Document mpjbMRx9Ndbk1Z4zG4awD0m8B

/V P Ce: R. C. Buck -D uP ont ff Chemical Solutions Enterprise P. O. Box 80402, ESL 402-5231 Wilmington, DE 19880-0402 OPPT Document Control Office EPA East, Room 6428 1201 Constitution Avenue, NW Washington, D. C. 20460 Attn : Mary Dominiak March 31, 2003 Dear Mary: Please find enclosed information describing a specific DuPont Telomer Manufacturing Commitment submitted on behalf of the Telomer Research Program (TRP). This is part of the TRP Characterizing Potential Release o f PFOAfrom Telomer-Based Product Manufacture item described in the Voluntary Commitment, Item 3, on page 4 of the 14 March, 2003 Letter of Intent submitted to the Agency by the TRP of which DuPont is a member. The information provided herein is specific to DuPont who volunteered to provide applicable existing industrial hygiene air monitoring data and summary data on existing employee blood monitoring results from its telomer manufacturing operations. This submission does not include CBI information. As an additional cross-reference, this submission meets the commitment to provide this information to the Agency as described in Appendix 1, on page 9 of the Letter of Intent, which describes the specific timeline for submission o f information to the Agency. Please contact me if you have any questions regarding this submission. Best regards, 1 Stephen H. Korzeniowski Phone: 302.695.8672 Fax : 302.695.8680 Email : stephen.h.korzeniowski@usa.dupont.com ro -o ZX) " t J r n I CO "O O --tn t ~o n p i F3 XT XT CONTAIN HO CBI I 1)1/? Chemical Solutions Enterprise P. O. Box 80402, BMP23-1302 Wilmington, DE 19880-0023 March 31, 2003 Mr. Stephen L. Johnson Assistant Administrator for Prevention, Pesticides and Toxic Substances US Environmental Protection Agency (7101M) 1200 Pennsylvania Avenue NW Washington, DC 20460 Re: March 14, 2003 Letter of Intent (LOI) for the Telomer Research Program - Appendix 1 Submission Dear Mr. Johnson: Information in this letter is being submitted per Appendix 1 of the above-identified LOI. Specifically, in the last paragraph of Appendix 1, DuPont committed to provide EPA with: applicable existing industrial hygiene air monitoring data from its operations at Chambers Works, New Jersey, summary data on employee blood monitoring results from ammonium perfluorooctonoate* salt (APFO, CAS #3825-26-1) recycle operations at Chambers Works, New Jersey, and summary data on employee blood monitoring results from telomer manufacturing operations available from DuPont facilities. *PFOA will be used throughout this letter and its attachments to represent both the salt and acid forms of perfluorooctanoic acid DuPont Chemical Solutions Enterprise (DCSE) manufactures telomers at three sites: Washington Works in Parkersburg, WV, Chambers Works in Deepwater, NJ and at a site recently acquired from ATOFINA (the chemicals branch of TotalFinaElf) in Villers St. Paul, France. Chambers Works is a complex site with many manufacturing operations, including an operation to recycle PFOA for the Washington Works fluoropolymers facility. In addition, in Chambers Works Secure Environmental Treatment (SET) unit, a state-of-the-art wastewater treatment plant, a wastestream containing 200-400 ppm of PFOA from Washington Works fluoropolymers operations is processed. A summary of available industrial hygiene air monitoring data for the PFOA recycling operation and SET are provided in Attachment 1 of this letter. A summary of employee PFOA blood monitoring data for the PFOA recycle operation at Chambers Works is provided in Attachment 2 of this letter. Included in Attachment 3 is a summary of data obtained from ATOFINA re: blood monitoring of its employees (prior to acquisition by DuPont) at the Villers St. Paul site. There has been no monitoring for PFOA in the blood of telomer workers at Chambers Works. However, we do have blood monitoring data for Chambers Works workers from the late 1970's/early 1980's that showed no elevated levels of total fluorine. We have limited blood monitoring data (3 data points for 2002 campaign) for Washington Works telomer employees. Since the telomer manufacturing area is a small unit at this complex manufacturing site with other sources of PFOA, we have not included these data in this letter. These results will be included in the data submitted by the Washington Works site. We would like the opportunity to discuss the information provided in this letter with you, or members of your staff, in person at some point in the near future and will continue to provide applicable additional data as it becomes available. Sincerely, Barbara J. Dawson, CIH, CSP Senior Safety, Health and Environmental Consultant Attachment 1 Summary Industrial Hygiene Air Monitoring Data Chambers Works PFOA Recycle and SET Chambers Works PFOA Recycle In 1999, a process to recycle PFOA from Washington Works fluoropolymers unit started at DuPont's Chambers Works facility in Deepwater, NJ. Totes containing a 20% PFOA salt solution in water are received from Washington Works. The material is treated with acid and distilled to purify it and then converted back to the salt. It is shipped back to Washington Works for re-use. Since this process was new to Chambers Works, air monitoring was conducted to characterize the potential airborne exposure. Samples are collected using a sorbent tube containing Tenax. Samples are desorbed using methanolic hydrogen chloride to convert the PFOA to its methyl ester. The methyl ester is quantified using a gas chromatograph equipped with electron capture detector. Samples were collected during each batch of PFOA that was processed. A summary of the air monitoring data is shown below. DuPont has an internal Acceptable Exposure Limit (AEL) of 0.010 mg/m3 (0.57 ppb) for an 8- or 12hour time-weighted average exposure. Monitoring consisted of full-shift and short-term samples and area and personal samples. Task duration samples were collected to assess the airborne concentration during specific tasks and represented the only known exposure during the shift in which the sample was collected. A rule-of-thumb in industrial hygiene practice is the concept of an action level, usually defined as one-half of the exposure limit. The action level is used to trigger investigation of exposures before an exposure limit would be exceeded. <LOQ (0.034 ppb/ sample) <action level (<0.285 ppb) 270 samples consisting of: 63 full-shift personal samples 9 task duration personal samples 174 full-shift area samples 24 task duration area samples 253 10 >action level and < AEL (>0.285 and <0.57 ppb) 3 >AEL (>0.57 ppb) 4 These results show that only 1.5% (4/270) of the samples exceeded the exposure limit. All of the exceedances were short term task duration samples and, when extrapolated to an 8-hour time-weighted average, show results less than the exposure limit. In addition, workers involved in these tasks wore full personal protective equipment including air-supplied respirators. 3 Attachment 1 Summary Industrial Hygiene Air Monitoring Data Chambers Works PFOA Recycle and SET (continued) Chambers Works Secure Environmental Treatment The SET unit at Chambers Works includes a state-of-the-art wastewater treatment plant. The wastestream from Washington Works is a very small fraction of the water treated at the plant. Personal samples were collected during the connect/disconnect of the Washington Works railcars containing a wastestream with 200-400 ppm PFOA. All of the results were below the limit of quantitation of 0.034 ppb per sample. Area samples were collected throughout the SET operations and these results were all also less than the limit of quantitation. The results are shown in the following table. 47 samples consisting of: 12 short-term task duration personal samples 35 full-shift area samples <Limit of Quantitation (0.034 ppb/sample) 47 <action level (<0.285 ppb) 0 >action level and < AEL (>0.285 and <0.57 ppb) 0 >AEL (>0.57 ppb) 0 Attachment 2 Summary Blood Monitoring Data Chambers Works Recycle Operations Chambers? Works PFOA Recycle Prior to start-up of the PFOA Recycle process, baseline blood samples were collected on workers who would be assigned to the recycle process and its support operations so that future sampling could be compared to the baseline levels. Blood monitoring is conducted as an industrial hygiene tool to evaluate the effectiveness of the controls. Baseline samples of 42 workers were collected in 1999. A contract laboratory analyzed samples as whole blood for PFOA using gas chromatography with electron capture detector. This laboratory had been analyzing blood samples for Washington Works for several years. Workers who volunteered for testing included operators, mechanics and laboratory personnel involved with the PFOA recycling process. A second round of sampling was conducted in 2000 that included 30 people from the original 1999 group and 34 newly assigned workers. DuPont analytical chemists found that in both the 1999 and 2000 blood monitoring campaigns, the lowest calibration standard used by the lab was 100 ppb. PFOA was detected in many of the Chambers Works samples, but it could not be reliably quantified at concentrations less than 100 ppb. All of the samples in both the 1999 and 2000 blood monitoring campaigns showed results <100 ppb. This experience led DuPont to work with a different contract analytical laboratory on another method that would be more sensitive and provide more scientifically accurate and reliable data at the low levels in which we were interested. A third campaign of blood sampling was conducted in 2002 utilizing a newly developed LC/MS/MS method for PFOA in blood serum with a limit of quantitation (LOQ) of 50 ppb. The results are shown in the table below. Means and standard deviations were calculated using 25 ppb (1/2 of the LOQ) for those samples reported as less than the LOQ. These results suggest that workers may be exposed to PFOA in the workplace at low levels. Operators appear to have the greatest potential for exposure and laboratory workers appear to have the lowest potential for exposure. We are evaluating the adequacy of our industrial hygiene controls and investigating our work practices to ensure that the appropriate PPE is being worn and worn correctly. Number of Samples Operators (n= 17) Mechanics (n=18) Lab Technicians (n=21) Supervision (n=6) # of Sam p les < LOQ (50 ppb) 0 2 15 3 Average Concentration (ppb) (m in -m ed -m ax) 373 + 461 (53-175-1650) 168 156 (<LOQ-91-658) 35 17 (<LOQ-<LOQ-89) 92 113 (<LOQ-58-313) f Attachment 3 Summary Blood Monitoring Data Telomers Operations Villers St. Paul Telomer Manufacturing The telomer production area at the Villers St. Paul, France site is a small unit in a large industrial park. Telomers have been manufactured at this site since 1996, initially by ATOFINA and, since September 2002, by DuPont. DuPont obtained preliminary information from ATOFINA about blood monitoring of ATOFINA's employees. This monitoring was conducted before DuPont purchased the business and it is unclear what workers were included in the monitoring and what criteria were used for the exposed/not exposed classifications. It is known that the samples were analyzed by a German laboratory, but we are unsure of the analytical technique although it was probably by GC/MS. Preliminary discussions with the laboratory suggest that the LOQ is 10 ppb. We are currently trying to find additional information about these results. PFOA has not been used on this site. Exposed (n= 28) Not Exposed (n=8) Average Concentration (ppb) (min-med-max) 25 15 (5-26-52) 5