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

Fourth Quarter 2006 Progress Report January 20, 2007 

Page 1 of 3 

4th Quarter 2006 Progress Report 

October 1, 2006 to December 31, 2006 

Biodegradation Supplemental Environmental Project (SEP A)

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 January 30, 2006 satisfies said 

requirement. 

1. Description of Activities Undertaken

A. Progress Toward a Purification Procedure Agreement 

After much negotiation and engaging discussion between EPA and DuPont from March to August, a path 

forward agreement was finalized by the EPA and communicated to DuPont on August 23, 2006 (email 

from Ilana Saltzbart, 08/23/2006, 4:46 PM) with attachment entitled “Final Purification Path Forward 

Agreement 8-23-06.pdf. Along with the path forward agreement, EPA proposed a new Purification 

Procedural Agreement deadline of November 27, 2006. 

From August to October, DuPont worked with Exygen Research to develop methods, establish protocol 

and perform interlaboratory equivalency. A progress report outlining the results of the equivalency 

studies was submitted to EPA on October 24, 2006 (CD-2006-28). 

On November 21, 2006, Dupont, EPA and Exygen met to discuss the results of the first progress report 

submitted on October 24, 2006. EPA requested via email (Ilana Saltzbart, 11/22/2006 04:09 PM) a path 

forward proposal describing the validation studies that remain before beginning the control and two 

additional sparging experiments. This email included particular constraints of the additional validation 

studies (see attached email, Ilana Saltzbart, 11/22/2006 04:09 PM). On November 28, 2006, DuPont 

received a path forward proposal from Exygen. This proposal was reviewed by DuPont and submitted to 

EPA via email on November 30, 2006 (Email to Ilana Saltzbart, November 30, 2006 04:43 PM). The 

Exygen path forward Proposal is attached and was approved by EPA via email on December 08, 2006 

(Ilana Saltzbart, December 08, 2006 02:09 PM). The EPA approval came with additional requirements 

for Exygen. These additional requirements were passed on to Exygen, accepted by Exygen and EPA was 

notified that Exygen agreed to and accepted the additional requirements. The additional experimental 

requirements requested by EPA, required approval for $2500 in additional funding to Exygen. EPA 

approved the additional costs via email (see attached email from Ilana Saltzbart, 12.13.2006 05:35 PM). 

Exygen is currently working to complete the remaining validation and control analyses. 

November 08, 2006, DuPont submitted a fifth request for extension for agreement for the procedures for 

purification of the fluorotelomer commercial products. On November 15, 2006, EPA granted DuPont’s 

request and extended the deadline to March 7, 2006 to receive data and March 30, 2006 to reach final 

agreement by both parties (see attached email Ilana Saltzbart, 11/15/2006 04:16 PM). 

B. Panel Administrator Contract Negotiation 

On November 3, 2006 a second draft version of the Panel Administrator Contract was submitted to the 

EPA (CD-2006-29). EPA responded on November 22, 2006 (Ilana Saltzbart, 11/22/06, 3:49 PM) with 

additional changes to the Panel Administrator Contract documents. Those changes were reviewed with 

DuPont and ILSI legal. The Panel Administrator contracts were submitted a third time to EPA for 
TSCA-HQ-2004-0016, et. al. 

Fourth Quarter 2006 Progress Report January 20, 2007 

Page 2 of 3 

approval on November 27, 2006 (CD-2006-31). EPA had additional changes and the Panel Administrator 

contracts were resubmitted a fourth time on December 22, 2006 (CD-2006-32P and CD-2006-32CBI). An 

informal deadline was set by Ilana Saltzbart for the EPA to review and respond to the December 22, 2006 

submission by January 05, 2007. 

C. Submission of Third Quarter 2006 Progress Report Describing Progress from July 01, 2005 to 

September 30, 2006 

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 October 23, 2006, a third quarter 2006 progress report covering the time period from July 01, 2005 to 

September 30, 2006 was submitted to the EPA (CD-2006-27). 

D. Biodegradation and Characterization RFPs 

On December 28, 2006, EPA sent via email (see attached email from Ilana Saltzbart, 12/28/2006, 01:00 

PM) a request for DuPont to resubmit the Biodegradation and Analytical Requests for Proposals. The 

resubmission will include review, modification and incorporation of the language as it was negotiated in 

the Panel Administrator contracts where applicable. The deadline for this submission was set for 

February 01, 2007. 

2. Pending Issues and Document Reviews

 A. Requests for Proposals to the EPA for Approval 

Per request of EPA, DuPont is currently modifying the Biodegradation and Analytical Requests for 

Proposal. The revised RFPs will be submitted to EPA on or before February 01, 2007. 

B. Panel Administrator Contract Status 

The final version of the Panel Administrator Contracts as they were negotiated between ILSI, DuPont and 

EPA was submitted to EPA on December 22, 2006 (CD-2006-32P and 32CBI). The Panel Administrator 

contract documents pending approval by EPA which is tentatively scheduled for January 05, 2007. 

 C. Agreement on the Mabury Method of Purification 

The new deadline for agreement on a purification procedure is March 30, 2007.

3. Compliance with Schedules or Milestones

This section outlines the various requests for extension granted between October 01, 2006 and December 

31, 2006. All deadlines in the fourth quarter were met. Pending deadlines and open issues are described 

below. 
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Fourth Quarter 2006 Progress Report January 20, 2007 

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A. Purification Procedure 

The deadline to reach agreement on the purification procedure was extended a fifth time on November 15, 

2006. The new deadline is March 30, 2007. 

B. Panel Administrator Contract Submission to the EPA 

EPA approval for the Panel Administrator Contracts is anticipated to be January 05, 2007. Once DuPont 

received EPA approval from EPA, DuPont would within 7 days present the contract documents to ILSI. 

 C. Quarterly Progress Reports 

On October 23, 2006, the third quarter 2006 progress report covering the time period from July 1, 2006 to 

September 30, 2006 was submitted to the EPA (CD-2006-27). 

 D. Pending Deadline Summary 

All deadlines were met in the fourth quarter of 2006. The two pending deadlines are: 

1) March 30, 2007 to reach Agreement of the Purification Method, and 

2) February 06, 2007 for resubmission of the Biodegradation and Analytical RFPs. 

4. 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 DuPont costs resulting from 

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

The cost of the SEP from October 01, 2006 to December 31, 2006 as it was accounted on cost ledger is 

shown in Attachment A. The table shows the costs from both accounts and breaks the cost distribution 

down into salaries, overheads, travel, operating supplies and analytical costs. The year to date (YTD) 

costs are $279,007 and $122,812 for the SEP Biodegradation Main and the SEP Biodegradation Synthesis 

accounts, respectively. A negative number signifies a cost correction due to an account error in the 

previous month. 

The Agilent Costs to perform the analysis required by the two additional experiments will total per quote 

Q2319E to $164,800 (min) to $204,400 (max). A range of cost was quoted to allow for flexibility 

associated with the range of experiments that may be required. Exygen began analyses in September 

2006, a fee of $82,833 was charged in September to cover the method development and validation costs. 

In December, Exygen charged an additional $41,417 to cover the equivalency studies. Going forward the 

remaining Exygen costs will be changed upon services rendered. It is anticipated that the remainder of 

the costs associated with the Exygen Research quote will be spent in the first quarter of 2007. 

5. Attachments

 Title Number of Pages

Attachment A. SEP Cost Summary for 2006 1 

Attachment B. Email correspondance described in this report 40