Need to return call by / at/between and

. Signature: Project No.: 0172 .09.005. 421 Page 1 of 3

Project Name: 304m 2012 Annual Review 

### CBI?

Yes

No TELEPHONE CALL RECOR D Incoming Outgoing Date: 03/16/2012 Time:

1:30 am

pm

Company Name: EPA

– PFOA Stewardship Program

Contacts ERG Staff Name: Elizabeth Sabol

Contact Name: Toni Krasnic

Laurence Libelo Contact Phone Number: 202

- 564

- 0984 (Krasnic)

202

- 564

- 8553 (Libelo)

General Subject: Long Chain PFCs Discharge Data



### TOPICS DISCUSSED AND ACTION TAKEN

Call with Toni Krasnic:

I tried contacting Toni Krasnic of EPA on Friday, March 16, 2012 to discuss the manufacturing companies in

the PFOA Stewardship Program and if any discharge monitoring data was available for long chain PFCs as part of the program . Mr. Krasnic’s answering machine indicated that he was out of the office until Tuesday, March
20, 2012.

I called Mr. Krasnic back on Tue sday, March 20 to discuss long chain PFCs and the companies participating in the PFOA Stewardship Program. Mr. Krasnic stated that there are two ongoing monitoring programs for a 3M facility in Alabama and a Dupont facility in West Virginia. Mr. Krasnic st ated that the monitoring program s collected emissions data and discharge data. To get more information about the monitoring data, Mr. Krasnic suggested I call Laurence Libelo of EPA (202

- 564

- 8553).

Additionally, I asked Mr. Krasnic if the manufacturing a nd downstream users were moving away from the C8 chain length perfluorinated compounds and using shorter chain length perfluorinated compounds (i.e., C6). Mr. Krasnic confirmed that this was a current trend in the industry and that C6 chemicals are not as toxic as the C8 chemicals. For example, the C8 chemicals have a half life of approximately 4 years in humans, while C6 chemicals have a half life of days or hours.

Call with Laurence Libelo:

I tried contacting Laurence Libelo on Wednesday, March 21, 2012 at 11:45 am to obtain information on the monitoring programs for the 3M and Dupont facilities mentioned by Tony Krasnic. I left a message asking Mr. Libelo to return my call.

Mr. Libelo retur ned my call later that day at 2:00 pm. Mr. Libelo informed me that there are 12 plants that are currently monitoring discharges for PFOA and PFOS. These plants included 3M and Daikin in Alabama, Dupont facilities in West Virginia and New Jersey, among othe rs. Mr. Libelo stated that data is being collected as part of the TSCA con sent orders for these companies with effluent discharge measurements as an added requirement.

I asked Mr. Libelo if any of the chemicals were measure d in the wastewater data or if t hey were non

- detect

results. Mr. Libelo stated that there are no non

- detects, because any company manufacturing or using PFCs have discharges of these chemicals. Mr. Libelo stated that they are seeing discharges from municipalNeed to return call by / at/between and

. Signature: wastewater treatment faciliti es, because of all the products containing PFOA and PFOS. He stated that larger plants manufacturing or using PFCs will likely have an onsite wastewater treatment system and discharge the

process wastewater; m edium sized plants likely send wastewater to a pretreatment facility; and that some smaller plants collect the wastewater in drums in a batch process . He stated that the water is treated a t a commercial wastewater treatment facility usually with a biological treatment system. Other than that, they may be sending wastewater to an incinerator.

Mr. Libelo stated that biological treatment systems are not successful in treating these chemicals. In addition, because the wastewater likely contains precursors to PFOA and PFOS , which are degraded in the sewage plant

, the effluent discharges are higher than the influent concentrations. Mr. Libelo stated that incineration is the best

treatment for these chemicals. Another treatment that will remove some of the PFOA and PFOS is carbon adsorption. Additionally, Mr. Libelo stated that PFCs with chain lengths of C9 or greater are more likely to stay in treatment sludge and be land applied. Conversely, C8 chain length PFCs are likely to be discharged in the liquid phase.

Mr. Libelo stated that the 8 major manufacturers included in the PFOA Stewardship Program likely supply 80 percent of the market (however, this number is decreasing as some plants phase out PFOA and PFOS) with

these chemicals . He confirmed that the majority of these companies are moving to the manufactu re of C4 and C6 length chemicals. However, there are still companies overseas supplying C8 chemicals to consum ers in the United States. These countries include Italy, India, Russia, and China. Companies are still using the C8 chemicals because they are mor e effective and cost half as much as the C4 and C6 chemicals produced in the

United States.

Mr. Libelo stated that EPA knows many companies are still purchasing these C8 chemicals because the levels in the discharges are not decreasing, as would be expec ted, with the decrease in manufacturing. Mr. Libelo stated that a SNUR may be the way to get long chain PFCs off the market. However, these chemicals will likely stay in FDA products (i.e., makeup).

Mr. Libelo stated that the larger companies (3M, Dupont, Diakin, etc.) are captured in the PFOA program and monitor their discharges. Additionally, some of the “second tier” manufacturers or users have also been identified; however, these facilities are not likely monitoring. The remaining users (applications t o clothes or cookware) have not all been identified (likely hundreds of companies) and these facilities aren’t monitoring wastewater discharges for PFOA or PFOS either.

I asked Mr. Libelo about the data mentioned in the beginning of the call. He stated th at there is data available

and that they are not CBI. Mr. Libelo stated that data could likely be found in the EPA docket

. Mr. Libelo stated that NPDES permits were starting to include monitoring requirements for perfluorinated chemicals, specifically

i n West Virginia, Ohio, New Jersey, Alabama (soon) and Minnesota. He stated that I could call these companies for the data as they usually have it readily available. Mr. Libelo stated that this data isn’t CBI; however, replacement chemicals may be CBI. He s tated that West Virginia requires these companies to make their discharge data public.

Mr. Libelo stated that the data he has for 3M and Dupont is raw data directly from the labs. He stated that the two labs analyzing this data include MPI in State Colleg e, PA and Axys in British Columbia. He stated that I

should be able to call the labs for the analytical methods they use, and that the method is likely published (Mr. Libelo stated that the primary author is likely John Flarity). Mr. Libelo will e

- mail me the available data for 3M and Dupont (email: Libelo.Laurence@epa.gov).

Mr. Libelo stated that the Stewardship Program website has the locations of the facility included in the program (not just the companies).Need to return call by / at/between and

. Signature: Currently, there are no reporting limits for long chain PFCs (PFOA and PFOS); however, some states are moving forward with monitoring requirements for these facilities . Mr. Libelo stated that no states will set a limit because the federal government has not developed a toxicity factor (i.e., refe rence dose). Mr. Libelo stated that caution is exercised when developing this factor because all the land applied sludge containing PFCs (specifically Decatur, AL and all other areas where municipal sludge is land applied) will likely have to be

remediated

.

Mr. Libelo also stated that most discussion of regulating PFCs surrounds the C8 (PFOA and PFOS) chemicals. He mentioned that companies also use C9, 10, 11, ad 12 length chemicals that are equally or more toxic.

For health affects, Mr. Libelo stated tha t new CEC monitoring data shows that tetanus shots can be ineffective in some humans with PFOA in their blood, as it will shutdown antibody formation. Mr. Libelo stated that the determinations of human health effects from 10 years ago are outdated and shou ld be revisited. He thinks new

studies will show more effects.