TSCA-HQ-2004-0016, et. al. First Quarter 2006 Progress Report April 25, 2006

Page 1 of 7 

### 1 st 

### Quarter 2006 Progress Report January 01, 2006 to March 31, 2006 Biodegradation Supplemental En vironmental Project (SEP)

Pursuant to Section V.l.a. of the SEP, DuPont is re quired 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 Conf identiality 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 th e 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 ema il by DuPont on January 27, 2006. The hard copy of the approved Confidentiality Agreement w as 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). Fo r 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 concen tration. 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 thir ty days after the end of each calendar-year quarter (i.e., by April 30, July 31, October 30 and Janua ry 30) after execution of this Consent Agreement pursuant to Paragraph IX.9., respondent shall subm it in writing a quarterly report for the preceding quarter that shall include a discussion of the Re spondent’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 repor t 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 deadli ne 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 Fe bruary 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 se ven 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 re quest that such confidentiality agreement be signed and returned by a date consistent with the deadlin es 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 laborator ies 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 Agreem ent will be made available upon request.

G. Panel Administrator Selection and Approval

Section V.E.1. of the SEP provides that “By Februa ry 1, 2006, the parties will agree to the Panel Administrator. On January 30, 2006, DuPont request ed 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 su bmission 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 betw een 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 Pane l Administrator have nego tiated. Since the Panel Administrator was not chosen and agreed upon by th e 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 Administrato r Contract (both CBI and public versions, CD-2006-19 and CD-2006-19a) was submitted to the EPA for revi ew 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 Dingla san-Panlilio and Scott A. Mabury, Department of Chemistry, University of Toronto: Environ. Sci. & Te ch. 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 fo r initial studies to determine the applicability of the “Mabury Method” for the purification of Fluorot elomer-based Commercial Products. The progress toward determining the applicability of the “Ma bury Method” is outlined below in Section 1.K.

Additionally, the February 06, 2006 resulted in additi onal 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 Informa tion 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 Produc ts 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 mee ting 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 “Mabur y 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 Febr uary 7, 2006 to March 17, 2006, DuPont and EPA planned a conference call to discuss a path forward. Th e 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 st udies 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) show ing the quantity of test substance needed for the analytical characterization and the biodegradatio ns 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 tabl e 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 th e Fluorotelomers-based Commercial Products. TheTSCA-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 h as 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 extensi on granted between January 1, 2006 and March 31, 2006. All deadlines were met. Pending dead lines 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 we re 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 befo re 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 extracti on 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 pur ification 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 conducte d and for the parties to reach agreement on the purification procedure. Section II.L.3. of SEP A provid es 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 wa s 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 request ed 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 Sc iences 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 Pane l Administrator have nego tiated. Since the Panel Administrator was not chosen and agreed upon by th e 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 Admini strator 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 fo r 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 unde r 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 Biodegrada tion 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 (1 st 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. Cham bers Works and Barley Mill are staff locations. The travel expenses shown are for the trip to atte nd 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 r esult, the Chambers Works charges are posted at a one month lag to the SAP ledger. A breakdown of sta ff hours are shown on page 2 of Attachment B. The average salary rate is $65 per hour. The average co st 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 expe riments. 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 2 nd Quarter Progress Report.

5. Attachments

Title Number of Pages

a. Table 1. Quantity of Test Substance 1
b. Cost Distribution for 1Q 2006 2TSCA-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 1TSCA-HQ-2004-0016, et.al. First Quarter 2006 Progress April 25, 2006

SEP Biodegradation: Synthesis Account - VZ78101073
FEB MA R 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 MA R 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

Nam e Function Locatio n Time (hours)

M. Kaiser CCA S ES L 2 L. Wrightso n Sourcn g BMP 15.25
J. Franchina R&D-DCS E J L 3.75
K. Raifor d R&D-DCS E ES L 13.5 P. Fitzgerald R&D-DCS E J L 10
T. Vadden Finance BMP 2 H. Bryndz a DCSE-Tech Directo r BMP 13.25 L. Stephans SEP Manage r J L 128 J. Quinn Finance JL 3
E. Godono o Raiford-Admin Assistan t ES L 1 E. King Finance-DCS E BMP 2
193.75
SEP-S y nthesis Account

Nam e Function Locatio n Time (hours)

J. Franchina R&D-DCS E J L 3.5
3.5

SEP Main Account

Nam e Function Locatio n Time (hours) L. Stephans SEP Manage r J L 120 J. Quinn Finance JL 5 L. Wrightso n Sourcin g BMP 37.75
R. Stranahan DCSE Admi n J L 0.75 H. Brynzd a DCSE Tech Directo r BMP 3.5

167
SEP-S y nthesis Account

Nam e Function Locatio n Time (hours) Patrick Fitzgerald DCSE-R& D J L 22

James Bowers DCSE-R& D J L 17
J. Franchina R&D-DCS E BMP 7

B. Buc k DCS E BMP 9.5 L. Stephans DCSE-SEP Manage r J L 8 H. Brynzd a DSC E BMP 8
71.5

SEP Main Account

Nam e Function Locatio n Time (hours) L. Stephans SEP Manage r J L 120 H. Brynzd a DSC E BMP 3 J. Quinn Finance JL 3 L. Wrightso n Sourcin g BMP 7.5
R. Stranahan DCSE Admi n J L 4
137.5
SEP-S y nthesis Account

Nam e Function Locatio n Time (hours)

Kim Raifor d DCSE-R& D ES L 7 Patrick Fitzgerald DCSE-R& D J L 37

James Bowers DCSE-R& D J L 70

B. Buc k DCS E BMP 3 L. Stephans DCSE-SEP Manage r J L 8 H. Brynzd a DSC E BMP 4.25
129.25 Attachment B Page 2

Januar y 2006 SEP Time Summar y

Februar y 2006 SEP Time Summar y

March 2006 SEP Time Summar y