Document xzG4LwD4OnaQMzeyvqm2ZMx5E

ff 12 M ay 2006 C O RECEIVED OPPI CRIC mm\% & Andrea V. Malinowski Corporate Counsel DuPont Legal Wilmington Office Buildings 1007 Market Street Wilmington, DE 19898 302-774-6443 Tel 302-774-4812 Fax andrea.v.malinowski@usa.dupont.com E-mail VIA OVERNIGHT MAIL gena. _ oro6 \6U-<SO TSCA Document Processing Center EPA East - Room 6428 Attn: Section 8(e)/FYI U.S. Environmental Protection A gency 1201 C onstitution Avenue, N W CONTAIN W ashington, D.C. 20004-3302 Phone: 202-564-8940 Re: Perfluorooctanoate W ell Sampling Results Penns Grove W ater Supply Company Carneys Point Township. Salem County. New Jersey CV11 fO m Dear Sir/Madam: Please find enclosed a copy o f a letter, with its Attachments, submitted by DuPont to the New Jersey Department o f 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 inform ation provided w ith this submittal is indicative o f substantial risk, D uPont is providing this inform ation in light o f the A gency's continued interest in perfluorinated substances. A copy o f this submission is also provided on CD, for your convenience. Very truly yours, Andrea V. Malinowski 60 Enclosures'. Letter dated May 10, 2006 from DuPont to NJDEP with Attachments (44 pages) 1 CD (identified as May 12, 2006 Submission - PFOA Well Sampling Results; Penns Grove) 88060000232 88 E.l. du Pont de Nemours and Company I $1 3 8 Chambers W orte Deepwater, NJ 08023 May 10,2006 Eileen Murphy, Director NJDEP Policy, Planning and Science Division of Science, Research & Technology P.O. Box 409 401 East State Street, 1st Floor Trenton NJ 08625-0409 > i)ir O 7 ~o'c~i cr> -- t r n J* CfTl O c*n XT RE: 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 o f samples collected 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 Penns Grove and Carneys Point. Two o f 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 Penns Grove High School. Samples were collected from a shallow well (between 60 and 70 feet deep) and a deep well (between 350 and 400 feet deep) at each o f the two well fields. A trip blank and field blank were also submitted with the samples. Samples were submitted to two separate laboratories (Exygen Research Inc. o f State College, Pennsylvania and Axys Analytical Services Ltd. o f British Columbia, Canada) for analysis of thirteen different perfluorinated compounds. Please note that there is no standard analytical 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 20th for perfluorooctanoate (PFOA) only using the method validated according to US FDA criteria (Guidance for Industry). As discussed more frilly 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 (ng/L) in the Route 48 well field and from 57 to 190 ng/L in the Layton well field. PFOA concentrations (average o f laboratory duplicate analysis) based on the validated method were 98.6 and 190 ng/L in the shallow wells at the Route 48 and Layton well fields, respectively. Ms. Eileen Murphy May 10,2006 Page2of2 The analytical data reports are presented in Attachment B. The full laboratory data deliverables for the thirteen perfluarinated compounds are undergoing data validation review and will be submitted separately upon completion o fthat review. The analytical data package for PFOA determination by the validated analytical method has undergone review for data quality parameters and were considered final on April 24. This data package will also be submitted separately. The results reflect PFOA levels far below any established regulatory guidance for drinking water. We believe, therefore, that the water we tested for PFOA is safe for human consumption. To put the results in numerical perspective: A part per trillion is a thousand times smaller than a part per billion and a million times smaller than a part per million. A class action lawsuit recently filed against DuPont implies that 50 parts per trillion is an unacceptable level o f PFOA in drinking water. In feet, that number is neither a public health standard nor a threshold for obtaining compensation through litigation. Despite the feet that PFOA is not a regulated chemical, we have dramatically reduced emissions of PFOA from our facilities. We already have reduced emissions 95 percent from our U.S. manufacturing facilities since 2000. In addition, DuPont has developed technologies which will substantially eliminate PFOA content in its products and emissions from its manufacturing facilities b y 2007. Thank you for your attention. We will continue to update our employees, our community and the NJDEP on developments related to PFOA and the local drinking water supply. In the meantime, if you have any questions please contact me at (856) 540-3438 or the letterhead address. Sincerely, Cynthia N. McManus Environmental Manager Attachments c G. Zeigler, Perms Grove Water Supply Company K. Fell, NJDEP F. Faranca, NJDEP File 3