To:
Nhan Nguyen, RAD Branch Chief
From:
Joe Avcin, RAD Staff


Date:
1/30/2015
Re:
Close-Out of Technical Matters associated with the ECA Incineration Testing Program: Laboratory-Scale Incineration Testing of Fluoropolymers

The ECA Incineration Testing Program: Laboratory-Scale Incineration Testing of Fluoropolymers was completed on October 30, 2009.  The final study report associated with this effort consisted of about 3,900 pages of main report body pages and the associated supporting appendices.  The central conclusion of this study was that Phase II combustion testing of Fluoropolymer Composites 1, 2, 3, and 4 in the laboratory-scale thermal reactor system determined that waste incineration of fluoropolymers does not emit detectable levels of PFOA under conditions representative of typical municipal waste combustor operations in the U.S.  Based on this testing, waste incineration of fluoropolymers is not expected to be a source of PFOA in the environment.  

Both Phase I and Phase II testing described in the Final Study Report were performed in accordance with the requirements of the Enforcable Consent Agreement (ECA) and the TSCA GLPs as embodied in the EPA-approved Quality Assurance Project Plans (QAPPs).  Upon review of the report and appendices, EPA did find eight areas that required additional technical clarification from the test sponsors.  These areas have been discussed with Philip Taylor, the Study Director, and Robert Giraud, the Technical Project Manager/Facility Management.

Satisfactory responses to Area #1, 2, 5, 7, and 8 have been obtained.  These topics and their responses are detailed in the file "Responses to EPA Review of Fluoropolymers Final Study Report.pdf." 

The following areas remain open at the time of the writing of this memo pending a response from Robert Giraud:

      Area #3  -  O-ring a soure of F?
      Area #4  -  CGA Concerns
      Area #6  -  Other Perfluorinated Compounds
      
The closure of these issues while important in providing technical completeness are not necessary in order to close-out the study itself.  Any potential outcome of these issues would not alter the conclusions of the study.  Reponses to these open matters are expected within the first half of 2015.  These responses will be documented as appropriate when they are received.  

