Mary
Dominiak
10/
14/
2003
03:
56
PM
To:
Mary
Dominiak/
DC/
USEPA/
US@
EPA
cc:
(
bcc:
Mary
Dominiak/
DC/
USEPA/
US)
Subject:
Summaries
of
PFOA
ECA
Technical
Workgroup
Meetings,
Sep.
16,
17,
and
22,
2003
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
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****************************************************************************************
TO:
PFOA
ECA
Technical
Workgroup
and
Plenary
Meeting
Attendees
The
summaries
of
the
PFOA
ECA
Telomer,
Fluoropolymer,
and
Monitoring
Technical
Workgroup
meetings
held
on
September
16,
17,
and
22,
2003,
respectively,
are
attached
for
your
information
and
review.

Copies
of
these
summaries
have
been
submitted
to
the
docket
with
this
email
message.
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
the
meetings,
including
agendas,
attendance
lists,
and
presentation
documents,
appear
in
the
docket
at
OPPT­
2003­
0012­
0197
through
0201.

Please
contact
me
if
you
have
any
difficulty
opening
the
attached
files,
or
if
you
have
any
questions
or
comments
concerning
the
PFOA
ECA
process.

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
Workgroup
09­
16­
03.
pFluoropolymer
Workgroup
09­
17­
03
Monitoring
Workgroup
09­
22­
03.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
October
8,
2003
PFOA
ECA
Telomer
Technical
Workgroup
Meeting
Summary,
9/
16/
03
66
participants;
Attendance
list
and
presentation
materials
in
docket
at
OPPT­
2003­
0012­
0198.

The
meeting
included
five
sections:
I.
Fire
Fighting
Foam
Coalition
Presentation
II.
EPA
Data
Needs
Review
III.
Telomer
Degradation
Technical
Expert
Subgroup
Progress
Report
and
Discussion
IV.
Telomer
Incineration
Technical
Expert
Subgroup
Progress
Report
and
Discussion
V.
Next
Steps
I.
Fire
Fighting
Foam
Coalition
Presentation
In
response
to
Item
#
11
on
EPA's
draft
ECA
Preliminary
Framework
Document
(
OPPT­
2003­
0012­
0056)
section
on
telomers,
the
Fire
Fighting
Foam
Coalition
(
FFFC)
gave
a
presentation
on
telomer­
based
Aqueous
Film­
Forming
Foams
(
AFFFs).
AFFFs
were
described
as
the
most
effective
agents
currently
available
to
fight
hydrocarbon
fuel
fires
in
military,
industrial
and
municipal
settings.
Background
information
on
the
chemical
nature
of
the
compounds
was
presented
with
an
emphasis
that
AFFFs
are
not
made
with
PFOA
and
no
PFOAbased
products
are
added.
At
the
request
of
FFFC,
a
report
was
prepared
by
Dr.
Jennifer
Field
using
AFFF
data
independently
collected
for
groundwater
at
3
multiple
use
application
military
bases
as
well
as
a
single
application
crash
site.
FFFC
presented
a
summary
of
the
Field
report,
detailed
important
study
considerations,
and
summarized
conclusions
derived
from
the
study.
The
presentation
can
be
located
in
the
docket
at
OPPT­
2003­
0012­
0201.
Because
this
presentation
contains
pre­
publication
information
from
the
Field
report
which
is
subject
to
copyright,
the
presentation
is
not
available
online,
but
it
can
be
reviewed
in
the
docket
public
reading
room.

EPA
agreed
to
review
the
Fire
Fighting
Foam
Coalition
information
on
AFFF
and
prepare
to
discuss
this
information
at
the
PFOA
ECA
Telomer
Technical
Workgroup
meeting
in
October.
At
the
October
meeting,
a
brief
discussion
will
take
place
to
develop
a
Workgroup
proposal
for
presentation
to
the
Plenary
concerning
whether
or
not
AFFF
chemicals
should
continue
to
be
a
consideration
in
the
PFOA
ECA
process.

II.
EPA
Data
Needs
Review
EPA
presented
individual
tables
summarizing
the
data
needs
for
telomers
and
telomer
degradation
from
the
Preliminary
Framework
Document
(
OPPT­
2003­
0012­
0056)
that
have
not
yet
been
satisfied
as
part
of
the
Letter
of
Intent
(
LOI)
commitments
or
in
discussions
for
a
proposed
ECA.
Telomer
information
included
ECA
Framework
Items
3,
4,
5,
7,
8,
and
9.
Degradation
and
Incineration
data
needs
were
addressed
separately.
The
tables
are
in
the
docket
at
OPPT­
2003­
0012­
0198.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
October
8,
2003
2
In
addition,
EPA
presented
draft
Telomer
Selection
Criteria
that
it
proposes
to
use
for
determining
the
representativeness
and
sufficiency
of
the
chemicals
which
the
Telomer
Research
Program
(
TRP)
has
proposed
to
test
in
the
TRP
LOI
and
in
proposed
PFOA
ECA
activities.
The
criteria
include
category
of
use;
structure
information;
fluorochemical
production
volume;
Rf
composition;
degradation
pathways
and
likelihood;
and
exposure
likelihood.
The
proposed
criteria
are
in
the
docket
at
OPPT­
2003­
0012­
0198.
EPA
suggested
that
within
two
weeks
(
by
October
10,
2003),
industry
and
interested
parties
submit
comments/
suggestions
on
EPA's
proposed
chemical
selection
criteria.
Thoughts
on
the
relative
weighting
factors
that
may
be
applied
to
the
various
criteria
are
particularly
of
interest.
A
meeting
may
be
arranged
if
warranted
after
EPA
makes
chemical
selections.

III.
Telomer
Degradation
Technical
Expert
Subgroup
Progress
Report
TRP
presented
information
on
a
Telomer­
Based
Polymeric
Products
(
TBPP)
Biodegradation
Study
strategy
including
the
objective
of
biodegradation
studies
for
TBPPs;
analytical
capabilities
for
measuring
biodegradation
(
e.
g.,
measurement
of
formation
of
PFOA,
loss
of
Total
Organic
Fluorine
(
TOF),
production
of
fluoride
ion,
analysis
for
8­
2
Telomer
B
alcohol);
other
analytical
considerations
and
limitations;
biodegradation
in
sludge
and
soil;
and
summary
and
conclusions.
The
presentation
is
in
the
docket
at
OPPT­
2003­
0012­
0198.

Discussions
on
degradation
testing
yielded
agreements
on
the
importance
of
ultimate
degradation
tests
(
Zahn­
Wellens
and
SCAS);
importance
of
degradation
in
soil
(
OECD
307);
importance
of
mass
balance;
analysis
of
TBPPs
and
isolated
polymers;
analysis
of
volatiles
in
SCAS
and
soil
tests;
and
a
duration
of
at
least
6
months
for
soil
testing.

The
workgroup
defined
areas
where
issues
still
exist.
EPA
raised
concerns
that
the
measurement
of
PFOA
alone
or
the
use
of
nonspecific
analytical
techniques
as
proposed
by
the
TRP
would
make
it
difficult
to
determine
whether
all
PFOA
precursors
remaining
in
the
test
system
would
be
identified.
Other
issues
included
rate
constant
determination;
extension
of
soil
test
duration
beyond
6
months
possibly
to
1
year;
analysis
of
degradants;
chemical
selection;
sludge
and
soil
sources
for
degradation
testing;
meaningfulness
of
level
of
detection
(
LOD)
and
level
of
quantification
(
LOQ)
values
as
triggers;
and
addressing
data
quality.

Duration
of
soil
testing
was
discussed
and
concluded
with
the
workgroup
agreeing
that
the
6
month
time
period
would
be
initially
sufficient;
however,
the
group
asked
TRP
to
consider
extending
the
duration
to
up
to
1
year.
Due
to
the
uncertainty
surrounding
the
time
for
degradation
to
PFOA,
workgroup
participants
felt
that
there
could
possibly
be
key
degradation
products
detected
in
the
6
month
period,
but
not
enough
time
for
PFOA
formation
TRP
agreed
to
consider
the
request.
EPA
has
agreed
to
provide
a
list
of
priorities
for
determining
key
analytes
to
look
for
from
degradation
testing.
This
could
help
to
determine
whether
a
longer
test
duration
period
may
be
necessary,
should
key
degradation
products
but
not
PFOA
be
detected
at
the
6
month
period.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
October
8,
2003
3
EPA
requested
TRP
provide
the
identities
of
the
2
chemicals
selected
for
initial
degradation
testing
(
SCAS
and
soil)
and
the
criteria
used
to
select
those
chemicals
to
demonstrate
that
they
are
representative
of
the
overall
group
of
12
chemicals
being
sponsored
by
TRP.
EPA
also
has
asked
TRP
to
consider
4
initial
chemicals
for
analysis
rather
than
just
the
2
proposed.

The
group
discussed
the
meaningfulness
of
LOD
and
LOQ
values
of
triggers
for
continuation
of
SCAS
and
Soil
testing.
The
concern
is
that
these
yet
undetermined
values
make
discussions
and
agreement
difficult.
TRP
agreed
to
develop
a
draft
testing
protocol
with
specific
concentrations
and
triggers
for
consideration
of
possible
next
steps
in
the
SCAS
and
soil
tests.

IV.
Telomer
Incineration
Technical
Expert
Subgroup
Progress
Report
The
workgroup
participants
discussed
the
TRP
Incineration
Testing
Protocol
Outline
and
agreed
that
the
next
step
was
to
form
a
Drafting
Committee.
The
committee
would
be
comprised
of
technical
experts
from
industry,
EPA,
and
other
registered
interested
parties
to
draft
the
protocol
for
an
ECA
proposal
to
go
to
the
Plenary
in
October
for
approval.

TRP
prepared
a
presentation
on
Telomer­
Based
Polymeric
Paper
and
Textile
Products
Incineration
Testing
Protocol
Outline;
however,
the
presentation
was
not
given
because
the
group
considered
it
unnecessary.
Interested
parties
can
locate
the
presentation
in
the
docket
at
OPPT­
2003­
0012­
0198.

V.
Identification
of
Workgroup
Next
Steps
°
Within
two
weeks
(
by
October
10,
2003),
industry
and
interested
parties
should
submit
comments/
suggestions
on
EPA's
proposed
chemical
selection
criteria.
Thoughts
on
the
relative
weighting
factors
that
may
be
applied
to
the
various
criteria
are
particularly
of
interest.
A
meeting
may
be
arranged
if
warranted
after
EPA
makes
chemical
selections.
Comments
on
the
proposed
criteria
should
be
submitted
either
by
email
to
Mary
Dominiak
at
dominiak.
mary@
epa.
gov
or
directly
to
the
electronic
docket.
You
can
make
docket
submissions
by
going
to
www.
epa.
gov/
edocket/,
and
using
the
"
Quick
Search"
feature
to
locate
and
open
docket
OPPT­
2003­
0012.
°
The
Drafting
Committee
formed
to
address
the
telomer
incineration
testing
protocol
should
complete
the
draft
protocol
for
presentation
to
the
October
Plenary
meeting.

TRP
°
TRP
will
provide
EPA
with
the
identities
of
the
2
chemicals
selected
for
initial
degradation
testing
(
SCAS
and
soil)
and
the
criteria
used
to
select
those
chemicals
to
demonstrate
that
they
are
representative
of
the
overall
group
of
12
chemicals
being
sponsored
by
TRP.
EPA
has
asked
that
TRP
consider
4
initial
chemicals
rather
than
2.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
October
8,
2003
4
°
TRP
will
develop
a
draft
testing
protocol
with
specific
concentrations
and
triggers
for
consideration
of
possible
next
steps
(
SCAS
and
Soil).
°
TRP
to
consider
extending
testing
duration
of
soil
testing
to
1
year.

EPA
°
EPA
will
review
the
Fire
Fighting
Foam
Coalition
information
on
AFFF
and
prepare
to
discuss
this
information
at
the
PFOA
ECA
Telomer
Technical
Workgroup
meeting
in
October.
At
the
October
meeting,
a
brief
discussion
will
take
place
to
develop
a
Workgroup
proposal
for
presentation
to
the
Plenary
concerning
whether
or
not
AFFF
chemicals
should
continue
to
be
a
consideration
in
the
PFOA
ECA
process.
°
EPA
to
provide
list
of
priorities
for
determining
key
analytes
to
look
for
from
degradation
testing.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
October
6,
2003
PFOA
ECA
Fluoropolymer
Technical
Workgroup
Meeting
Summary,
9/
17/
03
52
participants;
Attendance
list
and
presentation
materials
in
docket
at
OPPT­
2003­
0012­
0199.

The
meeting
included
five
sections:
I.
EPA
data
needs
review
II.
Fluoropolymer
Incineration
Technical
Expert
Subgroup
Progress
Report
and
Discussion
III.
Fluoropolymer
Aged
Articles
Technical
Expert
Subgroup
Progress
Report
and
Discussion
IV.
Discussion
on
QA
of
Stack
Sampling
V.
Next
Steps
I.
EPA
Data
Needs
Review
EPA
presented
a
table
summarizing
the
data
needs
identified
in
the
Preliminary
Framework
Document
(
OPPT­
2003­
0012­
0056)
that
have
not
yet
been
satisfied
as
part
of
the
Letter
of
Intent
(
LOI)
commitments
or
in
discussions
on
a
proposed
ECA.
The
information
includes
ECA
Framework
Items
3,
4,
5,
7,
8,
and
9.
The
presentation
is
in
the
docket
at
OPPT­
2003­
0012­
0199.

EPA
suggested
tasking
a
Subgroup
to
develop
language
for
Item
#
3,
concerning
the
elucidation
of
degradation
pathways
and
the
identification
of
degradation
products,
with
particular
attention
to
thermal
degradation
issues.

II.
Fluoropolymer
Incineration
Technical
Expert
Subgroup
Progress
Report
The
Fluoropolymer
Manufacturers
Group
(
FMG)
made
a
brief
presentation
detailing
their
incineration
test
protocol
outline.
The
presentation
included
information
on
the
testing
objective;
explanation
of
experimental
approach;
test
materials
and
methods;
description
of
testing
apparatus;
combustion
test
sampling
and
analysis;
and
reporting
of
results.
The
presentation
is
in
the
docket
at
OPPT­
2003­
0012­
0199.

The
workgroup
participants
discussed
the
FMG
Incineration
Testing
Protocol
Outline
and
agreed
that
the
next
step
was
to
form
a
Drafting
Committee
to
address
the
fluoropolymer
incineration
testing
protocol.
The
committee
would
be
comprised
of
technical
experts
from
industry,
EPA,
and
other
registered
interested
parties.
The
committee
would
draft
the
ECA
proposal
for
presentation
to
the
October
Plenary
meeting.
FMG
stated
that
Robert
Girard
and
David
Menotti
would
represent
industry
on
this
committee.

III.
Fluoropolymer
Aged
Articles
Technical
Expert
Subgroup
Progress
Report
FMG
provided
a
presentation
on
their
Aged
Articles
of
Commerce
(
AAOC)
Testing
Program.
The
presentation
included
discussion
of
the
objectives
and
definitions;
aged
article
U.
S.
Environmental
Protection
Agency
Meeting
Summary
October
6,
2003
2
selection
process;
test
condition
considerations;
proposed
test
conditions;
and
proposed
next
steps.
The
presentation
is
in
the
docket
at
OPPT­
2003­
0012­
0199.

Discussions
on
aged
articles
yielded
agreements
on
the
need
for
discussion
on
development
of
methods
to
determine
whether
water
is
an
appropriate
solvent.

The
workgroup
defined
areas
where
issues
still
exist
including
selection
of
aged
articles;
representativeness
of
articles
chosen;
water
as
an
effective
solvent
to
release
PFOA
from
polymer;
determination
of
initial
amounts
of
PFOA
prior
to
migration;
amount
of
plenum
cable
to
be
used
in
testing;
submersion
in
solvent
as
a
useful
simulation
of
aging;
important
factors
to
consider
when
aging;
test
duration;
test
temperature;
and
mass
balance.

Workgroup
participants
discussed
the
aged
articles
selected
for
testing
(
plenum
cable,
membranes
for
apparel,
and
cookware)
and
questioned
their
representativeness.
EPA
agreed
to
have
a
response
on
aged
article
selection
within
2
weeks
and
send
e­
mail
communications
to
the
group.
Another
meeting
may
be
held
if
further
discussion
is
necessary.

Discussions
concerning
solvent
selection
were
extensive.
Members
of
the
workgroup
questioned
the
appropriateness
of
water
as
a
solvent
for
testing.
The
proposed
FMG
protocols
utilize
water
as
a
solvent
to
dissolve
any
PFOA
that
has
migrated
to
the
surface
during
aging.
Members
of
the
group
suggested
the
initial
determination
of
the
total
content
of
PFOA
contained
in
the
article
by
using
chloroform
as
the
solvent.
Chloroform
has
been
shown
to
"
swell"
the
polymer
and
allow
extraction
of
available
PFOA.
EPA
asked
FMG
to
provide
a
written
explanation
on
the
appropriateness
of
water
as
the
solvent
selected
for
aged
article
testing.

The
workgroup
participants
discussed
the
appropriateness
of
the
aged
article
testing
protocols
with
regards
to
representativeness
of
samples
to
be
tested,
test
duration,
test
temperature,
and
testing
techniques.
The
group
requested
a
level
of
detail
of
how
the
samples
for
testing
would
be
chosen,
including
batches,
lots,
different
manufacturers,
etc.
The
group
questioned
the
amount
of
sample
to
be
tested;
the
test
duration
as
related
to
simulation
of
5­
10
years
of
use;
the
proposed
submersion
of
samples
in
solvent
rather
than
air
during
aging;
and
the
appropriateness
of
the
temperatures
selected
with
regards
to
adequate
simulation
of
normal
use
or
foreseeable
misuse
of
the
articles.
EPA
requested
that
FMG
answer
the
"
quick"
questions
regarding
proposed
accelerated
aging
testing,
including
what
facts
document
that
the
proposed
solvents,
temperatures,
and
techniques
are
appropriate.
EPA
agreed
to
list
key
factors
for
consideration
in
designing
testing
to
simulate
article
aging,
and
to
provide
a
more
thoughtful
response
on
aged
articles
testing
proposal
and
to
develop
a
side­
by­
side
comparison
on
data
gaps.

The
group
questioned
whether
the
use
of
a
mass
balance
approach
would
be
utilized
to
find
what
is
being
emitted
and
where
it
is
being
emitted,
or
whether
analysis
would
take
place
only
in
the
solvent.
The
group
noted
that
there
might
be
emissions
from
a
solid
to
air
during
U.
S.
Environmental
Protection
Agency
Meeting
Summary
October
6,
2003
3
aging
and
use,
and
queried
whether
such
emissions
would
be
taken
into
account
in
a
testing
program
that
assessed
only
emissions
from
a
solid
into
a
solvent.

IV.
Discussion
of
QA
Stack
Sampling
FMG
proposed
a
brief
discussion
regarding
the
quality
assurance
issues
associated
with
stack
sampling.
Concerns
are
that
there
is
no
approved
EPA
methodology
guideline
for
high
temperature
stack
sampling
and
that
method
development
would
be
necessary
to
meet
the
QAPP
(
Quality
Assurance
Project
Plan)
guidelines.
EPA
stated
that
it
is
not
necessary
to
use
approved
methodology
but
to
develop
a
method
with
an
appropriate
level
of
quality
control
that
can
be
documented
in
the
QAPP.

V.
Identification
of
Workgroup
Next
Steps
°
Task
a
Subgroup
to
develop
language
for
Item
#
3,
concerning
the
elucidation
of
degradation
pathways
and
the
identification
of
degradation
products,
with
particular
attention
to
thermal
degradation
issues.
°
The
Drafting
Committee
formed
to
address
the
fluoropolymer
incineration
testing
protocol
should
complete
the
draft
protocol
for
presentation
to
the
October
Plenary
meeting.

FMG
°
FMG
to
provide
written
explanation
on
confidence/
appropriateness
of
solvent
selection
for
aged
article
testing.
°
FMG
to
answer
the
"
quick"
questions
regarding
proposed
accelerated
aging
testing.
°
What
facts
document
that
the
proposed
solvents,
temperatures,
and
techniques
are
appropriate?

EPA
°
EPA
to
have
response
on
aged
article
selection
within
2
weeks
and
send
e­
mail
communications
to
the
group.
Another
meeting
may
be
held
if
further
discussion
is
necessary.
°
EPA
to
list
key
factors
for
consideration
in
designing
testing
to
simulate
article
aging.
°
EPA
to
provide
more
thoughtful
response
on
aged
articles
testing
proposal
and
develop
side
by
side
comparison
on
data
gaps.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
October
6,
2003
PFOA
ECA
Monitoring
Technical
Workgroup
Meeting
Summary,
9/
22/
03
58
participants;
Attendance
list
and
presentation
materials
in
docket
at
OPPT­
2003­
0012­
0200.

The
meeting
included
five
sections:
I.
EPA
Data
Needs
Review
II.
Presentation
by
3M
on
results
of
environmental
sampling
and
monitoring
(
including
biota)
for
PFOA
III.
Telomer
Monitoring
Discussion
IV.
Fluoropolymer
Monitoring
Discussion
V.
Next
Steps
I.
EPA
Data
Needs
Review
EPA
presented
individual
tables
summarizing
the
data
needs
expressed
in
the
Preliminary
Framework
Document
(
OPPT­
2003­
0012­
0056)
that
have
not
yet
been
satisfied
as
part
of
Letter
of
Intent
(
LOI)
commitments
or
in
proposed
ECA
discussions
concerning
monitoring
relating
to
fluoropolymers
and
telomers.
Information
included
monitoring
needs
for
manufacturing
releases,
manufacturing
sites,
off­
site
locations
from
manufacturing
facilities,
user
releases,
user
sites,
and
off­
site
locations
from
use
facilities.
EPA
emphasized
that
the
need
is
for
screening­
level,
baseline
monitoring
to
establish
a
background
against
which
to
measure
future
trends
rather
than
for
attributing
the
PFOA
contamination
to
any
particular
source.
The
tables
are
in
the
docket
at
OPPT­
2003­
0012­
0200.

II.
Presentation
by
3M
on
results
of
environmental
sampling
and
monitoring
(
including
biota)
for
PFOA
3M
presented
a
report
on
the
results
of
environmental
monitoring
programs
for
PFOA.
The
presentation
included
background
information,
the
purpose
of
the
3M
sponsored
monitoring
programs,
discussion
of
results
on
3
monitoring
programs,
and
a
summary
of
results.
The
3
studies
included
monitoring
of
the
Tennessee
River
Valley
for
surface
water,
sediment,
fish
and
clams;
a
multi­
city
study
analysis
of
drinking
water,
surface
water,
quiet
water,
POTW
effluent
and
sludge,
landfill
leachate,
sediment
and
foodstuffs;
and
a
biosphere
environmental
monitoring
of
a
wide
variety
of
wildlife
species.
The
presentation
is
in
the
docket
at
OPPT­
2003­
0012­
0200.

The
group
inquired
whether
additional
information
may
be
available
on
some
of
the
studies,
particularly
including
the
source
of
the
samples
used
in
the
market
basket
study
and
data
concerning
storage
stability
for
the
stored
samples
from
the
Geisy
studies.
3M
agreed
to
investigate
and
to
provide
any
additional
available
information.

III.
Telomer
Monitoring
Discussion
With
regard
to
the
EPA­
presented
table
for
Telomer
Monitoring
data
needs,
the
Telomer
research
Program
(
TRP)
questioned
how
the
proposed
baseline
information
would
be
used
and
U.
S.
Environmental
Protection
Agency
Meeting
Summary
October
6,
2003
2
how
the
findings
would
be
handled.
EPA
stated
their
intention
as
finding
where
sufficient
quantities
of
PFOA
and
PFOA
precursors
are
for
further
investigation
opportunities.

Concerns
were
expressed
regarding
the
"
legacy"
of
PFOA
contamination
from
sources
other
than
telomers,
and
the
need
for
feedback
on
the
acceptability
of
the
Mill
Pilot
study
as
a
way
to
establish
attribution
from
telomers.
TRP
suggested
providing
written
certification
of
laboratory
scale
equipment
if
necessary.
EPA
expressed
concerns
regarding
the
Mill
Pilot
study
including
uncertainty
with
the
proposed
scale­
up
representation
for
industry,
and
suggested
monitoring
to
verify
the
use
of
modeling.

The
group
questioned
whether
the
appropriate
parties
were
present
for
discussion
of
monitoring
at
customer
user
sites.
One
area
of
concern
was
the
willingness
of
customers
to
participate
in
such
monitoring
activities
and
what
avenues
would
be
explored
to
foster
participation.
Suggestions
were
made
to
blind
the
results
monitoring
as
a
means
of
participation,
so
that
monitoring
results
themselves
would
be
public,
but
specific
facility
names
and
locations
would
not
be
publicly
disclosed.

After
consideration,
TRP
suggested
consulting
with
3M
concerning
possible
joint
monitoring
at
customer
sites.
EPA
will
conduct
parallel
work
in
consideration
of
a
legal
vehicle
(
LOI,
ECA,
MOU)
that
would
allow
monitoring
of
customer
sites
not
under
the
control
of
the
monitoring
party.
A
tentative
meeting
with
EPA
and
other
interested
parties
concerning
this
discussion
is
scheduled
for
October
9,
2003.

IV.
Fluoropolymer
Monitoring
Discussion
FMG
presented
information
on
the
status
of
the
Dispersion
Mass
Balance
work
proposed
as
part
of
the
LOI
commitment.
FMG
expressed
concerns
with
making
their
work
deadline
due
to
other
work­
streams
associated
with
the
PFOA
ECA
meetings.
The
current
status
of
the
process
is
that
the
letters
are
ready
to
be
sent
out
to
sites
for
participation,
and
the
draft
study
protocol
is
ready
for
approval.
One
problem
FMG
noted
is
the
reluctance
for
participation
due
to
confidentiality
concerns.
FMG
proposed
that
EPA
be
given
all
relevant
individual
site
survey
information
with
the
exception
of
company
name
and
specific
location
to
satisfy
the
CBI
concerns.
This
would
serve
to
protect
the
identities
of
the
participants
while
informing
EPA
of
the
representativeness
of
the
sites
selected
for
evaluation.
EPA
asked
FMG
to
provide
information
on
representativeness
of
aqueous
dispersion
sites
selected
for
mass
balance
work
and
that
FMG
report
on
the
site
selection
criteria.

FMG
presented
information
on
Fluoropolymer
Environmental
Monitoring.
The
presentation
included
a
brief
program
overview
detailing
the
various
LOI
work­
streams
including
time­
lines
for
completion;
a
landfill
discussion;
and
information
on
soil
sampling.
The
presentation
can
be
located
in
the
docket
at
OPPT­
2003­
0012­
0200.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
October
6,
2003
3
Discussions
for
Fluoropolymer
monitoring
covered
the
topics
of
air
modeling,
air
sampling,
landfill
sampling,
adsorption/
desorption
test
results
relating
to
soil
sampling,
and
biota
monitoring.
The
group
agreed
that,
based
on
the
data
presented,
landfill
monitoring
would
not
be
a
high
priority
at
this
time,
although
some
questions
were
raised
concerning
whether
different
landfill
conditions
from
those
specifically
presented
could
produce
different
impacts.
The
group
also
agreed
that
groundwater
monitoring
is
important
and
should
be
conducted.
FMG
agreed
to
provide
a
start/
stop/
stage­
gate
approach
for
each
criteria
for
testing.

Concerns
were
expressed
with
regard
to
the
proposed
use
of
air
modeling
as
a
predictor
for
where
air
monitoring
samples
would
be
taken.
FMG
agreed
provide
a
detailed
protocol
for
air
sample
collection
for
verification
of
the
air
dispersion
model.
EPA
will
comment
on
the
air
dispersion
model
and
any
inconsistency
between
submitted
data
and
model
output.

The
group
suggested
that
soil
sampling
also
be
considered
as
a
way
of
verifying
air
deposition
modeling.
FMG
requested
that
EPA
review
the
adsorption/
desorption
results
and
provide
feedback..
EPA
requested
that
FMG
provide
written
justification
as
to
why
no
further
soil
sampling
would
be
necessary
based
on
the
results
of
the
adsorption/
desorption
data
presented
at
the
meeting.
FMG
expressed
the
opinion
that
because
PFOA
does
not
adsorb
to
soil,
rain
would
carry
it
quickly
down
from
the
surface
to
the
groundwater,
and
that
groundwater
measurements
would
be
more
significant.
EPA
noted
that
soil
samples
would
assist
in
the
verification
of
air
deposition
assumptions,
and
expressed
concern
about
the
potential
for
PFOA
deposited
on
soil
to
be
taken
up
by
plants
and
herbivores.

The
group
discussed
the
possibility
of
additional
sampling
of
biota
other
than
fish
based
upon
concerns
for
plants,
herbivores,
etc,
identified
in
the
EPA
data
needs
table.
EPA
requested
that
FMG
provide
written
justification
as
to
why
no
further
biota
testing
would
be
necessary.
FMG
requested
that
EPA
review
the
3M
soil
and
biota
data
and
provide
feedback
regarding
sufficiency.
(
Need
to
determine
what
is
needed,
what
is
missing,
what
is
considered
sufficient,
and
representativeness
of
the
data.)

V.
Identification
of
Workgroup
Next
Steps
TRP
°
TRP
to
consult
with
3M
concerning
possible
joint
monitoring
at
customer
sites.
A
tentative
meeting
with
EPA
and
other
interested
parties
concerning
this
discussion
is
scheduled
for
October
9,
2003.

FMG
°
FMG
will
provide
a
detailed
protocol
for
air
sample
collection
for
verification
of
the
air
dispersion
model.
°
FMG
to
provide
written
justification
as
to
why
no
further
soil
sampling
is
necessary
based
on
the
results
of
the
adsorption/
desorption
data
presented
at
the
meeting.
U.
S.
Environmental
Protection
Agency
Meeting
Summary
October
6,
2003
4
°
FMG
to
provide
written
justification
as
to
why
no
further
biota
testing
is
necessary.
°
FMG
to
provide
information
on
representativeness
of
aqueous
dispersion
sites
selected
for
mass
balance
work.
°
FMG
to
provide
a
start/
stop/
stage­
gate
approach
for
each
criteria
for
testing.

EPA
°
EPA
to
conduct
parallel
work
in
consideration
of
a
legal
vehicle
(
LOI,
ECA,
MOU)
that
would
allow
monitoring
of
customer
sites
not
under
the
control
of
the
monitoring
party.
°
EPA
to
review
adsorption/
desorption
results
and
provide
feedback.
°
EPA
to
review
3M
soil
and
biota
data
and
provide
feedback
regarding
sufficiency.
(
Need
to
determine
what
is
needed,
what
is
missing,
what
is
considered
sufficient,
and
representativeness
of
the
data.)
°
EPA
to
comment
on
the
air
dispersion
model
and
any
inconsistency
between
submitted
data
and
model
output.
