Document Z4G8k6bV8XEwyVm5X3Ya5xRxY

Biennial Report for the Manufacture of APFO Calendar Years of 2002 and 2003 DuPont Company - Fayetteville Work Page 1 of 4 /87& Biennial Report for the Manufacture of APFO Calendar Years of 2002 and 2003 DuPont Company - Fayetteville Works Note: The information contained in this document is submitted voluntarily and may be subject tofuture revision and/or modification. CONFIDENTIAL BUSINESS INFORMATION IS REDACTED This report is submitted pursuant to commitments made by DuPont in a March 14, 2003, Letter of Intent (LOI) to Stephen L. Johnson, Assistant Administrator, USEPA, entitled "Voluntary Actions to Evaluate and Control Emissions of Ammonium Perfluorooctanoate (APFO)". Pursuant to Addendum III of this LOI, provision 5, a facility manufacturing APFO is required to, beginning in the year after production commences, and continuing for five consecutive years following, for the prior calendar year, report to EPA biennially the following information on a calendar year basis: 1. Annual production volume of APFO; 2. Emissions per facility (air, water, waste); 3. Summary report of groundwater monitoring results; 4. Summary report of surface water monitoring results; 5. Workplace industrial hygiene monitoring; and 6. Summary data on employee blood monitoring results. This report provides the above information for calendar years 2002 and 2003. Note that while APFO is the substance produced at the facility, the substance measured by analytical techniques is the perfluorooctanoate anion (PFO ), which is reported herein as perfluorooctanoic acid (PFOA). General Facility Information Company Name: Site Location: E. I. du Pont de Nemours and Company Site where APFO is manufactured: DuPont Company - Fayetteville Works 22828 NC Highway 87 W Fayetteville, NC 28306-7332 Confidential Business Information Redacted Company Sanitized Biennial Report for the Manufacture of APFO Calendar Years of 2002 and 2003 DuPont Company - Fayetteville Works Page 2 of 4 1. Annual production volume of APFO The DuPont Company - Fayetteville Works' APFO Manufacturing Facility commenced production in late 2002. The following table shows the total production volume of APFO for calendar years 2002 and 2003. Calendar Year APFO Production 2002 [] 2003 ______ u______ 2. Emissions per facility (air, water, waste); The estimated quantity of air emissions to the atmosphere from the APFO manufacturing facility at Fayetteville was determined using engineering calculations. In addition, stack testing performed in 2003 showed PFOA air emissions to be less than the analytical detection limit. Annually a sample of the site's surface water discharge to the Cape Fear River is analyzed for PFOA; however that monitoring shows the PFOA to be less than the quantification limit of the analytical method. The waste emissions are the quantities of PFOA, on a dry basis, that are estimated to have been present in the various solid waste streams transferred from the Fayetteville Works site. The following table gives the estimated emissions of PFOA to specific media from the Fayetteville Works during the subject years: Emission Media Air Water Waste 2002 17 lb. Note 1 35 lb. 2003 22 lb. NQ 3,236 lb. Note 1: Due to the late start-up of the APFO Manufacturing Facility and the short duration of the 2002 production run, no surface water monitoring occurred in 2002. NQ = less than the practical analytical quantification limit of 0.05 pg/L 3. Summary report of groundwater monitoring results In 2002, the DuPont Company - Fayetteville Works performed air dispersion modeling to determine the most probable locations for the atmospheric deposition of PFOA from the new manufacturing facility. New monitoring wells were installed in the surficial aquifer at Confidential Business Information Redacted Biennial Report for the Manufacture of APFO Calendar Years of 2002 and 2003 DuPont Company - Fayetteville Works Page 3 of 4 the two locations predicted by the modeling. In 2003, the Fayetteville Works site began annual monitoring of the groundwater for PFOA. The monitoring involved the two newly installed wells described above, and included two existing monitoring wells. Groundwater monitoring conducted in January and March 2003 showed no quantifiable levels of PFOA in the two new wells and the existing well at the Old Biosludge Lagoon (SMU-01, SWM-02, and MW-1S respectively). These monitoring events did indicate levels of PFOA above the quantification limit at the existing well located upgradient of the Nation Common Sump. Following discussions with the North Carolina Division of Waste Management, the 2004 groundwater monitoring was expanded to include three existing wells downgradient of the Nation Common Sump area. The 2004 monitoring results were virtually identical to those in 2003, and the three above-mentioned downgradient wells showed PFOA concentrations of 0.303 pg/L, 1.530 pg/L, and 0.123 pg/L respectively. It is believed that the detected PFOA is a result of a historical release originating from the Nafion manufacturing area's common process wastewater sump. That source has been eliminated from the site. The following table shows the groundwater monitoring analytical results for 2003 and 2004: Confidential Business Information Redacted Biennial Report for the Manufacture of APFO Calendar Years of 2002 and 2003 DuPont Company - Fayetteville Works Page 4 of 4 Sample Name (Monitoring Well Description) SMU-01 (New well on River Pump Road; East of APFO Facility) SMU-02 (New well at Construction Gate entrance; Southwest of APFO Facility) MW-IS (Existing well at Old Biosludge Lagoon SWMU by Central WWTP; South of APFO Facility) NAF-01 (Existing well upgradient of Nation Common Sump; Southeast of APFO Facility) NAF-02 (Existing well downgradient of Nafion Common Sump; Southeast of APFO Facility) NAF-03 (Existing well downgradient of Nafion Common Sump; Southeast of APFO Facility) NAF-04 (Existing well downgradient of Nafion Common Sump; Southeast of APFO Facility) Monitoring Date 01/27/03 03/27/03 02/04/04 01/27/03 03/27/03 02/04/04 01/28/03 01/28/03 03/27/03 02/04/04 01/27/03 03/27/03 03/27/03 02/04/04 02/04/04 02/04/04 02/04/04 PFOA (hg/L) <0.01 <0.01 <0.01 <0.01 <0.01 <0.01 <0.05 <0.05 <0.05 <0.05 0.065 0.068 0.063 0.062 0.303 1.530 0.123 4. Summary report of surface water monitoring results As reported in Item 1 above, the DuPont Company - Fayetteville Works annually monitors for PFOA in the site's surface water discharge to the Cape Fear River. The monitoring conducted in both 2003 and 2004 shows the PFOA to be less than the quantification limit of the analytical method, or less than 0.05 pg/L. No surface water monitoring occurred in 2002 due to the late start-up of the APFO Manufacturing Facility and the short duration of the 2002 production run. 5. Workplace industrial hygiene monitoring The DuPont Company - Fayetteville Works began workplace monitoring for PFOA with the start up of the APFO Manufacturing Facility in 2002. The workplace monitoring in 2002 and 2003 consisted of stationary area monitors that sampled the building air space for twelve (12) continuous hours. These sampled locations are limited access restricted areas in which Confidential Business Information Redacted Biennial Report for the Manufacture of APFO Calendar Years of 2002 and 2003 DuPont Company - Fayetteville Works Page 5 of 4 personnel wear both respiratory and dermal personnel protection. The analytical results reported in the following table are the 12-hour time weighted average (TWA) PFOA concentration values. Year 2002 2003 Sample Type Area 12-hr TWA Number of Samples 4 105 Minimum Cone. (mg/m3) 0.008 0.000 Maximum Cone. (mg/m3) 0.024 0.292 Average Cone. (mg/m3) 0.017 0.010 mg/m3= milligrams per cubic meter 6. Summary data on employee blood monitoring results At the DuPont Company - Fayetteville Works, blood serum levels of PFOA have been measured since 2002. A summary of results of employees with identified APFO exposure potential in 2002 and 2003 is presented in the table below. The entire data set of blood concentrations is available upon request. Year 2002 2003 Number of Samples 17 44 Minimum Concentration (ppm) 0.004 0.008 Maximum Concentration (ppm) 0.020 2.280 Average Concentration (ppm) 0.011 0.217 ppm = parts per million Confidential Business Information Redacted