Draft
12­
08­
2003
EPA
Telomers
Telomers
in
the
Environment:

in
the
Environment:

EPA's
Current
Understanding
of
Sources
EPA's
Current
Understanding
of
Sources
and
Pathways
and
Pathways
December
8,
2003
December
8,
2003
A
"
Road
Map"
for
a
Path
Forward
Draft
12­
08­
2003
EPA
Proposed
Path
Forward
°
At
the
October
9,
2003
meeting
of
the
Telomers
Monitoring
Work
Group,
EPA
proposed
to
focus
its
efforts
initially
on
additional
data
needed
for
priority
setting
and
screening.

°
Based
on
the
data
collected
and
analyzed,

additional
studies
would
be
prioritized.
Draft
12­
08­
2003
EPA
Proposed
Path
Forward
(
continued)

°
EPA
has
reviewed
its
Data
Needs
Tables
and
the
data
available
thus
far.
EPA
has
identified
tests
needed
to
to
better
understand
sources
of
PFOA
entering
the
environment
and
pathways
leading
to
human
exposures.

°
The
results
of
these
tests
will
enable
the
Agency
to
establish
priorities
for
future
studies
°
Some
of
EPA's
Data
Needs
have
been
met
by
industry;

others
are
included
in
LOI
commitments
or
ECA
proposals,
and
some
are
still
outstanding.

°
All
of
EPA's
Data
Needs
are
critical
to
understanding
sources
and
pathways.
Draft
12­
08­
2003
EPA
Proposed
Path
Forward
(
continued)

°
This
presentation
is
a
"
Road
Map"
which
describes
EPA's
current
understanding
of
sources
and
pathways,
available
data,
and
telomer
basic
data
needs
which
will
enable
further
priority
setting.

°
Once
these
basic
data
are
available,
additional
priorities
will
be
identified
for
further
testing
and
monitoring.

°
This
is
an
overall
summary;
the
details
of
the
data
and
EPA's
Data
Needs
are
described
in
the
relevant
dockets.
Draft
12­
08­
2003
EPA
Primary
Questions
°
In
order
to
understand
and
prioritize
the
potential
telomer
sources
and
pathways,
EPA
needs
to
understand
whether
telomers
can
undergo
transformation
to
PFOA
in
the
environment.

°
In
addition,
EPA
needs
to
better
understand
the
sources
of
PFOA
entering
the
environment
and
pathways
leading
to
human
exposures.

°
Point
source
releases
could
result
in
levels
that
could
be
significant;
additional
screening
level
information
is
needed
to
better
understand
these
sources.
Draft
12­
08­
2003
EPA
°
Incineration:

 
Incineration
testing
to
determine
incineration
byproducts
(
proposed
ECA)

°
Degradation:

 
Zahn­
Wellens
Test
OECD
302B
(
LOI
Commitment)

 
SCAS
Test
for
Insoluble
and
Volatile
Chemicals
(
OPPTS
835.5045)
and
Aerobic/
Anaerobic
Transformation
in
Soil
(
OECD
307)
for
telomer­
based
materials
(
ECA
agreement
in
principle)

ECA
Tests
Proposed,
LOI
Commitments,
and
Outstanding
Data
Needs
Draft
12­
08­
2003
EPA
°
Degradation
(
continued):

 
Aerobic
Sewage
Treatment
Simulation
Test
(
OECD
303A)
(
ECA
agreement
in
principle)

 
Anaerobic
Biodegradability
of
Organic
Compounds
in
Digested
Sludge:
Measurement
of
Gas
Production
(
OECD
311)
(
ECA
agreement
in
principle)

 
Aerobic
and
Anaerobic
Transformations
in
Aquatic
Sediment
Systems
(
OECD
308)
(
ECA
agreement
in
principle)
ECA
Tests
Proposed,
LOI
Commitments,
and
Outstanding
Data
Needs
Draft
12­
08­
2003
EPA
°
Degradation
(
continued)

 
Abiotic
degradation
tests:
UV/
Visible
Absorption
(
OPPTS
830.7050),
Direct
Photolysis
in
Water
(
OPPTS
835.2210),
and
Indirect
Photolysis
Screening
Test
(
OPPTS
835.5270)
(
outstanding
data
needs)

°
Article
testing:

 
TRP
has
an
LOI
commitment;
an
update
will
be
provided
at
the
December
2003
Workgroup
meeting
ECA
Tests
Proposed,
LOI
Commitments,
and
Outstanding
Data
Needs
(
continued)
Draft
12­
08­
2003
EPA
°
Monitoring:

 
Mill
Pilot
Study
(
LOI
commitment)

 
Material
balance
information
from
manufacturing
and
customer
sites
to
supplement
the
Mill
Pilot
Study
(
outstanding
data
need)

 
Manufacturing
facilities
and
off­
site
from
these
facilities:

concentrations
in
air,
surface
water,
groundwater,
wastewater
treatment,
soil,
sludges,
and
biota
(
outstanding
data
need).

 
Use
facilities
and
off­
site
from
these
facilities:
air,
surface
water,
groundwater,
wastewater
treatment,
groundwater,
soil,

sludges,
and
biota
(
outstanding
data
need).

ECA
Tests
Proposed,
LOI
Commitments,
and
Outstanding
Data
Needs
(
continued)
Draft
12­
08­
2003
EPA
Take
Advantage
of
Available
Information:

°
EPA
has
asked
whether
preliminary
information
on
the
storage
stability
testing
could
be
made
available.
These
data
would
be
very
helpful
as
we
develop
the
biodegradation
ECA.

°
EPA
and
TRP
agree
that
the
Telomer
8­
2
Alcohol
test
data
should
be
used
to
inform
degradation
testing
to
be
conducted.
Draft
12­
08­
2003
EPA
Possible
Future
Data
Needs­

Examples:

°
Incineration:

 
Physical/
chemical
,
fate
and
transport
properties
of
incineration
byproducts
(
to
be
determined
based
on
incineration
results)

°
Additional
monitoring
for
PFOA
and
PFOA
precursors,
to
be
prioritized
based
on
screening
level
test
results
and
other
available
data.

°
Other
studies
as
indicated
from
results
of
tests
or
monitoring
conducted,
or
other
available
data.
Draft
12­
08­
2003
EPA
Telomers:
The
Road
Map
A
Summary
of
the
Telomer
Lifecycle;
Potential
Sources
and
Pathways;
Data
Which
Are
Available,
Pending,
and
Needed;

and
EPA's
Rationale
for
Additional
Data
Needs
Draft
12­
08­
2003
EPA
Wastewater
Air
Solid
Waste/

sludge
Groundwater
(
Spillage,
Leaching,

Direct
Injection)
Container
waste
rinsate
Air
POTW
Treatment
Discharge
to
Surface
Water
Sludge
Disposal
(
Land,
Landfill,

Incineration)

Landfill,
Incineration,

Recycling
Soil,
Biota
Soil,
Biota
Product
Life
Cycle:

Product
Life
Cycle:
Telomers
Telomers
Chemical
Manufacturing
Chemical
Use
in
Manufacture
of
Articles
Shipping
Article
Use,
Breakdown,

Disposal
Soil,
Biota
Continue
to
Environmental
Fate
Disposal
Surface
&
groundwater
Surface
&
groundwater
Surface
&
groundwater
Indoor
air
Outdoor
air
Draft
12­
08­
2003
EPA
Wastewater
Air
Solid
Waste/

sludge
Groundwater
(
Spillage,
Leaching,

Direct
Injection)
POTW
Treatment
Discharge
to
Surface
Water
Sludge
Disposal
(
Land,
Landfill,

Incineration)
Landfill,
Incineration,

Recycling
Soil,
Biota
Soil,
Biota
Manufacture
of
Manufacture
of
Telomers
Telomers
Chemical
Manufacturing
Soil,
Biota
Return
to
Product
Life
Cycle
Ingestion
?

Ingestion
?

Ingestion,
Inhalation
?
Ingestion
?

Ingestion
?
Inhalation
?
Ingestion
?
Data
Sources
And
Needs
Continue
to
Environmental
Fate
Surface
&
groundwater
Groundwater
Pending:

LOI/
other:
some
ongoing
monitoring
is
being
conducted.

ECA:
Incineration
(
under
development);
Outstanding
Data
Needs:

ECA:
materials
balance,

monitoring
of
concentrations
on
and
off­
site
in
air,
surface
water,

groundwater,
wastewater,
soil,

sludges,
biota
Draft
12­
08­
2003
EPA
Wastewater
Container
waste
rinsate
POTW
Treatment
Discharge
to
Surface
Water
Sludge
Disposal
(
Land,
Landfill,

Incineration)
Soil,
Biota
Shipping
of
Shipping
of
Telomers
Telomers
Shipping
Return
to
Product
Life
Cycle
Ingestion
?

Ingestion
?

Ingestion
?
Data
Sources
And
Needs
Continue
to
Environmental
Fate
Groundwater
Pending:

LOI:
none
ECA:
none
Outstanding
Data
Needs:

ECA:
none
at
present
Draft
12­
08­
2003
EPA
Wastewater
Solid
Waste/

sludge
Air
POTW
Treatment
Discharge
to
Surface
Water
Sludge
Disposal
(
Land,
Landfill,

Incineration)

Landfill,
Incineration,

Recycling
Soil,
Biota
Manufacture
of
Manufacture
of
Telomer
Telomer­
based
Articles
based
Articles
Chemical
Use
in
Manufacture
of
Articles
Soil,
Biota
(
Carpet,
textiles,

paper,
leather )
Return
to
Product
Life
Cycle
Data
Sources
And
Needs
Ingestion
?

Ingestion
?

Inhalation
?

Ingestion,

Inhalation
?
Ingestion,

Inhalation
?
Ingestion
?
Continue
to
Environmental
Fate
Pending:

LOI:
Mill
Pilot
study
ECA:
Incineration
(
under
development)
Outstanding
Data
Needs:

ECA:
materials
balance,

monitoring
of
concentrations
on
and
off­
site
in
air,
surface
water,
groundwater,

wastewater,
landfill
leachate,

soil,
sludges,
biota
Draft
12­
08­
2003
EPA
Wastewater
POTW
Treatment
Discharge
to
Surface
Water
Sludge
Disposal
(
Land,
Landfill,

Incineration)
Indoor
air
Outdoor
air
Dermal
contact
?

Ingestion
?
Soil,
Biota
Telomers
Telomers:
Article
Use,
Breakdown,

:
Article
Use,
Breakdown,

and
Disposal
and
Disposal
Article
Use,
Breakdown,

Disposal
Landfill,
Incineration,

Recycling
Return
to
Product
Life
Cycle
Data
Sources
And
Needs
Inhalation
?
Ingestion
?

Ingestion
?
Continue
to
Environmental
Fate
Ingestion
?
Pending:

LOI:
article
testing
ECA:
none
Outstanding
Data
Needs:

ECA:
to
be
determined
after
update
on
LOI
article
testing
Draft
12­
08­
2003
EPA
V
o
la
tiliza
tio
n
V
o
la
tiliza
tio
n
,

T
ra
n
s
p
o
rt
o
n
p
a
rtic
u
la
te
s
Runoff,

Particulate
erosion
FLUOROPOLYMERS
 
Fate
in
the
Environment
Environmental
Fate
of
Environmental
Fate
of
Telomers
Telomers
Return
to
Product
Life
Cycle
Water
Air
Soil
Biodegradation
Hydrolysis
Photolysis
Sorption
Biodegradation
Sorption
Photolysis
Treatment
Hydrolysis
Photolysis
Irrigation
W
et,
dry
deposition
W
et,
dry
deposition
Pending:

LOI:
Zahn
Wellens
(
OECD
302B)

ECA:
SCAS,
Soil
(
OECD
307),

STP
(
OECD
303A),
Sediment
(
OECD
308),
Sludge
(
OECD
311);
Outstanding
Data
Needs:

ECA:
Abiotic
tests
Draft
12­
08­
2003
EPA
Environmental
Fate:

Environmental
Fate:

Biodegradation
in
Water
Biodegradation
in
Water
Available
Data
Available
Data
Preliminary
laboratory
studies
(
28
days
or
less)
show
that
8
Preliminary
laboratory
studies
(
28
days
or
less)
show
that
8­
2
Telomer
Telomer
B
Alcohol
B
Alcohol
undergoes
rapid
biodegradation
via
intermediates
to
PFOA.
The
ma
undergoes
rapid
biodegradation
via
intermediates
to
PFOA.
The
major
products
jor
products
are
intermediates
that
have
the
potential
to
be
transformed
to
P
are
intermediates
that
have
the
potential
to
be
transformed
to
PFOA
over
a
FOA
over
a
longer
period
of
time.

longer
period
of
time.
References
References
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
The
TRP
LOI
Commitment
includes
the
The
TRP
LOI
Commitment
includes
the
Zahn
Zahn­
Wellens
Wellens
test
(
OECD
302B)

test
(
OECD
302B)

References
References
EPA
has
identified
information
on
the
biodegradation
of
EPA
has
identified
information
on
the
biodegradation
of
telomer
telomer
based
polymers,

based
polymers,

precursors
and
8
precursors
and
8­
2
Telomer
Telomer
B
Alcohol
in
aerobic
/
anaerobic
aquatic
sediment
B
Alcohol
in
aerobic
/
anaerobic
aquatic
sediment
systems
as
important
data
needs
to
determine
if
these
processes
systems
as
important
data
needs
to
determine
if
these
processes
can
lead
to
the
can
lead
to
the
release
of
PFOA.
This
information
would
be
determined
using
OEC
release
of
PFOA.
This
information
would
be
determined
using
OECD
308
D
308
Aerobic/
Anaerobic
Transformation
in
Aquatic
Sediment
Systems.
References
References
Also,

Also,
Anaerobic
Sludge
Digestion
OECD
311
testing
is
needed
Anaerobic
Sludge
Digestion
OECD
311
testing
is
needed
because
because
preliminary
laboratory
tests
show
potential
for
rapid
biodegradat
reliminary
laboratory
tests
show
potential
for
rapid
biodegradat
ion
ultimately
ion
ultimately
leading
to
PFOA
leading
to
PFOA.
Return
to
Environmental
Fate
Draft
12­
08­
2003
EPA
Environmental
Fate:
Hydrolysis
in
Environmental
Fate:
Hydrolysis
in
Water
and
Soil
Water
and
Soil
Available
Data
Available
Data
8­
2
Telomer
Telomer
B
Alcohol
does
not
hydrolyze.

B
Alcohol
does
not
hydrolyze.
Reference
Reference
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
None.

None.
Additional
Data
Needed
via
ECA
and
Rationale
Additional
Data
Needed
via
ECA
and
Rationale
None
at
this
time.

None
at
this
time.
Return
to
Environmental
Fate
Draft
12­
08­
2003
EPA
Environmental
Fate:

Environmental
Fate:
Photolysis
Photolysis
in
in
Water
and
Soil
Water
and
Soil
Available
Data
Available
Data
8­
2
Telomer
Telomer
B
Alcohol
does
not
absorb
light
in
the
UV
range;
direct
B
Alcohol
does
not
absorb
light
in
the
UV
range;
direct
photolysis
photolysis
cannot
occur.

cannot
occur.

Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
None.

None.
Additional
Data
Needed
via
ECA
and
Rationale
Additional
Data
Needed
via
ECA
and
Rationale
Indirect
Indirect
photolysis
photolysis
of
8
of
8­
2
TBA
in
water
and
soils
as
part
of
2
TBA
in
water
and
soils
as
part
of
abiotic
abiotic
tests
which
tests
which
have
been
discussed
in
have
been
discussed
in
Telomer
Telomer
workgroup
meetings
and
are
outstanding
data
workgroup
meetings
and
are
outstanding
data
needs.

needs.
Return
to
Environmental
Fate
Draft
12­
08­
2003
EPA
Environmental
Fate:
Soil
Environmental
Fate:
Soil
Biodegradation
Biodegradation
Available
Data
Available
Data
Preliminary
laboratory
studies
(
28
days
or
less)
show
that
8
Preliminary
laboratory
studies
(
28
days
or
less)
show
that
8­
2
Telomer
Telomer
B
Alcohol
B
Alcohol
undergoes
rapid
biodegradation
via
intermediates
to
PFOA.
The
m
undergoes
rapid
biodegradation
via
intermediates
to
PFOA.
The
major
products
are
ajor
products
are
intermediates
that
have
the
potential
to
be
transformed
to
PFOA
intermediates
that
have
the
potential
to
be
transformed
to
PFOA
over
a
longer
period
over
a
longer
period
of
time.
Soil
may
be
a
significant
pathway
as
it
serves
as
an
of
time.
Soil
may
be
a
significant
pathway
as
it
serves
as
an
integrator
and
may
integrator
and
may
serve
as
a
reservoir.

serve
as
a
reservoir.
References
References
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
A
proposed
ECA
would
include
the
A
proposed
ECA
would
include
the
Aerobic
/
Anaerobic
Transformation
in
Soil
test
(
OECD
307).
Additional
Data
Needed
via
ECA
and
Rationale
Additional
Data
Needed
via
ECA
and
Rationale
Soil
biodegradation
data
including
biodegradation
rates
and
identification
of
degradation
products
needs
to
be
included
as
part
of
the
OECD
307
testing.
These
data
are
needed
to
enable
the
Agency
to
determine
if
o
determine
if
soils
are
a
potential
reservoir
where
telomers
can
degrade
to
produce
PFOA
and/
or
PFOA
precursors.

Return
to
Environmental
Fate
Draft
12­
08­
2003
EPA
Environmental
Fate:
Sorption
Environmental
Fate:
Sorption
Available
Data
Available
Data
8­
2
Telomer
Telomer
B
Alcohol
adsorption/

B
Alcohol
adsorption/
desorption
desorption
isotherm
data
indicate
moderate
to
isotherm
data
indicate
moderate
to
strong
sorption
to
soils
and
sediments.

strong
sorption
to
soils
and
sediments.
References
References
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
None
at
this
time;
Possible
future
needs.

None
at
this
time;
Possible
future
needs.

Additional
Data
Needed
via
ECA
and
Rationale
Additional
Data
Needed
via
ECA
and
Rationale
Additional
sorption
or
other
data
may
be
needed
to
determine
whe
Additional
sorption
or
other
data
may
be
needed
to
determine
whether
ther
degradation
products
are
mobile
in
soils.
These
data
could
be
degradation
products
are
mobile
in
soils.
These
data
could
be
needed
to
enable
needed
to
enable
the
Agency
to
determine
if
soils
or
sediment
are
a
significant
r
the
Agency
to
determine
if
soils
or
sediment
are
a
significant
route
of
exposure
oute
of
exposure
for
for
telomers
telomers
or
or
telomer
telomer
degradation
products
which
eventually
break
down
to
degradation
products
which
eventually
break
down
to
PFOA.

PFOA.
Return
to
Environmental
Fate
Draft
12­
08­
2003
EPA
Environmental
Fate:
Atmospheric
Environmental
Fate:
Atmospheric
Photolysis
Photolysis
Available
Data
Available
Data
An
atmospheric
oxidation
study
on
a
substance
similar
to
8
An
atmospheric
oxidation
study
on
a
substance
similar
to
8­
2
Telomer
Telomer
B
Alcohol
indicates
the
substance
undergoes
degradation
to
an
Alcohol
indicates
the
substance
undergoes
degradation
to
an
aldehyde
aldehyde.
No
.
No
information
on
the
potential
of
the
information
on
the
potential
of
the
aldehyde
aldehyde
to
form
PFOA
is
available.

to
form
PFOA
is
available.

Other
studies
show
similar
chemicals
degrade
to
Other
studies
show
similar
chemicals
degrade
to
perfluorocarboxylic
perfluorocarboxylic
acids.

acids.

Based
on
this
information,
EPA
concludes
that
the
8
Based
on
this
information,
EPA
concludes
that
the
8­
2
Telomer
Telomer
B
Alcohol
B
Alcohol
degrades
in
the
atmosphere
to
unknown
products.

degrades
in
the
atmosphere
to
unknown
products.
Reference
Reference
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
None.

None.
Additional
Data
Needed
via
ECA
and
Rationale
Additional
Data
Needed
via
ECA
and
Rationale
The
identity
and
fate
of
degradation
products
in
the
atmosphere
The
identity
and
fate
of
degradation
products
in
the
atmosphere
could
be
could
be
needed.
This
information
would
help
determine
if
this
transform
needed.
This
information
would
help
determine
if
this
transformation
ation
pathway
could
be
a
significant
route
to
PFOA,
and
an
exposure
pa
pathway
could
be
a
significant
route
to
PFOA,
and
an
exposure
pathway
for
thway
for
PFOA.

PFOA.
Return
to
Environmental
Fate
Draft
12­
08­
2003
EPA
Environmental
Fate:
Aerobic
Environmental
Fate:
Aerobic
Wastewater
Treatment
Wastewater
Treatment
Available
Data
Available
Data
None.

None.
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Draft
ECA
proposal
specifies
Draft
ECA
proposal
specifies
Modified
SCAS
Test
for
Insoluble
and
Volatile
Modified
SCAS
Test
for
Insoluble
and
Volatile
Chemicals
(
SCAS)
b
Chemicals
(
SCAS)
biodegradation
testing
for
iodegradation
testing
for
Telomer
Telomer­
Based
Polymers
Based
Polymers
(
TBPss
TBPss).
Note:
SCAS
(
OPPTS
835.5045)
is
not
a
wastewater
treatment
).
Note:
SCAS
(
OPPTS
835.5045)
is
not
a
wastewater
treatment
simulation
test.

simulation
test.
Reference
Reference
Data
to
determine
if
Data
to
determine
if
Telomer
Telomer
Based
Polymer
Products
(

Based
Polymer
Products
(
TBPPs
TBPPs)
degrade
to
degrade
to
PFOA
and
PFOA
precursors
in
wastewater
treatment
using
OECD
303A
PFOA
and
PFOA
precursors
in
wastewater
treatment
using
OECD
303A
Aerobic
Sewage
Treatment
Simulation
Test.

Aerobic
Sewage
Treatment
Simulation
Test.
Reference
Reference
These
data
are
needed
because
preliminary
laboratory
tests
show
These
data
are
needed
because
preliminary
laboratory
tests
show
potential
potential
for
rapid
biodegradation
ultimately
leading
to
PFOA.

for
rapid
biodegradation
ultimately
leading
to
PFOA.
TBPPs
TBPPs
are
expected
to
are
expected
to
be
released
to
wastewater
treatment
systems.
It
is
also
needed
be
released
to
wastewater
treatment
systems.
It
is
also
needed
to
to
determine
if
wastewater
treatment
can
lead
to
the
release
of
PF
determine
if
wastewater
treatment
can
lead
to
the
release
of
PFOA.

OA.

Return
to
Environmental
Fate
Draft
12­
08­
2003
EPA
References:

References:
Biodegradation
Biodegradation
Return
Telomer
Telomer
Research
Program
(
2003).
Letter
of
Intent
for
the
Research
Program
(
2003).
Letter
of
Intent
for
the
Telomer
Telomer
Research
Program.
March
14,
2003.
Letter
to
Stephen
Johnson.

Research
Program.
March
14,
2003.
Letter
to
Stephen
Johnson.

Wang,

Wang,
Ning
Ning,
Biodegradation
of
,
Biodegradation
of
14
14
C­
Labeled
8
Labeled
8­
2
Telomer
Telomer
B
Alcohol
(
Modified
B
Alcohol
(
Modified
OECD
301D
Closed
Bottle
Test),

OECD
301D
Closed
Bottle
Test),
Telomer
Telomer
Research
Program,
Arlington,
VA,
Study
Research
Program,
Arlington,
VA,
Study
completion
date:
October
24,
2003.

completion
date:
October
24,
2003.

Lange,

Lange,
Cleston
Cleston
C.,
Biodegradation
Screen
Study
for
C.,
Biodegradation
Screen
Study
for
Telomer
Telomer­
Type
Alcohols,

Type
Alcohols,

Pace
Analytical
Services,
Inc.,
Minneapolis,
MN,
November
6,
200
Pace
Analytical
Services,
Inc.,
Minneapolis,
MN,
November
6,
2002
(
AR226
2
(
AR226­
1149).

1149).

Wang,

Wang,
Ning
Ning,
Accelerated
Biodegradation
of
8
,
Accelerated
Biodegradation
of
8­
2
Telomer
Telomer
B
Alcohol
B
Alcohol
­
A
Preliminary
Screening
Study,
E.
I.

Preliminary
Screening
Study,
E.
I.
Du
Du
Pont
de
Nemours
and
Company,
Wilmington,
DE,

Pont
de
Nemours
and
Company,
Wilmington,
DE,

Study
completion
date:
March
20,
2003.

Study
completion
date:
March
20,
2003.

Organization
for
Economic
Cooperation
and
Development
(
OECD).
O
Organization
for
Economic
Cooperation
and
Development
(
OECD).
OECD
ECD
Guideline
for
Testing
of
Chemicals.
Inherent
biodegradability:
M
Guideline
for
Testing
of
Chemicals.
Inherent
biodegradability:
Modified
SCAS
test.

odified
SCAS
test.

No.
302A.
May
12,
1981.

No.
302A.
May
12,
1981.

Organization
for
Economic
Cooperation
and
Development
(
OECD).
O
Organization
for
Economic
Cooperation
and
Development
(
OECD).
OECD
ECD
Guideline
For
The
Testing
of
Chemicals.
Proposal
for
Updating
Gu
Guideline
For
The
Testing
of
Chemicals.
Proposal
for
Updating
Guideline
303.

ideline
303.

Simulation
Test
Simulation
Test
­
Aerobic
Sewage
Treatment:
303
A:
Activated
Sludge
Units
Aerobic
Sewage
Treatment:
303
A:
Activated
Sludge
Units
­
303
B:

303
B:

Biofilms
Biofilms.
January
22,
2001.

.
January
22,
2001.
Draft
12­
08­
2003
EPA
References:

References:

Atmospheric
Atmospheric
Photolysis
Photolysis
Return
Ellis,
D.
A.,
J.
W.
Martin,
S.
A.

Ellis,
D.
A.,
J.
W.
Martin,
S.
A.
Mabury
Mabury,
M.
D.

,
M.
D.
Sulbaek
Sulbaek
Andersen,
and
T.
J.

Andersen,
and
T.
J.

Wallington,

Wallington,
 
Atmospheric
Lifetime
of
Atmospheric
Lifetime
of
Fluorotelomer
Fluorotelomer
Alcohols
Alcohols 
Environmental
Environmental
Science
and
Technology,
37
(
2003)
3816
Science
and
Technology,
37
(
2003)
3816­
3820,
November
17,
2003.

3820,
November
17,
2003.

Mabury
Mabury,
S.
A.,

,
S.
A.,
Telomer
Telomer
Research
program,
Progress
Report.

Research
program,
Progress
Report.

September
1,
2001
to
September
1,
2002.
AR
226
September
1,
2001
to
September
1,
2002.
AR
226­
1281.

1281.

LeBras
LeBras,
C.
C.,

,
C.
C.,
Boussoutrot
Boussoutrot,
V.,
and
,
V.,
and
Magneron
Magneron,
I.
Study
of
the
,
I.
Study
of
the
Atmospheric
Fate
of
Fluorinated
Alcohols.
Final
Report,
July
20
Atmospheric
Fate
of
Fluorinated
Alcohols.
Final
Report,
July
2003.

03.

Kaiser,
M.
A.,
UV
Spectrum
of
8:
2
Kaiser,
M.
A.,
UV
Spectrum
of
8:
2
Telomer
Telomer
B
Alcohol,
Dupont
Report
B
Alcohol,
Dupont
Report
No.
12734,
AR
226
No.
12734,
AR
226­
1290,
March
21,
2003
1290,
March
21,
2003
Draft
12­
08­
2003
EPA
References:

References:

Hydrolysis
Hydrolysis
Return
Berti
Berti,
William
R.,
Aqueous
Stability
of
8
,
William
R.,
Aqueous
Stability
of
8­
2
Telomer
Telomer
B
Alcohol
as
a
B
Alcohol
as
a
Function
of
pH,

Function
of
pH,
DuPont
DuPont
Central
Research
&
Development,
Newark,
Delaware,

Central
Research
&
Development,
Newark,
Delaware,

April
25,
2003
(
AR226
April
25,
2003
(
AR226­
1348).

1348).
Draft
12­
08­
2003
EPA
Primary
References:

Primary
References:
Telomer
Telomer
Manufacturing,
Monitoring
Manufacturing,
Monitoring
3M
Environmental
Laboratory,
Environmental
Monitoring
3M
Environmental
Laboratory,
Environmental
Monitoring
­
Multi
Multi­
City
City
Study;
Water,
Sludge,
Sediment,
POTW
Effluent
and
Landfill
Study;
Water,
Sludge,
Sediment,
POTW
Effluent
and
Landfill
Leachate
Leachate
Samples.

Samples.

June
25,
2001.

June
25,
2001.
Telomer
Telomer
Research
Program
(
2000).

Research
Program
(
2000).
Telomer
Telomer
Research
Program
Research
Program
Update
and
Status
Report,
Presented
to
US
EPA,
OPPT.
October
23
Update
and
Status
Report,
Presented
to
US
EPA,
OPPT.
October
23,
2000.
(
AR
,
2000.
(
AR
226
226­
0947).

0947).
Telomer
Telomer
Research
Program
(
2003).

Research
Program
(
2003).
Letter
of
Intent
for
the
Letter
of
Intent
for
the
Telomer
Telomer
Research
Program.
March
14,
2003.
Letter
to
Stephen
Johnson.

Research
Program.
March
14,
2003.
Letter
to
Stephen
Johnson.

E.
I.

E.
I.
DuPont
DuPont
de
Nemours
&
Company
(
2003).

de
Nemours
&
Company
(
2003).
DuPont
Telomer
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Level
s
i
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Level
s
in
Air
and
n
Air
and
Water.
Corporate
Remediation
Group
(

Water.
Corporate
Remediation
Group
(
DuPont
DuPont/
URS
Diamond).
Wilmington,
DE
/
URS
Diamond).
Wilmington,
DE
September
2003.
Project
#
508501
September
2003.
Project
#
508501­
18983843.00003
18983843.00003
Kissa
Kissa,
Erik
(
2001).
Fluorinated
Surfactants
and
Repellants.
Second
,
Erik
(
2001).
Fluorinated
Surfactants
and
Repellants.
Second
Edition.
New
York:
Marcel
Edition.
New
York:
Marcel
Dekker
Dekker.
615
pp.

.
615
pp.

Daikin
America
Inc.
(
2003)
Progress
report
on
monitoring
effor
Daikin
America
Inc.
(
2003)
Progress
report
on
monitoring
effor
ts
at
ts
at
Daikin
America,
Inc.
Decatur
facility.
Letter
from
Randy
Daikin
America,
Inc.
Decatur
facility.
Letter
from
Randy
Roussel
Roussel,
Safety
,
Safety
Manager,
Daikin
America,
to
USEPA/
OPPT
Document
Control
Office.

Manager,
Daikin
America,
to
USEPA/
OPPT
Document
Control
Office.

September
15,
2003.
OPPT
September
15,
2003.
OPPT­
2003
2003­
0012
0012­
0208.

0208.
Continue
Return
Draft
12­
08­
2003
EPA
Martin,
Jonathan,
Derek
Muir,
Cheryl
Moody,
David
Ellis,

Martin,
Jonathan,
Derek
Muir,
Cheryl
Moody,
David
Ellis,
Wai
Kwan
Wai
Kwan,

Keith
Solomon,
and
Scott
Keith
Solomon,
and
Scott
Mabury
Mabury,
 
Collection
of
Airborne
Fluorinated
Collection
of
Airborne
Fluorinated
Organics
and
Analysis
by
Gas
Chromatography/
Chemical
Ionization
Organics
and
Analysis
by
Gas
Chromatography/
Chemical
Ionization
Mass
Mass
Spectrometry
Spectrometry 
Analytical
Chemistry
(
AR226
Analytical
Chemistry
(
AR226­
1062).

1062).

Levine,
A.
D.,
E.
L.

Levine,
A.
D.,
E.
L.
Libelo
Libelo,
G.

,
G.
Bugna
Bugna,
T.
Shelley,
H.
Mayfield,
T.
B.

,
T.
Shelley,
H.
Mayfield,
T.
B.

Stauffer,

Stauffer,
 
Biogeochemical
assessment
of
natural
attenuation
of
JP
Biogeochemical
assessment
of
natural
attenuation
of
JP­
4­

contaminated
ground
water
in
the
presence
of
fluorinated
surfact
contaminated
ground
water
in
the
presence
of
fluorinated
surfactants
ants 
The
The
Science
of
the
Total
Environment,
208
(
1997)
179
Science
of
the
Total
Environment,
208
(
1997)
179­
195.

195.

Kaiser,
M.
A.,
Water
Solubility
of
8:
2
Kaiser,
M.
A.,
Water
Solubility
of
8:
2
Telomer
Telomer
B
Alcohol,

B
Alcohol,
DuPont
DuPont
Report
No.
12718,
Test
Guideline
OECD
105,
AR226
Report
No.
12718,
Test
Guideline
OECD
105,
AR226­
1287,
December
27,

1287,
December
27,

2002.

2002.
Kaiser
M.
A.,
Vapor
Pressure
of
8:
2
Kaiser
M.
A.,
Vapor
Pressure
of
8:
2
Telomer
Telomer
B
Alcohol,

B
Alcohol,
DuPont
DuPont
Report
No.
12735,
AR
226
Report
No.
12735,
AR
226­
1288,
March
21,
2003.

1288,
March
21,
2003.

Primary
References:

Primary
References:
Telomer
Telomer
Manufacturing,
Monitoring
Manufacturing,
Monitoring
(
continued)

(
continued)
Return
to
Data
Sources
and
Needs
Draft
12­
08­
2003
EPA
Manufacture
of
Manufacture
of
Telomers
Telomers
Available
Data
Available
Data
TRP
members
include
Asahi
Glass,

TRP
members
include
Asahi
Glass,
Clariant
Clariant,
Daikin
Industries,
and
,
Daikin
Industries,
and
DuPont
DuPont.

Telomers
Telomers
are
manufactured
by
are
manufactured
by
DuPont
DuPont
at
the
Washington
Works
site
in
at
the
Washington
Works
site
in
Parkersburg,
WV,
and
at
the
Chambers
Works
site
in
Deepwater,
NJ
Parkersburg,
WV,
and
at
the
Chambers
Works
site
in
Deepwater,
NJ.
References
References
Information
on
the
manufacturing
process,
facilities,
locations,

Information
on
the
manufacturing
process,
facilities,
locations,
uses/
applications
uses/
applications
of
of
telomers
telomers,
CAS
#
s,
chemical
names,
synthetic
sequences,
and
,
CAS
#
s,
chemical
names,
synthetic
sequences,
and
production/
import
volumes.
(
LOI
Commitment)
Much
of
this
info
production/
import
volumes.
(
LOI
Commitment)
Much
of
this
information
is
CBI,

rmation
is
CBI,

although
some
use
and
location
information
is
non
although
some
use
and
location
information
is
non­
CBI.

CBI.
References
References
DuPont
DuPont
has
also
submitted
Monitoring
of
has
also
submitted
Monitoring
of
DuPont
Telomer
DuPont
Telomer
Manufacturing
Facilities
Manufacturing
Facilities
(
LOI
Commitment),
which
was
completed
September
29,
2003.
Addi
(
LOI
Commitment),
which
was
completed
September
29,
2003.
Additional
tional
monitoring
data
and
methods
have
also
been
reviewed.

monitoring
data
and
methods
have
also
been
reviewed.
References
References
The
Multi
The
Multi­
City
study
showed
some
PFOA
contamination,
but
also
measured
PFO
City
study
showed
some
PFOA
contamination,
but
also
measured
PFOS.

S.

Because
both
Because
both
telomers
telomers
and
and
fluoropolymers
fluoropolymers
are
manufactured
in
Decatur
AL,
and
are
manufactured
in
Decatur
AL,
and
3M
previously
manufacture
PFOS
at
this
site,
there
are
legacy
is
3M
previously
manufacture
PFOS
at
this
site,
there
are
legacy
issues
associated
sues
associated
with
this
site.

with
this
site.
Reference
Reference
Continue
Return
to
Product
Life
Cycle
Draft
12­
08­
2003
EPA
Manufacture
of
Manufacture
of
Telomers
Telomers
(
continued)

(
continued)

Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Incineration
Analysis
Incineration
Analysis
 
ECA
Proposal
is
being
drafted;
anticipate
results
roughly
ECA
Proposal
is
being
drafted;
anticipate
results
roughly
18
months
from
start
of
the
test,
based
on
similar
studies.

18
months
from
start
of
the
test,
based
on
similar
studies.

Additional
Data
Needed
via
ECA
and
Rationale
Additional
Data
Needed
via
ECA
and
Rationale
Materials
balance
on
the
Materials
balance
on
the
telomer
telomer
manufacturing
facilities.
M
manufacturing
facilities.
Monitoring
of
onitoring
of
concentrations
on
and
off
concentrations
on
and
off­
site
in
air,
surface
water,
groundwater,
wastewater,

site
in
air,
surface
water,
groundwater,
wastewater,

soil,

soil,
sludges
sludges,
biota.

,
biota.
Very
little
off
Very
little
off­
site
data
are
available
to
the
Agency,
and
site
data
are
available
to
the
Agency,
and
thus,
the
extent
of
the
contribution
of
these
point
sources
to
t
thus,
the
extent
of
the
contribution
of
these
point
sources
to
the
general
he
general
population
exposures
is
largely
unknown.

population
exposures
is
largely
unknown.

The
materials
balance
data
would
provide
basic
information
on
th
The
materials
balance
data
would
provide
basic
information
on
the
amount
of
e
amount
of
release,
the
compartments
to
which
the
release,
the
compartments
to
which
the
telomers
telomers
are
released,
and
the
amount
are
released,
and
the
amount
contained
in
their
products.
The
monitoring
would
enable
the
A
contained
in
their
products.
The
monitoring
would
enable
the
Agency
to
gency
to
determine
additional
priorities
for
testing
and
monitoring
based
determine
additional
priorities
for
testing
and
monitoring
based
on
screening
on
screening
level
data
for
sources
and
pathways
associated
with
level
data
for
sources
and
pathways
associated
with
telomer
telomer
manufacturing
manufacturing
facilities.

facilities.
Return
to
Product
Life
Cycle
Draft
12­
08­
2003
EPA
Telomers
Telomers:
Shipping
from
:
Shipping
from
Manufacturer
to
Customers
Manufacturer
to
Customers
Available
Data
Available
Data
EPA
has
some
CBI
information
from
one
company
about
practices
of
EPA
has
some
CBI
information
from
one
company
about
practices
of
this
company
with
respect
to
what
types
of
containers
are
used,

this
company
with
respect
to
what
types
of
containers
are
used,
and
and
how
the
containers
are
handled.

how
the
containers
are
handled.
Reference
Reference
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
None.

None.
Additional
Data
Needed
via
ECA
and
Rationale
Additional
Data
Needed
via
ECA
and
Rationale
None
at
this
time.

None
at
this
time.
Return
to
Product
Life
Cycle
Draft
12­
08­
2003
EPA
Telomers
Telomers:
Manufacture
of
Articles
:
Manufacture
of
Articles
Available
Data
Available
Data
Information
on
uses/
applications
of
Information
on
uses/
applications
of
telomers
telomers,
and
production/
import
volumes,
CAS
,
and
production/
import
volumes,
CAS
#
s,
chemical
names
(
LOI
Commitment).
Much
of
this
information
#
s,
chemical
names
(
LOI
Commitment).
Much
of
this
information
is
CBI.

is
CBI.

Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Mill
pilot
study
(
LOI
Commitment)
will
provide
information
on
ho
Mill
pilot
study
(
LOI
Commitment)
will
provide
information
on
how
much
w
much
Telomer
Telomer
is
is
used
per
unit
coverage,
exhaust
from
baths,
discharge
media,
as
used
per
unit
coverage,
exhaust
from
baths,
discharge
media,
as
a
result
of
bench
a
result
of
bench
scale
studies
which
are
typically
used
to
test
new
coatings
and
scale
studies
which
are
typically
used
to
test
new
coatings
and
formulations.
EPA
formulations.
EPA
has
concerns
about
scale
up
of
this
data,

has
concerns
about
scale
up
of
this
data,
representativeness
representativeness,
and
the
fact
that
,
and
the
fact
that
these
laboratory
studies
have
not
been
used
to
estimate
environm
these
laboratory
studies
have
not
been
used
to
estimate
environmental/
human
ental/
human
exposure.

exposure.
Reference
Reference
TRP
and
3M
have
agreed
to
work
together
to
address
monitoring
at
TRP
and
3M
have
agreed
to
work
together
to
address
monitoring
at
Telomer
Telomer
user
user
sites
to
determine
process
release/
emissions
and
plant
ambient
t
sites
to
determine
process
release/
emissions
and
plant
ambient
testing.
They
esting.
They
stipulate
that
there
be
no
attribution
to
current
and
past
suppl
stipulate
that
there
be
no
attribution
to
current
and
past
suppliers,
and
that
iers,
and
that
monitoring
be
conducted
under
a
non
monitoring
be
conducted
under
a
non­
ECA
format.
EPA,
TRP,
and
3M
are
ECA
format.
EPA,
TRP,
and
3M
are
discussing
the
proposed
approach.

discussing
the
proposed
approach.
Continue
Return
to
Product
Life
Cycle
Draft
12­
08­
2003
EPA
Telomers
Telomers:
Manufacture
of
Articles
:
Manufacture
of
Articles
(
continued)

(
continued)

Additional
Data
Needed
via
ECA
and
Rationale
Additional
Data
Needed
via
ECA
and
Rationale
Material
balance
information
to
supplement
the
mill
pilot
study.

Material
balance
information
to
supplement
the
mill
pilot
study.
Monitoring
of
onitoring
of
concentrations
on
and
off
concentrations
on
and
off­
site
in
air,
surface
water,
groundwater,
wastewater,

site
in
air,
surface
water,
groundwater,
wastewater,

soil,

soil,
sludges
sludges,
biota.

,
biota.
Very
little
off
Very
little
off­
site
data
are
available
to
the
Agency,
and
thus,

site
data
are
available
to
the
Agency,
and
thus,

the
extent
of
the
contribution
of
these
point
sources
to
the
gen
the
extent
of
the
contribution
of
these
point
sources
to
the
general
population
eral
population
exposures
is
largely
unknown.

exposures
is
largely
unknown.

The
material
balance
data
are
needed
because
EPA
has
concerns
ab
The
material
balance
data
are
needed
because
EPA
has
concerns
about
the
out
the
reliability
of
scaling
up
the
mill
pilot
study.
The
monitoring
w
reliability
of
scaling
up
the
mill
pilot
study.
The
monitoring
would
enable
the
ould
enable
the
Agency
to
determine
additional
priorities
for
testing
and
monito
Agency
to
determine
additional
priorities
for
testing
and
monitoring
based
on
ring
based
on
screening
level
data
for
sources
and
pathways
associated
with
screening
level
data
for
sources
and
pathways
associated
with
telomer
telomer
manufacturing
facilities.

manufacturing
facilities.
Return
to
Product
Life
Cycle
Draft
12­
08­
2003
EPA
Telomers
Telomers
 
"
Aged"
Articles
and
"
In
"
Aged"
Articles
and
"
In
Use"
Articles
Use"
Articles
Available
Data
Available
Data
None.

None.
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
TRP
has
an
LOI
commitment
to
test
articles
in
commerce
and
aged
TRP
has
an
LOI
commitment
to
test
articles
in
commerce
and
aged
articles.

articles.

EPA
has
identified
some
concerns
with
the
proposed
testing,
and
EPA
has
identified
some
concerns
with
the
proposed
testing,
and
TRP
is
TRP
is
seeking
input
from
others
on
the
proposed
testing.
EPA
recomme
seeking
input
from
others
on
the
proposed
testing.
EPA
recommends
using
nds
using
an
aggressive
solvent
extraction
to
determine
whether
PFOA
is
po
an
aggressive
solvent
extraction
to
determine
whether
PFOA
is
potentially
tentially
available
in
the
article.
Depending
on
the
results
of
this
test
available
in
the
article.
Depending
on
the
results
of
this
test,
a
mass
,
a
mass
balance
approach
using
test
conditions
which
simulate
actual
use
balance
approach
using
test
conditions
which
simulate
actual
use
conditions
and
foreseeable
misuse
conditions
for
the
in
use
and
conditions
and
foreseeable
misuse
conditions
for
the
in
use
and
aged
aged
articles
would
be
conducted.
A
final
solvent
extraction
would
b
articles
would
be
conducted.
A
final
solvent
extraction
would
be
conducted
e
conducted
to
determine
whether
PFOA
was
generated
during
use
of
the
articl
to
determine
whether
PFOA
was
generated
during
use
of
the
articl
e.

e.

References
References
Additional
Data
Needed
via
ECA
and
Rationale
Additional
Data
Needed
via
ECA
and
Rationale
TRP
has
agreed
to
update
the
work
group
at
the
December
2003
meeting.

Depending
on
the
results
of
this
meeting,
the
work
group
will
develop
a
recommendation
to
the
Plenary
on
this
data
need.
Return
to
Product
Life
Cycle
Draft
12­
08­
2003
EPA
References:

References:
Telomer
Telomer
Manufacture
of
Manufacture
of
Articles
Articles
Return
Telomer
Telomer
Research
Program
(
2003).
Letter
of
Intent
for
the
Research
Program
(
2003).
Letter
of
Intent
for
the
Telomer
Telomer
Research
Program.
March
14,
2003.
Letter
to
Stephen
Johnson.

Research
Program.
March
14,
2003.
Letter
to
Stephen
Johnson.

Kissa
Kissa,
Erik
(
2001).
Fluorinated
Surfactants
and
Repellants.

,
Erik
(
2001).
Fluorinated
Surfactants
and
Repellants.

Second
Edition.
New
York:
Marcel
Second
Edition.
New
York:
Marcel
Dekker
Dekker.
615
pp.

.
615
pp.
Draft
12­
08­
2003
EPA
References:

References:
Telomer
Telomer
"
Aged"
Articles
"
Aged"
Articles
and
"
In
Use"
Articles
and
"
In
Use"
Articles
Return
Telomer
Telomer
Research
Program
(
2003).
Letter
of
Intent
for
the
Research
Program
(
2003).
Letter
of
Intent
for
the
Telomer
Telomer
Research
Program.
March
14,
2003.
Letter
to
Stephen
Johnson.

Research
Program.
March
14,
2003.
Letter
to
Stephen
Johnson.

American
Society
for
Testing
and
Materials
(
ASTM).
Standard
guid
American
Society
for
Testing
and
Materials
(
ASTM).
Standard
guide
for
small
for
small­
scale
emission
chamber
determinations
from
indoor
scale
emission
chamber
determinations
from
indoor
materials/
products.
ASTM
D
materials/
products.
ASTM
D­
5116
5116­
97.
Available
at
97.
Available
at
www.

www.
astm
astm.
org
.
org.
Draft
12­
08­
2003
EPA
References:

References:
Telomer
Telomer
Sorption
Sorption
Return
Dekleva
Dekleva,
Lynn
(
2003)

,
Lynn
(
2003)
 
Adsorption/

Adsorption/
Desorption
Desorption
of
Ammonium
of
Ammonium
Perfluorooctanoate
Perfluorooctanoate
to
Soil
(
OECD
106)

to
Soil
(
OECD
106) 
Study
conducted
at
E.
I.

Study
conducted
at
E.
I.
du
du
Pont
de
Pont
de
Nemours
and
Company
site
in
Newark,
DE,
Report
number
EMSER
17
Nemours
and
Company
site
in
Newark,
DE,
Report
number
EMSER
17­
03.

03.

Welsh,
Stephen
(
1978)

Welsh,
Stephen
(
1978)
 
Adsorption
of
FC
95
and
FC
143
on
soil.

Adsorption
of
FC
95
and
FC
143
on
soil. 

Report
1,
Project
9970612633,
February
27,
1978.
(
AR226
Report
1,
Project
9970612633,
February
27,
1978.
(
AR226­
0488)

0488)
Draft
12­
08­
2003
EPA
References:

References:
Telomer
Telomer
Waste
Water
Waste
Water
Treatment
Treatment
OECD
Guideline
For
The
Testing
of
Chemicals.
Proposal
for
Updati
OECD
Guideline
For
The
Testing
of
Chemicals.
Proposal
for
Updating
ng
Guideline
303.
Simulation
Test
Guideline
303.
Simulation
Test
­
Aerobic
Sewage
Treatment:
303
A:
Activated
Aerobic
Sewage
Treatment:
303
A:
Activated
Sludge
Units
Sludge
Units
­
303
B:

303
B:
Biofilms
Biofilms.
January
22,
2001.

.
January
22,
2001.
Return
Draft
12­
08­
2003
EPA
References:

References:
Shipping
from
Shipping
from
Telomer
Telomer
Manufacturers
to
Customers
Manufacturers
to
Customers
DCN
6303000.0036.
Page
5,
and
mentioned
in
the
cover
letter.

DCN
6303000.0036.
Page
5,
and
mentioned
in
the
cover
letter.

This
reference
contains
Confidential
Business
Information
(
CBI)

This
reference
contains
Confidential
Business
Information
(
CBI)
and
is
not
and
is
not
available
in
the
public
docket.

available
in
the
public
docket.
Return
