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 RECORD

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 Tuesday, 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 stated that the monitoring programs 

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 and 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 returned 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 others. Mr. Libelo stated that data is being collected 

as part of the TSCA consent orders for these companies with effluent discharge measurements as an added 

requirement.

I asked Mr. Libelo if any of the chemicals were measured in the wastewater data or if they 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 municipal 
Need to return call by / at/between and . Signature:

wastewater treatment facilities, 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; medium 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 at 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 manufacture of C4 and 

C6 length chemicals. However, there are still companies overseas supplying C8 chemicals to consumers in the 

United States. These countries include Italy, India, Russia, and China. Companies are still using the C8 

chemicals because they are more 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 expected, 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 to 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 that 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 

in 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 stated 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 College, 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., reference 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 that 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 should be revisited. He thinks new 

studies will show more effects.