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


Date:
3/4/2015
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 Enforceable 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 all eight areas have been obtained.  These topics and their responses are detailed in the files "Responses to EPA Review of Fluoropolymers Final Study Report 07-11-2013.pdf" and "Responses to EPA Review of Fluoropolymers Final Study Report 03-02-2015.pdf."

