Document KzGGbjEOKwRN91Q3LX4bvOjz0

4.3.3 China 4.3.3.1 Tangxun Lake, Wuhan, China T a n g x u n L a k e is a re la tiv e ly sh allo w b o d y o f w ater 36 km-' area w id e located in W u h a n , C h in a (p o p u la tio n ten m illion). T angxun L ake .water drains to the nearby Y an g tze river. F devaicd serum c o n ce n tra tio n s o f PFA Ss w ere reported in the surface w ater an d sed im en ts of T angxun L ake, its aquatic biota sam ples, and serum from c o m m e rc ia l fish erm en on th e lake iZ h o u et al. 2013, 2014). i-'Iuorochem icai m anu fa c tu rin g p la n ts w e re id e m iiie d in an in d u stria l park u p stream from the w a ste w a te r treatm en t p lan t situated on the upper reaches of the lake. As previously mentioned. W ang et al. (2010) describ ed an environm ental assessm ent at a m anufacturing facility near W uhan, (H ubei Province) China, The m ain products produced by ECF were perrtuoroalkyi sulfonic acid, per fluoroearhoxylie acids, and perlluom ieriiary am ines an d th eir d eriv ativ es. W h eth er this plant is part of this industrial park is uncertain. G.W. OI Fig* 4.17 Median scrum PFOS ami PFOA concentrt!' is(n I their family members. Tangxun Lake. Wuhan* China _ ishcfy jyeesand Fig. 4.17 Median scrum PFOS and PFOA concentrations (ng/mL) among fishery employees and their family members Tangxun Lake. Wuhan. China Upstream from this Tangxim Lake wastewater treatment plant were wraler samples that had the following concemiatinns menstiled: PFBA 47.8 pg/L, PFOA 2.6 pg/L; PFBS 16.2 pg/L; PFHxS 0.49 pg/L: and PFOS 2,14 pg/L. Effluent from the wastewater treatment plant had similar mean concentrations ol PFOS and I B B hut mean cnncentratioiis o f PFBA and PFBS declined to o pg/f and 6 pg/L, respec tively. Surface lake water concentrations of PFOA and PFOS ranged between ().! and 0.3 pg/L. For PFBA and PFBS, the average .surface lake water concentrations were 4.8 pg/L and 3.7 pg/L, respectively. For perspective, the US EPA Provisional Advisory for Water for PFOS and PFOA are 0.2 pg/L and 0.4 pg/L (See Chap. 17 for other advisory values from other states and countries.} Figure 4,17 presents the median PFAS serum concentrations for 37 Tangxon Lake fishermen, 7 family members, and 9 reference individuals. The median, PFOS concentrations were 10,400 ng/mL, 3,540 ng/mL, and 19 ng/mL, respectively. The linear/branch PFOS ratio was 3.6:1 which approximates the ratio to be expected with the ECF manufacture of POSF. The highest serum PFOS concentration m easured was 31,400 ng/mL in a commercial Mshe mi an. This concentration is threefold higher than the next highest value ever reported - a worker engaged in 4 PFAS Bio monitoring in Higher Exposed Populations 111111 t'Jilf, j '!>; 1,'i; ..!:> ,.!i A ............:...... ' ... .. :.. .' -i ... ' !. ; 1 / ' / ^^ H r ! : I; 1...'Ij !j 1 ' !. .... .............!:....( !, !-'j ' |'iI { ! ! ! ' . ' ` ' .1 .. ; .,. ;. , | i ! I 'T "I '_,j . !i i..j j ......... t -ll POSF production workers at the 3M Decatur plant (Olsen el al, 2003b). PFHxS concentrations were also considerably higher in the commercial fishermen (median 542 ng/mL} but lower for PFOA (41 ng/mL) (Fig. 4.16). Several species of Tangxun lake carp, shrimp and snail had PFOS concentrations ranging between 200 and 600 ng/g/ww (Zhou et al. 2013). Exposures to commercial fishermen on Thngxun Lake were considered likely due to their fish consumption (Zhou et al. 2014). Zhou et al. concluded the population identified around Tangxun Lake may offer an excel lent research opportunity to resolve controversial PFAS findings in the published epidemiologic studies. 4.4 Other Biomonitoring Data (Medical, Occupational, and Consumer) ^ . - r * T . L - 1- V ' ` .. ... *" !'-- '-rj, o j ' I - ' , * f .<``-` ll^ 'i'l ; 4.4.1 Phase I Clinical Trial of Cancer Patients 'U^ APFO has been shown to cause endoplasmic reticulum stress, inhibit PIM kinases, and exhibit anti-cancer activity in multiple xenograft models (MacPherson et al. 2010, 201 I). The tolerability, safety and pharmacokinetics of APFO were reported in an update of a phase I clinical trial in 41 human patients with advanced (solid) cancer (MacPherson et al. 2010). Sequential cohorts of three patients were enrolled il't;- in this dose escalation trial that followed a standard 3+3 design until dose-limiting toxicity was observed in two or more of six patients at a given dose. The protocol- mmdefined maximum tolerated dose was not reached. The recommended Phase 2 dose S|B: was 1,000 mg weekly based on the common cumulative drug-related toxicity o f fatigue, nausea, vomiting, and diarrhea at weekly 1,20(1 mg doses. Based on a poster1 rrcsentation <McPherso n e t al.2010.), highest plasm a level o fP F p A achieved in a . IlilPIPSilSflR p ORA-03 Office of Record Access OPRA RECORDS CHAIN OF CUSTODY FORM OPRA, LR, NR #: \ l ( A o O C rv , Requester: 'Pnv/,r\ n-e lY" v 0, u Case/File Name: M U K 0 h > ' -ir- Proiect/Case/Permit #: 1 \J 6Li f\ -5") Check One 1 1 File Review Date: 1 1Copy Request Folders Binders Boxes Size Q Originals DuPont Chemicals and Fluoroproducts Chambers Works Deepwater, NJ 08023 CERTIFIED MAIL - Return Receipt Requested March 9, 2010 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division o f Water Quality Bureau o f Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - November and December 2009 Sampling - Outfall DSN662 Dear Ms. Rosenwinkel, As per Part IV, Section G.5.a o f the NJPDES permit, we are submitting a summary o f PFOA analysis results for the weekly grab samples taken at JJSN662A during November and December 2009. A data summary is attached. I am also sending copies o f this report to the EPA at the addresses listed below. If you have any questions, please do not hesitate to call me at (856) 540-3105. Sincerely, Karen L. Pinder SHE Consultant - Environmental DuPont Chambers Works Attachment copy: Document Control Office US Environmental Protection Agency Office o f Pollution Prevention and Toxics EPA East Room 642$ 1200 Pennsylvania Avenue, NW \Yashington, DC 20460 Director. Chemical Control Division US Environmental Protection Agency Office o f Pollution Prevention and Toxics EPA East Room 4146 1201 Constitution Avenue, NW Washington, DC 20004 Summary of Analytical Results (662 - November 2009) A n a ly te 3F0A u nits ug/L T o ta l (T )/ D iss.(D ) T S a m p le ID Date Top (ft) B o tto m (ft) D uplicate # 6 6 2-G R A B 11/2/09 0 0 1 29.9 662-GRAB 11/9/09 0 0 1 15.9 662-G R A B 11/16/09 0 0 1 22.7 662-G R A B 11/23/09 0 0 1 27.7 662-G R A B 11/30/09 0 0 1 16.3 PFOA = Perfluorooctanoic Acid ug/L = microgram s per liter -- Samples were analyzed by Critical Path Services. Reported results represent a single ana ysis. -- Summary of Analytical Results (662 - December 2009) Vnalyte 'FOA .. u n its ug/L T o ta l (T)/ D iss. (D) 1 S am ple ID Date Top (ft) B ottom (ft) D uplicate # 662-GRAB 12/7/09 0 0 1 26.4 662-GRAB 12/14/09 0 0 1 51.1 662-GRAB 12/21/09 0 0 1 20.8 662-GRAE 12/28/09 0 0 1 15.1 PFOA = Perfluorooctanoic Acid ug/L = micrograms per liter & Samples were analyzed by Critical Path Services. Reported results represent a single analysis. DuPont Chemical Solutions Enterprise Chambers Works Deepwater, NJ 08023 CERTIFIED MAIL --Return Receipt Requested January 6, 2009 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division of Water Quality Bureau o f Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - November 2008 Sampling - Outfall DSN662 Dear Ms. Rosenwinkel, As per Part IV, Section G.5.a of the NJPDES permit, we are submitting a summary of PFOA analysis results for the weekly grab samples taken at DSN662A during November 2008. A data summary is attached. Also, I am sending copies o f this report to the EPA at the addresses below. If you have any questions, please do not hesitate to call me at (856) 540-3105. Sincerely, Karen L. Pinder SET Environmental Coordinator DuPont Chambers Works Attachment copy: Document Control Office US Environmental Protection Agency Office of Pollution Prevention and Toxics EPA East Room 6428 1200 Pennsylvania Avenue, NW Washington, DC 20460 Director, Chemical Control Division US Environmental Protection Agency Office of Pollution Prevention and Toxics EPA East Room 4146 1201 Constitution Avenue, NW Washington, DC 20004 > Summary of Analytical Results (662 Grab November 2008) -- Analyte PFOA units ug/L Total (T)/ D iss. (D) Y Sam ple ID Date Top (ft) Bottom (ft) Duplicate # 662-GRAB 11/3/08 0 0 1 * CD 662-GRAB 11/10/08 0 0 1 7.3*^ 662-GRAB 11/17/08 0 0 1 13+ 662-GRAB ---------- -11/24/08 0 0 1 8.0++ < PFOA = Perfluorooctanoic Acid -- ug/L = micrograms per liter * Result represents a single analysis. Sample was not run in duplicate. ** Result represents a single analysis. Sample was not run in duplicate. +Result represents a single analysis. Sample was not run in duplicate. ++ Result represents the average (rounded) of the sample (7.6 ug/L) and lab duplicate (8.3 ug/L) results. Samples were analyzed by MPI using a newly modified wastewater method. _________1______ APR O? 2009 DuPont Chemical Solutions Enterprise Chambers Works Deepwater, NJ 08023 C E R T IF IE D M A IL --R eturn R eceipt R equested M arch 31, 2009 M s. Susan Rosenwinkel Principal Environmental Engineer N JD EP D ivision o f W ater Quality Bureau o f Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, N J 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - December 2008 Sampling - Outfall DSN662 D ear Ms. Rosenwinkel, 0 As per Part IV, Section G.5.a o f the NJPDES permit, we are submitting a summary o f PFOA analysis results for the w eekly grab samples taken at DSN662A during December 2008. A data sum m ary is attached. Also, I am sending copies o f this report to the EPA at the addresses below. If you have any questions, please do not hesitate to call me at (856) 540-3105. Sincerely, i/ ioJ uM j Karen L. Pinder SET Environmental Coordinator DuPont Chambers W orks A ttachm ent copy: Document Control Office US Environmental Protection Agency Office of Pollution Prevention and Toxics EPA East Room 6428 1200 Pennsylvania Avenue, NW Washington, DC 20460 Director, Chemical Control Division US Environmental Protection Agency Office of Pollution Prevention and Toxics EPA East Room 4146 1201 Constitution Avenue, NW Washington, DC 20004 ---------1 j Total (T)/ \nalyte JrUA units tigL Dlss >> 1 Sample ID Date Top (ft) Bottom(ft) Duplicato # Od.' GRAB " t82GRAB 12/1/08 12/8/08 00 00 I1 6.5* tvlV* Summary of Analytical Results (662 Grab December 2008) 002 GRAB 12/15/08 0 0 1 8.0+ BTOGRAnrun?-grab 12/22/08 12/20/08 00 00 11 8.++ 2.9+++ < PFOA = Perfluorooctanoic Acid ug 1 nik'iooum s poi litoi * Result represents the average (rounded) of the sample (6.4 ug/L) and lab duplicate (6.5 ug/L) resulted Result represents the average (rounded) of the sample (5.9 ug/L) and lab duplicate (6.0 ug/L) results. Result represents a single analysis. Sample was not run in duplicate. |~ ++ Result represents a single analysis. Sanale was not run in duplicate. +++ Result represents the average (rounded) of the sample (2.9 ug/L) and lab duplicate (2.9 ug/L) results. Samples were analyzed by MPI using a newly modified wastewater method. (JM DuPont Chemicals and Fluoroproducts Chambers Works Deepwater, NJ 08023 CERTIFIED MAIL - Return Receipt Requested CMRRR# 7004 2890 0003 2089 1757 December 17, 2010 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division of Water Quality Bureau of Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - September / October 2010 Sampling - Outfall DSN662 Dear Ms. Rosenwinkel, As per Part IV, Section G.5.a o f the NJPDES permit, we are submitting a summary o f PFOA analysis results for the weekly grab samples taken at DSN662A during September and October 2010. A data summary is attached. I am also sending copies of this report to the EPA at the addresses listed below. If you have any questions, please do not hesitate to call me at (856) 540-3105. inri'rpl V SHE Consultant - Environmental DuPont Chambers Works Attachment RECEIVED BUREAU OF ' J A N - 5 2011 SURFACE WATER PERMITTING copy: Document Control Office US Environmental Protection Agency Office o f Pollution Prevention and Toxics EPA East Room 6428 1200 Pennsylvania Avenue, NW W ashington, DC 20460 Director, Chemical Control Division US Environmental Protection Agency Office o f Pollution Prevention and Toxics EPA East Room 4146 1201 Constitution Avenue, NW Washington, DC 20004 Summary of Analytical Results (662 - September 2010) A nalyte PFOA u n its ug/L T otal (T )/ D iss. (D) T S a m p le ID D a te Top (ft) B otto m (ft) D up licate # 662-GRAB 9/7/10 0 0 1 13.0 662-GRAB' 9/13/10 0 0 1 12.9 662-GRAB 9/20/10] 0 0 1 8.28 662-GRAB 9/27/10 0 0 1 12.4 PFOA = Perfluorooctanoic Acid ug/L = micrograms per Liter Samples were analyzed by Critical Path Services. Reporte results represent a single analysis, except for the sample collected on 9/7/10. The reported result for the sample collected on 9/7/10 represents the average (rounded) of analysis in duplicate. (662 - October 2010) A nalyte p f Oa u n its ug/L T o ta l {1)1 D iss. (D) T S a m p le ID Date Top (ft) B ottom (ft) D uplicate # 662-GRAB 10/4/10 0 0 1 15.6 662-GRAB 10/11/10 0 0 1 35.4 662-GRAB 10/18/10 0 0 1 16.4 662-GRAB 10/25/10 0 0 T 8.46 PFOA = Perfluorooctanoic Acid ug/L = micrograms per Liter Samples were analyzed by Critical Path Services. Reported results represent a single analysis, except for the sample collected on 10/4/10. The reported result for the sample collected on 10/4/10 represents the average (rounded) of ana ysis in duplicate. y' DuPont Chemicals and Fluoroproducts Chambers Works Deepwater, NJ 08023 CERTIFIED MAIL - Return Receipt Requested CMRRR# 7009 1410 0002 3359 4802 May 4, 2010 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division of Water Quality Bureau of Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - January and February 2010 Sampling - Outfall DSN662 Dear Ms. Rosenwinkel, As per Part IV, Section G.5.a of the NJPDES permit, we are submitting a summary of PFOA analysis results for the weekly grab samples taken at DSN662A during January and February 2010. A data summary is attached. Please note that the January 4, 2010 sample was not obtained due to a frozen sample line. I am also sending copies of this report to the EPA at the addresses listed below. If you have any questions, please do not hesitate to call me at (856) 540-3105. Sincerely, Joe Greenfield SHE Consultant - Environmental DuPont Chambers Works Attachment RECEIVED BUREAU OF MAY 1 2 2010 I SURFACE WATER PERMITTING r copy: Document Control Office US Environmental Protection Agency Office o f Pollution Prevention and Toxics EPA East Room 6428 1200 Pennsylvania Avenue, NW Washington, DC 20460 Director, Chemical Control Division US Environmental Protection Agency Office o f Pollution Prevention and Toxics EPA East Room 4146 1201 Constitution Avenue, NW Washington, DC 20004 Summary of Analytical Results ( 6 6 2 - January 2010) Summary of Analytical Results (662 - February 2010) Analyte PFOA u n its ug/L Total ( 1)1 D iss. (D) T _____ Sam ple ID Date Top (ft) Bottom (ft) Duplicate # 662-GRAB 2/1/10 0 0 1 7.83 662-GRAB 2/8/10 0 0 1 7.67 662-GRAB 2/15/10 0 0 1 10.6 662-GRAB 2/22/10 0 0 1 19.7 PFOA = Perfluorooctanoic Acid ug/L = micrograms per liter < Samples were analyzed by Critical Path Services. Reported results represent a single ana ysis. <3> IVC. PFOA Data Submittal - March 2U1U sam pling -----------Dear Ms. Rosenwinkel, As per Part IV, Section G.5.a o f the NJPDES perm it, w e are su b m ittin g a s u m m a ry o f P F O A analysis results for the weekly grab samples taken at t)S N 6 6 2 A d u rin g M a rc h 2 0 1 0 . A d a ta summary is attached. I am also sending copies o f this report to the EPA at the addresses liste d b e lo w . If you have any questions, please do not hesitate to call m e at (8 5 6 ) 5 4 0 -3 1 0 5 . Sincerely, Joe Greenfield SHE Consultant - Environmental copy: Document Control Office US Environmental Protection Agency Office of Pollution Prevention and Toxics EPA East Room 6428 1200 Pennsylvania Avenue, NW Washington, DC 20460 Director, Chemical Control Division US Environmental Protection Agency Office of Pollution Prevention and Toxics EPA East Room 4146 1201 Constitution Avenue, NW Washington, DC 20004 Summary of Analytical Results (662 - March 2010) A nalyte PFOA u nits ug/L Total (T)/ ' D iss. (D) T S a m p le ID Date Top (ft) B ottom (ft i D uplicate # -- -- ----------------------------- 662-GRAB 3/1/10 0 0 1 12.0 662-GRAB 3/8/10 0 0 1 11.4 66 2 -G R A B 3/15/10 0 0 1 12.4 PFOA = Perfluorooctanoic Acid ug/L = m icrogram s per liter 6 6 2-G R A B 3/22/10 0 1 19.6 6 62-G R A B 3/29/10 0 0 1 8.52 Sam ples were analyzed by Critical Path Services. Reported results represent a single analysis. DuPont Chemicals and Fluoroproducts Chambers Works Deepwater, NJ 08023 RECEIVED BUREAU OF CERTIFIED MAIL - Return Receipt Requested CMRRR# 7009 1410 0002 3359 4956 AUG 6 2010 July 22, 2010 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division of Water Quality Bureau of Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 SURFACE WATER PERMUTI! Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - April and May 2010 Sampling - Outfall DSN662 Dear Ms. Rosenwinkel, & As per Part IV, Section G.5.a of the NJPDES permit, we are submitting a summary of PFOA analysis results for the weekly grab samples taken at DSN662A during April and May 2010. A data summary is attached. I am also sending copies of this report to the EPA at the addresses listed below. If you have any questions, please do not hesitate to call me at (856) 540-3105. SHE Consultant - Environmental DuPont Chambers Works Attachment Summary of Analytical Results A nalyte PFOA u n its ug/L T otal (7)1 D iss. (D) T S a m p le ID D a te T op (ft) B ottom (ft D uplicate # Summary of Analytical Results (662-M ay 2010) 6 62-G R A B 1 5/3/10 0 0 1 6.43 662-GRAE" 5/10/10 0 0 1 11.8 662-G RAf3 5/17/1 3 () C 1 9.30 -- 662-RAB 5/24/10 0 1 6.54 -------------- -- -- PFOA = Perfluorooctanoic Acid ug/L = m icrogram s per liter i rI--------------------------------------------]--------------------------------------------_7-- represent the average (rounded) o f analysis in triplicate. -_ ........_______ I--------------------------------- I I J------ ---------------- --- ------------- --- -- DuPont Chemicals and Fluoroproducts Chambers Works Deepwater, NJ 08023 CERTIFIED MAIL - Return Receipt Requested CMRRR# 7004 2890 0003 2089 1535 September 3, 2010 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division of Water Quality Bureau of Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - June 2010 Sampling - Outfall DSN662 Dear Ms. Rosenwinkel, As per Part IV, Section G.5.a of the NJPDES permit, we are submitting a summary of PFOA analysis results for the weekly grab samples taken at DSN662A during June 2010. A data summary is attached. I am also sending copies of this report to the EPA at the addresses listed below. If you have any questions, please do not hesitate to call me at (856) 540-3105. Sincerely, Joe Greenfield SHE Consultant - Environmental DuPont Chambers Works Attachment copy: Document Control Office US Environmental Protection Agency Office of Pollution Prevention and Toxics EPA East Room 6428 1200 Pennsylvania Avenue, NW Washington, DC 20460 Director, Chemical Control Division US Environmental Protection Agency Office of Pollution Prevention and Toxics EPA East Room 4146 1201 Constitution Avenue, NW Washington, DC 20004 Summ ary of Analytical Results (662 - June 2010) PFOA = Perfluorooctanoic Acid ug/L = micrograms per liter Samples were analyzed by Critical Path Services. Reported results represent the average (rounded) of analysis in triplicate, except for the sample collected on 6/28/10. The reported result for the sample collected on 6/28/10 represents the average (rounded) of analysis in duplica DuPont Chemicals and Fluo Cham! Deepwater, CERTIFIED MAIL --Return Receipt Requested CMRRR# 7004 2890 0003 2089 1627 October 14, 2010 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division of Water Quality Bureau of Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - July / August 2010 Sampling - Outfall DSN662 Dear Ms. Rosenwinkel, As per Part IV, Section G.5.a o f the NJPDES permit, we are submitting a summary o f PF( analysis results for the weekly grab samples taken at DSN662A during July and August 21 data summary is attached. I am also sending copies of this report to the EPA at the addresses listed below. If you have any questions, please do not hesitate to call me at (856) 540-3105. Sincerely, SHE Consultant - Environmental DuPont Chambers Works Attachment copy: Document Control Office US Environmental Protection Agency Office of Pollution Prevention and Toxics EPA East Room 6428 1200 Pennsylvania Avenue, NW Washington, DC 20460 Director, Chemical Control Division US Environmental Protection Agency Office of Pollution Prevention and Toxics EPA East Room 4146 1201 Constitution Avenue, NW Washington, DC 20004 G |Analyte IPF" Total ( 1)1 units Piss. (D) ug/L Summary of Analytical Results (662 - August 2010) ample ID Date Top (ft) Bottom (ft) Duplicate # "662-GRAB 8/ 2/10 0 0 1 17.4 "662-GRB 8/9/10 0 0 14.8 "662-6 RAB 8/16/10 0 TU 662-GRAB 8/23/10 0 0 1 1 " 6 6 2 - 6 RAB 8/30/10 0 14.8 PFOA = Perfluorooctanoic Acid ug/L = micrograms per liter Sam ples were analyzed by Critical Path Services. Reported results represent a single analysis, except for the sample collected on 8/2/10. The reported result for the sample collected on 8/2/10 represents the average (rounded) of analysis in duplicate. APR O 8'2009 DuPont Chemical Solutions Enterprise Chambers Works Deepwater, NJ 08023 CERTIFIED MAIL --Return Receipt Requested April 1,2009 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division of Water Quality Bureau of Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - January 2009 Sampling - Outfall DSN662 Dear Ms. Rosenwinkel, As per Part IV, Section G.5.a of the NJPDES permit, we are submitting a summary of PFOA analysis results for the weekly grab samples taken at DSN662A during January 2009. A data summary is attached. Also, I am sending copies of this report to the EPA at the addresses below. If you have any questions, please do not hesitate to call me at (856) 540-3105. Sincerely, Karen L. Pinder SET Environmental Coordinator DuPont Chambers Works Attachment Summary of Analytical Results (662 Grab January 2009) Total (T)/ Analyte units Diss. (D) PFOA ug/L Sample ID Date Top (ft) Bottom (ft) Duplicate # 662-GRAB 1/5/09 0 1 2.9* 662-RAB 1/12/09 662-GKAB 79709 T TV* Z91 PFOA = Perfluorooctanoic Acid ug/L = micrograms per liter 662-RB 1/26/09 TT++ Result represents the average (rounded) of the sample (2.9 ug/L) and lab duplicate (2.8 ug/L) results. "Result represents a single analysis. Sample was not run in duplicate. Result represents a single analysis. Sample was not run in duplicate. ++Result represents the average (rounded) of the sample (3.1 ug/L) and lab duplicate (3.0 ug/L) results. Samples were analyzed by MPI using a newly modified wastewater method. DuPont Chemical Solutions Enterprise Chambers Works Deepwater, NJ 08023 CERTIFIED MAIL --Return Receipt Requested May 19, 2009 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division of Water Quality Bureau of Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - February 2009 Sampling - Outfall DSN662 Dear Ms. Rosenwinkel, As per Part IV, Section G.5.a of the NJPDES permit, we are submitting a summary of PFOA analysis results for the weekly grab samples taken at DSN662A during February 2009. A data summary is attached. Also, I am sending copies of this report to the EPA at the addresses below. If you have any questions, please do not hesitate to call me at (856) 540-3105. Sincerely, Karen L. Pinder SET Environmental Coordinator DuPont Chambers Works Attachment Summary of Analytical Results (662 Grab February 2009) talyte :OA 1 1 1T o ta l {1)1 u n its D iss. (D) ug/L T 1----------- 1 Sam ple IDI Date Top (ft) Bottom (ft)l D u p lic a te #1 662-GRAB -- 662-Gr a b -- 6 6 2 ^ R A B 2/2/09 2/9/09 2 /6 / 9 00 0 0 0 11 i 4.5* 3T 7 3.2+ PFOA = Perfluorooctanoic Acid ug/L = micrograms per liter 662-G R A & 2/23/09 0 01 4.9++ < I* Result represents a single analysis. Sample was not run in duplicate. ` Result represents a single analysis. Sample was not run in duplicate.______________________________ U-Resuit represents the average (rounded) of the sam ple and lab duplicate (3.3 ug/L) results |++Result represents the average (rounded) of the sam ple (4.9 ug/L) and lab duplicate (4.9 ug/L) result Samples were analyzed by MPI using a newly modified w astew ater m ethod. DuPont Chemical Solutions Enterprise Chambers Works Deepwater, NJ 08023 CERTIFIED MAIL - Return Receipt Requested July 23,2009 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division of Water Quality Bureau of Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - March 2009 Sampling - Outfall DSN662 Dear Ms. Rosenwinkel, As per Part IV, Section G.5.a of the NJPDES permit, we are submitting a summary of PFOA analysis results for the weekly grab samples taken at DSN662A during March 2009. A data summary is attached. Also, I am sending copies of this report to the EPA at the addresses below. If you have any questions, please do not hesitate to call me at (856) 540-3105. Sincerely, Karen L. Pinder SET Environmental Coordinator DuPont Chambers Works Attachment RECEIVED BUREAU Of UK t O SURFACE WATER PERMITTING copy: Document Control Office US Environmental Protection Agency Office of Pollution Prevention and Toxics EPA East Room 6428 1200 Pennsylvania Avenue, NW Washington, DC 20460 Director, Chemical Control Division US Environmental Protection Agency Office of Pollution Prevention and Toxics EPA East Room 4146 1201 Constitution Avenue, NW Washington, DC 20004 A nalyte P'A u n its ug/L Total (T)/ D iss. (D) T------------- ample T5te Topift) B o ttom (ft) D uplicate# Summary of Analytical Results (662 Grab March 2009) 3/3/091 0 0 1 3.9* 662-RAB -----662-RA7 3/9/09 3/16/09 00 00 V 3.7U 4.1 + 6 6 2 - 0 ^ ----- 662- B B 1 3/23/09 0 3/30/09 ____________ 0 0 11 4.1++ 7.3+++ PFOA = Perfluorooctanoic Acid ug/L = micrograms per liter Result represents a single analysis. Sample was not run in duplicate. Result represents a single analysis. Sample was not run in duplicate. +Result represents a single analysis. Sample was not run in duplicate. ++Result representsthe average (rounded) of the sample (4.1 ug/L) and lab duplicate (4.1 ug/L) result! +++Result represents the average (rounded) of the sample (7.7 ug/L) and lab duplicate (6.9 ug/L) resui Samples were analyzed by MPI using a newly modified wastewater method. DuPont Chemical Solutions Enterprise Chambers Works Deepwater, NJ 08023 CERTIFIED MAIL - Return Receipt Requested July 27, 2009 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division of Water Quality Bureau of Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - April 2009 Sampling - Outfall DSN662 Dear Ms. Rosenwinkel, As per Part IV, Section G.5.a of the NJPDES permit, we are submitting a summary of PFOA analysis results for the weekly grab samples taken at DSN662A during April 2009. A data summary is attached. ^ Also, I am sending copies of this report to the EPA at the addresses below. If you have any questions, please do not hesitate to call me at (856) 540-3105. Sincerely, SET Environmental Coordinator DuPont Chambers Works Attachment tm 4 t a SURFACE WATER PERMlTTMa Summary of Analytical Results (662 Grab April 2009) Analyte ^FOA units ug/L Total (T)/ Diss. (D) T Sample ID Date Top (ft) Bottom (ft) Duplicate # 6 6 2-G R A B 4 /6 /0 9 0 0 1 5.1* 6 6 2-G R A B 4/13/09 0 0 1 4!6Tr 66 2 -G R A B ----- 6 6 2 - R A S 4/20/09 4/27/09 00 00 11 7.8+ ----------- 5 T i^ P F O A = Perfluorooctanoic Acid ug/L = m icrograms per liter < * Result represents a single analysis. Sam ple was not run in duplicate. **R esult represents a single analysis. Sam ple was not run in duplicate. +Result represents a single analysis. S am ple was not run in duplicate. [ ++Result represents the average (rounded) of the sample (4.8 ug/L) and lab duplicate (5.3 ug/L) results. Sam ples were analyzed by MPI using a newly modified wastewater method. r Ll ________ L DuPont Chemical Solutions Enterprise Chambers Works Deepwater, NJ 08023 CERTIFIED MAIL --Return Receipt Requested September 18, 2009 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division of Water Quality Bureau of Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - May and June 2009 Sampling - Outfall DSN662 Dear Ms. Rosenwinkel, As per Part IV, Section G.5.a of the NJPDES permit, we are submitting a summary of PFOA analysis results for the weekly grab samples taken af DSN662A during May and June 2009. A data summary is attached. Also, I am sending copies of this report to the EPA at the addresses below. If you have any questions, please do not hesitate to call me at (856) 540-3105. Sincerely, SET Environmental Coordinator DuPont Chambers Works Attachment RECEIVED BUREAU OF OCT - 1 2009 SURFACE WATER PERMITTING A nalyte PFOA u n its ug/L T o ta l (T )/ D iss. (D) T S am ple ID Date Top (ft) B ottom (ft) D uplicate # Sum m ary of Analytical Results (662 Grab May 2009) 5/4/09 0 1 6.8* 662-GRAB I 5/11/09 0 0 1 6.2** 662-GRAB ' 5/18/09 0 1 7.8+ 662-GRAB ' ---------- ---- ( 5/25/09 0 0 1 9.4++ PFOA = Perfluorooctanoi c Acid ug/L = micrograms per liter -- * Result represents the average (rounded) of the sample (6.5 ug/L) and lab duplicate (7.1 ug/L) results. " Result represents a single analysis. Sample was not run in duplicate. +Result represents a single analysis. Sample was not run in duplicate. ++Resuit represents the average (rounded) of the sample (9.2 ug/L) and lab duplicate (9.6 ug/L) results. Samples were analyzed by MPI using a newly modified wastewater method. Summary of Analytical Results (662 Grab June 2009) Analyte PFOA units ug/L Total (T)/ Diss. (D) T Sample ID Date Top (ft) Bottom (ft) Duplicate # 662-GRAB 6/1/09 0 0 1 11* 662-GRAB 6/8/09 0 0 1 10" 662-GRAB 6/15/09 0 0 1 12+ 662-GRAB 6/22/09 0 0 1 11++ 662-GRAB r 6/29/09 0 0 1 9.6+++ PFOA = Perfluorooctanoic Acid ug/L = micrograms per liter * Result represents a singly analysis. Sample was not run in duplicate. ` ` Result represents a single analysis. Sample was not run in duplicate. +Result represents the average (rounded) of the sample (11 ug/L) and lab duplicate (12 ug ++Result represents a single analysis. Sample was not run in duplicate. +++Result represents the average (rounded) of the sample (9.3 ug/L) and lab duplicate (9. Samples were analyzed by MPI using a newly modified wastewater method. ______ l DuPont Chemical Solutions Enterprise Chambers Works Deepwater, NJ 08023 CERTIFIED MAIL - Return Receipt Requested October 12, 2009 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division of Water Quality Bureau of Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - July 2009 Sampling - Outfall DSN Dear Ms. Rosenwinkel, RECEIVED BUREAU OF OCT 2 3 2009 SURFACE WATER PERMITTING As per Part IV, Section G.5.a of the NJPDES permit, we are submitting a summary of PFOA analysis results for the weekly grab samples taken at DSN662A during July 2009. A data summary is attached. Also, I am sending copies of this report to the EPA at the addresses below. If you have any questions, please do not hesitate to call me at (856) 540-3105. Sincerely, Karen L. Pinder SHE Consultant - Environmental DuPont Chambers Works Attachment Summary of Analytical Results (662 Grab July 2009) A nalyte PFOA u n its u g /L T o ta l (T )/ D iss . (D) T S a m p le ID D ate T o p (ft) B o tto m (ft) D u p licate # 662-G R A B 7 /6 /0 9 0 0 1 8 .8 * 662-G RAB 7 /1 3 /0 9 0 0 1 7 .7 " 662-G R A B 7 /2 0 /0 9 0 0 1 7 .5 + 662-G R A B 7 /2 7 /0 9 0 0 1 7 .2 + + (--- P F O A = Perfluorooctanoic Acid ug/L = m icrogram s per liter ------------------ ---- * Result represents the average (rounded) of the sam ple (8.8 ug/L) and lab duplicate (8 .7 ug/L) results. ` ` R esult represents the average (rqunded) of the sam ple (7.9 ug/L) and lab duplicate (7 .5 ug/L) results. + R e s u lt re p re s e n ts a sin g le a n a ly s is . S a m p le w a s not run in d u p lic ate . + + R e s u lt re p re s e n ts a sin g le a n a ly s is . S a m p le w a s not run in d u p lic ate . S am ples w ere analyzed by M P I using a newly m odified w astew ater m ethod. mm DuPont Chemical Solutions Enterprise Chambers Works Deepwater, NJ 08023 CERTIFIED MAIL --Return Receipt Requested January 12, 2010 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division of Water Quality Bureau of Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - August 2009 Sampling - Outfall DSN662 Dear Ms. Rosenwinkel, As per Part IV, Section G.5.a of the NJPDES permit, we are submitting a summary of PFOA analysis results for the weekly grab samples taken at DSN662A during August 2009. A data summary is attached. I am also sending copies of this report to the EPA at the addresses listed below. If you have any questions, please do not hesitate to call me at (856) 540-3105. Sincerely, Karen L. Pinder SHE Consultant - Environmental DuPont Chambers Works Attachment I r Analyte PFOA units ug/L Total (T)/ Diss. (D) T S am p le ID Date Top (ft) Bottom (ft) Duplicate # 662-GRAB 8/3/09 0 0 1 9.60* 662-GRAB 8/10/09 0 0 1 8.70 662-GRAb 8/17/09 0 0 1 9.66 PFOA = Perfluorooctanoic Acid ug/L = micrograms per liter Samples were analyzed by Critical Path Serv * A split sample collected on 8/3/09 and anab S' DuPont Chemical Solutions Enterprise Chambers Works Deepwater, NJ 08023 CERTIFIED MAIL - Return Receipt Requested January 20, 2010 Ms. Susan Rosenwinkel Principal Environmental Engineer NJDEP Division of Water Quality Bureau of Point Source Permitting - Region 2 401 E. State Street P.O. Box 029 Trenton, NJ 08625-0029 Re: DuPont Chambers Works NJPDES Permit No. NJ0005100 PFOA Data Submittal - September and October 2009 Sampling - Outfall DSN662 Dear Ms. Rosenwinkel, As per Part IV, Section G.5.a of the NJPDES permit, we are submitting a summary of PFOA analysis results for the weekly grab samples taken at 6SN662A during September and October 2009. A data summary is attached. I am also sending copies of this report to the EPA at the addresses listed below. If you have any questions, please do not hesitate to call me at (856) 540-3105. Sincerely, Karen L. Pinder SHE Consultant - Environmental DuPont Chambers Works Attachment copy: Document Control Office US Environmental Protection Agency Office o f Pollution Prevention and Toxics EPA East Room 6428 1200 Pennsylvania Avenue, NW Washington, DC 20460 Director, Chemical Control Division US Environmental Protection Agency Office of Pollution Prevention and Toxics EPA East Room 4146 1201 Constitution Avenue, NW Washington, DC 20004 Analyte PFOA Total (1)1 units D is s .(D) ug/L T Sample ID Date Top (ft) Bottom (ft) Duplicate # Summary of Analytical Results (662 - October 2009) 662 10/2/09 0 0 1 12.1 662-GRAB 10/5/09 0 0 1 17.0 662-GRAB 10/12/09 0 0 1 8.45 PFOA = Perfluorooctanoic Acid ug/L = micrograms per liter 662-GRAB 10/19/09 0 0 1 10.5 662-GRAB 1/26/09 0 0 1 9.08 . ________________________________ X Samplee were analyzed by Critical Path Services. Reported results represent a single analysis. Reply Reply To Ali F o rw a rd Send To Me View images Print ^ Prev & Email From: To: Subject: Robert C Buck <Robert.C.Buck@USA.dupont.com> Gloria Post Re: Request for poster from PFAA Days 111 Message Headers Sent:6/22/2010 8:20:25 AM Gloria, I Thank you for your suggestion. We will most certainly include the phosphates in future presentations and they will be included in the full written paper we plan to publish. Many thanks and kind regards, Bob DuPont Surface Protection Solutions $ 4417 Lancaster Pike, BMP23-2236, Wilmington, DE 19803 USA Tel. +1 302 892 8935 | Fax +1 302 355 2093 | Mobile +1 610 322 1923 | Email robert.c.buck@usa.dupont.com jThis communication is for use by the intended recipient and contains ;information that nay be Privileged, confidential or copyrighted under [applicable law. if you are not the intended recipient, you are hereby iformally notified that any use, copying or distribution of this e-mail, in whole or in part, is strictly prohibited. Please notify the sender by return e-mail and delete this e-mail from your system. Unless explicitly and conspicuously designated as "F,-Contract Intended", this e-mail does not constitute a contract offer, a contract amendment, or an acceptance of a contract offer. This e-nail does not constitute a consent to the use of sender's contact information for direct marketing purposes or for ttransfers of data to third parties. [Franais Deutsch Italian Espanoi Portugues Japanese Chinese Korean http ://www.DuPont.com/corp/emailjiisclaimer.html O Email From : To: CC: Subject: Post, Gtoiia Buck, Robert Louis, Judy ; Upplncott, Lee Re: Requestfor poster from PFAA Oays III Message Bob, Headers *mvr linages Print Prev ttexi t f you bav coo^ t o add i n f o r a t i o n t o ycur p o s t e r , or i f you produce i t m another force t { .9 . PowerPoint) with 'inlim ted j p a c e , i t a i g h t b o u s e f u l t o add tt.e p h o sp h a te cotipoiitds, -osoPAPS end diPArS. t h a t have been found to r e le a s e teloxer alcohols upon degradation. jJcTohmisp o iusn des .s p e c i a l l y in-portant b e c a u s e t h e phosphates can be easily confused with the phophinates in discussions of these Jl An not 4 chorus t, so I hope that I have expressed the ab o w thoughts correctly. Thank you? Gloria ^ IGlorie S. Post, Ph.D., DABT Research Scientist Office of science Hew Jersey Cepartnent of invlronreatal Protection PO Box 420 Trenton, IJ 08625 T elephone: (609) 292-8497 F> ax : R o (b6e0r9t ) C2B9u2c-k7.3 4<0R o b e r t .C .B u c k O V S A .d u p o n t . co=> 4 / 2 0 / 2 0 1 0 1 : 4 0 FM > Hi G loria, Please find attached a copy of ny poster. It is a w o r k - i n - p r o g r e s s . Coraeata volcoced. < r; y--- ^ y ^.:. rfr .. . . . ' j_ Message Headers IHi Gloria, l X Please find attached a copy of my poster. It is a work-in-progress. Comments welcomed. (Kind regards, IBob Buck j DuPont Surface Protection Solutions 4417 Lancaster Pike, BMP23-2236, Wilmington, DE 19803 USA Tel. +1 302 892 8935 | Fax +1302 355 2093 | Mobile +1 610 322 1923 | Email robert.c.buck@usa.dupont.com T h is c c r tn .u n ic a tio n i s f o r u s e by th e in te n d e d recipient and contains i n f o r m a t i o n t h a t n ay b e P r i v i l e g e d , c o n f i d e n t i a l cr copyrighted under a p p l i c a b l e la w . I? you a r e n o t t h e in t e n d e d recipient, you are hereby f o r m a l l y n o t i f i e d t h a t any u s e, c o p y i n g or distribution of this e-mail, i n w h o l e o r i n p a r t , i s s t r i c t l y p r o h i b i t e d . Please notify the sender by r e t u r n e - a a i i an d d e l a t e t h i s e - m a i l from your system. Unless explicitly a n d c o n s p i c u o u s l y c e s i g n a t e d as "S-Ccntract Intended", this e-mail does n o t c o n s t i t u t e a c o n t r a c t o f f e r , a c o n t r a c t amendment, or an acceptance o f a c o n t r a c t o f f e r T h i s e - m a i l d o es n o t constitute a consent t o the u s e of s e n d e r ' s c o n t a c t i n f o r m a t i o n for direct marketing purposes or for transfers of cats rc th ird o a rtie s, _ < ________ -- - lj ( mall rrim i Toi ftubletf Pol/rt< Muck ..Hvi+QAX-iKt} (llOfll POft fa: faquM t for profit from f'fAA Day* fi/ far,} V, / ; p m Attachm ent* mny contain v lru ** that nr* harmful to your computar, Attnchma/it* may nor rfiap/ay eorrn/.tly * 010 Blunc! f'FAA finyn ill ^omtnrJattim f><i^irr?r .one paga.pdf (90Kb) Message H e a d e rs )HI G loria, i I Please find attached a copy of my poster. It is a work-in-progress. Comments welcomed. j Kind regards, !Bob Buck 0 DuPont Surface Protection Solutions 4417 Lancaster Pike, BMP23-2236, Wilmington, DE 19803 USA sTel. +1 302 892 8935 | Fax +1 302 355 2093 | Mobile +1 610 322 1923 | Email robert.c.buck@usa.dupont.com T h is cor<rranication is foe use by the intended recipient and contains information that nay be Privileged, confidential or copyrighted under applicable law. If you are not the intended recipient, you are hereby foma.xy notified that any use, copying or distribution of this e-ctail, t: , whole or in part, i3 strictly prohibited. Please notify the sender by return e-maiu. and delete this e-mail from your system. Unless explicitly ar.d cor.sp, ouo is / designated as "S-Contract Intended", this e-a .11 does >, cor,tract offer, a contract amendment, or an acceptance of - 'onrrac- offer this e-ioail does not constitute a consent to the ,,, of sender's contact ;*fornation for direct saricefcing purposes or for t of oats to third oefties. "'i ~___ j A V > F ro m ; To: Subject: Diane L Nabb Post, Gloria SOT poster request S ent;3/16/2010 1:5 6 :4 9 PM f---------------------------------- -- ----- ------- ----- ------- --_________ _______ ___________________________________________________ ____ , _____________ -- A tta c h m e n ts m ay contain v iru ses th a t are harm ful to your com puter. A ttachm ents may not display correctly. 1___ _____________ ______________________________________________________ __ ___________ ___________ | SOT Poster final IPK.ppt (5727Kb) Message Headers [Good Afternoon, i ]T h a n k you for your interest in my poster at SOT. Feel free to contact me jif you have any questions. Please find a copy of my poster attached to |this e-mail. Kind Regards, Diane L. Nabb [Senior Staff Scientist |DuPont Haskell Global Centers |for Health and Environmental Sciences j1090 Elkton Road !Newark, DE 19714 1.302-461-3309 Tel 302-451-3568 Fax ID i a n e .L .Nabb-iansa.dupont.com {See attached file: SOT Poster final IPK.pptl this communication is for use by the intended recipient and contains information that mav be Privileged, confidential or copyrighted under S l a w . if you are not the intended recipient, you are hereby f o r ^ U y notified that any use, copying or distribution of this e-mail, Ln r nr in cart " .7 _ is strictly prohibited. Please notify the sender b/ Ttsss sssz:this e-nail from your system. Unless explicitly > Kathryn K. McCord E. I. du Pont de Nemours and Company Vice President, Risk Management 1007 Market Street Wilmington. DE 10893 Telephone: 30X909.5.103 Facsimile: 102.999.3404 Kathryn-Kamins.mccordgusa.dupont.com 7'May 21.2009 Commissioner Mark Mauriello -New Jersey Department of Environmental Protection *401 East State Street lV7lh Floor. East Wing > . O. Box 402 Trenton. NJ 08625-0402 Dear Commissioner Mauriello: DuPont has received from the Delaware Riverkeeper and other signatories a copy of their April 28, 2009 letter to your office regarding PFOA. As you know, DuPont has already informed NJDEP that DuPont looks forward to engaging with NJDEP in the prescribed regulatory process that is open and transparent and considers the substantial body o f new scientific knowledge that has been developed in recent years on PFOA. It is the Company's understanding that New Jersey^ Drinking Water Quality Institute has initiated the process necessary to establish a drinking water standard enforceable statew ide for PFOA, and DuPont intends to participate in that process to comment on an appropriate MCL. Ms. Carluccio's letter, however, is based upon several inaccurate statements with potential for causing undue public alarm and calls for action that is unwarranted. Accordingly. DuPont is compelled to respond at this time. NJDEP has a preliminary guidance number for PFOA in drinking water at 0.04 ppb. This preliminary' guidance number vva3 calculated based solely upon the . toxicology data available and cited in the US EPA's draft risk assessment from 2005; it has neither been updated nor been evaluated through the prescribed regulatory' process. aThe recent paper published independently bv NJDEP scienlisl Gloria Post, the principal ^author of the initial review that led to the preliminary' value, similarly does not reflect . thorough consideration o f all the available scientific literature. Accepted risk assessment methodology should incorporate analysis of all relevant findings even if they run counter to the author's premise. incorporate an relevant scienunc inform ation pertinent to souna regulatory decision m aking. By way o f exam ple, a recent study o f time to pregnancy is referred to incorrectly as an infertility study. The actual study not only makes clear that every participant was able to get pregnant, but also sets forth liniitations<pn the study and cautions against draw ing conclusions without additional research. Also, while some early studies suggested there mav have been an effect on birth weight, more recently conducted studio have found no such associations. Sim ilarly incomplete is the discussion around whether PFOA is a human carcinogen. Although it is correct that US EPA's Science Advisory Board in 2006. by a split vote, recommended the regulatory classification o f "likely to be carcinogenic/' the SAB strongly urged the US EPA to consider peer-reviewed new information to strengthen the risk assessment. Recognizing the importance o f then-ongoing scientific studies to this regulatory classification decision, US EPA did not adopt the SAB's -------ttc p p a ha further stated that 'Tilt would be premature to draw PI!A but also that drinking water with PFOA levels under the PI iA does not require treatment. Additional!), subsequent to XJDEP's announcement of its preliminary guidance saJuc. several other regulatory agencies hav e thoroughly reviewed available science, and all have calculated lifetime exposure health-based numbers that are significantly higher than New Jersey's preliminary guidance. These regulatory levels are summarized as follows: United States MX - 0.3 ppb health risk limit NC - 2.0 ppb interim maximum allowable concentration (0.63 ppb Health Guidance Level for private wells) European Union Germany - 0.3 ppb (Life Time Exposure-LTF): 0.5 ppb (concern): 5.0 ppb (immediate action) l 'K - 0.3 ppb (LTD; 10 ppb (concern); 00 ppb (immediate action) According to the XJDEP. PFOA levels that exceed the preliminary guidance number have been measured in multiple locations in the State, not just in a water supplynear the DuPont Chambers Works site. The PFOA levels found in public drinking water supplies in New Jersey drinking water throughout the State are consistent with levels found in other areas of the country, including locations in which US EPA has neither sought remedial measures nor recommended any restriction on water consumption. N.1DEP has prev iously acknowledged that multipfe sources of PFOA in the environment exist, and DuPont is not the only company in New Jersey that has used or emitted PFOA. Use of New Jersey's preliminary guidance number to compel treaiment with focus solely on DuPont, as suggested by Ms. Carluecio's letter, is patently unwarranted. Although PFOA is biopersistent. as study of the compound continues, scientists are learning that the half-life in humans may be-shorter than the 4.3 year half-life derived from occupational studies. This development is quite relevant in the area of risk management, as a shorter half-life will impact the risk assessment calculation. This further illustrates why it is imperative that these important scientific developments are incorporated into regulatory evaluation and decision-making. The biopersistence of PFOA, as well as customer interest in product alternatives, is leading DuPont to develop new products and processes that reduce our environmental footprint and are more environmentally sustainable. !n support of the US EPA 2010 15 PFOA Stewardship Program. DuPont has reduced PFOA manufacturing emissions globally by 97 percent (year end 2007). DuPont has made considerable investments across ail sites to accomplish this objective. Reductions at Chambers Works from all operations have exceeded 95 percent. DuPont is well on its way to meeting or exceeding all commitments of the US FPA 2010 15 Stewardship Program. Additionally, in February 2007. the company committed to.no longer make, buy or use PFOA by 2015. or earlier 1'possible. DuPont has taken all of these actions notwithstanding our belief that the weight of scientific evidence does not establish a causal connection between PFOA and human disease. Again, DuPont looks forward to engaging with NJDEF in a regulatory process open to all interested parties that affords appropriate weight to ali of the science available as related to the sources o f PFOA in the environment as well as any potential to cause adverse human health effects. Please feel free to contact me if you wish to discuss this matter further. Sincerely. A'U/i.y Kathryn K. McCord 0 CC: Dr. Mark Robson. Rutgers University Irene Kropp. NJDEP Jeanne Herb. NJDEP Nancy Wittenberg. NJDEP Scon Brubaker. NJDEP m REFERRAL NO REFE`t>R* RED to ACTION CODE Mv 2090390 POLICY, PLANNING AND SCIENCE ; GOVERNOR NO FOR SIGNATURE OF ASSISTANT COMMISSIONER OR DESIGNEE. LETTER DATE 5/21/2009 DATE REFER i 5/26/2009 date" due 6/9/2009 DAYS LATE -14 INFORMATION ON CORRESPONDENCE &_ TITLE . . .. .. .. .. .. i SENDER S iGCORd ' FN KATHRYN ADDRESS 10Q7MatkeLStree.L.................................... - ....... ............ 1 CITY rWilminRton ........ .............. } STATE `DELAWARE *"! ZIP 110898- SUBJECT C: Site Remediation, Environmental Regulation and Land Use Management PFOANew Jersey's Drinking Water Ml K REVW-DATE ' NOTE j l i DATE COMPLETED 1 . REASON DESC s w *. viuuuiuu^mnuic acia ^JbUA) Dear Commissioner Martin, The purpose o f this letter is twofold: First, to bring to ypur attention a matter that lias been before the Department for a number o f years; and, second, to ask for your assistance in obtaining information relating to that issue. The matter involves the chemical perfluorooctanoic acid (PFOA), which is used by industry as a processing aid in the manufacture of a wide range o f high-performance products with benefits to society that include safety, emissions reductions and communications. PFOA has been used by or is present in operations o f various companies at sites around the State and is also present in some forms o f fire fighting foam used by fire companies and industrial and military fire brigades in New Jersey. Background - Drinking Water Limits PFOA is a stable and persistent chemical present at very low levels in the environment and in the blood o f the general population. Over the past five years, a number o f state and foreign governments have reviewed the latest science and set health-based protective drinking water limits for PFOA between 0.3 and 0.5 ppb (see attached table). In 2007, New Jersey DEP established a preliminary guidance value for PFOA of 0.04 parts per billion (ppb--equivalent to 40 parts per trillion), beginning the first phase of a process to establish a State drinking-water standard (Maximum Contaminant Level, or MCL) involving the Drinking Water Quality Institute (DWQI). The regulatory and scientific landscape for PFOA has In 2009, USEPA issued a Provisional Health Advisory (PHA) for PFO A of 0.4 ppb (400 parts per trillion) in response to PFOA found in wastewater treatment facility sludge that had been applied to farmland near Decatur, Alabama. USEPA not only stated that this PHA is for use nationally, but also that drinking water with levels below the PHA does not require treatment. USEPA is in the process of developing a science-based permanent Health Advisory, which is expected to be completed in the spring of 2011. Despite the preponderance of other regulatory bodies setting water limits an order of magnitude higher, in September 2010, the DWQI Health Effects Subcommittee issued a memorandum presenting health-based maximum contaminant levels for PFOA ranging from 0.01 ppb to 0.04 ppb. This range was proposed without the benefit of a completed risk assessment. DuPont believes that these levels are neither justified by nor reflective of the latest science as is demonstrated by the other recently established regulatory limits. In fact, in their draft risk assessment released just last month (October, 2010), the Canadian departments for health and the environment stated, "Based on the available information on the potential to cause harm to human health and the resulting margins of exposure, it is proposed that PFOA and its salts are not entering the environment in a quantity or concentration or under conditions that constitute or may constitute a danger in Canada to human life or health." The low levels of exposure in Canada's general population are similar to those in New Jersey. According to NIDEP, which has conducted occurrence studies, PFOA levels that exceed the NJDEP preliminary guidance value have been measured in public water systems at multiple locations in the State. These very low PFOA levels are consistent with levels found in other areas of the country. In fact, when USEPA tested public drinking water in the Alabama situation, it found levels below 0.04 ppb and stated, "Based on its current understanding, EPA believes these levels are not of concern and residents may r,ely upon public water systems." DuPont Actions in New Jersey and Planned Phase-out DuPont does not manufacture PFOA in New Jersey. We are one of a number of companies who use or may have PFOA present in their processes in some New Jersey sites either now or in the past. At the DuPont Chambers Works facility in Deepwater, PFOA occurs at trace levels as an unintended by-product in the manufacture of some fluorotelomer-based products and is used as a processing aid in small quantities for one other product line. DuPont, in coordination with NJDEP, voluntarily conducted a private drinking water well survey and sampling program for PFOA of properties in the vicinity of the Chambers Works plant. Of more than 100 drinking water wells tested, only one well measured slightly above 0.40 ppb, the USEPA PHA for PFOA. DuPont installed and provides for maintenance of a granular activated carbon water treatment system for this homeowner. The presence of PFOA in people's blood raises questions that are being addressed by industry through an extensive, multi-year effort under the USEPA 2010/15 PFOA Stewardship Program to reduce manufacturing emissions and product content of PFOA and related compounds. Due to these questions, as well as customer interest in product alternatives, DuPont committed to phase out the use and production of PFOA by 2015, or earlier if possible, and to develop new products and processes that are more environmentally sustainable. As part of this effort, PFOA emissions at Chambers Works have been reduced nearly 99 percent. You may be aware that DuPont has been involved in litigation in West Virginia, including a class action that was settled in 2005. The issues in West Virginia class action related to communities near the DuPont Washington Works facility, where PFOA was used extensively over many decades. PFOA levels in some of those communities were detected at substantially higher levels than in New Jersey. Even with those higher levels, there are no health effects known to be caused by exposure to PFOA for workers or the community. PFOA Health Studies Based on extensive health and toxicological studies, DuPont believes that PFOA exposure does not pose a health risk to the general public. Human studies have evaluated many health end points across a wide range of exposed populations. While some associations have been reported, no human health effects are known to be caused by PFOA. A considerable number of human health studies have been conducted over the years and are ongoing. Ongoing study includes work being conducted by an independent panel of scientists established in 2005 as a result of the settlement in West Virginia. The panel is charged with evaluating whether there is a probable link between PFOA and any human disease. The Science Panel is conducting a series of eleven studies, as well as performing its evaluation of the body of available scientific evidence. The Science Panel is expected to deliver its findings on whether or not a probable link exists between PFOA exposure and human disease starting next year. Information Request & On a number of occasions DuPont has urged the Department to follow an open, transparent and accountable process regarding the regulation of PFOA. Confidence in that process has been shaken by what appeared to be influence on PFOA-related regulatory matters by outside parties, including some of those involved in ongoing litigation in New Jersey against DuPont. As a result of these communications and the closed-door process undertaken by DWQI, DuPont was compelled to serve a series of Open Public Records Act (OPRA) and Right to Know Requests to the NJDEP. These requests have been the only means of obtaining public information that should have been readily available to all stakeholders in the regulatory process. These requests simply asked for communications, research and studies, memoranda, and data pertaining to, among other things, the basis on which NJDEP developed its preliminary guidance value for PFOA, the on-going NJDEP risk assessment for PFOA, and the information and science being considered by DWQI in the context of considering an MCL for PFOA. In their recent letter to you, the Chemistry Council ofNew Jersey expressed concern about the apparent lack of scientific integrity and transparency in the DWQI standard setting process. We share this concern and hope DWQI's procedures improve with the appointment of new leadership. An open approach by definition assumes that NJDEP and DWQI will consider all available scientific views and the submissions of all stakeholders in the process. While the DWQ1 approach has been opaque, at least the OPRA requests made by DuPont in September 2009, December 2009, and March 2010 were responded to by NJDEP. However, NJDEP has completely refused to respond to the most recent set of requests submitted in August 2010, even though (a) they are exactly the same as previously submitted requests, (b) NJDEP fully responded to all of those requests, and (c) the former and presently pending requests wpre/are specifically limited in time and scope. We have been impressed by Governor Christie's commitment to regulatory reform and to ensuring scientific integrity in the regulatory process. In addition, your leadership in transforming the Department and engaging stakeholders throughout the process, as well as utilizing the newly established Scientific Advisory Board to review and advise on science-based proposals, will serve to improve standard-setting and will ultimately result in a better method by which to protect the citizens of New Jersey. As with any transformation, it takes time for change to occur. The denial of DuPont's OPRA request runs counter to the Governor's commitment, as well as your emphasis on the importance of an open and transparent regulatory process and standard setting based on sound science. I urge you to review this matter, and I hope that the Department will reconsider its denial of our information request. I also encourage you and your new leadership team to review the PFOA issue in general and to particularly examine the process by which water standards are being developed by NJDEP and the DWQI for PFOA to ensure a fair, open process and an ultimate standard reasonablyjustified by the science. Thank you for your consideration of this important issue. I would be pleased to answer any questions you might have as a result of your review. Please feel free to contact me at the number above. Sincerely, Attachment cc: Irene Kropp, NJDEP John Plonski, NJDEP David W. Boothe T able 1. PF O A R egulatory D rinking W ater Guidance Levels* State or C o u n try United States D rin k in g W ater Guidance Level 0.4 ppb Minnesota 0.3 ppb West Virginia 0.4 ppb Germany 0.1 ppb 0.3 ppb 0.5 ppb United Kingdom 0.3 ppb 10 ppb 90 ppb Description < Provisional Health Advisory; U.S. Environmental Protection Agency Office of Water (2009) Health Risk Limit; Minnesota Department of Health (2009) Precautionary site-specific action level; US EPA SDWA Order on Consent (2009) Health-based precautionary value, Tolerable maximum value-life time exposure, Precautionary action value-infants; German Drinking Water Commission (2006) Sampling/monitoring trigger, Wholesomeness trigger for reduction measureslifetime exposure basis, Consult with health authorities-action to reduce exposure within 7 days; United Kingdom Drinking Water Inspectorate (2007) *Water levels were developed using science-based risk assessments to evaluate chronic exposure.