Document 3JOLymn14oZbj61dwGDoBQ8JD
( R R 9 .3 - &
-4 R i i & - \ & C
Ce: S. Korzeniowski - DuPont K. Smythe - Rand M. Dominiate - U.S. EPA
mm
Chemical Solutions Enterprise P. O. Box 80023, BMP 23-1324 Wilmington, DE 19880-0023
OPPT Document Control Office EPA East, Room 6428 1201 Constitution Avenue, NW Washington, D. C. 20460
January 31, 2002
To Whom It May Concern:,
Please find enclosed an updated copy of the Telomer Research Program presentation submitted to the Agency at the meeting held on December 18,2001. The CBI claim for the information on pages 37 and 63 is withdrawn. These pages contain no CBI and should be included in the public record. Text has been added to pages 37 and 63 to clarify that the proposed timelines are subject to change. Otherwise, these pages do not differ in any other way from the documents that were provided on December 18, 2001. In addition, a typographical error on page 31, replacing the word "Liver" with the word "Kidney" has also been made on both the CBI and non-CBI versions. The non-CBI version of this document is intended to replace the previous version (AR226-1044) in the public record.
Please contact me if you have any questions regarding this submission.
Best regards,
<rM td C ^ y ^
Robert C. Buck, Ph.D. Sr. Technology Consultant
Phone: 302.892.8935 Fax : 302.892.1124 Email : robert.c.buck@usa.dupont.com
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17 Dec 2001
Telomer Research Program Update and Status Report
United States Environmental Protection Agency
18 December 2001
Telomer Research Program
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Agenda
17 Dec 2001
TRP General Update; TRP Meetings Radio-label Update Pharmacokinetics Toxicology & Descriptive Biology Environmental Fate & Effects Summary Discussion and Path Forward
Telomer Research Program
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17 Dec 2001
TRP Review with U S EPA - 21 Feb. 2001
Toxicology Program Status & Timing Environmental Fate & Effects Program,
Protocols, & Timeline Radiolabel Material Status, Timeline
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17 Dec 2001
Telom er Research Program (TRP) : 2001 Key E vents
- January 9, 2001 : Environmental Fate & Effects Research Team Meeting
- February 21, 2001 : U.S. EPA
- March 9, 2001 : METI
- March 20-22, 2001 : TRP Meeting, Osaka
- April 19, 2001: Environment Canada
- May 16-17, 2001 : Environmental Fate & Effects Research Team Meeting
- May 18, 2001 : U.K. Environment Agency
- June-September 2001: Sub-team meetings and Conference Calls
- October 31 - Nov. 2, 2001 : TRP Meeting, Frankfurt
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3
TRP Osaka Meeting Highlights 20-22 March 2001
17 Dec 2001
Updates on 8-2 Alcohol Starting Material and Quality Radio-label Synthesis Strategic Plan and Path Forward TRP Database Status Review and Upgrades to Toxicology and Pharmacokinetics
Plans Review and Upgrades to EF&E Work Plans: Tier I, II, III Communications Team Work Plan
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TRP Frankfurt Meeting Highlights 31 October - 2 November 2001
17 Dec 2001
Toxicology Data Review and Subsequent Upgrades to Overall Tox Plans; Review Data to Date and Scheduling
Radio-label Synthesis Review, Sourcing Plan, and Timing Pharmacokinetics Plans due to Radio-label Schedule Analytical Effort Overview and Challenges EF&E Tier I and II Workplan Updates and Revisions; Review
Data to Date and Scheduling Workplan for Compounds Beyond 8-2 Alcohol TRP Sponsorship of Outside Research Communication Strategy and Path Forward Next Meeting(s): Conference Calls and In Person
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17 Dec 2001
CBI has been redacted
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n-C8F17CH2CH2OH Analysis Profile
Purity > 99% by G.C.
- 99.2% n-C8F 17CH2CH2OH - no other CnF2n+1CH2CH2OH species - 0.8% impurity
CBI has been redacted
7 17 Dec 2001
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n-C8F17CH2CH2OH Selection Criteria
17 Dec 2001
Selection Criteria Included: Simple, Single, Pure, Representative, and Readily Characterized
Most Common and Representative from Each of 5 Major ProducersIncludes Both Type and Chain Length
Telomer 8-2 Alcohol - F(CF2CF2)4-CH2CH2-OH - Was Chosen To - Be Able to Characterize a Single Compound versus a Complex Product Mixture - Enable the Research Team to Study Metabolites in the Pharmacokinetics Work (ADME) - Study the Degradation Products and Locations in the Environmental Fate Studies - Enable the Team to Measure Critical Physical Property Data - Enable the Team to Radio-label a Single Key Compound for the Toxicology and Environmental Fate Studies
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n-C8F17CH2CH2OH Selection Criteria
17 Dec 2001
Due to the Complexity and Non-Classic Behavior of the Fluorochemicals, Numerous Testing Protocols Had to be Developed and Validated. By Definition, a Single Compound was the Only Viable Alternative that Held Prospects to Gain Significant and Interpretable Results of Common Value
The Ability to Analyze Products, By-Products, Metabolites, and Attain Low Detection Limits Drove the Research Team to a Single Representative Molecule, Not a Product Mixture
Products from the 5 Major Producers Do Share Some Similarities But are for the Most Part Different
Protocols Developed by the TRP Research Team Will Have Broad Applicability for Use by TRP Members on Other Compounds and Products of Their Choice and Relevant to their Company
CBI has been redacted
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&
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Radiolabeled 8-2 Tetomer B Alcohol
17 Dec 2001
F(CF2)714CF2-c h 2c h 2-o h
Needed for Pltartuacoktiii < i- I nenonm ental fa te Studies
Status
Synthetic Route Demonstrated & Reproducible : can put ,4C "in" Necessary Documentation & Samples being finalized Partner identified to accomplish hot synthesis Timing to completion: March 2002
Telomer Research Program
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Synthetic Strategies for Radiolabeled Fluorotelomers
17 Dec 2001
C tF is^ ^ ^ O H
RF
C77rF15
December 2001
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7
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General Synthetic Strategy
17 Dec 2001
- practical synthesis not demonstrated; SHE issues
* Must use readily available sources of 14C
- e.g., C 0 2 (ex. BaCOj), NaCN, etc. - ample literature precedent for conversion o f C = 0 into CF2 - typical reagents: Et2NSF3 (DAST); (MeOCH2CH2)2NSF3 (DeoxoFluor)
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17 Dec 2001
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17 Dec 2001
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17 Dec 2001
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17 Dec 2001
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17 Dec 2001
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17 Dec 2001
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17 Dec 2001
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Radiolabel Path Forward
F(CF2)714CF2-c h 2c h 2-o h
17 Dec 2001
C hem ical Synthesis M ethods P a c k a g e out fo r Bid A nalytical M ethods C old S tandards 13C M aterial as Standard 1 4 C Study M aterial D elivery
2001 Dec
Jan
2002 Feb
M ar
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TRP Toxicology Studies
17 Dec 2001
Repeated-Dose Pilot Study - Rats
8-2 Alcohol
Objective : To determine test concentration for 90-Day toxicity study A) In vivo response B) Attain steady-state blood fluorine levels
Procedure : Dose Groups* of rats with 0, 5, 25 or 125 mg/kg/day of 8-2 Telomer Alcohol
A) Monitor clinical observations, weigh rats 2x/week B) Total blood fluorine analysis weekly
* 10 males, 5 females / group
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l
13
TRP Toxicology Studies
Repeated-Dose Pilot Study - Rats
8-2 Alcohol
Results - Clinical Observations
17 Dec 2001
125 mg/kg/day - Males: striped teeth (7/10), teeth clipped (4/10) - Females : striped teeth (4/5)
No Effects : 5 - 25 mg/kg/day
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TRP Toxicology Studies
Repeated-Dose Pilot Study - Rats
8-2 Alcohol
Results - Body Weight Gains
Dose Level (me/ke/dav)
Males
Females
0 297 80
5 288 119
25 275 115
125
238*
110
* p<0.05
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17 Dec 2001
Mean Body Weight for Males (Day 0 - 81 )
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TRP Toxicology Studies
Repeated-Dose Pilot Study - Rats
8-2 Alcohol
Results - Liver Weight / Ratios
2001
Dose Level
(m g/kg/dav) 0 5
25 125
Liver Weight (g) M _z
23.4 10.3 21.1 11.1 22.7 11.3 27.9 12.7
Liver/Body Weight
g /100g
MF
3.9 3.2
3.7 3.2
4.1 3.4
5.5*
3.6*
0.05Telomer Research Program * p <
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6
15
TRP Toxicology Studies
Repeated-Dose Pilot Study - Rats
8-2 Alcohol
Results - Kidney Weight / Ratios
Dose Level im e/ke/davi
0 5 25 125
Liver Weight (g)
M _E
4.5 2.2 4.3 2.4 4.1 2.4 4.4 2.7*
Kidney/Body Weight g/100g
MF
0.76 0.70 0.76 0.71 0.75 0.73 0.87 0.78*
Telomer Research Program
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17 Dec 2001
Total Blood Fluorine Analysis in Male Rats Dosed with Telomer 8-2 Alcohol
Telomer Research Program
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TSCA CBI
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1
17 Dec 2001
Total Blood Fluorine Analysis in Female Rats Dosed with Telomer 8-2 Alcohol
TSCA CBI
Repeated-Dose Pilot Study
17 Dec 2001
Analysis of Pooled Plasma Samples Obtained at Steady State (test day 84) (PFOA, Parent Compound, and total fluorine levels)
The level of parent detected did not exceed 0.074 ppm in either males
or females. The following plasma levels of PFOA were detected in males and females dosed with 0, 5, 25, and 125 mg/kg/day of 8-2 Telomer Alcohol
Dose (mg/kg/day)
Male PFOA (ppm)
Male PFOA converted to ppm F
Male total plasma
F (ppm)a
Female PFOA (ppm)
Female PFOA converted to ppm F
Female total
plasma
F (ppm)a
0
0.07
0.05
NM 0.0
0.0
NM
5
2.19
1.51
NM 0.08 0.05
NM
25
8.47*
5.83
8.11 0.54 0.37
5.88
125 65.60* 45.16
53.24 1.85*
1.27
23.2
"Determined using Wickbold Torch; *mean of two separate runs; NM-not measured
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TRP Toxicology Studies
Repeated-Dose Pilot Study - Rats
8-2 Alcohol
125 mg/kg/day 8-2 Telomer Alcohol
Produces clinical effects / body weight effects Blood Fluorine level reached plateau day 50<-->80 Degree o f response compatible with adequate survival
5 - 25 mg/kg/day Telomer Alcohol
N o clinical signs or weight effects Blood fluorine level reaches plateau day 40<-->60 N o signs of adverse response
90-Day Test Levels (suggested)
1 - 5 -2 5 - 125 mg/kg/day
Telomer Research Program
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17 Dec 2001
35
TRP Toxicology Studies
17 Dec 2001
Repeated-Dose Pilot Study Conclusions
Analysis limited to blood only - Significant male/female differences - Results confirm earlier studies results - Other metabolites are present & predominate in females - There is a significant amount of fluorinated organic material eliminated or elsewhere
Validates need to conduct pharmacokinetic studies as planned with radiolabeled study material
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17 Dec 2001
TRP Toxicology and Descriptive Biology Studies: Timeline*
Test Material 8-2 Alcohol
TRP W ork
= Work Contracted
2001
2002
2003
Contract
W ork Acute Oral Ranae-Findina Oral Toxicrtv
1Q 2Q 3Q 4Q 1Q 20 3Q 40 10 2Q 3Q 40 Lab Haskell Haskell
Subchronic 90 Day Gavage (Rat) w1 recoverv
Haskell
Multigeneration Reproduction LBatl_________________________
Developmental Toxicitv (Rat)
Bacterial Reverse Nhitation
Haskell Haskell Covance
Bone Marrow Erythrocyte Micronucleus Test (Rat)
Covance
Telomer Research Program
* This is a proposed timeline and subject to change.
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17 Dec 2001
TRP Pharmacokinetics Studies: Timeline
v = Work Contracted
Test Material 8-2 Alcohol
TRP Work
Work s ADME Mass Balance
In Vitro Metabolism (m icrosom es)
In Vitro Metabolism (hepatocytes)
2002
2003
Contract
1 0 2 0 3 0 4 0 102Q 3Q 4Q Lab
Haskell
Haskell
Haskell
Only Haskell Lab bid on entire package and will conduct the work Start of studies delayed 6+ months due to radio-label synthesis
Telomer Research Program
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3g
O
19
TRP Pharmacokinetics Study
Radiolabeled Fluorotelom er Alcohol
14C Label In perfnoro-cham (C #3)
F(CF2)714CF2-c h 2c h 2-o h
17 Dec 2001
Telomer Research Program
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TRP Pharmacokinetics Study
17 Dec 2001
Toxicokinetics of Telomer 8-2 Alcohol in the Rat
- The objectives o f this study are to determine the Absorption, Distribution, Metabolism and Excretion (ADME) o f Telomer 8-2 Alcohol in male and female rats following oral and dermal dosing.
Telomer Research Program
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TRP Pharmacokinetics Study
17 Dec 2001
Toxicokinetics of Telomer 8-2 Alcohol (TBA) in the Rat
Objective: Determine the absorption, distribution, metabolism and excretion o f Telomer 8-2
Alcohol in male and female rats following oral and dermal dosing
Method:
* Conduct pilot experiments
** Radiolabeled and cold TBA used as test material
** 2 male and 2 female rats
** Determine plasma kinetics following a single high oral dose o f TBA
** Determine excretion and metabolism following a single high oral dose o f radiolabeled TBA
* Conduct absorption experiments
** TBA test material ** 4 male and 4 female rats
** Single low and single high oral dose * * Single low and single high dermal exposure (8 hrs)
** Single low intravenous dose ** Follow plasma concentrations o f test material
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TRP Pharmacokinetics Study
''Dec 2001
Toxicokinetics of Telomer 8-2 Alcohol (TBA) in the Rat (Continued)
* Distribution experiments ** Radiolabeled TBA test material ** 4 male and 4 female rats ** Conduct oral and dermal exposures ** Evaluate tissue distribution of test material at Tmax and Tmax/2
* Excretion and metabolism experiments ** Radiolabeled TBA test material ** 4 male and 4 female rats ** Single low and high oral doses ** Single low and high dermal doses ** Daily dose of TBA with last dose being radiolabeled TBA ** Identify excretion rates and metabolic profiles
Results: * Metabolic profiles of TBA * Qualitative and quantitative description of biodistribution of TBA * Description of absorption characteristics of TBA * Sex linked differences in TBA handling in rats * Description of TBA metabolism at varying concentrations and between sexes
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17 D ec 2001
TRP Pharmacokinetics Study
In Vitro Microsomal Metabolism Study
- The objective of this study is to determine the rate of metabolism of a test compound in microsomes prepared from livers of a number of species (normally rat, rabbit, dog, monkey, and human) and to identify the metabolites produced in each species.
Metabolism of Telomer 8-2 Alcohol by Mammalian Hepatocytes
- The objective of this study is to determine the rate of metabolism of a test compound in cultured liver cells prepared from a number of species (normally rat, rabbit, dog, monkey, and human) and to identify the metabolites produced in each species.
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TRP Pharmacokinetics Study
17 Dec 2001
Metabolism of Telomer 8-2 Alcohol by Mammalian Microsomes
Objective: Determine the rate of test material metabolism and metabolic product identification in liver microsomes prepared from several mammalian species.
Method: * Microsomes prepared from rat, rabbit, dog, monkey and human * Samples analyzed by HPLC-MS * Determine linearity of reaction rate and protein concentration ** Reaction media contains an NADP regeneration system, cofactors, microsomes, test compound and phosphate buffer at pH 7.4, 37C ** Determines kinetics of test compound ** Reactions carried out at constant initial test material concentration and at a constant protein concentration ** Time course metabolism by microsomes evaluated
Results: * Rate of microsomal metabolism o f test compound by each species tested * Identity of metabolic products * Estimates of test material half-life in-vitro and intrinsic clearance
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TRP Pharmacokinetics Study
17 Dec 2001
Metabolism of Telomer 8-2 Alcohol by Mammalian Hepatocytes
O bjective: To evaluate the rate o f metabolism and identification o f metabolic products in cultured liver cells from several mammalian species.
Method :
Prepare hepatocytes from rat, mouse, rabbit, monkey, dog and human Negative (vehicle) and positive (ethoxycoumarin) controls included Hepatocytes and compound incubated at 37C for 2 hrs Samples analyzed by HPLC-MS for test compound and metabolites
R esu lts: Qualitative and quantitative description o f metabolic activity toward test material in several species Description o f metabolism in a metabolically "complete" system Identity o f test material metabolites in a whole cell system
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TRP Pharmacokinetics Study
17 Dec 2001
Developm ent of a Biologically-Based Kinetic Model:
Objective:
- Quantitatively Relate Exposure to Internal Dose Using a Biologically-based Kinetic Model
Critical Information Requirements: - Partitioning in Biological Tissue - Qualitative and Quantitative Aspects of Biotransformation - Mass Balance and Biodistribution - Uptake and Elimination Kinetics
Telomer Research Program
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TRP Toxicology Studies
17 Dec 2001
Developmental Toxicity - Rats 8-2 Alcohol
Status: Initiate 3Q 2002 Pregnant rats Dose days 6-19 of gestation Doses from 90-day study (project 1<--> 1 0 ,10<-->50, 50<-- >125 mg/kg) Maternal parameters
- clinical signs, body weights, liver weight Fetal parameters
- external examination, internal organ examination, liver weight, skeletal examination
Compare maternal/fetal response
Telomer Research Program
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TRP Toxicology Studies
17 Dec 2001
Acute Toxicity - Rats 8-2 Alcohol
Status: Completed
Rat - Male and Female - 5/sex/group - Single oral dose o f 2,000 mg/kg (0.5% aqueous methylcellulose) - Results No mortality No clinical signs including body weight Lethal dose >2,000 mg/kg
Telomer Research Program
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4g
TRP Toxicology Studies
90-Day Toxicity Study - Rats 8-2 Alcohol
17 Dec 2001
Additions to Protocol
1. Test levels (4 instead o f 3) 1, 5 ,2 5 , and 125 mg/kg 2. Extend recovery period - 90 days 3. Add measure o f peroxisome proliferation - P-oxidation 4. Add thyroid weights, plasma and urinary [F]
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TRP Toxicology Studies
17 Dec 2001
Genetic Toxicity 8-2 Alcohol
Status: Draft Reports
Salmonella/Escherichia coli Assay TA 98, TA 100, TA 1535, TA 1537 WP2uvrA With/without S9 activation To 5,000 pg/plate Negative (draft report to issue 12/01)
Telomer Research Program
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so
TRP Toxicology Studies
Genetic Toxicity 8-2 Alcohol
In Vivo Rat Micronucleus Study
0, 500, 1,000, 2,000 mg/kg single dose oral gavage
6 male rats/group (examined 5) - harvest at 24 and 48 hours
60 mg/kg cyclophosphamide positive control
Micronucleated cells/2000/animal
Dose (mg/kg!
24 hrs 48 hrs
0 0.04 0.07
CP-60
3.10 0.78
8-2 Alcohol - 500 0.04 0.09
-1000
0.15 0.09
-2000
0.10 0.09
* Conclude: No increase in micronucleated cells
(draft report available 12/5/01)
Telomer Research Program
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TRP Toxicology Studies
17 Dec 2001
Reproductive Toxicity - Rats Multigeneration Reproduction - 8-2 Alcohol
Status: Pending Outcome o f 90-Day Study/Developmental Toxicity
Rat - dosing levels/control - treat 70 days pre-mating - 2nd generation from F 1 offspring
Parameters - estrous cycling/sperm assessment
- fertility/reproductive function
- gestational/lactational performance
- pup growth/survival/structural integrity
- P I/F I parental pathology (focus on reproductive system)
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17 Dec 2001
TRP Environmental Fate & Effects Studies
Physical - Chemical Properties Environmental Fate Environmental Effects Bioconcentration
Telomer Research Program
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Physical - Chemical Properties n-C8F17CH2CH2OH
UV / Visible Absorption Spectrum Vapor Pressure Sorption Water Solubility Henry's Law Constant Log K ow (Octanol - Water Partition)
17 Dec 2001
Telomer Research Program
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UV-Visible Spectra : n-C8F17CH2CH2OH
17 Dec 2001
A b s orbance/N anom e te rs File #1 010681 .CSV TEL 66 -2A4.323G J- MEOH 1CM KAISER,M6,,
Paged Y-Zoom CURSOR Res=None
No absorbance in visible light range, 350-800nm Direct photolytic degradation not expected Indirect Photolysis [OH Radical] work underway
Telomer Research Program
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Vapor Pressure : n-C8F17CH2CH2OH
17 D ec 2001
0.022 Torr at 21 C
Telomer Research Program
Tem perature (C)
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28
Physical - Chemical Properties : Sorption n-C8F17CH2CH2OH
17 Dec 2001
rapid sorption from saturated aqueous solution - glass, silanized glass, plastic, PTFE, stainless steel
evidence o f time-dependent adsorption with decreasing ability to recover materialfrom surface(s)
specific recovery methods had to be developed and validated
- weeks for each sample to reach equilibrium with continuous analysis - 8 to 20 samples replicated to establish method and analysis confidence
makes water solubility measurement much more complicated and mass balances difficult to achieve
Telomer Research Program
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17 D e c 2001
Physical - Chemical Properties : Water Solubility n-C 8F 17C H 2C H 2OH
pH 3, 7, 9 ; T = 12, 25, 37, 60C see no differences in solubility versus pH material is adsorbed to the container, not in the water, when
excess material is no longerpresent
- sorbed to the container surfaces
CBI has been redacted
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5g
29
Physical - Chemical Properties : Water Solubility n-C8F17CH2CH2OH
17 Dec 2001
C 8F 17C H 2C H 2 0 H
APFO PFOS
Solubility ug / mL (ppm)
12C
25C
37C
60C
0.134 + 0.029 0.150 i 0.005 0.318 0.176
> 10 wt%
680
De-ionized water measurements
T doraer Research Program
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17 D ec 2001
Physical - Chemical Properties : Henry's Law Constant n-C8F17CH2CH2OH
Computed from Water Solubility and Vapor Pressure Non-linearity and Non-traditional behavior Surface Tension Driving Behavior? Measure utilizing Static Headspace Method
Telomer Research Program
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60
30
Physical - Chemical Properties : Conclusions n-C8F17CH2CH2OH
17 Dec 2001
Water Solubility varies with T but not pH and is in the 100's of ppb Highly sorptive onto many surfaces and may remain highly sorbed and
difficult to remove Preliminary VP data do not exhibit anomalies No visible light absorbance
These properties present significant m ethod developm ent and analysis challenges goin g forward and will require use o f radiolabeled material for more studies than expected
Teloraer Research Program
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Environmental Fate & Effects Work Plan
17 Dec 2001
n-C8F 17CH2CH2OH
r Environmental Fate : Abiotic
Hydrolysis
Adsorption / Desorption *
Physical Properties
Indirect Photolysis in Air
UV/Visible Spectrum Water Solubility Adsorption to Glass Air-Water Partition
Coefficient
<
Environm ental Fate : Biotic
Anaerobic Biodegradation* Aerobic Biodegradation*
(* Radiolabeled Material)
Telomer Research Program
Environmental Effects
Bioconcentration Factor
90 Day Early Life Stage Study -
Rainbow Trout
*21 Day Invertebrate Daphnia Study
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17 Dec 2001
TRP Environmental Fate & Effects Studies Timeline*
F = Fate Study ; E = Effects Study
P = Physical Property Study
Test Materials
Work
8-2 Alcohol
EJ Hydrolysis F Adsorption / Desorption ( 1 4 0
F Aolna / Seauestration ( 1 4 0
T R P W ork
F Aerobic Biodegradation (1 4 0
F Anaerobic Biodegradation ( 1 4 0
F Indirect Photolysis in Air
I2001
3Q14Q11
a
2002
2003
3Q 4Q !IQ 2Q 3Q 4Q
p illi
:
CNR5 B
r~
E Acute Fish : Fathead Minnow E Acute Invertebrate : Daphnia r n a q n a I Biological Concentration Factor (BCF) 1140 F 90 Day Rainbow Trout Chronic E 21 Day Daphnia Magna C h r o n ic E 7 2 Hr Algae Acute & Chronic
I F W ater Solubility. Vo. Sorption
p Henry's Law Constant
Li
HI I L : :l
zj i
[ _ __ 1
1
Telomer Research Program
* This is a proposed timeline and subject to change.
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TRP Path Forward Items
17 Dec 2001
Toxicology & Descriptive Biology Pharmacokinetics Radiolabel Environmental Fate Environmental Effects Mass Balance Effort
Telomer Research Program
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17 Dec 2001
Discussion and Path Forward
Telomer Research Program
Company Sanitized. Does not Contain TSCA CBI
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