
occurring.
Further,
the
FMG
group
detailed
the
goal
of
this
meeting
as
the
understanding
the
role
of
environmental
monitoring
in
characterizing
the
manufacturing
contribution
to
PFOA
levels
in
the
environment.
This
would
be
done
primarily
by
using
modeling
with
limited
sampling
to
provide
inputs
and
to
verify
model
results.

FMG
provided
a
detailed
discussion
of
various
models
for
PFOA
detection
including
the
ISCST3
model
for
ambient
air
and
deposition
modeling;
PRZM
model
for
unsaturated
soil;
MODFLOW
model
for
groundwater
transport;
and
PDM
model
for
river
evaluations.
FMG
detailed
the
appropriateness
of
the
models;
model
input
requirements;
and
model
outputs.

FMG
presented
comparison
data
between
selected
models
and
actual
field
measurements.
FMG's
conclusions
drawn
from
the
soil,
groundwater,
and
river
models
were
that
there
was
good
correlation
between
the
model
and
measurements;
and
that
the
models
were
useful
in
providing
conservative
estimates,
predicting
a
general
distribution,
and
are
good
for
longer
term
averages.
Conclusions
drawn
from
the
air/
water
model
comparison
were
that
there
is
a
trend
in
the
data
where
higher
depositions
correlate
with
higher
groundwater
measurements.
FMG
concluded
that
a
direct
correlation
is
not
possible,
but
air
modeling
results
can
define
where
sampling
should
occur
and
where
it
is
not
needed.
FMG
stated
that
the
open
issue
is
whether
the
air
dispersion
model
provides
conservative
estimates
of
ambient
air
concentrations.
Their
plan
to
resolve
this
issue
is
to
develop
and
validate
sampling
and
analysis
method,
design
a
verification
plan,
and
execute
a
plan.

FMG
concluded
that
these
environmental
models
are
useful
and
effective
for
characterizing
the
contribution
of
manufacturing
to
PFOA
levels
in
the
environment,
and
that
the
role
of
monitoring
is
to
provide
model
input
data
and,
where
appropriate,
verify
model
outputs.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
2
FMG's
recommendations
included
verifying
modeled
ambient
air
concentrations;
and
PFOA
contribution
determination
including
analysis
of
APFO
manufacturing,
fluoropolymer
manufacturing,
and
fluoropolymer
processing.

Lastly
the
FMG
group
suggested
discussion
of
the
next
steps
of
the
process.

II.
Discussion
Participants
discussed
the
impact
geology
variation
would
have
on
sampling
and
modeling
results.
Concerns
were
that
the
type
of
geology
sampled
could
have
a
significant
impact
on
the
results
found.
The
PRZM
model
was
noted
to
take
into
account
differences
in
geologies
by
consideration
of
different
soil
types.

Members
of
the
group
suggested
the
inclusion
of
fugitive
emissions
analysis
during
the
monitoring
process.
Concerns
were
that
the
rate
of
fugitive
emissions
should
be
verified.
It
was
stated
that
stack
emissions
evaluations
were
likely
to
dwarf
any
fugitive
emissions
that
might
occur,
but
that
they
could
not
be
discounted.

Subgroup
participants
discussed
the
proposed
dispersion
processors
material
balance
to
be
completed
as
part
of
the
FMG
Letter
of
Intent
(
LOI)
commitment.
The
stated
purpose
of
the
material
balance
was
to
use
effluent
sampling
combined
with
engineering
estimates
to
provide
an
industry
balance
of
potential
releases
rather
than
an
individual
facility
analysis.
Discussions
involved
the
use
of
the
material
balance
results
as
model
input.
FMG
committed
to
providing
a
report
on
this
material
balance
work
by
December
31,
2003.

There
were
concerns
raised
regarding
the
usefulness
of
the
air
model
in
predicting
groundwater
concentrations.
The
participants
questioned
whether
useful
groundwater
information
could
be
found
from
use
of
the
proposed
air
model.
The
proposed
process
would
use
output
from
the
air
model
as
input
for
the
soil
model,
whose
results
would
then
be
input
into
the
groundwater
model
to
predict
groundwater
values.
The
stated
purpose
of
the
modeling
was
not
as
a
predictor
of
groundwater
levels,
but
rather
as
a
pointer
of
where
to
take
samples
based
on
the
highest
air
model
concentrations.

The
group
discussed
the
possibility
of
including
soil
testing
in
the
monitoring
efforts
by
emphasizing
the
potential
for
human
exposure
to
soil,
and
noting
that
air
emissions
would
deposit
PFOA
onto
soil.
Submitted
adsorption/
desorption
results
were
referenced
as
justification
for
excluding
soil
evaluations.
FMG
indicated
that
the
study
results
showed
that
PFOA
moves
directly
through
soil
and
goes
straight
to
the
groundwater
and,
combined
with
the
known
high
water
solubility
of
PFOA,
served
to
favor
the
position
of
exclusion
of
soil
monitoring.
The
group
suggested
that
FMG
consider
inclusion
of
soil
sampling
in
their
monitoring
commitments.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
September
11,
2003
3
Subgroup
participants
discussed
the
issue
of
bioaccumulation
impact
of
PFOA
on
biota.
Discussions
involved
results
from
a
3M
study
indicating
bioaccumulation
in
fish.
The
group
suggested
that
3M
be
invited
to
present
their
environmental
biota
sampling
findings
at
the
Monitoring
Technical
Workgroup
meeting
on
September
18,
2003.

Another
topic
for
discussion
was
the
suggested
consideration
of
disposal
sites
as
part
of
the
proposed
monitoring.
Results
of
previous
landfill
sampling
as
part
of
the
Multi­
Media
Consent
Order
were
cited
as
having
groundwater
concentrations
of
concern.
The
group
agreed
to
review
the
results
of
the
landfill
sampling
and
be
prepared
to
discuss
the
topic
at
the
Monitoring
Technical
Workgroup
meeting
on
September
18,
2003.

Participants
brought
up
the
possibility
of
modeling
human
blood
levels,
indicating
that
a
draft
model
available
for
review
in
the
docket
(
OPPT­
2003­
0012­
0174)
utilized
air
and
water
values
to
predict
a
level
in
human
blood.
The
suggestion
was
made
to
review
the
model
information
and
discuss
its
potential
relevance
at
the
Monitoring
Technical
Workgroup
meeting
on
September
18,
2003.

There
were
questions
regarding
how
the
sampling
was
conducted
on
the
data
presented.
Concerns
were
whether
gradient
was
taken
into
consideration
when
sampling.
Participants
indicated
that
the
results
could
be
significantly
influenced
by
the
location
of
the
sampling.

Members
of
the
subgroup
voiced
concerns
regarding
model
variations.
Concerns
are
based
on
the
known
variability
in
the
input
being
used
for
the
model
which
could
significantly
impact
the
output
results.
Members
questioned
the
sensitivity
of
the
output
being
generated
and
suggested
providing
error
bars
on
the
output.

Members
of
the
group
discussed
the
data
gaps
that
the
LOI
commitment
did
not
seem
to
address,
including
volatility
and
PFOA
density.
These
topics
will
be
carried
over
to
the
Monitoring
Technical
Workgroup
Meeting
on
September
18,
2003.

III.
Identification
of
subgroup
next
steps
°
Progress
report
of
ongoing
air
modeling
from
Dyneon
due
to
EPA
by
September
15,
2003.
°
FMG
report
on
mass
balance
work
of
aqueous
dispersion
processors
industry
by
December
31,
2003.
°
FMG
report
on
air
modeling
in
1st
quarter
of
2004.
°
Subcommittee
members
to
review
the
Human
Blood
Model
and
landfill
sampling
for
discussion
at
the
Monitoring
Technical
Workgroup
meeting
on
September
18,
2003.
°
3M
to
provide
a
presentation
on
biota
at
the
September
18
meeting.
°
Group
requested
FMG
consider
soil
sampling
as
part
of
the
monitoring
work.
°
Take
questions
to
the
Monitoring
Technical
Workgroup
on
September
18,
2003.
