Document dQkXwb38RNdBwNY2w3RomOJxq

$9 rr ARRR6 -- [307 TAFT, STETTINIUS & HOLLISTER LLP 425 WALNUT STREET. SUITE 1800 CINCINNATI. OHIO 45202-2057 ROBERTA. BiLOTT sLiion@iamiaiw.dcom April 4,2003 eeTon cueR HveoemCe eshsatnreo-za:on FEDERAL EXPRESS Dr. Charles M. Auer Chemical Control Division OfficeofPrevention, Pesticides and Toxic Substances U.S. Environmental Protection Agency 1201 Constitution Avenue, N.W. Mail Code 7405M Washington, DC 20004 Jennifer Seed U.S. Environmental Protection Agency 410 M Street, S.W. Washington, DC 20460 Christopher Jones, Esq. Director O1h2i2oSoEuntvhirFornomnetnSttarleePtrotection Agency Columbus, OH 43215 Thomas V. Skinner Regional Administrator USS. Environmental Protection Agency 77 West Jackson Blvd. Chicago, IL. 60604 Oscar Hemandez Director, Risk Assessment Division Officeof Prevention, Pesticides and Toxic Substances USS. Environmental Protection Agency 1201 Constitution Avenue, N.W. Mail Code 7405M Washinglon, DC 20004 John Wheeler. Ph.D. ATSDR 1825 Century Center Blvd. Atlanta, GA 30345 Donald S. Welsh Regional Administrator UR.eSg.ioEnnviilronmental Protection 1650 Arch Street Philadelphia. PA 19103-2029 Agency = g =3 oXnR N32 3 E=< = 35 = Re: Human Health Threat Arising From ReleasesOf AFOA/APFO/C-8 In `West Virginia And Ohio Ladies and Gentlemen: "This letter serves as a supplement to our letter on the referenced topic dated February 3, 2003 (AR-226-1216). In that letter, we provided information to you in connection with our concen that there may be a threat to the health of those living in both Ohio and West Virginia ; LAER 000001 April 4,2003 Page2 `whose drinking water is contaminated with C-8 from DuPont's Washington Works Plant in Wood County, West Virginia. Since the mailing of that letter. information has been made available through public disclosure ofUSEPA's March 17, 2003 "Preliminary Risk Assessment OfThe Developmental Toxicity Associated With Perfluorooctanoate Acid And lis Salts" and in a report recently relcased by the Environmental Working Group on its Web site (ewg.org) indicating that USEPA may not possess certain information generated by E.I. duPont de Nemours and Company ("DuPont") with respect to the human health effectsof C-8. More specifically, it is not clear whether your agencies have reviewed certain information possessed by DuPont relating to the healthofworkers at its Washington Works Plant where potential C- exposure has occurred, not only in the specific manufacturing areas where C- is used, but throughout the Plant by virtue of historic C-8 contaminationofthe Plant's air and drinking water. Thus, because we understand that USEPA and other govemmental agencies are in the process of evaluating all available human health information in order to determine how bestto respond to this human health threat, we have enclosed the following documents for consideration and inclusion in USEPA's Administrative Record 226 for C-8 1. DuPont Internal Memo, "Ammonium Perfluorooctanoate (FC-143) C-8 Compounds" (3/25/81) (EID096503); 2. DuPont Intemal Memo, "C-8 Blood Sampling Results: Births and Pregnancies" (81) (EIDOT9375); 3. DuPont Intemal Memo, "C-8 Study" (8/5/96) (EID107066-71); 4 DuPont Epidemiology Surveillance Report, "Mortality And Cancer Incidence Surveillance At Washington Works" (6/30/96) (EID121880-94); 5. DuPont Toxic Substance Control Act (TSCA) Section 8(c) Form: Allegation of Significant Adverse Health/Environmental Effect (8/26/97) (YLPO00136-139); 6. DuPont Internal Memo, "Cancer Incidence Report 1959-2001 2 All-Cause Mortality Report 1957-2000, Washington Works. Parkersburg, West Virginia" (1/27/03) (EID645647-65). We also have enclosed a copy of an internal DuPont memorandum (EID613678-687) indicating that, according to DuPont, certain adverse effects were observed in the recent 2-generation C-8 rat Study at dose levels lower than certainofthe adverse effect levels referenced by the study's Asadefendant ina class action lawsuit pending against DuPont in the West Virginia State Court in which we serve as class counsel, DuPont has the right to mark documents produced in that case as falling under the terms ofa Stipulated Protective Order that allows parties to limit distributionof documents, if they qualify as documents for which "confidential business information" (CBI). protection would be available under. among other provisions, 40 C.F.R. Part 2, Subpart B. DuPont did not stamp anyof the attached copies from ts files as subject to the terms of the Stipulated Protective Order. tis not clear why this more current cancer incidence report apparently omits data from 1956-1958, which was included in DuPont's earlier, 1996 cancer incidence report. 000002 April 4, 2003 Page 3 rat study at dose levels lower than certainofthe adverse effect levels referenced by the study's authors and by USEPA in its March 17, 2003, preliminary risk assessment for PFOA, indicating that the risks to human health may, in fact, be significantly higher than indicated in USEPA's current draft risk assessment. Nery uly fous. / |- (ober! AY BT RAB/mdm Enclosures cc: R. Edison Hill, Esq. (w/o encls.) Larry A. Winter, Esq. (w/o encls.) Gerald J. Rapien, Esq. (w/o encls.) Mary Dominiak, (USEPA, OPPT) (for inclusion in AR-226) (w/ encls.) 000003