Document OOdaN0B9v0nwnexNnrjqaq4e

Andrea V. Malinowski Corporate Counsel 12 May 2006 DuPont Legal Wilmington Office Buildings 1007 Market Street Wilmington, DE 19898 302-774-6443 Tel 302-774-4812 Fax andrea.v.malinowskiQusa.dupont.com E-mail VIA OVERNIGHT MAIL TSCA Document Processing Center EPA East - Room 6428 Attn: Section 8(e)/FYI U.S. Environmental Protection Agent 120 1 Constitution Avenue, NW Washington, D.C. 20004-3302 Phone: 202-564-8940 gmfA - K&G Re: Perfluorooctanoate Well Sampling Results Penns Grove Water Supply Company Carnevs Point Township, Salem Countv, New Jersey Dear Sir/Madam: Please find enclosed a copy of a letter, with its Attachments, submitted by DuPont to the New Jersey Department of Environmental Protection (NJDEP) reporting initial perfluorooctanoate (PFOA) analytical results for samples collected from the aboveidentified water supply company. As stated in the letter, the results reflect PFOA levels far below any established regulatory guidance for drinking water. While DuPont does not believe that the information provided with this submittal is indicative of substantial risk, DuPont is providing this information in light of the Agency's continued interest in perfluorinated substances. A copy of this submission is also provided on CD, for your convenience. Very truly yours, -Andrea V. Malinowski IIll1Ill1I1lIl1lll1lIll1ll1lll1lll1l1ll111I1ll1111111 8EHQ-06-16460 Enclosures: Letter dated May lo,2006 from DuPont to NJDEP with Attachments (44 pages) 1 CD (identified as May 12,2006 Submission - PFOA Well Sampling Results; Penns Grove) I~llll~~llll/~IblllIjill~l lll~lll~llllll~ll EA. du Pont diNemows and Company May lo,2006 Eileen Murphy, Director NJDEP Policy, Planning and Science Division of Science,Research& Technology P.O. Box 409 401East StateStreet, 1st Floor Trenton NJ 086250409 RF2 Penns Grove Water Supply Company Water Supply Well Sampling Results Carneys Point Township, Salem County, New Jersey Dear MS Murphy: This letter transmits the initial analytical results of samplescollected from Penns Grove Water Supply Company wells located in Carneys Point Township, Salem County, New Jersey. On February 27, 2006, DuPont sampled four wells that supply water to households in PennsGrove and Carneys Point. Two of the wells were located in the Layton Well Field, near the A. Clemente Inc. plant site.The other two were located in the Route 48 Well Field, near PennsGrove High School. Sampleswere collected from a shallow well (between 60 and 70 feet deep) and a deep well (between 350 and 400 feet deep) at each of the two well fields. A trip blank and field blank were also submitted with the samples.Sampleswere submitted to two separatelaboratories (Exygen ResearchInc. of State College, Pennsylvania and Axys Analytical Services Ltd. of British Columbia, Canada) for analysis of thirteen different perfluorinated compounds. Pleasenote that there is no standardanalytical method for this measurement approved by any governmental agency or testing organization. A subsequent aliquot of the sample submitted to Exygen Research Inc. was analyzed on April 20* for perfluorooctanoate (PFOA) only using the method validated according to US FDA criteria (Guidance for Industry). As discussedmore fully in Attachment A, analytical results for PFOA were variable between the laboratories and methods. In the two deep wells, PFOA was not found in the water at detectable concentrations by either laboratory. In the two shallower wells PFOA was reported at concentrations ranging from 37.8 to 123 parts per trillion (t&L) in the Route 48 well field and from 57 to 190 rig/L in the Layton well field. PFOA concentrations (average of laboratory duplicate analysis) based on the validated method were 98.6 and 190 ngIL in the shallow wells at the Route 48 and Layton well fields, respectively. _-- --~.-.- _.- Ms. E&en Murphy May lo,2006 Page 2 of2 Theanalyticaldata&portsarepresentedin At(achmentB. Thefi$l laboratorydatadeliverablesfor the thkteeuperktied compoundsareundergoingdatava&dationkeeewandwill besubmitted sepamtelyuponcompletionof thatreview.Theak@ical datapackagefar PFOA determinationby thevalidatedatdytical methodhasundergonereviewfor dataqualityparametersandwereconsidered iin@ oi April 24. Thiscjatapackagwe ill also be submittedseparately. TheresultsreflectPFOA levelsfTabrelow,anyestablishedn&la-tory guidkxx for drink&water. We believe,thereforet,hatthewaterwe testedfor PFOAis &fe for humanconsumption. Toputtheresults ihnumericalperspective:Apartpertrillionis athousandtimessmaktbanapart perbillionandamilliontimessmalIerthanapartpermillidn. A classactionlawsuitrecentlyf3edagainstDuPont&$ies that50partsp&rtr$Eonis anunacceptable levelof PFOA in drinkingwater. hi f&c6thatnumberis neitherapublic he&h standardnor a thresholdfor obtaimngcompensatiort~hroughlitigation. Despitethefact thatPFOAis not aregulatedchemical,we havedrama$callyreducedknissionsof pPOA Cornourfacilities.We ahcadybave.reducedem&ions 95percentfkomourU.S. man&cmkg G&litios since2000. In additia DuPonthasdevelopedteohnol&s which will substant@lyeliminatePFOAcontentin its productsandemissionsfkomits rnanufactukg facilities by2007. Thadi yoti for your attention-We wiil continue$3updateour ernploy~ our cornmkily andthe NJDEP on developmentsrelatedto PFOA andthelo& drinkingwak supply. + themeantime,if ycuhaveanyquestions.please'contacmte at (856) J4&3438 or the`letterheadaddrek, Sincerely, . CynuliaN. McManus Environme&lManager < Al%hnlents` c G. Zeigler,PennsGroveWaterSupplyCompany K. peli, N.lYiDE@ F. Faranca,NJDEP File : 3