Draft
12­
19­
2003
EPA
EPA's
Current
Understanding
of
the
EPA's
Current
Understanding
of
the
Potential
Sources
and
Pathways
of
PFOA
Potential
Sources
and
Pathways
of
PFOA
in
the
Environment
Resulting
from
the
in
the
Environment
Resulting
from
the
Manufacture
and
Use
of
Manufacture
and
Use
of
Fluoropolymers
Fluoropolymers
December
19,
2003
December
19,
2003
A
"
Road
Map"
for
a
Path
Forward
Draft
12­
19­
2003
EPA
This
Presentation
°
This
presentation
is
a
"
Road
Map"
which
describes
EPA's
current
understanding
of
the
potential
sources
and
environmental
pathways
for
PFOA
in
the
environment
resulting
from
the
manufacture
and
use
of
fluoropolymers.

°
It
provides
EPA's
view
of
data
which
has
been
provided,
is
pending
via
an
industry
voluntary
commitment
or
proposed
to
be
collected
via
an
Enforceable
Consent
Agreement,
and
data
which
is
still
outstanding.

°
This
is
an
overall
summary;
the
details
of
the
data
and
EPA's
Data
Needs
are
described
in
the
dockets.
Draft
12­
19­
2003
EPA
Proposed
Path
Forward
°
EPA
has
reviewed
its
Data
Needs
Tables
and
the
data
available
thus
far.
Based
on
this
review
EPA
identified
outstanding
data
needs
which
would
enable
it
to
better
understand
sources
of
PFOA
entering
the
environment
and
pathways
leading
to
human
exposures.

°
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
important
to
understanding
and
prioritizing
sources
and
pathways.

°
EPA
may
revise
this
Road
Map
as
needed
based
on
its
review
of
incoming
data.
Draft
12­
19­
2003
EPA
Primary
Questions
°
EPA
needs
to
better
understand
the
potential
fluoropolymer
pathways
and
sources
of
PFOA
before
it
is
able
to
prioritize
them.

°
The
tests
identified
in
this
presentation
are
designed
to
answer
some
of
the
fundamental
questions
regarding
which
sources
and
pathways
are
the
most
significant.

°
Point
source
releases
could
result
in
levels
that
may
be
significant;
additional
information
is
needed
to
better
understand
these
sources.
Draft
12­
19­
2003
EPA
ECA
Tests
Proposed,
LOI
Commitments,
and
Outstanding
Data
Needs
°
Incineration:

 
Incineration
testing
to
determine
incineration
byproducts
(
proposed
ECA)

°
Article
testing:

 
FMG
will
conduct
testing
on
articles
in
commerce
(
LOI
commitment)

 
There
is
an
agreement
in
principle
on
testing
of
aged
articles
(
proposed
ECA)
Draft
12­
19­
2003
EPA
°
Article
testing
(
continued):

 
Thermal
degradation
data
on
fluoropolymers
and
determination
of
PFOA
FPA
contamination
of
processed
fluoropolymer
(
solid)
is
also
needed
and
could
possibly
be
included
in
this
testing.

(
outstanding
data
need)

°
Monitoring:

 
Manufacturing
facilities:
concentrations
in
air,

surface
soil,
and
additional
biota
(
outstanding
data
need).

ECA
Tests
Proposed,
LOI
Commitments,
and
Outstanding
Data
Needs
(
continued)
Draft
12­
19­
2003
EPA
°
Monitoring:

 
Off­
site
from
manufacturing
facilities:
air,

surface
water,
groundwater
(
background
concentrations),
wastewater
treatment
and
sludge,
soil,
and
biota
(
outstanding
data
need.)

 
Use
facilities
and
off­
site
from
these
facilities:

air,
surface
water,
groundwater,
wastewater,

soil,
sludges,
and
biota
(
outstanding
data
need.)

ECA
Tests
Proposed,
LOI
Commitments,
and
Outstanding
Data
Needs
(
continued)
Draft
12­
19­
2003
EPA
Take
Advantage
of
Available
Information:

°
Basic
information
(
e.
g.,
input
and
output
values,

chemical
properties
(
particulate,
vapor,
etc.),
used
in
modeling
conducted
by
industry,
and
x­
y
locations
for
groundwater
samples)
has
also
been
requested
by
EPA.

°
These
data
are
needed
so
EPA
can
analyze
and
interpret
the
data
submitted
by
industry
and
evaluate
the
statements
made
regarding
the
need
for
additional
monitoring.
Draft
12­
19­
2003
EPA
Possible
Future
Data
Needs
­

Examples
°
Other
tests
as
indicated
from
results
of
these
tests
or
available
data,
for
example:

 
Physical/
chemical,
fate
and
transport
properties
of
incineration
byproducts
or
of
degradation
products
(
to
be
determined
based
on
incineration
results
and
thermal
degradation
data)

 
More
extensive
monitoring
(
to
be
determined
based
on
initial
monitoring
results)
Fluoropolymers:
The
Road
Map
A
Summary
of
the
Fluoropolymer
Life
Cycle;
Potential
Sources
and
Pathways;
Data
Which
Are
Available,
Pending,
and
Needed;

And
EPA's
Rationale
for
Additional
Data
Needs
Draft
12­
19­
2003
EPA
Wastewater
Air
Solid
Waste/

sludge
Groundwater
(
Spillage,
Leaching)
Container
waste
rinsate
Air
Treatment
Discharge
to
Surface
Water
Sludge
Disposal
(
Land
application,
Landfill,

Incineration)

Landfill,
Incineration,

Recycling
Indoor
air
Outdoor
air
Soil,
Biota
Soil,
Biota
Product
Life
Cycle:

Product
Life
Cycle:
Fluoropolymers
Fluoropolymers
Fluoropolymer
Manufacturing
Fluoropolymer
Use
in
Manufacture
of
Articles
Shipping
Article
Use,
Breakdown,

Disposal
Soil,
Biota
Continue
to
Environmental
Fate
Surface
&
groundwater
Groundwater
Soil,
Biota
Disposal
Draft
12­
19­
2003
EPA
Manufacture
of
Manufacture
of
Fluoropolymers
Fluoropolymers
(
Parkersburg,
WV
Facility)

(
Parkersburg,
WV
Facility)
Data
Sources
And
Needs
Decatur,
AL
Manufacturing
Site
Wastewater
Air
Solid
Waste/

sludge
Groundwater
(
Spillage,
Leaching)
Treatment
Discharge
to
Surface
Water
Landfill,
Incineration,

Recycling
Soil,
Biota
Soil,
Biota
Fluoropolymer
Manufacturing
Soil,
Biota
Surface
water
Groundwater
Ingestion
?

Ingestion
?

Ingestion,
Inhalation
?
Ingestion
?

Ingestion
?
Inhalation
?
Ingestion
?

Sludge
Disposal
(
Land,
Landfill,

Incineration)
Return
to
Product
Life
Cycle
Continue
to
Environmental
Fate
Surface
&
groundwater
Groundwater
Pending:

LOI/
other:
some
ongoing
monitoring
is
being
conducted.

ECA:
Incineration
(
under
development)
Outstanding
Data
Needs:

ECA:
monitoring
of
air,
surface
soil,

biota
on­
site;
monitoring
of
air,

surface
water,
groundwater,

wastewater,
soil,
sludges,
and
biota
off­
site
Draft
12­
19­
2003
EPA
Manufacture
of
Manufacture
of
Fluoropolymers
Fluoropolymers
(
Decatur,
AL
Facilities)

(
Decatur,
AL
Facilities)
Data
Sources
And
Needs
Wastewater
Air
Solid
Waste/

sludge
Groundwater
(
Spillage,
Leaching)
Treatment
Discharge
to
Surface
Water
Landfill,
Incineration,

Recycling
Soil,
Biota
Soil,
Biota
Fluoropolymer
Manufacturing
Soil,
Biota
Ingestion
?

Ingestion
?

Ingestion,
Inhalation
?
Ingestion
?

Ingestion
?
Inhalation
?
Ingestion
?

Sludge
Disposal
(
Land
application,
Landfill,

Incineration)
Return
to
Product
Life
Cycle
Continue
to
Environmental
Fate
Groundwater
Surface
&
groundwater
Pending:

LOI/
other:
some
ongoing
monitoring
is
being
conducted
ECA:
Incineration
(
under
development);
Outstanding
Data
Needs:

ECA:
monitoring
of
air,
surface
soil,
biota
on­
site;
monitoring
of
air,

surface
water,
groundwater,

wastewater,
soil,
sludges,
and
biota
off­
site
Draft
12­
19­
2003
EPA
Shipping
of
Shipping
of
Fluoropolymers
Fluoropolymers
from
the
from
the
Manufacturer
to
Customers
Manufacturer
to
Customers
Data
Sources
And
Needs
Return
to
Product
Life
Cycle
Continue
to
Environmental
Fate
Wastewater
Container
waste
rinsate
POTW
Treatment
Discharge
to
Surface
Water
Sludge
Disposal
(
Land
application,
Landfill,

Incineration)
Soil,
Biota
Shipping
Ingestion
?

Ingestion
?

Ingestion
?
Groundwater
Pending:

LOI:
none
ECA:
none
Outstanding
Data
Needs:

ECA:
none
at
this
time
Draft
12­
19­
2003
EPA
Manufacture
of
Manufacture
of
Fluoropolymer
Fluoropolymer­
Treated
Treated
Articles
Articles
Wastewater
Solid
Waste/

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

Incineration)
Landfill,
Incineration,

Recycling
Soil,
Biota
Fluoropolymer
Use
in
Manufacture
of
Articles
Soil,
Biota
(
nonstick
cookware,

breathable
membranes
for
apparel,
gaskets,
thread
sealant
tape )
Ingestion
?

Ingestion
?

Inhalation
?

Ingestion,

Inhalation
?

Ingestion,

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

LOI:
dispersion
processor
materials
balance
ECA:
Incineration
(
under
development);
articles
(
ECA
agreement
in
principle)

Outstanding
Data
Needs:

ECA:
monitoring
of
air,
surface
water,
groundwater,

wastewater,
soil,
sludges,
and
biota
Draft
12­
19­
2003
EPA
Fluoropolymers
Fluoropolymers:
Article
Use,
Breakdown,

:
Article
Use,
Breakdown,

and
Disposal
and
Disposal
Wastewater
POTW
Treatment
Discharge
to
Surface
Water
Sludge
Disposal
(
Land
application,
Landfill,

Incineration)
Indoor
air
Outdoor
air
Dermal
contact
?

Ingestion
?
Soil,
Biota
Article
Use,
Breakdown,

Disposal
Landfill,
Incineration
Data
Sources
And
Needs
Inhalation
?
Ingestion
?

Ingestion
?
Ingestion
?

Return
to
Product
Life
Cycle
Continue
to
Environmental
Fate
Surface
water
Groundwater
Pending:

LOI:
articles
in
commerce
testing
ECA:
Incineration
(
under
development);
aged
articles
(
ECA
agreement
in
principle)

Outstanding
Data
Needs:

ECA:
none
at
this
time
Draft
12­
19­
2003
EPA
V
olatiliza
tion
V
o
la
tiliza
tio
n
,

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

Particulate
erosion
Environmental
Fate
of
Environmental
Fate
of
Fluoropolymers
Fluoropolymers
Return
to
Product
Life
Cycle
Water
Air
Soil
Biota
W
et,
dry
deposition
W
et,
dry
deposition
Irrigation
Pending:

LOI:
none
ECA:
none
Outstanding
Data
Needs:

ECA:
none
at
this
time
Draft
12­
19­
2003
EPA
Environmental
Fate:
Water
Environmental
Fate:
Water
Available
Data
Available
Data
Little
information
on
the
environmental
fate
of
fluoropolymers
is
available.
However,

based
on
the
structure
of
fluoropolymers,
information
provided
on
their
stability
under
chemically
and
environmentally
rigorous
conditions,
and
what
is
known
about
the
behavior
of
other
high
molecular
weight
synthetic
organic
polymers,

fluoropolymer
degradation
in
water
is
not
expected
to
be
a
significant
source
of
PFOA.
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
None.

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

None
at
this
time.
Return
to
Environmental
Fate
Draft
12­
19­
2003
EPA
Environmental
Fate:
Air
Environmental
Fate:
Air
Available
Data
Available
Data
A
screening
assessment
of
long
A
screening
assessment
of
long­
range
atmospheric
transport
using
a
simple
range
atmospheric
transport
using
a
simple
transport
and
deposition
model
has
been
conducted.
Results
of
t
transport
and
deposition
model
has
been
conducted.
Results
of
the
evaluation
he
evaluation
indicate
that
PFOA
can
move
up
to
800
km
after
being
released
to
indicate
that
PFOA
can
move
up
to
800
km
after
being
released
to
the
air.
This
the
air.
This
study,
while
limited,
indicates
that
PFOA
may
be
transported
in
study,
while
limited,
indicates
that
PFOA
may
be
transported
in
the
atmosphere
a
the
atmosphere
a
significant
distance.
EPA
needs
additional
information
to
deter
significant
distance.
EPA
needs
additional
information
to
determine
whether
air
is
a
mine
whether
air
is
a
significant
pathway
for
significant
pathway
for
fluoropolymers
fluoropolymers.
Air
modeling
has
also
been
conducted,
as
.
Air
modeling
has
also
been
conducted,
as
described
elsewhere
in
this
presentation,
but
EPA
needs
addition
described
elsewhere
in
this
presentation,
but
EPA
needs
additional
information
on
al
information
on
the
modeling
input
and
output
parameters
to
evaluate
the
study.

the
modeling
input
and
output
parameters
to
evaluate
the
study.
Reference
Reference
Pending/
Expected
Data
via
LOI
or
ECA
Pending/
Expected
Data
via
LOI
or
ECA
None.

None.
Additional
Data
Needed
via
ECA
and
Rationale
Additional
Data
Needed
via
ECA
and
Rationale
No
additional
data
on
the
environmental
fate
of
PFOA
in
air
is
n
No
additional
data
on
the
environmental
fate
of
PFOA
in
air
is
needed
at
this
time.

eeded
at
this
time.

Return
to
Environmental
Fate
Draft
12­
19­
2003
EPA
Environmental
Fate:
Soil
Environmental
Fate:
Soil
Available
Data
Available
Data
Little
information
on
the
environmental
fate
of
PFOA
in
soil
is
Little
information
on
the
environmental
fate
of
PFOA
in
soil
is
available.

available.
Adsorption
Adsorption
studies
in
soil
are
available,
but
the
studies
are
limited
and
d
studies
in
soil
are
available,
but
the
studies
are
limited
and
do
not
sufficiently
o
not
sufficiently
address
the
complex
soil
media.
T
address
the
complex
soil
media.
The
Agency
believes
that
soil
may
be
an
important
he
Agency
believes
that
soil
may
be
an
important
pathway
for
human
exposure
to
PFOA,
and
is
requesting
additional
pathway
for
human
exposure
to
PFOA,
and
is
requesting
additional
surface
soil
surface
soil
monitoring
data
to
better
understand
this
pathway
and
the
releva
monitoring
data
to
better
understand
this
pathway
and
the
relevant
sources
of
soil
nt
sources
of
soil
contamination.

contamination.
References
References
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
No
additional
information
on
the
environmental
fate
of
PFOA
in
s
No
additional
information
on
the
environmental
fate
of
PFOA
in
s
oil
is
needed
at
this
oil
is
needed
at
this
time,
however,
surface
soil
testing
is
needed
in
order
to
unders
time,
however,
surface
soil
testing
is
needed
in
order
to
understand
whether
soil
is
a
tand
whether
soil
is
a
significant
pathway
for
exposure
to
PFOA.

significant
pathway
for
exposure
to
PFOA.
Return
to
Environmental
Fate
Draft
12­
19­
2003
EPA
References:

References:

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

0488)

U.
S.
EPA,
Soil
Screening
Guidance:
Users
Guide.
EPA
Publication
U.
S.
EPA,
Soil
Screening
Guidance:
Users
Guide.
EPA
Publication
9355.4
9355.4­

23,
July
1996.

23,
July
1996.

U.
S.
EPA,
Fate,
Transport
and
Transformation
Test
Guidelines,
OP
U.
S.
EPA,
Fate,
Transport
and
Transformation
Test
Guidelines,
OPPTS
PTS
835.1220
Sediment
and
Soil
Adsorption/

835.1220
Sediment
and
Soil
Adsorption/
Desorption
Desorption
Isotherm.
EPA
712
Isotherm.
EPA
712­
C­
96
96­
048,

048,

April
1996.

April
1996.
Organization
for
Economic
Cooperation
and
Development
(
OECD)
(
20
Organization
for
Economic
Cooperation
and
Development
(
OECD)
(
2003).

03).

Adsorption/

Adsorption/
desorption
desorption
of
ammonium
of
ammonium
perfluorooctanoate
perfluorooctanoate
to
soil.
OECD
106
test
to
soil.
OECD
106
test
guideline.
EMSE
study
number
T0111/
14107,
report
number
17
guideline.
EMSE
study
number
T0111/
14107,
report
number
17­
03.

03.

Return
to
Environmental
Fate
Draft
12­
19­
2003
EPA
Manufacture
of
Manufacture
of
Fluoropolymers
Fluoropolymers:
General
:
General
Information
and
Specific
Information
at
the
Information
and
Specific
Information
at
the
Parkersburg,
WV
Facility
Parkersburg,
WV
Facility
Available
Data
Available
Data
Fluoropolymer
Fluoropolymer
Manufacturers
Group
(
FMG)
members
include
Asahi
Glass
Manufacturers
Group
(
FMG)
members
include
Asahi
Glass
Fluoropolymers
Fluoropolymers,
Daikin,

,
Daikin,
DuPont
DuPont,
and
,
and
Dyneon
Dyneon.
Fluoropolymers
Fluoropolymers
are
manufactured
are
manufactured
by
by
DuPont
DuPont
at
the
Washington
Works
facility
in
Parkersburg,
WV,
and
by
Daik
at
the
Washington
Works
facility
in
Parkersburg,
WV,
and
by
Daikin
at
in
at
the
Decatur,
AL
facility.

the
Decatur,
AL
facility.
DuPont
DuPont
is
the
only
U.
S.
manufacturer
of
APFO
which
is
is
the
only
U.
S.
manufacturer
of
APFO
which
is
used
to
make
used
to
make
fluoropolymers
fluoropolymers.
References
References
Information
on
the
basic
Information
on
the
basic
physical/
chemical
properties
of
the
physical/
chemical
properties
of
the
fluoropolymers
fluoropolymers,
the
,
the
manufacturing
process,
facilities,
locations,
uses/
applications
manufacturing
process,
facilities,
locations,
uses/
applications
of
of
fluoropolymers
fluoropolymers,

CAS
#,
chemical
names,
synthetic
sequences,
and
production/
impor
CAS
#,
chemical
names,
synthetic
sequences,
and
production/
import
volumes.

t
volumes.

(
LOI
Commitment)
Much
of
this
information
is
CBI,
however,
FMG
(
LOI
Commitment)
Much
of
this
information
is
CBI,
however,
FMG
has
provided
has
provided
detailed,
non
detailed,
non­
CBI
information
on
CBI
information
on
fluoropolymer
fluoropolymer
use
categories,
and
some
use
categories,
and
some
companies
have
provided
non
companies
have
provided
non­
CBI
plant
location
CBI
plant
location
References
References
EPA
also
has
some
materials
balance
information
for
one
facility
EPA
also
has
some
materials
balance
information
for
one
facility.
EPA
also
has
.
EPA
also
has
annual
release
data
for
the
Parkersburg,
WV
facility
which
provi
annual
release
data
for
the
Parkersburg,
WV
facility
which
provides
information
on
des
information
on
the
amount
of
PFOA
released,
the
compartments
to
which
the
mater
the
amount
of
PFOA
released,
the
compartments
to
which
the
materials
are
ials
are
released.
This
provides
an
understanding
of
potential
pathways
released.
This
provides
an
understanding
of
potential
pathways
at
manufacturing
at
manufacturing
facilities.

facilities.
References
References
Continue
Return
to
Fluoropolymer
Manufacture
Draft
12­
19­
2003
EPA
Manufacture
of
Manufacture
of
Fluoropolymers
Fluoropolymers
at
the
at
the
Parkersburg,
WV
Facility
(
continued)

Parkersburg,
WV
Facility
(
continued)

Available
Data
(
continued)

Available
Data
(
continued)

Results
from
several
Results
from
several
DuPont
DuPont­
sponsored
studies
of
the
Washington
Works
facility
sponsored
studies
of
the
Washington
Works
facility
and
surrounding
area
are
also
available.
In
summary,
ppb
level
and
surrounding
area
are
also
available.
In
summary,
ppb
levels
of
PFOA
were
s
of
PFOA
were
detected
in
a
variable
pattern
within
a
2
mile
radius
of
the
fac
detected
in
a
variable
pattern
within
a
2
mile
radius
of
the
fac
ility
in
groundwater.

ility
in
groundwater.

High
levels
(

High
levels
(
ppm
ppm)
were
detected
in
soil
associated
with
waste
disposal.
On
)
were
detected
in
soil
associated
with
waste
disposal.
On­
site
site
soil
samples
in
other
areas
not
associated
with
waste
disposal
w
soil
samples
in
other
areas
not
associated
with
waste
disposal
were
in
the
10
ere
in
the
10­
50
50
ppb
range.
Only
two
off
ppb
range.
Only
two
off­
site
soil
samples
were
analyzed;
these
detected
levels
of
site
soil
samples
were
analyzed;
these
detected
levels
of
110
and
170
ppb
in
the
Little
Hocking
well
field,
approximately
110
and
170
ppb
in
the
Little
Hocking
well
field,
approximately
1
mile
off
1
mile
off­
site.

site.

In
surface
water,
low
to
sub
In
surface
water,
low
to
sub­
ppb
levels
were
found
downstream
of
the
facility.

ppb
levels
were
found
downstream
of
the
facility.

PFOA
was
not
detected
upstream
of
the
outfall.
Local
public
wat
PFOA
was
not
detected
upstream
of
the
outfall.
Local
public
water
supplies
were
er
supplies
were
also
tested,
and
low
ppb
to
sub
also
tested,
and
low
ppb
to
sub­
ppb
levels
were
detected.
Air
modeling
using
ppb
levels
were
detected.
Air
modeling
using
ISCST3
has
also
been
conducted,
and
ISCST3
has
also
been
conducted,
and
DuPont
DuPont
believes
the
results
can
be
used
to
believes
the
results
can
be
used
to
predict
where
to
conduct
groundwater
monitoring.
EPA
has
looke
predict
where
to
conduct
groundwater
monitoring.
EPA
has
looked
at
the
results
d
at
the
results
and
other
available
information
and
disagrees.

and
other
available
information
and
disagrees.
DuPont
DuPont
believes
that
air
deposition
believes
that
air
deposition
followed
by
rapid
migration
through
the
soil
to
groundwater
is
t
followed
by
rapid
migration
through
the
soil
to
groundwater
is
the
major
route
of
he
major
route
of
the
contamination.
EPA
needs
additional
data
on
this
pathway
t
the
contamination.
EPA
needs
additional
data
on
this
pathway
to
determine
o
determine
whether
this
theory
is
supportable.

whether
this
theory
is
supportable.
References
References
Continue
Return
to
Fluoropolymer
Manufacture
Draft
12­
19­
2003
EPA
Manufacture
of
Manufacture
of
Fluoropolymers
Fluoropolymers
at
the
at
the
Parkersburg,
WV
Facility
(
continued)

Parkersburg,
WV
Facility
(
continued)

Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Additional
data
(
location
of
monitoring
wells
and
soil
samples,

Additional
data
(
location
of
monitoring
wells
and
soil
samples,
and
input
and
and
input
and
output
files
for
air
modeling)
has
been
requested
to
enable
EPA
output
files
for
air
modeling)
has
been
requested
to
enable
EPA
to
better
to
better
understand
the
modeling
and
monitoring
and
understand
the
modeling
and
monitoring
and
DuPont s
DuPont s
interpretation
of
the
data.

interpretation
of
the
data.

Incineration
Analysis
Incineration
Analysis
 
ECA
Proposal
is
being
drafted;
anticipate
results
roughly
18
ECA
Proposal
is
being
drafted;
anticipate
results
roughly
18
months
from
start
of
the
test,
based
on
similar
studies.

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

Additional
Data
Needed
via
ECA
and
Rationale
Additional
Data
Needed
via
ECA
and
Rationale
At
manufacturing
facilities,
monitoring
of
air,
surface
soil,
and
biota
are
needed.

Off­
site
from
these
facilities,
monitoring
of
concentrations
in
air,
surface
water,

groundwater
(
background),
wastewater
treatment
and
sludges,
and
biota
are
needed.
Very
little
off­
site
data
are
available
to
the
Agency,
and
thus,
the
extent
of
the
contribution
of
these
point
sources
to
the
general
population
exposures
is
largely
unknown.
Continue
Return
to
Fluoropolymer
Manufacture
Draft
12­
19­
2003
EPA
Manufacture
of
Manufacture
of
Fluoropolymers
Fluoropolymers
at
the
at
the
Parkersburg,
WV
Facility
(
continued)

Parkersburg,
WV
Facility
(
continued)

Continue
Return
to
Fluoropolymer
Manufacture
Additional
Data
Needed
via
ECA
and
Rationale,
continued
Additional
Data
Needed
via
ECA
and
Rationale,
continued
These
data
are
needed
to
better
understand
the
pathway
from
air
These
data
are
needed
to
better
understand
the
pathway
from
air
transport
transport
and
deposition
onto
soil
followed
by
migration
to
groundwater.

and
deposition
onto
soil
followed
by
migration
to
groundwater.
This
would
This
would
enable
EPA
to
determine
the
potential
for
these
point
sources
to
enable
EPA
to
determine
the
potential
for
these
point
sources
to
impact
the
impact
the
general
population.

general
population.
Draft
12­
19­
2003
EPA
References:
General
References:
General
Fluoropolymer
Fluoropolymer
and
and
Parkersburg,
WV
Site
Parkersburg,
WV
Site
APFO
Users
Letter
of
Intent,

APFO
Users
Letter
of
Intent,
 
Voluntary
Actions
to
Evaluate
and
Control
Voluntary
Actions
to
Evaluate
and
Control
Emissions
of
Ammonium
Emissions
of
Ammonium
Perfluorooctanoate
Perfluorooctanoate
(
APFO).
The
Society
of
the
Plastics
(
APFO).
The
Society
of
the
Plastics
Industry,
to
Stephen
L.
Johnson,
Assistant
Administrator,
OPPT
Industry,
to
Stephen
L.
Johnson,
Assistant
Administrator,
OPPTS,
EPA,
March
14,

S,
EPA,
March
14,

2003.

2003.
DuPont
de
Nemours
and
Company.
Voluntary
Use
and
Exposure
Information
Profile
for
Ammonium
Perfluorooctanoate
(
APFO).
Undated.
AR226­
0599.

3M
Company
(
2003)
Letter
from
Michael
Santoro
and
George
Millet
3M
Company
(
2003)
Letter
from
Michael
Santoro
and
George
Millet
to
to
Document
Control
Officer,
OPPT,
EPA
on
the
subject
of
P
Document
Control
Officer,
OPPT,
EPA
on
the
subject
of
P­
Chem
Chem
Properties
for
Properties
for
fluoropolymers
fluoropolymers.

Kudo
Kudo,
Naomi,
Naoki
Bandai,
Yoichi
Kawashima,

,
Naomi,
Naoki
Bandai,
Yoichi
Kawashima,
 
Determination
of
Determination
of
perfluorocarboxylic
perfluorocarboxylic
acids
by
gas
acids
by
gas­
liquid
chromatography
in
rat
tissues.

liquid
chromatography
in
rat
tissues. 
Toxicity
Toxicity
Letters,
99
(
1998)
183
Letters,
99
(
1998)
183­
190.

190.

Sottani
Sottani,
Christina,
and
Claudio
,
Christina,
and
Claudio
Minoia
Minoia,
 
Quantitative
determination
of
Quantitative
determination
of
perfluorooctanoic
perfluorooctanoic
acid
ammonium
salt
in
human
serum
by
high
acid
ammonium
salt
in
human
serum
by
high­
performance
liquid
performance
liquid
chromatography
with
atmospheric
pressure
chemical
ionization
tan
chromatography
with
atmospheric
pressure
chemical
ionization
tandem
mass
dem
mass
spectrometry
spectrometry 
Rapid
Communications
in
Mass
Spectrometry
16
(
2002)
650
Rapid
Communications
in
Mass
Spectrometry
16
(
2002)
650­
654.

654.

Continue
Return
to
Fluoropolymer
Manufacture
Draft
12­
19­
2003
EPA
References:
Parkersburg,
WV
Site
References:
Parkersburg,
WV
Site
(
continued)

(
continued)

Flaherty,
John,
and
Karen
Flaherty,
John,
and
Karen
Risha
Risha,
Method
of
Analysis
for
the
Determination
,
Method
of
Analysis
for
the
Determination
of
Ammonium
of
Ammonium
Perfluorooctanoate
Perfluorooctanoate
(
APFO)
in
Water
Revision
1,

(
APFO)
in
Water
Revision
1,
Exygen
Exygen
Research,

Research,

State
College,
PA.
January,
2003.

State
College,
PA.
January,
2003.

Corporate
Remediation
Group
(
An
Alliance
between
Corporate
Remediation
Group
(
An
Alliance
between
DuPont
DuPont
and
URS
and
URS
Diamond),
Sampling
Investigation
Results
Little
Hocking
Water
As
Diamond),
Sampling
Investigation
Results
Little
Hocking
Water
Association
Well
sociation
Well
Field;
Washington
County,
Ohio,
Project
number
748218983762.0001
Field;
Washington
County,
Ohio,
Project
number
748218983762.00010,
April,
2003.

0,
April,
2003.

(
AR226
(
AR226­
1416).

1416).
Corporate
Remediation
Group
(
An
Alliance
between
Corporate
Remediation
Group
(
An
Alliance
between
DuPont
DuPont
and
URS
and
URS
Diamond),
Groundwater
Investigation
Quality
Assurance
Project
Pl
Diamond),
Groundwater
Investigation
Quality
Assurance
Project
Plan
For
Washington
an
For
Washington
Works
Plant,
Project
number
D6WW7423.01,
January,
2002.

Works
Plant,
Project
number
D6WW7423.01,
January,
2002.

DuPont
Fluoroproducts
DuPont
Fluoroproducts,
Ammonium
,
Ammonium
Perfluorooctanoate
Perfluorooctanoate
(
C
(
C­
8)
Groundwater
8)
Groundwater
Investigation
Steering
Team
Report,
Consent
Order
No.
GW
Investigation
Steering
Team
Report,
Consent
Order
No.
GW­
2001
2001­
019,
August,
2003.

019,
August,
2003.

Corporate
Remediation
Group
(
An
Alliance
between
Corporate
Remediation
Group
(
An
Alliance
between
DuPont
DuPont
and
URS
and
URS
Diamond),
C
Diamond),
C­
8
Data
Summary
Report;
Consent
Order
GWR
8
Data
Summary
Report;
Consent
Order
GWR­
2001
2001­
019,

019,
DuPont
DuPont
Washington
Works
Facility
and
Local
Washington
Works
Facility
and
Local
Letart
Letart
And
Dry
Run
Landfills;
Project
number
And
Dry
Run
Landfills;
Project
number
742318983635,
February,
2003.
(
AR226
742318983635,
February,
2003.
(
AR226­
1415)

1415)
Continue
Return
to
Fluoropolymer
Manufacture
Draft
12­
19­
2003
EPA
References:
Parkersburg,
WV
Site
References:
Parkersburg,
WV
Site
(
continued)

(
continued)

Corporate
Remediation
Group
(
An
Alliance
between
Corporate
Remediation
Group
(
An
Alliance
between
DuPont
DuPont
and
URS
and
URS
Diamond),
C
Diamond),
C­
8
Data
Summary
Report;
Consent
Order
GWR
8
Data
Summary
Report;
Consent
Order
GWR­
2001
2001­
019,

019,
DuPont
DuPont
Washington
Works
Facility
and
Local
Washington
Works
Facility
and
Local
Letart
Letart
And
Dry
Run
Landfills;
Project
number
And
Dry
Run
Landfills;
Project
number
742318983635,
February,
2003.
(
AR226
742318983635,
February,
2003.
(
AR226­
1415)

1415)

DuPont
DuPont
(
2003)
Letter
from
Andrew
(
2003)
Letter
from
Andrew
Hartten
Hartten
to
David
Watkins,
West
Virginia
to
David
Watkins,
West
Virginia
Department
of
Environmental
Protection
on
the
subject
of:
2Q03
P
Department
of
Environmental
Protection
on
the
subject
of:
2Q03
Public
Water
Supply
ublic
Water
Supply
Results,
West
Virginia
and
Ohio
Results,
West
Virginia
and
Ohio
DuPont
DuPont
Washington
Works,
Washington,
WV,
June
Washington
Works,
Washington,
WV,
June
25,
2003.
(
AR226
25,
2003.
(
AR226­
1417)

1417)

Sprenger
Sprenger,
Mark,
and
Michael
Horne,
Draft
Report,
Dry
Run
Creek;

,
Mark,
and
Michael
Horne,
Draft
Report,
Dry
Run
Creek;

Washington,
Wood
County,
West
Virginia,
Environmental
Response
T
Washington,
Wood
County,
West
Virginia,
Environmental
Response
Team
Center,

eam
Center,

Office
of
Emergency
&
Remedial
Response,
November,
1997.
(
AR226
Office
of
Emergency
&
Remedial
Response,
November,
1997.
(
AR226­
1474)

1474)

DuPont
Fluoroproducts
DuPont
Fluoroproducts,
Ammonium
,
Ammonium
Perfluorooctanoate
Perfluorooctanoate
(
C
(
C­
8)
Groundwater
8)
Groundwater
Investigation
Steering
Team
Report,
Consent
Order
No.
GW
Investigation
Steering
Team
Report,
Consent
Order
No.
GW­
2001
2001­
019,
August,
2003.

019,
August,
2003.

Corporate
Remediation
Group
(
An
Alliance
between
Corporate
Remediation
Group
(
An
Alliance
between
DuPont
DuPont
and
URS
and
URS
Diamond),
Site
Screening
Level
Assessments
for
PFOA
and
the
Rele
Diamond),
Site
Screening
Level
Assessments
for
PFOA
and
the
Relevance
of
Soil
vance
of
Soil
Sampling,
Project
number
18983753.00034,
October
20,
2003.

Sampling,
Project
number
18983753.00034,
October
20,
2003.

Continue
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to
Fluoropolymer
Manufacture
Draft
12­
19­
2003
EPA
References:
Parkersburg,
WV
Site
References:
Parkersburg,
WV
Site
(
continued)

(
continued)
Return
to
Fluoropolymer
Manufacture
Corporate
Remediation
Group
(
An
Alliance
between
Corporate
Remediation
Group
(
An
Alliance
between
DuPont
DuPont
and
The
W
and
The
W­
C
Diamond
Group),
RCRA
Facility
Investigation
Report;

Diamond
Group),
RCRA
Facility
Investigation
Report;
DuPont
DuPont
Washington
Works;

Washington
Works;

Washington,
West
Virginia;
USEPA
Permit
Number
WVD04
Washington,
West
Virginia;
USEPA
Permit
Number
WVD04­
587
587­
5291,
Project
5291,
Project
number
0D6W7205,
June
30,
1999.

number
0D6W7205,
June
30,
1999.

Corporate
Remediation
Group
(
An
Alliance
between
Corporate
Remediation
Group
(
An
Alliance
between
DuPont
DuPont
and
URS
and
URS
Diamond),
Compilation
of
Historical
C
Diamond),
Compilation
of
Historical
C­
8
Data;

8
Data;
DuPont
DuPont
Washington
Works;
Main
Washington
Works;
Main
Plant
and
Landfills;
Project
number
D6WW7423,
January,
2002.

Plant
and
Landfills;
Project
number
D6WW7423,
January,
2002.

DuPont
DuPont
(
2003)
Letter
from
David
(
2003)
Letter
from
David
Rurak
Rurak
to
Document
Control
Officer,

to
Document
Control
Officer,

OPPT,
EPA
on
the
subject
of:
Follow
OPPT,
EPA
on
the
subject
of:
Follow­
up
to
September
15,
2003
Submission
of
up
to
September
15,
2003
Submission
of
DuPont
DuPont
Progress
Report
on
Environmental
Assessments
Pursuant
to
the
APF
Progress
Report
on
Environmental
Assessments
Pursuant
to
the
APFO
Users
LOI
dated
March
14,
2003:
Air
Dispersion
Modeling
Reports,

Users
LOI
dated
March
14,
2003:
Air
Dispersion
Modeling
Reports,
October
20,

October
20,

2003.

2003.
Corporate
Remediation
Group
(
An
Alliance
between
Corporate
Remediation
Group
(
An
Alliance
between
DuPont
DuPont
and
URS
and
URS
Diamond),

Diamond),
DuPont
Telomer
DuPont
Telomer
Manufacturing
Sites:
Environmental
Assessment
of
Manufacturing
Sites:
Environmental
Assessment
of
PFOA
Levels
in
Air
and
Water,
Project
number
50850118983843.0000
PFOA
Levels
in
Air
and
Water,
Project
number
50850118983843.00003,
September,

3,
September,

2003.

2003.
Corporate
Remediation
Group
(
An
Alliance
between
Corporate
Remediation
Group
(
An
Alliance
between
DuPont
DuPont
and
URS
and
URS
Diamond),
C
Diamond),
C­
8
Data
Summary
Report;
Consent
Order
GWR
8
Data
Summary
Report;
Consent
Order
GWR­
2001
2001­
019,

019,
DuPont
DuPont
Washington
Works
Facility
and
Local
Washington
Works
Facility
and
Local
Letart
Letart
And
Dry
Run
Landfills;
Project
number
And
Dry
Run
Landfills;
Project
number
742318983635,
February,
2003.
(
AR226
742318983635,
February,
2003.
(
AR226­
1415)

1415)
Draft
12­
19­
2003
EPA
References:
Parkersburg,
WV
Site
References:
Parkersburg,
WV
Site
(
continued)

(
continued)
Return
to
Fluoropolymer
Manufacture
Society
of
the
Plastics
Industry
(
SPI)
(
2003).
Detecting
and
Quantifying
Low
Levels
of
Fluoropolymer
Polymerization
Aids:
A
Guidance
Document.
Fluoropolymer
Manufacturers
Group,
Technical
Working
Group,

Analytical
Working
Group.
Washington,
DC.
SPI
Catalog
No.
BZ­
102.

Drobny,
J.
G.
(
2001).
Technology
of
Fluoropolymers.
Boca
Raton,
FL:

CRC
Press.
172
pp.

Schiers,
J.
(
Ed.)
(
1997).
Modern
Fluoropolymers:
High
Performance
Polymers
for
Diverse
Applications.
Chichester:
Wiley
&
Sons.
637
pp.

Taylor
PH,
Dellinger
B,
and
Lee
CC
(
1990).
Development
of
a
thermal
stability
based
ranking
of
hazardous
organic
compound
incinerability.
Environ
Sci
Technol
24:
316­
328.

Napoli,
M.,
Fraccaro
C,
Scipioni
A,
and
Armelli
R
(
1984).
Thermal
decomposition
of
pefluoroalkanesurfonyl
fluorides:
The
pyrolysis
of
perfluoro­

noctane
1­
sulfonyl
fluoride.
Journal
of
Fluorine
Chemistry,
24:
377­
385.

Tsang
W,
Burgess
DR,
and
Babushok
V
(
1998).
On
the
incinerability
of
highly
fluorinated
organic
compounds.
Combustion
Science
and
Technology
139:
385­
402.
Draft
12­
19­
2003
EPA
Manufacture
of
Manufacture
of
Fluoropolymers
Fluoropolymers
at
the
at
the
Decatur,
AL
Facility
Decatur,
AL
Facility
Available
Data
Available
Data
Several
studies
of
PFOA
contamination
in
the
vicinity
of
the
Dec
Several
studies
of
PFOA
contamination
in
the
vicinity
of
the
Decatur
facility.

atur
facility.

PFOA
has
been
detected
in
wastewater,
surface
water,
sediment,
a
PFOA
has
been
detected
in
wastewater,
surface
water,
sediment,
and
fish
nd
fish
tissue
near
the
facility
outfall
and
in
areas
downstream;
some
f
tissue
near
the
facility
outfall
and
in
areas
downstream;
some
fish
collected
ish
collected
upstream
of
the
outfall
had
measurable
PFOA
concentrations
as
we
upstream
of
the
outfall
had
measurable
PFOA
concentrations
as
well.
In
ll.
In
groundwater,
PFOA
was
detected
at
groundwater,
PFOA
was
detected
at
ppm
ppm
levels
near
the
facility,
including
some
levels
near
the
facility,
including
some
upgradient
upgradient
wells.
Contaminant
plumes
have
been
detected
at
the
facility
a
wells.
Contaminant
plumes
have
been
detected
at
the
facility
and
at
nd
at
a
nearby
landfill.

a
nearby
landfill.
References
References
A
limited
amount
of
air
modeling
data
have
been
generated
for
th
A
limited
amount
of
air
modeling
data
have
been
generated
for
the
Decatur
e
Decatur
facility,
but
the
data
have
not
undergone
a
rigorous
analysis
an
facility,
but
the
data
have
not
undergone
a
rigorous
analysis
and
EPA
needs
d
EPA
needs
additional
information
in
order
to
better
understand
the
results
additional
information
in
order
to
better
understand
the
results.
References
References
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Ongoing
monitoring
at
the
facility
is
being
conducted
and
the
Ag
Ongoing
monitoring
at
the
facility
is
being
conducted
and
the
Agency
expects
ency
expects
to
receive
this
data
when
it
becomes
available.

to
receive
this
data
when
it
becomes
available.
Continue
Return
to
Fluoropolymer
Manufacture
Draft
12­
19­
2003
EPA
Additional
Data
Needed
via
ECA
and
Rationale
Additional
Data
Needed
via
ECA
and
Rationale
Manufacturing
facilities
and
off­
site
from
these
facilities:
concentrations
in
air,
surface
water,
groundwater,
wastewater,
landfill
leachate,
soil,

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

and
thus,
the
extent
of
the
contribution
of
these
point
sources
to
the
general
population
exposures
is
largely
unknown.

These
data
are
needed
to
better
understand
the
pathway
from
air
These
data
are
needed
to
better
understand
the
pathway
from
air
transport
and
deposition
onto
soil
followed
by
migration
to
grou
transport
and
deposition
onto
soil
followed
by
migration
to
groundwater.

ndwater.

This
would
enable
EPA
to
determine
the
potential
for
these
point
This
would
enable
EPA
to
determine
the
potential
for
these
point
sources
sources
to
impact
the
general
population.

to
impact
the
general
population.

Manufacture
of
Manufacture
of
Fluoropolymers
Fluoropolymers
at
the
at
the
Decatur,
AL
Facility
(
continued)

Decatur,
AL
Facility
(
continued)

Continue
Return
to
Fluoropolymer
Manufacture
Draft
12­
19­
2003
EPA
References:

References:
Fluoropolymer
Fluoropolymer
Manufacture
Manufacture
Decatur,
AL
Site
Decatur,
AL
Site
Return
Entrix
Entrix,
Inc.
A
Survey
of
Selected
,
Inc.
A
Survey
of
Selected
Fluorochemicals
Fluorochemicals
in
the
Decatur
Alabama
in
the
Decatur
Alabama
Area
2002
Sampling,
prepared
for
3M,
St.
Paul,
Minnesota,
July,

Area
2002
Sampling,
prepared
for
3M,
St.
Paul,
Minnesota,
July,
2003.

2003.

3M
Company
(
2003)
Letter
from
Michael
Santoro
to
Document
Contro
3M
Company
(
2003)
Letter
from
Michael
Santoro
to
Document
Control
Officer,
OPPT,
EPA
on
the
subject
of:
Submission
of
Monitoring
D
Officer,
OPPT,
EPA
on
the
subject
of:
Submission
of
Monitoring
Data
Pursuant
to
the
ata
Pursuant
to
the
3M
LOI
dated
March
13,
2003
and
APFO
Users
LOI
dated
March
14,
2
3M
LOI
dated
March
13,
2003
and
APFO
Users
LOI
dated
March
14,
2003,
August
1,

003,
August
1,

2003.

2003.
Alabama
Department
of
Environmental
Management,
National
Polluta
Alabama
Department
of
Environmental
Management,
National
Polluta
nt
nt
Discharge
Elimination
System
Permit,
Daikin
America,
Inc.
(
AL006
Discharge
Elimination
System
Permit,
Daikin
America,
Inc.
(
AL0064351)
no
date.

4351)
no
date.

DuPont
DuPont
(
2003)
Letter
from
David
(
2003)
Letter
from
David
Rurak
Rurak
to
Document
Control
Officer,
OPPT,

to
Document
Control
Officer,
OPPT,

EPA
on
the
subject
of:
Follow
EPA
on
the
subject
of:
Follow­
up
to
September
15,
2003
Submission
of
up
to
September
15,
2003
Submission
of
DuPont
DuPont
Progress
Report
on
Environmental
Assessments
Pursuant
to
the
APF
Progress
Report
on
Environmental
Assessments
Pursuant
to
the
APFO
Users
LOI
O
Users
LOI
dated
March
14,
2003:
Air
Dispersion
Modeling
Reports,
October
2
dated
March
14,
2003:
Air
Dispersion
Modeling
Reports,
October
20,
2003.

0,
2003.

Daikin
(
2003)
Letter
from
Randy
Daikin
(
2003)
Letter
from
Randy
Roussel
Roussel
to
Document
Control
Officer,

to
Document
Control
Officer,

OPPT,
EPA
on
the
subject
of:
Progress
Report
on
Monitoring
Effor
OPPT,
EPA
on
the
subject
of:
Progress
Report
on
Monitoring
Efforts
at
Daikin
ts
at
Daikin
America,
Inc.
Decatur
Facility,
September
15,
2003.

America,
Inc.
Decatur
Facility,
September
15,
2003.

3M
Environmental
Laboratory,
Environmental
Monitoring
3M
Environmental
Laboratory,
Environmental
Monitoring
­
Multi
Multi­
City
Study;

City
Study;

Water,
Sludge,
Sediment,
POTW
Effluent
and
Landfill
Water,
Sludge,
Sediment,
POTW
Effluent
and
Landfill
Leachate
Leachate
Samples.
June
25,

Samples.
June
25,

2001.

2001.
Draft
12­
19­
2003
EPA
Shipping
From
Shipping
From
Fluoropolymer
Fluoropolymer
Manufacturer
to
Customers
Manufacturer
to
Customers
Return
Available
Data
Available
Data
EPA
has
no
information
on
what
types
of
containers
are
used,
and
EPA
has
no
information
on
what
types
of
containers
are
used,
and
how
the
how
the
shipping
containers
are
handled.

shipping
containers
are
handled.

Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
The
Dispersion
Processor
Materials
Balance
Study,
with
a
targete
The
Dispersion
Processor
Materials
Balance
Study,
with
a
targeted
completion
d
completion
date
of
2Q
2004,
should
provide
some
information
on
amount
of
co
date
of
2Q
2004,
should
provide
some
information
on
amount
of
container
waste
ntainer
waste
for
dispersions.

for
dispersions.

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

None
at
this
time.
Draft
12­
19­
2003
EPA
Fluoropolymers
Fluoropolymers:

Article
Manufacturing
Article
Manufacturing
Return
Available
Data
Available
Data
There
are
two
broad
uses
of
There
are
two
broad
uses
of
fluoropolymers
fluoropolymers:
a)
solid
polymer
which
is
ultimately
:
a)
solid
polymer
which
is
ultimately
molded
to
form
articles,
and
b)

molded
to
form
articles,
and
b)
fluoropolymer
fluoropolymer
dispersed
in
a
liquid
matrix,
with
dispersed
in
a
liquid
matrix,
with
PFOA
used
to
stabilize
the
emulsion.
The
dispersions
are
applie
PFOA
used
to
stabilize
the
emulsion.
The
dispersions
are
applied
onto
the
article
d
onto
the
article
and
the
article
is
heated
to
drive
off
PFOA
and
to
impart
favora
and
the
article
is
heated
to
drive
off
PFOA
and
to
impart
favorable
properties.

ble
properties.

References
References
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Dispersion
Materials
Balance
Study
will
assess
the
potential
for
Dispersion
Materials
Balance
Study
will
assess
the
potential
for
APFO
APFO
environmental
releases
during
dispersion
processing.
The
targe
environmental
releases
during
dispersion
processing.
The
target
date
for
t
date
for
completion
of
the
study
is
2Q
2004.

completion
of
the
study
is
2Q
2004.

Additional
Data
Needed
via
ECA
Additional
Data
Needed
via
ECA
Monitoring
on
Monitoring
on­
site
and
off
site
and
off­
site
of
concentrations
in
air,
soil,
surface
water,

site
of
concentrations
in
air,
soil,
surface
water,

groundwater,
wastewater
treatment
and
groundwater,
wastewater
treatment
and
sludges
sludges,
and
biota
is
needed
to
enable
,
and
biota
is
needed
to
enable
the
Agency
to
determine
whether
these
facilities
are
significant
the
Agency
to
determine
whether
these
facilities
are
significant
sources
of
PFOA.

sources
of
PFOA.
Draft
12­
19­
2003
EPA
Fluoropolymers
Fluoropolymers:

Article
Use/
Breakdown/
Disposal
Article
Use/
Breakdown/
Disposal
Available
Data
Available
Data
EPA
has
information
on
the
thermal
breakdown
of
EPA
has
information
on
the
thermal
breakdown
of
fluoropolymers
fluoropolymers
to
PFOA,
but
the
to
PFOA,
but
the
study
is
limited.
The
study
authors
burned
study
is
limited.
The
study
authors
burned
fluoropolymers
fluoropolymers
and
detected
PFOA.

and
detected
PFOA.

However,
thermal
degradation
data
were
not
included
in
this
stud
However,
thermal
degradation
data
were
not
included
in
this
study.

y.
EPA
also
has
EPA
also
has
basic
information
on
basic
information
on
fluoropolymers
fluoropolymers,
including
information
on
solvents
and
their
,
including
information
on
solvents
and
their
impact
on
impact
on
fluoropolymer
fluoropolymer
materials.

materials.

References
References
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
Pending/
Expected
Data
via
LOI
or
Proposed
ECA
FMG
has
committed
under
its
LOI
to
test
high
and
low
heat
consum
FMG
has
committed
under
its
LOI
to
test
high
and
low
heat
consumer
and
er
and
industrial
articles
of
commerce
using
FDA
Guidance
for
Industry
industrial
articles
of
commerce
using
FDA
Guidance
for
Industry
(
April
2002),

(
April
2002),

using
water
and
other
extraction
solvents
as
appropriate,
using
using
water
and
other
extraction
solvents
as
appropriate,
using
LC/
MS/
MS
analysis
LC/
MS/
MS
analysis
and
the
and
the
Exygen
Exygen
method.
In
addition,
a
proposed
ECA
is
under
discussion
and
method.
In
addition,
a
proposed
ECA
is
under
discussion
and
there
is
an
agreement
in
principle.
The
proposed
ECA
will
addre
there
is
an
agreement
in
principle.
The
proposed
ECA
will
address
testing
ss
testing
membranes
for
apparel,
household
cookware,
plenum
cable
and
thre
membranes
for
apparel,
household
cookware,
plenum
cable
and
thread
sealant
ad
sealant
tape
using
a
solvent
that
is
identified
by
a
solvent
comparison
tape
using
a
solvent
that
is
identified
by
a
solvent
comparison
test,
in
a
mass
test,
in
a
mass
balance
method
and
a
method
proposed
by
FMG
to
determine
the
pot
balance
method
and
a
method
proposed
by
FMG
to
determine
the
potential
for
ential
for
generation
of
PFOA
and
characterization
of
release
of
PFOA
from
generation
of
PFOA
and
characterization
of
release
of
PFOA
from
articles.

articles.

Continue
Return
to
Article
Use/
Breakdown/
Disposal
Draft
12­
19­
2003
EPA
Fluoropolymers
Fluoropolymers:

Article
Use/
Breakdown/
Disposal
Article
Use/
Breakdown/
Disposal
(
continued)

(
continued)

Additional
Data
Needed
via
ECA
and
Rationale
Additional
Data
Needed
via
ECA
and
Rationale
Thermal
degradation
data
are
needed.
This
testing
may
be
incor
Thermal
degradation
data
are
needed.
This
testing
may
be
incorporated
into
porated
into
the
article
testing
proposed,
but
EPA
needs
additional
informati
the
article
testing
proposed,
but
EPA
needs
additional
information
to
determine
on
to
determine
whether
the
testing
will
be
adequate.

whether
the
testing
will
be
adequate.

This
testing
would
determine
the
level
at
which
This
testing
would
determine
the
level
at
which
fluoropolymers
fluoropolymers
may
thermally
may
thermally
degrade
in
routine
use
and
reasonably
foreseeable
misuse
of
arti
degrade
in
routine
use
and
reasonably
foreseeable
misuse
of
articles.

cles.

Return
to
Article
Use/
Breakdown/
Disposal
Draft
12­
19­
2003
EPA
References:

References:

Article
Use/
Breakdown/
Disposal
Article
Use/
Breakdown/
Disposal
Return
Ellis,
David,
Jonathan
Martin,
Derek
Muir,
and
Scott
Ellis,
David,
Jonathan
Martin,
Derek
Muir,
and
Scott
Mabury
Mabury,
 
The
use
of
The
use
of
19
19
F
NMR
and
mass
spectrometry
for
the
elucidation
of
novel
fluorinat
NMR
and
mass
spectrometry
for
the
elucidation
of
novel
fluorinated
acids
and
ed
acids
and
atmospheric
atmospheric
fluoroacid
fluoroacid
precursors
evolved
in
the
precursors
evolved
in
the
thermolysis
thermolysis
of
of
fluoropolymers
fluoropolymers 
The
The
Analyst
128
(
2003)
756
Analyst
128
(
2003)
756­
764.

764.

Dionex
Dionex
Corp.
(
2000).
Accelerated
solvent
extraction
(
ASE)
of
additives
Corp.
(
2000).
Accelerated
solvent
extraction
(
ASE)
of
additives
from
from
polymer
materials.
Application
Note
331.

polymer
materials.
Application
Note
331.

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

www.
astm
astm.
org
.
org.

3M
Corp.
(
2003).
Letter
from
Michael
Santoro
and
George
Millet
t
3M
Corp.
(
2003).
Letter
from
Michael
Santoro
and
George
Millet
to
Document
Control
Officer,
OPPT,
EPA
on
the
subject
of
physical/
c
Document
Control
Officer,
OPPT,
EPA
on
the
subject
of
physical/
chemical
properties
hemical
properties
of
of
fluoropolymers
fluoropolymers.

APFO
Users
(
2003).
APFO
Users
Letter
of
Intent,

APFO
Users
(
2003).
APFO
Users
Letter
of
Intent,
 
Voluntary
actions
to
Voluntary
actions
to
evaluate
and
control
emissions
of
Ammonium
evaluate
and
control
emissions
of
Ammonium
Perfluorooctanoate
Perfluorooctanoate
(
APFO).

(
APFO). 

Submitted
with
a
cover
letter
from
Don
Duncan,
The
Society
of
th
Submitted
with
a
cover
letter
from
Don
Duncan,
The
Society
of
the
Plastics
Industry,

e
Plastics
Industry,

to
Stephen
L.
Johnson,
Assistant
Administrator,
OPPTS,
EPA.
Marc
to
Stephen
L.
Johnson,
Assistant
Administrator,
OPPTS,
EPA.
March
14,
2003.

h
14,
2003.
Draft
12­
19­
2003
EPA
Fluoropolymers
Fluoropolymers:
Biota
:
Biota
Available
Data
Available
Data
EPA
has
reviewed
biota
data
in
wildlife
from
Japan
and
Korea,
in
EPA
has
reviewed
biota
data
in
wildlife
from
Japan
and
Korea,
in
a
limited
study
of
a
limited
study
of
alfalfa
collected
from
the
site
of
a
3M
facility
which
encounter
alfalfa
collected
from
the
site
of
a
3M
facility
which
encountered
analytical
ed
analytical
problems,
and
from
a
market
basket
study
also
conducted
by
3M.

problems,
and
from
a
market
basket
study
also
conducted
by
3M.
The
m
The
market
arket
basket
study
included
food
purchased
in
Mobile,
AL;
Columbus,
GA
basket
study
included
food
purchased
in
Mobile,
AL;
Columbus,
GA;
Decatur,
AL;

;
Decatur,
AL;

Pensacola,
FL;
Cleveland,
TN;
and
Port
St.

Pensacola,
FL;
Cleveland,
TN;
and
Port
St.
Lucie
Lucie,
FL.

,
FL.
For
each
city,
six
samples
of
For
each
city,
six
samples
of
each
of
the
following
types
of
food
were
sampled:

each
of
the
following
types
of
food
were
sampled:
green
beans,
apples,
pork,

green
beans,
apples,
pork,

chicken,
eggs,
milk,
bread,
hot
dogs,
fish,
and
ground
beef.
Thi
chicken,
eggs,
milk,
bread,
hot
dogs,
fish,
and
ground
beef.
Thi
s
yielded
36
total
s
yielded
36
total
samples
for
each
food
type.

samples
for
each
food
type.
Purchase
times
and
food
origins
were
uncertain
for
Purchase
times
and
food
origins
were
uncertain
for
all
samples.
PFOA
was
not
detected
in
chicken,
pork,
eggs,
hot
all
samples.
PFOA
was
not
detected
in
chicken,
pork,
eggs,
hot
dogs,
or
fish.

dogs,
or
fish.

PFOS
(
but
not
PFOA)
was
detected
in
milk.
PFOA
was
detected
in
PFOS
(
but
not
PFOA)
was
detected
in
milk.
PFOA
was
detected
in
one
green
bean
one
green
bean
sample,
two
apple
samples,
one
bread
sample,
and
two
ground
beef
sample,
two
apple
samples,
one
bread
sample,
and
two
ground
beef
samples.
This
samples.
This
is
a
useful
study,
but
the
number
of
samples
collected
was
very
is
a
useful
study,
but
the
number
of
samples
collected
was
very
small
compared
to
small
compared
to
other
studies
(
e.
g.,
Pesticide
Data
Program)
which
are
used
to
p
other
studies
(
e.
g.,
Pesticide
Data
Program)
which
are
used
to
provide
reliable
rovide
reliable
results
about
the
nation
results
about
the
nation 
s
food
supply.

s
food
supply.
References
References
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
EPA
is
consulting
our
internal
experts
to
evaluate
these
studies
EPA
is
consulting
our
internal
experts
to
evaluate
these
studies
and
will
then
and
will
then
prepare
an
Agency
review
of
the
data,
including
whether
addition
prepare
an
Agency
review
of
the
data,
including
whether
additional
data
are
al
data
are
needed
via
an
ECA
and
rationale.

needed
via
an
ECA
and
rationale.
Return
to
Environmental
Fate
Draft
12­
19­
2003
EPA
References:
Biota
References:
Biota
Continue
Sanderson,
Hans,
Timothy
Boudreau,
Scott
Sanderson,
Hans,
Timothy
Boudreau,
Scott
Mabury
Mabury,
Keith
Solomon,

,
Keith
Solomon,

 
Impact
of
Impact
of
perfluorooctanoic
perfluorooctanoic
acid
on
the
zooplankton
community
in
indoor
acid
on
the
zooplankton
community
in
indoor
microcosms.
microcosms. 
Aquatic
Toxicology,
63
(
2003)
227
Aquatic
Toxicology,
63
(
2003)
227­
234.

234.

Kannan
Kannan,
Kurunthachalam
Kurunthachalam,
Jae
Jae­
Won
Won
Choi
Choi,
Naomasa
Naomasa
Iseki,

Iseki,
Kurunthachalam
Kurunthachalam
Senthilkumar
Senthilkumar,
Dong
Kim,
Shigeki
,
Dong
Kim,
Shigeki
Masunaga
Masunaga,
and
John
,
and
John
Giesy
Giesy,
 
Concentrations
of
Concentrations
of
perfluorinated
perfluorinated
acids
in
livers
of
birds
from
Japan
and
Korea,

acids
in
livers
of
birds
from
Japan
and
Korea, 
Chemosphere
Chemosphere
49
(
202)

49
(
202)

225
225­
231.

231.
Ohya
Ohya,
Takeshi,
Naomi
,
Takeshi,
Naomi
Kudo
Kudo,
Erika
Suzuki,
Yoichi
Kawashima,

,
Erika
Suzuki,
Yoichi
Kawashima,

 
Determination
of
Determination
of
perfluorinated
perfluorinated
carboxylic
acids
in
biological
samples
by
high
carboxylic
acids
in
biological
samples
by
high­

performance
liquid
chromatography
performance
liquid
chromatography 
Journal
of
Chromatography
720
(
1998)
1
Journal
of
Chromatography
720
(
1998)
1­
7.

7.

Giesy
Giesy,
John
P.
and
,
John
P.
and
Kurunthachalam
Kannan
Kurunthachalam
Kannan,
 
Global
Distribution
of
Global
Distribution
of
Perfluorooctane
Sulfonate
Perfluorooctane
Sulfonate
in
Wildlife
in
Wildlife 
Environmental
Science
&
Technology,
35
Environmental
Science
&
Technology,
35
(
2001)
1339
(
2001)
1339­
1342.

1342.

U.
S.
Department
of
Agriculture.
Pesticide
Data
Program.
Annua
U.
S.
Department
of
Agriculture.
Pesticide
Data
Program.
Annual
Summary
l
Summary
Calendar
Year
2001.
February
2003.

Calendar
Year
2001.
February
2003.
Draft
12­
19­
2003
EPA
References:
Biota
(
continued)

References:
Biota
(
continued)

Kannan
Kannan,
Kurunthachalam
Kurunthachalam,
J.
Christian
,
J.
Christian
Franson
Franson,
William
W.

,
William
W.
Bowerman
Bowerman,
Kris
,
Kris
J.
Hansen,
Paul
D.
Jones,
and
John
P.

J.
Hansen,
Paul
D.
Jones,
and
John
P.
Giesy
Giesy,
 
Perfluorooctane
Sulfonate
Perfluorooctane
Sulfonate
in
Fish
in
Fish­

Eating
Water
Birds
Including
Bald
Eagles
and
Albatrosses
Eating
Water
Birds
Including
Bald
Eagles
and
Albatrosses 
Environmental
Science
&

Environmental
Science
&

Technology,
35
(
2001)
3065
Technology,
35
(
2001)
3065­
3070.

3070.

Kannan
Kannan,
Kurunthachalam
Kurunthachalam,
Jaana
Koistinen
Jaana
Koistinen,
Kimberlee
Beckmen
Kimberlee
Beckmen,
Thomas
,
Thomas
Evans,
Jay
F.

Evans,
Jay
F.
Gorzelany
Gorzelany,
Kris
J.
Hansen,
Paul
D.
Jones,

,
Kris
J.
Hansen,
Paul
D.
Jones,
Eero
Helle
Eero
Helle,
Madeleine
,
Madeleine
Nyman
Nyman,
and
John
P.

,
and
John
P.
Giesy
Giesy,
 
Accumulation
of
Accumulation
of
Perfluorooctane
Sulfonate
Perfluorooctane
Sulfonate
in
Marine
in
Marine
Mammals
Mammals 
Environmental
Science
&
Technology,
35
(
2001)
1593
Environmental
Science
&
Technology,
35
(
2001)
1593­
1598.

1598.

3M
Environmental
Technology
and
Safety
Services,
Alfalfa
Summary
3M
Environmental
Technology
and
Safety
Services,
Alfalfa
Summary,

Centre
Centre
Analytical
Laboratories,
Inc.,
State
College,
PA,
no
date.

Analytical
Laboratories,
Inc.,
State
College,
PA,
no
date.

3M
Environmental
Technology
and
Safety
Services,
Analysis
of
PFO
3M
Environmental
Technology
and
Safety
Services,
Analysis
of
PFOS
and
S
and
PFOA
From
Various
food
Matrices
Using
HPLC
PFOA
From
Various
food
Matrices
Using
HPLC
Electrospray
Electrospray/
Mass
Spectrometry,

/
Mass
Spectrometry,

Centre
Centre
Analytical
Laboratories,
Inc.,
State
College,
PA,
June
21,
2001
Analytical
Laboratories,
Inc.,
State
College,
PA,
June
21,
2001.

Return
to
Environmental
Fate
Draft
12­
19­
2003
EPA
References:

References:

Air
Air
Franklin,
James,
Screening
Assessment
of
the
Potential
for
Franklin,
James,
Screening
Assessment
of
the
Potential
for
Long
Long­
Range
Atmospheric
Transport
of
Range
Atmospheric
Transport
of
perfluorooctanoic
perfluorooctanoic
acid,

acid,
Solvay
Solvay
Research
&
Technology,
March
24,
2002.

Research
&
Technology,
March
24,
2002.
Return
to
Environmental
Fate
Draft
12­
19­
2003
EPA
References:

References:

Manufactured
Articles
Manufactured
Articles
Society
of
the
Plastics
Industry
(
SPI)
(
2003).
Detecting
and
Quantifying
Low
Levels
of
Fluoropolymer
Polymerization
Aids:
A
Guidance
Document.

Fluoropolymer
Manufacturers
Group,
Technical
Working
Group,
Analytical
Working
Group.
Washington,
DC.
SPI
Catalog
No.
BZ­
102.

Dixon,
DA
(
2001).
Fluorochemical
decomposition
processes.

Unpublished.
6
pages.

Society
of
the
Plastics
Industry
(
SPI)
Fluoropolymers
Division
(
1998).

Guide
to
the
Safe
Handling
of
Fluoropolymer
Resins
(
3
rd
Edition.)
Washington,

DC:
SPI,
1998.
103
pp.
Return
to
Environmental
Fate
