TSCA-HQ-2004-0016, et. al. 

First Quarter 2006 Progress Report April 25, 2006 

Page 1 of 7 

1st Quarter 2006 Progress Report 

January 01, 2006 to March 31, 2006 

Biodegradation Supplemental Environmental Project (SEP)

Pursuant to Section V.l.a. of the SEP, DuPont is required to submit a quarterly report within thirty days 

after the end of each calendar-year quarter. This report which is due April 30, 2006 satisfies said 

requirement. 

1. Description of Activities Undertaken

A. Confidentiality Agreement Draft to the EPA for Approval 

Section III. A. of the SEP provides that “Within forty-five days from the date DuPont signs the Consent 

Agreement, DuPont shall submit to the EPA the Confidentiality Agreement that DuPont intends to use 

with any laboratory. The Consent Agreement was signed by DuPont on November 23, 2005. The first 

draft of the Confidentiality Agreement was sent to the EPA for review and approval on January 5, 2006 

(CD-2006-01). After review by the EPA and revision by DuPont, the final Confidentiality Agreement 

was sent to the EPA for final approval on January 24, 2006 (CD-2006-02). Approval of the final version 

of the Confidentiality Agreement was received by email by DuPont on January 27, 2006. The hard copy 

of the approved Confidentiality Agreement was received by DuPont on January 31, 2006. 

B. Submission of Table 1 Fluorotelomer Test Substances 

On January 27, 2006, DuPont submitted to the EPA a table describing the Fluorotelomer Test Substances 

to be used in the Biodegradation SEP (CD-2006-03). For the nine Fluorotelomer Test Substances and one 

Control, the table contained the CAS number, active ingredient, major components, CAS numbers for the 

major components and approximate component concentration. Both confidential business information 

(CBI) and public versions were submitted. 

C. First Quarterly Progress Report (November 23, 2005 – December 31, 2005) 

Section V.I.a. of the CAFO provides that “Within thirty days after the end of each calendar-year quarter 

(i.e., by April 30, July 31, October 30 and January 30) after execution of this Consent Agreement 

pursuant to Paragraph IX.9., respondent shall submit in writing a quarterly report for the preceding 

quarter that shall include a discussion of the Respondent’s progress in satisfying its obligations in 

connection with each SEP including a minimum, a narrative description of activities undertaken, 

compliance with the schedules or milestones set forth in the applicable appendix, and a summary of costs 

incurred since the previous report.” On January 30, 2006, a first progress report covering the time period 

from November 23, 2005 to December 31, 2005 was submitted to the EPA (CD-2006-04). 

D. Addendum to Table 1 of Attachment A 

On Feburary 23, 2006, the EPA and DuPont agreed to change the common name of the “control” 

identified in Table 1 of Attachment A from Telomer B Alcohol to Telomer 8-2 Alcohol. On February 28, 

2006, the change was approved by the EPA. 
TSCA-HQ-2004-0016, et. al. 

First Quarter 2006 Progress Report April 25, 2006 

Page 2 of 7 

E. Requests for Proposals to the EPA for Approval 

Section III. B. of the SEP provides that “By February 1, 2006, DuPont shall submit to EPA on or more 

draft Requests for Proposals (RFPs) to be sent to all of the laboratories identified in Attachment G to 

solicit proposals for (1) characterizing the Fluorotelomer Products and any Corresponding Polymers, and 

(2) conducting the OECD Guideline 303A and SCAS studies on the Fluorotelomer Products and any 

Corresponding Polymers (including pilot testing).” On January 27, 2006, DuPont requested and was 

granted a first extension (CD-2006-05). The deadline for submission of draft RFPs to the EAP was 

extended to March 2, 2006. Both draft RFPs were submitted to the EPA within the extended deadline as 

described below. 

a. Analytical Laboratory RFP 

The Analytical Laboratory Request for Proposal (both CBI and Public versions, CD-2006-12, CD 2006-

12a and CD-2006 12b) was submitted to the EPA on February 22, 2006. The Analytical Laboratory RFP 

is currently under review by the EPA. 

b. Biodegradation Laboratory RFP 

The Biodegradation Laboratory Request for Proposal (both CBI and Public versions, CD-2006-11 and 

CD 2006-11a) was submitted to the EPA on March 1, 2006. The Biodegradation Laboratory RFP is 

currently under review by the EPA. 

F. Confidentiality Agreement Launch to Biodegradation and Analytical 

Laboratories 

Section III. A. of the SEP provides that “Within seven business days of receipt of EPA’s approval (or 

acceptance) of the confidentiality agreement, DuPont must provide the laboratories listed in Attachment 

G of the SEP with a confidentiality agreement and request that such confidentiality agreement be signed 

and returned by a date consistent with the deadlines established in this Appendix”. The Confidentiality 

Agreements were launched to the six laboratories on January 31, 2006. An email and an official 

submission (CD-2006-08) were sent on February 10, 2006 to the EPA notifying the EPA of the launch 

date of the Confidentiality Agreements. The laboratories were asked to respond no later then February 

15, 2006. All Confidentiality Agreements were signed and returned to DuPont by February 15, 2006. 

Copies of the signed Confidentiality Agreement will be made available upon request. 

G. Panel Administrator Selection and Approval 

Section V.E.1. of the SEP provides that “By February 1, 2006, the parties will agree to the Panel 

Administrator. On January 30, 2006, DuPont requested and was granted a first extension for agreement 

of the Panel Administrator. The deadline to reach agreement of the Panel Administrator was extended to 

March 6, 2006. After the request for extension, EPA and DuPont collectively agreed on questions to pose 

to the Panel Administrator Candidate, International Life Sciences Institute-Research Foundation (ILSI). 

On February 17, 2006, while the EPA and DuPont were on a conference call with ILSI, ISLI was able to 

address all questions posed by EPA and DuPont. On February 22, 2006, the EPA and DuPont agreed on 

ILSI as the panel administrator. An official submission acknowledging ILSI as the panel administrator 

(CD-2006-13) was sent to the EPA on February 23, 2006. ILSI was contacted by DuPont on February 24, 

2006 and notified that they were chosen as the Panel Administrator. On February 27, 2006, contract 

negotiations began between ISLI and DuPont. 
TSCA-HQ-2004-0016, et. al. 

First Quarter 2006 Progress Report April 25, 2006 

Page 3 of 7 

H. Panel Administrator Contract Negotiation 

Section V.E.2 of the SEP provides that by March 15, 2006, DuPont must provide EPA with a final draft 

of the proposed contract that DuPont and the Panel Administrator have negotiated. Since the Panel 

Administrator was not chosen and agreed upon by the EPA and DuPont until February 22, 2006, a first 

request for extension (CD-2006-15) was requested by DuPont on March 13, 2006 and granted by the 

EPA. The deadline for Panel Administrator Contract submission to the EPA was extended to April 14, 

2006. On February 27, 2006, contract negotiations began between ISLI and DuPont. Negotiations 

between DuPont and ILSI ended successfully on April 10, 2006. 

I. Panel Administrator Contract Submission 

The first draft of the negotiated Panel Administrator Contract (both CBI and public versions, CD-2006-19 

and CD-2006-19a) was submitted to the EPA for review on April 12, 2006. The Panel Administrator 

Contract is currently under review by the EPA. 

J. February 06, 2006 Meeting with the EPA to discuss the Mabury Method of Purification 

On January 25, 2006, pursuant of Section I.E.2.a. of the SEP, the EPA provided DuPont with an in press 

copy of the “Maybury Method” entitled “Significant Residual Fluorinated Alcohols Present in Various 

Fluorinated Materials” by Mary Joyce A Dinglasan-Panlilio and Scott A. Mabury, Department of 

Chemistry, University of Toronto: Environ. Sci. & Tech. In preparation of the February 06, 2006 meeting 

between the EPA and DuPont, DuPont sent the EPA a response to the “Mabury Method” on February 02, 

2006 (CD-2006-07). During the meeting DuPont expressed concerns outlined in the February 02, 2006 

submission. The meeting resulted in a path forward for initial studies to determine the applicability of the 

“Mabury Method” for the purification of Fluorotelomer-based Commercial Products. The progress 

toward determining the applicability of the “Mabury Method” is outlined below in Section 1.K. 

Additionally, the February 06, 2006 resulted in additional questions for DuPont. In order for DuPont to 

address the EPA questions, two separate submissions were submitted to the EPA: (1) Requested 

Information from the February 06, 2006 Meeting with EPA: Part 1 (CD-2006-09 (CBI and Public 

versions), submitted February 10, 2006) and (2) Requested Information from the February 06, 2006 

Meeting with EPA: Part 2 (CD-2006-10), submitted on February 16, 2006. These submissions contained: 

1) the quantity of test substance calculation, 2) a table containing percent carbon and percent active for 

each of the nine Fluorotelomer-based Commercial Products and 3) a list of all the impurities measured on 

each of the nine Fluorotelomer-based Commercial Products. 

An additional request from the February 06, 2006 meeting was granted by DuPont. DuPont shipped two 

8 oz jars of Zonyl® FSO and two 8 oz. jars of Zonyl® FSE to John Washington at the USEPA on February 

13, 2006. 
TSCA-HQ-2004-0016, et. al. 

First Quarter 2006 Progress Report April 25, 2006 

Page 4 of 7 

K. Purification Progress Reports 

Exploratory studies on the applicability of the “Mabury Method” for the purification of Fluorotelomersbased Commercial Products began on February 7, 2006. Subsequently, a series of reports were 

submitted: 

a. Summary of Exploratory Studies to Date on the Applicability of the “Mabury 

Method” to Large Scale Purification of Fluoro-telomer Based Products for 

Biodegradation Studies: Part 1- Data from February 7, 2006 to February 27, 2006 

submitted on March 01, 2006 (CD-2006-14) 

b. Exploratory Studies on the Applicability of the “Mabury Method” to Large Scale 

Purification of Fluoro-telomer Based Products for Biodegradation Studies Part 2 – 

Data from February 28, 2006 to March 17, 2006, submitted on March 22, 2006 (CD2006-16) 

c. Exploratory Studies on the Applicability of the “Mabury Method” to Large Scale 

Purification of Fluoro-telomer Based Products for Biodegradation Studies Part 3 – 

Data from March 17, 2006 to March 22, 2006, submitted on by email on March 22, 

2006 and by official submission on March 23, 2006 (CD-2006-17). 

d. Exploratory Studies on the Applicability of the “Mabury Method” to Large Scale 

Purification of Fluoro-telomer Based Products for Biodegradation Studies Part 4 – 

Data from March 22, 2006 to April 04, 2006, submitted on April 12, 2006 (CD-2006-

20). 

All nine Fluorotelomer-based Commercial Products were initially evaluated and the progress was 

presented in the reports described above. As a result of the progress outlined in the two progress reports 

Part 1 and Part 2, covering the timeframe from February 7, 2006 to March 17, 2006, DuPont and EPA 

planned a conference call to discuss a path forward. The result of that conference call is outlined in I.M. 

below. 

L. Quantity of Test Substance Needed to Perform the Work Under the SEP 

DuPont requested guidance from the EPA on the quantity of test substance needed to perform the 

analytical characterization and the biodegradations studies as outlined in the SEP. During the February 

06, 2006 meeting between the EPA and DuPont, the EPA asked DuPont to provide the EPA with a 

calculation of test substance quantity based on percent active ingredient. On February 10, 2006, DuPont 

provided the EPA with the calculation (CD-2006-09) showing the quantity of test substance needed for 

the analytical characterization and the biodegradations studies as outlined in the SEP. On March 16, 

2006, the EPA sent an email approving the quantity of test substance calculation as presented by DuPont. 

Table 1 (in Attachment A) describes the quantity of test substance as it is calculated for each 

Fluorotelomer-based Commercial Products. This table was not presented to the EPA on February 10, 

2006 but is submitted formally here as part of this progress report. 

M. March 23, 2006 Conference call between the EPA and DuPont 

On March 23, 2006, EPA and DuPont had a conference call to discuss the progress with the applicability 

of the “Mabury Method” for the purification of the Fluorotelomers-based Commercial Products. The 
TSCA-HQ-2004-0016, et. al. 

First Quarter 2006 Progress Report April 25, 2006 

Page 5 of 7 

analytical results from the first and second progress reports (outlined above) were discussed. The EPA 

and DuPont discussed how, if at all, the Mabury Method could be modified or further developed such that 

it could be used to produce the nine Purified Fluorotelomer Products in a timely, feasible, and efficient 

manner. Based upon evaluation of the results from the first two purification progress reports, on March 

27, 2006, the EPA proposed additional experiments to conduct on two test substances. DuPont provided 

its response to the proposed experiments by email on April 07, 2006 and by official submission on April 

10, 2006 (CD-2006-18). 

Currently, DuPont and EPA are in the process of arranging a conference call to discuss and agree upon 

the additional experiments proposed for two specific test substances identified by EPA. A request for a 

third extension was submitted to the EPA on April 12. On April 14, the EPA granted an extension to 

June 30, 2006. 

N. Additional Progress 

DuPont is currently in the process of securing: 1) the required quantities of the nine Fluorotelomer-based 

Commercial Products, 2) the raw materials to make the nine lab-made Fluorotelomer-based Commercial 

products and 3) the high purity raw materials to make the lab-made high purity variants of the nine 

Fluorotelomer-based Commercial Products. DuPont has also set up a separate laboratory where the 

purification process will be performed. 

2. Compliance with Schedules or Milestones

This section outlines the various requests for extension granted between January 1, 2006 and March 31, 

2006. All deadlines were met. Pending deadlines and open issues are described below. 

A. Requests for Extensions 

a. Requests for Proposal 

Section III. B. of the SEP provides that “By February 1, 2006, DuPont shall submit to EPA on or more 

draft Requests for Proposals (RFPs) to be sent to all of the laboratories identified in Attachment G to 

solicit proposals for (1) characterizing the Fluorotelomer Products and any Corresponding Polymers, and 

(2) conducting the OECD Guideline 303A and SCAS studies on the Fluorotelomer Products and any 

Corresponding Polymers (including pilot testing).” On January 27, 2006, DuPont requested and was 

granted a first extension (CD-2006-05). The deadline for submission of the draft RFPs to the EPA was 

extended to March 2, 2006. Both draft RFPs were submitted to the EPA before the March 02, 2006 

deadline. 

b. Purification Procedure 

Section I.E.2.a. of SEP A provides that “On or before February 1, 2006, DuPont and EPA will agree on 

the procedure(s) that DuPont will use to purify the Fluorotelomer Products to produce Purified 

Fluorotelomer Products, taking into consideration the need to optimize various factors, including the 

appropriate duration of extraction and re-dispersion processes, the desired purity of the Purified 

Fluorotelomer Products, the schedule for delivery of the Purified Fluorotelomer Products to the 

laboratories for characterization, testing and studies, and the overall schedule for completing this 

biodegradation SEP.” 
TSCA-HQ-2004-0016, et. al. 

First Quarter 2006 Progress Report April 25, 2006 

Page 6 of 7 

The time for the parties to reach agreement on the purification procedure was first extended to March 2, 

2006 (CD-2006-05) and then extended a second time to April 17, 2006 (CD-2006-14). The parties are 

still actively evaluating parameters for modification of the Mabury Method and are also engaged in 

discussion concerning two additional experiments to be conducted that may provide further relevant 

information on the appropriate purification procedure to implement. As such, a third extension of time 

was necessary for the experiments to be conducted and for the parties to reach agreement on the 

purification procedure. Section II.L.3. of SEP A provides that extensions of time beyond a first extension 

are subject to EPA’s discretion and are granted for good cause shown. 

The information provided in Section 1.K. above was presented to show that good cause existed for the 

granting of the third extension of time. The time period for extension was based upon the length of time 

needed to conduct additional experiments. A request for a third extension was submitted to the EPA on 

April 12, 2006 (CD-2006-21). On April 14, the EPA granted an extension for agreement on the 

Purification Procedure to June 30, 2006. 

c. Panel Administrator Selection and Agreement 

Section V.E.1 of the SEP provides that by February 1, 2006, the parties will agree to a Panel 

Administrator. On January 30, 2006, DuPont requested and was granted a first request for extension for 

agreement of the Panel Administrator (CD-2006-06). The deadline to reach agreement of a Panel 

Administrator was extended to March 6, 2006. After the request for extension, EPA and DuPont 

collectively agreed on questions to pose to the panel administrator. On February 17, 2006, the EPA and 

DuPont conference called with International Life Sciences Institute-Research Foundation (ILSI). ISLI 

was able to address all questions posed by EPA and DuPont. On February 22, 2006, the EPA and DuPont 

agreed on ILSI as the panel administrator. An official submission (CD-2006-13) acknowledging ILSI as 

the panel administrator was send to the EPA on February 23, 2006. ILSI was contacted by DuPont on 

February 24, 2006 and notified that they were chosen as the Panel Administrator. On February 27, 2006, 

contract negotiations began between ISLI and DuPont. 

d. Panel Administrator Contract Submission to the EPA 

Section V.E.2 of the SEP provides that by March 15, 2006, DuPont must provide EPA with a final draft 

of the proposed contract that DuPont and the Panel Administrator have negotiated. Since the Panel 

Administrator was not chosen and agreed upon by the EPA and DuPont until February 22, 2006, a first 

request for extension (CD-2006-15) was requested by DuPont on March 13, 2006 and granted by the 

EPA. The deadline for Panel Administrator Contract submission to the EPA was extended to April 14, 

2006. The first draft of the negotiated Panel Administrator Contract (both CBI and public versions, CD2006-19 and CD-2006-19a) was submitted to the EPA for review on April 12, 2006. 

B. Deadlines

All deadlines were met in the first quarter of 2006. The current deadline for the Agreement of the 

Purification Method is June 30, 2006. 

C. Open Issues 

The Analytical and Biodegradation Requests for Proposals are currently under review by the EPA. The 

Panel Administrator Contract is also currently under review by the EPA. Agreement on the purification 

method must be reached by June 30, 2006. 
TSCA-HQ-2004-0016, et. al. 

First Quarter 2006 Progress Report April 25, 2006 

Page 7 of 7 

3. Summary of Costs Incurred

DuPont has established a system to capture all costs incurred for this SEP. Cost is broken down into two 

accounts, the “SEP Biodegradation Main” account (VZ789011724) and the “SEP Biodegradation 

Synthesis” account (VZ78101073). The SEP Biodegradation Main account is used for all eligible SEP 

costs while the SEP Biodegradation Synthesis account is used for costs resulting from preparation, 

purification, synthesis and characterization of the test substances as supplied to the SEP. 

The cost of the SEP from January 1, 2006 to March 31, 2006 as it was accounted on cost ledger is shown 

in Attachment B (1st Quarter 2006 Cost Summary, Cost Analysis for January 1, 2006 to March 31, 2006). 

The year to date (YTD) costs are $24,836 and $25,042 for the SEP Biodegradation Main and the SEP 

Biodegradation Synthesis accounts, respectively. Chambers Works and Barley Mill are staff locations. 

The travel expenses shown are for the trip to attend the February 06, 2006 meeting at the EPA. The 

Chambers Works charges are charged to a Chambers Works account and then transferred to the SEP 

accounts in SAP (DuPont accounting system). As a result, the Chambers Works charges are posted at a 

one month lag to the SAP ledger. A breakdown of staff hours are shown on page 2 of Attachment B. The 

average salary rate is $65 per hour. The average cost of overheads per person is $1550 per person, per 

month. The actual cost of overheads is calculated by multiplying the percent of the total hours worked on 

the SEP per month by $1550. Overheads for the Barley Mill staff were not included in the first quarter 

but will be added going forward in April. 

4. Other Comments

On March 23, 2006, the EPA and DuPont had a conference call to discuss a path forward for the 

purification procedure. On March 27, 2006, the EPA sent a request for information and a description of 

the path forward for the remaining purification experiments. DuPont responded to the March 27, 2006 

EPA request on April 07, 2006. The EPA response to the April 07, 2006 DuPont response and the 

outcome of the conference call will be presented in the 2nd Quarter Progress Report. 

5. Attachments

 Title Number of Pages

a. Table 1. Quantity of Test Substance 1 

b. Cost Distribution for 1Q 2006 2 
TSCA-HQ-2004-0016, et. al. 

 

First Quarter 2006 Progress Report April 25, 2006 

Table 1. Quantity of Test Substance Calculated for Each Test Substance

Pilot Test 

Group Test Sequence Order % active

Calculated Test 

Quantity (L)* Comments

Control 1 96

39.5-42.5 4.5 based on 39.5%

12.0-13.0 8.5 based on12 %

32.0 - 34.0 4.5 based on 32%

10.0 - 20.0 9.3 based on 10%

21.5 - 22.5 5.5 based on 21.5%

17 - 18 6.5 based on 17%

18 - 19 6.5 based on 18%

17 - 20 6.5 based on 17%

29 - 30 4.2 based on 29%

* rounded up to the nearest 1/2 L

Attachment A

A1 Group 1 Substance 2

A2 Group 1 Substance 3

A3 Group 1 Substance 1

B Group 2 Substance 1

C1 Group 3 Substance 3

C2 Group 3 Substance 2

D2 Group 4 Substance 2

C3 Group 3 Substance 1

D1 Group 4 Substance 1
TSCA-HQ-2004-0016, et.al. First Quarter 2006 Progress April 25, 2006

SEP Biodegradation: Synthesis Account - VZ78101073

FEB MAR YTD

Salaries 

Chambers Works 3,055 21,781 24,836

Barley Mill 0

Travel

Franchina 0

Stephans 0

Bryndza 0

Operating Supplies 0

Stephans 0

TOTAL 3,055 21,781 24,836

SEP Biodegradation: Main Account - VZ78911724

FEB MAR YTD

Salaries 

Chambers Works 11,080 9,052 20,132

Barley Mill 3,373 610 3,983

Travel#

Franchina 219 219

Stephans$ 437 437

Bryndza 210 210

Operating Supplies

Stephans 61 61

TOTAL 15,380 9,662 25,042

# February 06, 2006 meeting at the EPA

$ Included Travel Expenses for Pat Fitzgerald

Cost Analysis for January 1, 2006 to March 31, 2006

Attachment B (Page 1 of 2)
TSCA-HQ-2006-0016, et. al. First Quarter 2006 PRogress Report April 25, 2006

SEP Main Account

Name Function Location Time (hours)

M. Kaiser CCAS ESL 2

L. Wrightson Sourcng BMP 15.25

J. Franchina R&D-DCSE JL 3.75

K. Raiford R&D-DCSE ESL 13.5

P. Fitzgerald R&D-DCSE JL 10

T. Vadden Finance BMP 2

H. Bryndza DCSE-Tech Director BMP 13.25

L. Stephans SEP Manager JL 128

J. Quinn Finance JL 3

E. Godonoo Raiford-Admin Assistant ESL 1

E. King Finance-DCSE BMP 2

193.75

SEP-Synthesis Account

Name Function Location Time (hours)

J. Franchina R&D-DCSE JL 3.5

3.5

SEP Main Account

Name Function Location Time (hours)

L. Stephans SEP Manager JL 120

J. Quinn Finance JL 5

L. Wrightson Sourcing BMP 37.75

R. Stranahan DCSE Admin JL 0.75

H. Brynzda DCSE Tech Director BMP 3.5

167

SEP-Synthesis Account

Name Function Location Time (hours)

Patrick Fitzgerald DCSE-R&D JL 22

James Bowers DCSE-R&D JL 17

J. Franchina R&D-DCSE BMP 7

B. Buck DCSE BMP 9.5

L. Stephans DCSE-SEP Manager JL 8

H. Brynzda DSCE BMP 8

71.5

SEP Main Account

Name Function Location Time (hours)

L. Stephans SEP Manager JL 120

H. Brynzda DSCE BMP 3

J. Quinn Finance JL 3

L. Wrightson Sourcing BMP 7.5

R. Stranahan DCSE Admin JL 4

137.5

SEP-Synthesis Account

Name Function Location Time (hours)

Kim Raiford DCSE-R&D ESL 7

Patrick Fitzgerald DCSE-R&D JL 37

James Bowers DCSE-R&D JL 70

B. Buck DCSE BMP 3

L. Stephans DCSE-SEP Manager JL 8

H. Brynzda DSCE BMP 4.25

129.25

Attachment B Page 2

January 2006 SEP Time Summary

February 2006 SEP Time Summary

March 2006 SEP Time Summary