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Email: David.W.Boothe@usa.dupont.com 

Reply To: DAVID W. BOOTHE 

E.1 . du Pont de Nemours and Company 

Director, Corporate Risk Management 

1007 Market Street 

Wilmington, DE 19898 

Telephone: 302.999 .4091 

Facsimile: 302.999 .3404 

October 29, 2010 PUBLIC COPY - NO CBI 

VIA OVERNIGHT DELIVERY 

OPPT Document Control Office (DCO) 

Attention: Docket ID Number EPA-HQ-OPPT-2006-0621 

1201 Constitution Avenue, NW 

EPA East Building, Room 6428 

Washington, D.C. 20004 

Dear Sir/Madam: 

2010/15 PFOA Stewardship Program Report 

Please find enclosed, in both paper copy and on CD, the 2009 DuPont Report (CBI 

version) for the 2010/15 PFOA Stewardship Program. 

We look forward to further dialogue on ongoing reporting to best meet the program 

objectives. 

David W. Boothe 

Attachment and Enclosure (Paper and CD) 

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COmpany Sanitized 

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COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
2010/15 PFOA Stewardship Program October 30, 2009 

DuPont Submission Page 1 of 1 

Index of Documents - Public Version 

Document 

Number Document Number of 

On CD Date Document Pages 

001 10 .30 .09 Transmittal letter for report 1 

002-006 10.30.09 CBI 5 

007 10.30.09 Appendix D - Facility Report on Product 

Content - Aqueous Fluoropolymer Dispersion 5 

008 10.30.09 Appendix D - Facility Report on Product 

Content - Fluoroelastomer 6 

009 10.30.09 Appendix D - Facility Report on Product 

Content - Fluorotelomer 7 

010 10.30.09 Appendix F - Company Annual Report 

Summary of Reductions in Emissions and 

Product Content 3 

O11 10.30 .09 CBI (Attachments) 28 

Public Copy 
2010/15 PFOA STEWARDSHIP PROGRAM 

October 29, 2010 

DuPont Submission 

Document 002 

Claimed as Confidential Business Information 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
2010/15 PFOA STEWARDSHIP PROGRAM 

October 29, 2010 

DuPont Submission 

Document 003 

Claimed as Confidential Business Information 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
2010/15 PFOA STEWARDSHIP PROGRAM 

October 29, 2010 

DuPont Submission 

Document 004 

Claimed as Confidential Business Information 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
2010/15 PFOA STEWARDSHIP PROGRAM 

October 29, 2010 

DuPont Submission 

Document 005 

Claimed as Confidential Business Information 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
2010/15 PFOA STEWARDSHIP PROGRAM 

October 29, 2010 

DuPont Submission 

Document 006 

Claimed as Confidential Business Information 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
Appendix D 

Facility Report on Product Content 

Aqueous Fluoropolymer Dispersion 

COMPANY SANITIZED PUBLIC COPY 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
2010/15 PFOA Stewardship Program 

Facility Report on Product Content 

COMPANY SANITIZED PUBLIC COPY 

I. CHEMICAL IDENTIFICATION 

Identify the product (e.g fluoropolymer dispersion) for which you are submitting 

information: 

Product name: Aqueous Fluoropolymer Dispersion 

Product description (including concentrations of perfluoroalkyl chemicals identified in 

Section IV below and year of production): 

Aqueous fluoropolymer dispersions of PTFE and melt copolymers [CBI] 

II. COMPANY IDENTIFICATION 

Identify the company and location of the facility submitting information: 

Company name: E. I. du Pont de Nemours and Company 

Site location: [ CBI ] 

Identify a company technical contact who can respond to inquiries about the information 

submitted: 

Technical contact : Kirsten E. Myers 

Phone: 302-999-2111 

Address: DuPont Chemicals & Fluoropolymers 

CRP 711 /11 00-G 

4417 Lancaster Pike 

Wilmington DE, 19805 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
III. PRODUCTION 

Calendar year for which you are reporting: Jan 1, 2009 to Dec 31, 2009 

Provide the amount of the product for the reporting year at each specific 

site : 

Imported (not reported) kgs/yr 

Manufactured [ CBI ] 

[ CBI ] 

IV. PRODUCT CONTENT 

A. CONCENTRATIONS OF RELEVANT PERFLUOROALKYL CHEMICALS 

Please provide the concentrations (ppb) of various perfluoroalkyl chemicals in your 

product. For chemicals for which you do not have actual data, please provide range 

estimates . 

The following is a nonexhaustive list of chemicals that should be included: 

PFOA and its salts 

" Octanoic acid, pentadecafluoro- (CAS 335-67-1) 

" Octanoic acid, pentadecafluoro- ammonium salt (CAS 3825-26-1) 

PFOA precursors 

" Octane, l,1,l,2,2,3,3,4,4,5,5,6,6,7,7, 8,8-heptadecafluoro-8-iodo- (CAS 507-63-1) 

" 1-Decanol, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 678-39-7) 

" 1-Decene, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 21652-58-4) 

" 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl ester (CAS 

27905-45-9) 

" 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl 

ester (CAS 1996-88-9) 

" 2-Decenoic acid, 3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-hexadecafluoro- (CAS 70887-84-2) 

" Decanoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 27854-31-5) 

Higher homologues 

" Dodecane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12-pentacosafluoro-12--

iodo- (CAS 307-60-8) 

" Decane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10-heneicosafluoro-l0-iodo- (CAS 423-

62-1) 

" Nonanoic acid, heptadecafluoro- (CAS 375-95-1) 

COMPANY SANITIZED PUBLIC COPYN OCTOBER 29, 2010 
" Decanoic acid, nonadecafluoro- (CAS 335-76-2) 

" 1-Decanol, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 678-39-7) 

" Decane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8-heptadecafluoro-10-iodo- (CAS 2043-53-0) 

" Dodecane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10-heneicosafluoro-12-iodo- (CAS 

2043-54-1) 

" 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl ester (CAS 

4980-53-4) 

" 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,12-

heneicosafluorododecyl ester (CAS 17741-60-5) 

B. ANALYTICAL METHODS 

PFOA concentration is measured on all production by Gas Chromatograph/Electron Capture 

Detector (GC/ECD) at the US and European sites and by High Performance Liquid 

Chromatography (HPLC) method at our Japan site . The Limit of Detection (LOD) for the 

GC/ED method is 1 ppm. The LOD for the HPLC method is 3 ppm at this time. 

COMPANY SANITIZED PUBLIC COPYN OCTOBER 29, 2010 
p. 12 

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Appendix D 

Facility Report on Product Content 

Fluoroelastomers 

COMPANY SANITIZED PUBLIC COPY 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
2010/15 PFOA Stewardship Program 

Facility Report on Product Content 

COMPANY SANITIZED PUBLIC COPY 

I. CHEMICAL IDENTIFICATION 

Identify the product (e .g., fluoropolymer dispersion) for which you are submitting 

information: 

Product name : Fluoroelastomer 

Product description (including concentrations of perfluoroalkyl chemicals 

identified in Section IV below and year of production) : 

Elastomer made from fluorinated monomers in aqueous dispersion with 

the ammonium salt of PFOA, i .e . Octanoic acid, pentadecafluoroammonium salt (CAS 3825-26-1) 

II . COMPANY IDENTIFICATION 

Identify the company and location of the facility submitting information: 

Company name: DuPont Performance Elastomers LLC 

Site location: [ CBI J 

Identify a company technical contact who can respond to inquiries about the information 

submitted: 

Technical contact: Pascal Ferrandez 

Phone : 240 994 4967 

Address: Experimental Station ESL 323/127 

200 Powder Mill Rd. Rt141 

Wilmington, Delaware 19880-0323 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
III. PRODUCTION 

Calendar year for which you are reporting: Jan 1, 2009_ to Dec 31, 2009 

Provide the amount of the product for the reporting year at each specific 

site: 

Imported (not reported) kgs/yr 

Manufactured [ CBI ] 

[ CBI ] 

IV. PRODUCT CONTENT 

A. CONCENTRATIONS OF RELEVANT PERFLUOROALKYL CHEMICALS 

Please provide the concentrations (ppb) of various perfluoroalkyl chemicals in your 

product. For chemicals for which you do not have actual data, please provide range 

estimates. 

The following is a nonexhaustive list of chemicals that should be included : 

PFOA and its salts 

" Octanoic acid, pentadecafluoro- (CAS 335-67-1) 

" Octanoic acid, pentadecafluoro- ammonium salt (CAS 3825-26-1) 

PFOA precursors 

" Octane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7, 8,8-heptadecafluoro-8-iodo- (CAS 507-63-1) 

" 1-Decanol, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 678-39-7) 

" 1-Decene, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 21652-58-4) 

" 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl ester (CAS 

27905-45-9) 

" 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl 

ester (CAS 1996-88-9) 

" 2-Decenoic acid, 3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-hexadecafluoro- (CAS 70887-84-2) 

" Decanoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 27854-31-5) 

Higher homologues 

" Dodecane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12-pentacosafluoro-12-~ 

iodo- (CAS 307-60-8) 

" Decane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10-heneicosafluoro-10-iodo- (CAS 423-

62-1) 

" Nonanoic acid, heptadecafluoro- (CAS 375-95-1) 

Part IV (cont.) 

" Decanoic acid, nonadecafluoro- (CAS 335-76-2) 

" 1-Decanol, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 678-39-7) 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
" Decane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8-heptadecafluoro-10-iodo- (CAS 2043-53-0) 

" Dodecane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10-heneicosafluoro-12-iodo- (CAS 

2043-54-1) 

" 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl ester (CAS 

4980-53-4) 

" 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,12-

heneicosafluorododecyl ester (CAS 17741-60-5) 

B. ANALYTICAL METHODS 

The method of analysis consisted of a process of extraction using high purity methanol as the 

solvent, followed by LC-MS-MS analysis of the extract as described in the following article : 

Larsen, B. S .,Kaiser, M. A., Botelho, M., Wooler, G. R., Buxton, L. W. Comparison of 

Pressurized Solvent and Reflux Extraction methods for the determination of perfluorooctanoic 

acid in polytetrafluoroethylene polymers using LC-MS-MS . Analyst. 2005, 130, 59-62. 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
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Appendix D 

Facility Report on Product Content 

Fluorotelomers 

COMPANY SANITIZED PUBLIC COPY 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
2010/15 PFOA Stewardship Program 

Facility Report on Product Content 

Confidential Business Information 

I. CHEMICAL IDENTIFICATION 

Identify the product (e.g fluoropolymer dispersion) for which you are submitting information: 

Product name: Fluorotelomer-based polymeric and surfactant products 

Product description (including concentrations of perfluoroalkyl chemicals 

identified in Section IV below and year of production) : 

Production year: 2009 

[ CBI ] 

II . COMPANY IDENTIFICATION 

Identify the company and location of the facility submitting information: 

Company name: E. I. du Pont de Nemours and Company 

Site locations : [ CBI ] 

Identify a company technical contact who can respond to inquiries about the information 

submitted: 

Technical contact: Stephen Korzeniowski 

Phone: 302-695-8672 

Address: DuPont Experimental Station 

ESL 402-5231 

Route 141 and Henry Clay 

Wilmington, DE 19803 

III. PRODUCTION 

Calendar year for which you are reporting: Jan 1, 2009 to Dec 31, 2009 

Provide the amount of the product for the reporting year at each specific site : 

Imported NA kgs/yr 

Manufactured [ CBI ] 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
IV. PRODUCT CONTENT 

A. CONCENTRATIONS OF RELEVANT PERFLUOROALKYL CHEMICALS 

Please provide the concentrations (ppb) of various perfluoroalkyl chemicals in your product. For 

chemicals for which you do not have actual data, please provide range estimates . 

The following is a nonexhaustive list of chemicals that should be included: 

PFOA and its salts 

" Octanoic acid, pentadecafluoro- (CAS 335-67-1) 

" Octanoic acid, pentadecafluoro- ammonium salt (CAS 3825-26-1) 

PFOA precursors 

" Octane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7, 8,8-heptadecafluoro-8-iodo- (CAS 507-63-1) 

" 1-Decanol, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 678-39-7) 

" 1-Decene, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 21652-58-4) 

" 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl ester (CAS 

27905-45-9) 

" 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl 

ester (CAS 1996-88-9) 

" 2-Decenoic acid, 3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-hexadecafluoro- (CAS 70887-84-2) 

" Decanoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 27854-31-5) 

Higher homologues 

" Dodecane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12-pentacosafluoro-~12-iodo-

(CAS 307-60-8) 

" Decane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10-heneicosafluoro-l0-iodo- (CAS 423-62-

1) 

" Nonanoic acid, heptadecafluoro- (CAS 375-95-1) 

" Decanoic acid, nonadecafluoro- (CAS 335-76-2) 

" 1-Decanol, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluoro- (CAS 678-39-7) 

" Decane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8-heptadecafluoro-10-iodo- (CAS 2043-53-0) 

" Dodecane, 1,1,1,2,2,3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10-heneicosafluoro-12-iodo- (CAS 

2043-54-1) 

" 2-Propenoic acid, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,10-heptadecafluorodecyl ester (CAS 

4980-53-4) 

" 2-Propenoic acid, 2-methyl-, 3,3,4,4,5,5,6,6,7,7,8,8,9,9,10,10,11,11,12,12,12-

heneicosafluorododecyl ester (CAS 17741-60-5) 

[ CBI ] 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
B. ANALYTICAL METHODS - Not CBl 

The general methods used for the analyses reported here have been published in the following 

article: 

Larsen, B.S . ; Stchur, P. ; Szostek, B. ; Bachmura, S.F. ; Rowand, R.C . ; Prickett, K.B . ; 

Korzeniowski, S.H. ; Buck, R.C. Method development for the determination of residual 

fluorotelomer raw materials and perfluorooctanoate in fluorotelomer-based products by gas 

chromatography and liquid chromatography mass spectrometry . Journal of Chromatography A. 

2006 (1110),117-124 . 

In general the LOQ was 2 ppm and LOD was 0.7 ppm. 

Unpublished improvements have been made to the PFOA method providing for an LOQ of 0.5 

ppm and an LOD of 0.15 ppm. This improved method was used in 2007 - 2009. 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
p. 23 

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2010/15 PFOA STEWARDSHIP PROGRAM 

October 29, 2010 

DuPont Submission 

Document 011 

Claimed as Confidential Business Information 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
Index of Attachments 

1a Attachment 1a - Pascagoula PFOA RESULTS LTR 01-2009 thru 06-2009, 

1 b. Attachment 1 b - Pascagoula PFOA RESULTS LTR 06-2009 thru 12-2009 

2. Fayetteville biennial report - 2002 and 2003 

3 . Fayetteville biennial report - 2004 and 2005 

3a. CBI 

3b. CBI 

4. CBI 

5. CBI 

6. CBI 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
Attachment 1 A 1.31 

Sincerely, 

IIZST CHEMICAIL CORPOF 

1001 Industrial Road Pascagoula . MS 39581-3237 USA 

DO Box 7005 Pascagoula MS 39568-7005 USA 

228 762-0870 Fax : 228 769-5355 

S First Chemical Corporation 

A DuPont Company 

August 25, 2009 

Certified Mail No 7008 1830 0004 9185 8334 

Return eceivt Requested 

Mr . Toby Cook, PE 

Environmental Permits Division 

Mississippi Department of~Environmental Quality 

P O Box 2249 

Jackson, MS 39225-2249 

Dear Mr Cook: 

RE: MSP090360, Cc 

Please find attached First Chemical Corporation's PFOA discharge results for our w: 

January through Tune, 2009 as required by the above referenced discharge permit. C 

nuintained on site and can be made readily available to you or your agency upon rec 

collected as 24-hour composite samples and analyzed by an independent contract lat 

a minimum detection level of less than one (1-0) part per billion (ppb). The results a 

concentration and mass loading.. 

If you have any questions or need any further information, please contact Cari Field, 

228-938-2264 

James Freeman 

Operations and Maintenance N 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
/ 

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OCTOBER 29, 2010 
Attachment l R 

1001 Industrial Road Pascagoula, MS 39581-3237 USA 

P 0 Box 7005 Pascagoula MS 39568-7005 USA 

228 762-0870 Fax: 228 769-5355 

S First Chemical Corporation 

A DuPont Company 

February 24, 2010 

Certified Mail No : 7008 1830 0004 9185 8556 

Return Receipt Req-uested 

Ms Carla Blown 

Environmental Permits Division 

Mississippi Department of Environmental Quality 

P O. Box 2249 

Jackson, MS 39225-2249 

RE: MSP090360, Conditions M-1 & S-1 

Dear Ms Brown: 

Please find attached First Chemical Corporation's PFOA discharge results for our wastewater for the months of 

June through December, 2009 as required by the above referenced dischage permit Copies of all lab results an 

maintained on site and can be made readily available to you or your agency upon request All samples were 

collected as 24-hour composite samples and analyzed by an independent contract lab using a test method having 

a minimum detection level of' less than one (1 .0) part per billion (ppb) The results are reported in units of both 

concentration and mass loading 

If you have any questions or need any further information, please contact Can Field, Environmental Affairs, at 

228-938-2264 

Since:ely, 

FIRSI CHEMICAL CORPORA I ION 

Whit Griffin 

Plant Manage 

_p . 33 

_ 

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COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
p. 35 

ATTACHMENT 2 

Biennial Report for the Manufacture of APFO 

Calendar Years of 2002 and 2003 

DuPont Company - Fayetteville Works 

Note: The information contained in this document is submitted voluntarily and may be subject to future 

revision and/or modification . 

CONFIDENTIAL BUSINESS INFORMATION IS BRACKETED 

This report is submitted pursuant to commitments made by DuPont in a March 14, 2003, Letter of Intent 

(LOI) to Stephen L. Johnson, Assistant Administrator, USEPA, entitled "Voluntary Actions to Evaluate 

and Control Emissions of Ammonium Perfluorooctanoate (APFO). 

Pursuant to Addendum III of this LOI, provision 5, a facility manufacturing APFO is required to, 

beginning in the year after production commences, and continuing for five consecutive years f6llowing, 

for the prior calendar year, report to EPA biennially the following information on a calendar year basis: 

1 . Annual production volume of APFO; 

2 . Emissions per facility (air, water, waste) ; 

3 . Summary report of groundwater monitoring results; 

4. Summary report of surface water monitoring results; 

5 . Workplace industrial hygiene monitoring; and 

6. Summary data on employee blood monitoring results. 

This report provides the above information for calendar years 2002 and 2003 . 

General Facility Information 

Company Name : E. 1. du Pont de Nemours and Company 

Site Location : Site where APFO is manufactured: 

DuPont Company - Fayetteville Works 

22828 NC Highway 87 W 

Fayetteville, NC 28306-7332 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
Annual production volume of APFO ATTACHMENT 2 

The DuPont Company - Fayetteville Works' APFO Manufacturing Facility commenced 

production in late 2002. The following table shows the total production volume of APFO for 

calendar years 2002 and 2003. 

Calendar Year APFO Production 

2002 [CBIJ 

2003 [ CBI] 

1. Emission per facility (air, water, waste) ; 

Confidential 

Business 

Information 

The DuPont Company - Fayetteville Works' APFO Manufacturing Facility has estimated the 

quantity of PFOA emitted to the atmosphere as air emissions using engineering calculations . In 

addition, stack testing performed in 2003 showed the PFOA emissions to be less than the analytical 

detection limit.' Annually a sample of the site's surface water discharge to the Cape Fear River is 

analyzed for PFOA; however that monitoring shows the PFOA to be less than the quantification 

limit of the analytical method. The waste emissions are the quantities of PFOA, on a dry basis, that 

are estimated to have been present in the various solid waste streams transferred from the 

Fayetteville Works site . The following table gives the estimated emissions of APFO to specific 

media from the Fayetteville Works during the subject years : 

Emission Media 2002 2003 

Air 17 lb . 22 lb. 

Water Note 1 NQ 

Waste 35 lb. 3,236 lb. 

Note 1 : Due to the late start-up of the APFO Manufacturing Facility and the short 

duration of the 2002 production run, no surface water monitoring occurred 

in 2002 . 

NQ =1ess than the practical analytical quantification limit of 0.05 pg/L 

' While APFO is the substance manufactured at the facility, the substance measured by analytical techniques is the 

perfluorooctanoate anion (PFOA) 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
p. 37 

2. Summary report of groundwater monitoring results 

In 2002, the DuPont Company - Fayetteville Works performed air dispersion modeling to determine 

the most probable locations for the atmospheric deposition of PFOA from the new manufacturing 

facility. New monitoring wells were installed in the surficial aquifer at the two locations predicted by 

the modeling. 

In 2003, the Fayetteville Works site began annual monitoring of the groundwater for PFOA. The 

monitoring involved the two newly installed wells described above, and included two existing 

monitoring wells. 

Groundwater monitoring conducted in January and March 2003 showed no quantifiable levels of 

PFOA in the two new wells and the existing well at the Old Biosludge Lagoon (SMU-O1, SWM-02, 

and MW-1 S respectively). These monitoring events did indicate levels of PFOA above the 

quantification limit at the existing well located upgradient of the Nafion® Common Sump . 

Following discussions with the North Carolina Division of Waste Management, the 2004 

groundwater monitoring was expanded to include three existing wells downgradient of the Nafion® 

Common Sump area. The 2004 monitoring results were virtually identical to those in 2003, and the 

three above-mentioned downgradient wells showed PFOA concentrations of 0 .303 ~tg/L, 1 .530 ~tg/L, 

and 0.123 ~tg/L respectively . It is believed that the detected PFOA is a result of a historical release 

originating from the Nafion© manufacturing area's common process wastewater sump. That source 

has been eliminated from the site . 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
The following table shows the groundwater 

monitoring analytical results for 2003 and 

2004Sample Name 

(Monitorin g Well Descri ption) 

Monitoring 

Date 

PFOA 

(~Lg/L) 

SMU-O1 01/27/03 <0 .01 

(New well on River Pump Road; 03/27/03 <0 .01 

East of APFO Facility) 02/04/04 <0.01 

SW-02 01/27/03 <0.01 

(New well at Construction Gate entrance ; 03/27/03 <0.01 

Southwest of APFO Facility) 02/04/04 <0.01 

MW-1 S 01/28/03 <0.05 

(Existing well at Old Biosludge Lagoon SWMU O1/28/03 <0 .05 

by Central WWTP; South of APFO Facility) 03/27/03 <0.05 

02/04/04 <0.05 

NAF-01 01/27/03 0 .065 

(Existing well upgradient of Nafion® Common 03/27/03 0.068 

Sump; Southeast of APFO Facility) 03/27/03 0.063 

02/04/04 0.062 

NAF-02 

(Existing well downgradient of Nafion© 

Common Sump; Southeast of APFO Facility) 

02/04/04 0.303 

NAF-03 

(Existing well downgradient of Nafion® 

Common Sump; Southeast of APFO Facility) 

02/04/04 1 .530 

NAF-04 

(Existing well downgradient of Nafion® 

Common Sump; Southeast of APFO Facility) 

02/04/04 0.123 

3. Summary report of surface water monitoring results 

As reported in Item 1 above, the DuPont Company - Fayetteville Works annually monitors for PFOA 

in the site's surface water discharge to the Cape Fear River. The monitoring conducted in both 2003 

and 2004 shows the PFOA to be less than the quantification limit of the analytical method, or less 

than 0.05 ~tg/L. No surface water monitoring occurred in 2002 due to the late start-up of -the APFO 

Manufacturing Facility and the short duration of the 2002 production run. 

4. Workplace industrial hygiene monitoring 

The DuPont Company - Fayetteville Works began workplace monitoring for PFOA with the start up 

of the APFO Manufacturing Facility in 2002. The workplace monitoring in 2002 and 2003 consisted 

of stationary area monitors that sampled the building air space for twelve (12) continuous hours. 

These sampled locations are limited access restricted areas in which personnel wear both respiratory 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
p. 39 

and dermal personnel protection. The analytical results reported in the following table are the 12-

hour time weighted average (TWA) PFOA concentration values . 

Year 

Sample Type Number Minimum Maximum Average 

of Conc. Conc. Conc. 

Samples (mg/m') (mg/m3) (mg/m') 

2002 Area 12-hr 4 0.008 0.024 0.017 

TWA 

2003 105 0.000 0.292 0.010 

mg/m3 = milligrams per cubic meter 

5. Summary data on employee blood monitoring results 

At the DuPont Company - Fayetteville Works, blood serum levels of PFOA have been :measured 

since 2002. A summary of results of employees with identified APFO exposure potential in 2002 and 

2003 is presented in the table below. The entire data set of blood concentrations is available upon 

request. 

Number of Minimum Maximum Average 

Concentration Concentration Concentration Samples 

(ppm) (ppm) (ppm) 

Year 

2002 17 0.004 0.020 0.011 

2003 44 0.008 2.280 0.217 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
p. 40 

ATTACHMENT 3 

LETTER OF INTENT SUBMISSION 

Biennial Report for APFO Manufacture 

Calendar Years of 2004 and 2005 

E. I. du Pont de Nemours and Company 

Fayetteville Works Site 

Bladen County, North Carolina 

Note: The information contained in this document is submitted voluntarily and may be subject to future 

revision and/or modification . 

CONFIDENTIAL BUSINESS INFORMATION IS BRACKETED 

This report is submitted pursuant to commitments made by E.I . du Pont de Nemours and Company 

(DuPont) in a March 14, 2003, Letter of Intent (LOI) to Stephen L. Johnson, Assistant Administrator, 

United States Environmental Protection Agency (EPA), entitled "Voluntary Actions to Evaluate and 

Control Emissions of Ammonium Perfluorooctanoate (APFO)". 

Pursuant to Addendum III, provision 5, of this LOI, a facility manufacturing APFO will, beginning in the 

year after production commences, and continuing for five consecutive years following, for the prior 

calendar year, report to EPA biennially the following information on a calendar year basis : 

7 . Annual production volume of APFO; 

8 . Emissions per facility (air, water, waste) ; 

9. Summary report of groundwater monitoring results; 

10. Summary report of surface water monitoring results; 

11 . Workplace industrial hygiene monitoring; and 

12. Summary data on employee blood monitoring results. 

This report provides the above information for calendar years 2004 and 2005, and includes data received 

as of May 15, 2006, for the Fayetteville Works site ("the site") . 

General Facility Information 

Company Name: E. I. du Pont de Nemours and Company 

Site Location: Site where APFO is manufactured: 

DuPont Company - Fayetteville Works 

22828 NC Highway 87 W 

Fayetteville, NC 28306-7332 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
p. 41 

ATTACHMENT 3 

6. Annual production volume of APFO 

The following table shows the total production volume of APFO for calendar years 2004 and 2005 . 

Calendar Year APFO Production 

2004 [CBI] 

2005 [CBIJ 

7. Emission per facility (air, water, waste) 

Confidential 

Business 

Information 

For air emissions, the quantity of APFO emitted to the atmosphere in 2004 and 2005 fronn the site 

was estimated using engineering calculations . 

For surface water emissions, annually a sample of the site's final surface water discharge to the Cape 

Fear River is tested for the presence of APFOZ. For 2004 and 2005, results showed APFO to be less 

than the analytical method's quantification limit of 0.050 ~tg/L (0.050 parts per billion) . The reported 

emissions were calculated using this analytical result (<0.050 ~tg/L) and the average discharge flow 

rate (12.397 million gallons per day in 2004 and 10.441 million gallons per day in 2005). 

The waste emissions are the quantities of APFO, on a dry basis, that are estimated to have been 

present in the various solid waste streams transferred from the Fayetteville Works site . 

The following table gives the estimated emissions of APFO to specific media from the Fa.yetteville 

Works during the subject years : 

Media 2004 2005 

Air 47.3 lb. 55.5 lb. 

Water <1.9 lb. <l. 6 lb. 

Waste 9,914 lb. 10,019 lb. 

8. Summary report of groundwater monitoring results 

In 2004, 2005, and 2006, the Fayetteville Works site continued the annual groundwater monitoring 

for APFO that began in 2003 . The monitoring involved both newly installed wells and existing 

monitoring wells . All groundwater and surface water concentrations are reported as APFO (see 

footnote 1 on this page). This report also provides results available as of May 30, 2006 

2 While APFO is the substance manufactured at the facility, the substance measured by analytical techniques is the 

perfluorooctanoate anion (PFO-). The commercial laboratory converts this analytical result to an APFO value via molecular 

weight calculations . For consistency with the previously submitted biennial report for this site, results are reported as the 

calculated APFO values . 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
ATTACHMENT 3 

The following table reports the groundwater monitoring analytical results, both onsite and 

offsite, for 2004, 2005, and year-to-date 2006 : 

Summary of Groundwater Analytical Results 

DuPont Fayetteville Works 

2004 -2006 

Sample ID Monitoring APFO 

(Groundwater Monitoring Well Description) Date GLg/L,) 

MW-1S 02/03/04 NQ (<0.050) 

Onsite monitoring well located near the inactive Biosludge 06/20/05 NQ (<0.050) 

L ag oon area in the p erched g roundwater above a local clay 

feature ; South of the APFO Manufacturing Facility . O1/24/06 0 .038 

MW-2S 

Onsite monitoring well located near the inactive Biosludge 

06/20/OS NQ (<0 .050) 

Lagoon area in the perched groundwater above a local clay 

feature ; South of the APFO Manufacturing Facility . 

MW-5D 

Onsite monitoring well located near the inactive Biosludge 

06/20/OS NQ (<0.050) 

Lagoon area in the surficial groundwater beneath a local clay 

feature ; South of the APFO Manufacturing Facility . 

MW-7S 

Onsite monitoring well located near the inactive Biosludge 

Lagoon area in the perched groundwater above a local clay 10/18/OS 0.047 

feature ; South of the APFO Manufacturing Facility . 

MW-10D 

Onsite monitoring well located near the inactive Biosludge 

06/20/OS ND (<0.100) 

Lagoon area in the surficial groundwater beneath a local clay 

feature ; South of the APFO Manufacturing Facility. 

NAF-01 02/04/04 0.062 

Onsite monitoring well located upgradient of the Nafion® 06/15/05 0.104 

Common Sump in the perched groundwater above a local clay 10/13/05 0.151 

feature ; Southeast of the APFO Manufacturing Facility . 02/O1/06 0.115 

NAF-02 02/04/04 0.307 

Onsite monitoring well located downgradient of the Nafion® 06/15/05 0.338 

Common Sump in the perched groundwater above a local clay 10/14/05 0.24~6 

feature ; Southeast of the APFO Manufacturing Facility . 02/O1/06 0 .316 

NAF-03 02/04/04 1 .530 

Onsite monitoring well located downgradient of the Nafion® 06/15/05 0.663 

Common Sump in the perched groundwater above a local clay 10/14/05 0.872 

feature ; Southeast of the APFO Manufacturing Facility . O1/25/06 0.4-3 4 

~Lg/L = micrograms per liter or parts per billion 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
Summary of Groundwater Analytical Results 

DuPont Fayetteville Works 

2004 -2006 

ATTACHMENT .3 

Sample ID 

(Groundwater Monitoring Well Description) 

Monitoring 

Date 

APFI3 

GLg/L) 

NAF-04 02/04/04 0.124 

Onsite monitoring well located downgradient of the 06/17/05 0.093 

Nafion® Common Sump in the perched groundwater 10/18/05 0 .21 :2 

above a local clay feature; Southeast of the APFO 02/O1/06 0.06 .5 

NAF-05A 

Onsite monitorin well located downgradient of the 

11/11/04 0.239 

g 

Nafion® Common Sump in the perched groundwater 

above a local cla feature.- Southeast of the APFO 

10/13/05 0.187 

NAF-05B 

Onsite monitoring well located downgradient of the 

Nafion® Common Sump in the surficial groundwater 

beneath a local clay feature; Southeast of the APFO 

Manufacturing Facility. 

11/11/04 ND (<0.010) 

NAF-06 06/16/05 0 .262 

Onsite monitoring well located northeast of the 

Fluoromonomers production area in the perched 10/14/05 0.535 

groundwater above a local clay feature; Southeast of the 

O1/31/06 0.303 

NAF-07 06/16/05 NQ (<0.050) 

Onsite monitoring well located northeast of the 

Fluoromonomers production area in the perched 10/14/05 0.085 

groundwater above a local clay feature; Southeast of the 

F M n f in Facil ity. 

O1/31/06 0 .065 

NAF-08A 06/17/05 0.072 

Onsite monitoring well located southeast of the 

Fluoromonomers production area in the perched 10/13/05 0.172 

groundwater above a local clay feature' Southeast of the 

cility 01/31/06 0.053 

NAF-08B 06/21/05 ND (<0.010) 

Onsite monitoring well located southeast of the 

Fluoromonomers production area in the surficial 10/13/05 NQ (<0 .011) 

groundwater beneath a local clay feature; Southeast of O1/31/06 NQ (<0.012) 

NAF-09 06/16/05 0.080 

Onsite monitoring well located south of the 

i h h d 

10/13/05 0.1121 

Fluoromonomers production area n t e perc e 

groundwater above a local clay feature; Southeast of the 02/O1/06 0.086 

p,g/L = micrograms per liter or parts per billion 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
Summary of Groundwater Analytical Results 

DuPont Fayetteville Works 

2004- 2006 

Attachment 3 

Sample ID Monitoring APF0 

(Groundwater Monitoring Well Description) Date (gg/L) 

NAF-10 06/16/05 0.122 

Onsite monitoring well located south of the 10/13/05 0.134 

Fluoromonomers pro d uct i on area i n th e perc h e d 

oundwater above a local clay feature; Southeast of the 02/O1/06 0.0813 

NAF-11A 07/05/05 NQ (<0.05) 

Onsite monitoring well located northeast of the 

Fluoromonomers production area in the perched 10/17/05 0.021 

groundwater above a local clay feature; Southeast of the 01/26/06 0 .048 

NAF-11 B 

Onsite monitoring well located northeast of the 07/05/05 ND (<0.010) 

Fluoromonomers production area in the surficial 

groundwater beneath a local clay feature; Southeast of 

the APFO 

10/17/05 ND (<0.002) 

4328MLR 11/16/05 0.011 

Offsite private residential drinking water well; Northeast 

of the APFO Manufacturing Facility. 

11/16/05 NQ (<0.022) 

6999PED 11/16/05 ND (<0.005) 

Offsite private residential drinking water well; 

Northwest of the APFO Manufacturing Facility. 

11/16/05 ND (<0.002) 

PW-01 

Offsite private residential drinking water well; West of O1/25/06 ND (<0.002) 

the APFO Manufacturing Facility. 

PW-02 

Offsite transient noncommunity public water system; O1/25/06 ND (<0.002) 

West of the APFO Manufacturing Facility . 

PW-03 

Offsite transient noncommunity public water system ; O1/25/06 ND (<0.002) 

Southeast of the APFO Manufacturing Facility . 

PW-04 

Onsite transient noncommunity public water system ; O1/25/06 ND (<0.002) 

Northwest of the APFO Manufacturing Facility. 

PW-05 

Offsite transient noncommunity public water system ; O1/25/06 NQ (<0.012) 

North-northwest of the APFO Manufacturing Facility. 

~Lg/L = micrograms per liter or parts per billion 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
Summary of Groundwater Analytical Results 

DuPont Fayetteville Works 

2004 -2006 

ATTACHMENT .3 

Sample ID Monitoring APFtJ 

(Groundwater Monitoring Well Description) Date (p.g/L) 

PW-06 

Offsite transient noncommunity public water system; O1/25/06 ND (<0 .002) 

North-northwest of the APFO Manufacturing Facility. 

PW-07 

Offsite private residential drinking water well ; South- 03/30/06 ND (<0.001) 

southwest of the APFO Manufacturing Facility. 

PZ-04 

Onsite monitoring well located southeast of Naflon® 02/O1/06 0.617 

Common Sump in the perched groundwater above a local 

clay feature; Southeast of the APFO Manufacturing 

Facility. 

PZ-12 10/17/05 0.021 

Onsite monitoring well located southeast of the APFO 12/13/05 0.015 

Manu f actur i ng F ac ili ty i n t h e perc h e d groun d wa t er a b ove 

a local clay feature. 

Ol/26/06 0 .018 

PZ-15 

Onsite monitoring well located northwest of the PMDF O1/26/06 0.032 

Facility in the perched groundwater above a local clay 

feature; South-southeast of the APFO Manufacturing 

Facility. 

PZ-16 

Onsite monitoring well located southeast of the PMDF O1/26/06 NQ (<0.012) 

Facility in the perched groundwater above a local clay 

feature; South-southeast of the APFO Manufacturing 

Facility. 

SMW-O1 02/03/04 ND (<0.010) 

Onsite monitoring well located east of the Construction 06/20/05 ND (<0.010) 

G ate entrance near Hi g h way 87 i n th e sur fi c i a l aqu if er; 

Southwest of the APFO Manufacturing Facility. 

O1/24/06 ND (<0.002) 

SMW-02 02/03/04 ND <0.010 

Onsite monitoring well located north of the River Pump 06/20/05 ND <0 .010 

Road, north of the Fluoromonomers manufacturing area, 09/06/05 N <0 .007 

in the perched groundwater above a local clay feature; 10/17/05 ND <0 .002 

East of the APFO Manufacturing Facility. O1/26/06 NQ (<0.012) 

p,g/L = micrograms per liter or parts per billion 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 201.0 
Summary of Groundwater Analytical Results 

DuPont Fayetteville Works 

2004 -2006 

ATTACHMENT .; 

Sample ID Monitoring APFO 

(Groundwater Monitoring Well Description) Date (pg/L,) 

SMW-02B 

Onsite monitoring well located north of the River Pump 

Road, north of the Fluoromonomers manufacturing area, 10/17/05 ND (<0.022) 

in the surficial groundwater beneath a local clay feature; 

East of the APFO Manufacturing Facility . 

SMW-04B 10/17/05 2.25 

Onsite monitoring well located north of the River Pump 11/10/05 2.51 

R oa d , nor th o f th e APFO Manufacturin g Facilit y, in the 

surficial groundwater beneath a local clay feature. O1/24/06 1 .30 

SMW-05 10/17/05 147 

Onsite monitoring well located north of and adjacent to 

the APFO Manufacturing Facility, in the perched 12/13/05 765 

SMW-05P 

Onsite monitoring well located north of and adjacent to 02/22/06 6.5 

the APFO Manufacturing Facility, in the surficial 

SMW-06 12/13/05 0.224 

Onsite monitoring well located east of and adjacent to the 

APFO Manufacturing Facility, in the perched Ol/26/06 0.261 

SMW-07 10/17/05 0 .019 

Onsite monitoring well located south of and adjacent to 12/13/05 NQ (<0.012) 

the APFO Manufacturing Facility, in the perched 

Ol/26/06 NQ (<0.012) 

#562877 - Domestic H20 

Inactive onsite drinking water well located near the 07/15/04 ND (<0.010) 

Powerhouse area, screened in the Upper Cape Fear 

#562878 - Domestic H20 

Inactive onsite drinking water well located near the 07/15/04 ND (<0.010) 

Powerhouse area, screened in the Upper Cape Fear 

INSITU #1 Shallow 

Onsite monitoring well located near the facility's 12/20/05 NQ (<0 .013) 

northern property line in the upper level of the surficial 

urnrnmnwnrer~ North -nnrrneacr of the farri ) 

p.g/L = micrograms per liter or parts per billion 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 20110 
Summary of Groundwater Analytical Results 

DuPont Fayetteville Works 

2004 -2006 

ATTACHMENT .3 

Sample ID Monitoring APFIJ 

(Groundwater Monitoring Well Description) Date (n/L) 

INSITU #2 Deep 

Onsite monitoring well located near the facility's 12/20/OS ND (<0.027) 

northern property line in the lower level of the surficial 

groundwater; Northwest of the APFO Manufacturing 

Facility . 

INSITU #2 Shallow 

Onsite monitoring well located near the facility's 12/20/05 NQ (<0.013) 

northern property line in the lower level of the surficial 

groundwater; Northwest of the APFO Manufacturing 

Facility. 

LTW-01 

Onsite monitoring well located near the facility's eastern 02/02/06 0.033 

property line along the Cape Fear River in the surficial 

groundwater; East of the APFO Manufacturing Facility . 

LTW-02 

Onsite monitoring well located near the facility's eastern 

property line along the Cape Fear River in the surficial 02/02/06 ND (<0.002) 

groundwater; East-southeast of the APFO 

Manufacturing Facility. 

LTW-03 

Onsite monitoring well located near the facility's eastern 

property line along the Cape Fear River in the surficial 02/O1/06 ND (<0.002) 

groundwater; East-southeast of the APFO 

Manufacturing Facility . 

LTW-04 

Onsite monitoring well located near the facility's eastern O1/24/06 ND (<0.002) 

property line along the Cape Fear River in the surficial 

groundwater; Southeast of the APFO Manufacturing 

Facility . 

LTW-05 

Onsite monitoring well located near the facility's eastern 02/02/06 ND (<0.002) 

property line along the Cape Fear River in the surficial 

groundwater; Southeast of the APFO Manufacturing 

Facility. 

4g/L = micrograms per liter or parts per billion 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
9. Summary report of surface water monitoring results 

The Fayetteville Works facility annually monitors for APFO in the site's surface 

water discharge to the Cape Fear River. This monitoring location is the site's final 

effluent discharge at the NPDES permitted Outfall 002 . The results of that 

monitoring are shown in the following table: 

Surface Water Sample ID Monitoring APFO 

(Sample Description) Date (pg/L) 

Outfa11002 02/03/04 NQ 

Final NPDES permitted wastewater discharge; Located (<0.0~50) 

south of the central wastewater treatment plant and 06/20/05 NQ 

south of the APFO Manufacturing Facility . (<0.050) 

01/24/06 0.025 

p,g/L = micrograms per liter or parts per billion 

Monitoring of stagnant water in a stormwater conveyance ditch was conducted in 

2005 . While this stagnant water meets the definition of a surface water, it should be 

noted that this water consisted of exclusively non-flowing puddles of water at the 

time of the sampling. The results of that monitoring are shown in the following 

table: 

Surface Water Sample ID 

(Sample Description) 

Monitoring 

Date 

APFO 

(pg/L) 

SW-01 06/20/2005 0 .100 

Stormwater ditch north of Fluoromonomers area; East 09/06/2005 0 .129 

of the APFO Manufacturing Facility . 10/07/2005 0.068 

SW-02 06/20/2005 0.135 

Stormwater ditch north of Fluoromonomers area; East 09/06/2005 0.302 

of the APFO Manufacturing Facility. 10/07/2005 0.157 

SW-03 06/21/2005 0-142 

Stormwater ditch north of Fluoromonomers area; East 09/06/2005 0.298 

of the APFO Manufacturing Facility. 10/07/2005 0.149 

SW-04 06/20/2005 0.093 

Stormwater ditch north of Fluoromonomers area; East 10/07/2005 0.147 

SW-05 

Stormwater ditch north of Fluoromonomers area; East 

of the APFO Manufacturing Facility. 

10/07/2005 0.139 

p,g/L = micrograms per liter or parts per billion 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
ATTACHMENT :3 

Sampling of two unnamed tributaries to the Cape Fear River, and two streams 

flowing to one of those tributaries, was conducted in 2006. It is believed that the 

base flow in these tributaries is primarily from expressed groundwater, with 

additional episodic flow from stormwater runoff. The surface water samples 

described in the table that follows were taken during base flow conditions . The 

results of that monitoring are shown in the following table: 

Surface Water Sample ID Monitoring APFO 

(Sample Description) Date (pg/L) 

SW-06 

Located east of the Fluoromonomers area, in an O1/25/2006 0.027 

unnamed tributary (#1) to the Cape Fear River 

SW-07 

Located east of the Fluoromonomers area, in a stream O1/25/2006 0.040 

(#1) flowing into the unnamed tributary # 1 

SW-08 

Located east of the Fluoromonomers area, in a stream O1/25/2006 0.032 

(#2) flowing into the unnamed tributary #1 

SW-09 

Located east of the PMDF manufacturing area, in an O1/25/2006 0.027 

unnamed tributary (#2) to the Cape Fear River 

pg/L = micrograms per liter or parts per billion 

In 2005, the site's non-contact cooling water and the influent and effluent of the river 

water sediment basin were sampled. Both of these waters ultimately discharge 

through the site's NPDES permitted Outfall 002 . The non-contact cooling water is 

raw river water that is pumped from the Cape Fear River, through equipment to 

remove heat, and then back to the river. The river water sediment basins receive 

river water and its sediment that has been removed from the river water as a result of 

clarification. The results of that monitoring are shown in the following table: 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
Surface Water Sample ID Monitoring APF7O 

(Sample Description) Date (~Lg/L) 

NR-01 

Non-contact, once-through cooling water flowing in the 09/06/2005 0.0',77 

open ditch south of the Fluoromonomers area; East of 

the APFO Manufacturin Facilit 

RW-O 1 

Influent to the filtered river water sediment basin 09/06/2005 0.083 

located west of the Fluoromonomers area; East of the 

APFO Manufacturin Facilit 

RW-02 

Effluent from the filtered river water sediment basin 09/06/2005 0.081 

located west of the Fluoromonomers area; East of 

APFO the Manufacturin Facility 

~Lg/L = micrograms per liter or parts per billion 

10. Workplace industrial hygiene monitoring 

The DuPont Company - Fayetteville Works began workplace monitoring for 

perfluorooctanoic acid (PFOA) with the start up of the APFO Manufacturing Facility 

in 2002. The workplace monitoring in 2004 and 2005 consisted of stationary area 

monitors that sampled the building air space for twelve (12) continuous hours. 

These sampled locations are limited access restricted areas in which personnel wear 

both respiratory and dermal personnel protection. The 12-hour time weighted 

average (TWA) PFOA concentration values are shown in the following table: 

Number pFOA PFOA PFOA 

Year Sample Type Of Minimum Maximum Average 

Samples Conc. Conc. Conc. 

(mg/m3) (mg/m3) (mg/in ;, 

2004 Area 12-hour 85 0.00021 1.9 0.041 

2005 TWA 42 <0.00021 0.061 0.0081 

mg/m3 = milligrams per cubic meter 

11 . Summary data on employee blood monitoring results 

At the DuPont Company - Fayetteville Works, blood serum levels of PFOA have 

been measured since 2002. A summary of results of employees with identified 

APFO exposure potential in 2004 and 2005 is shown in the following table: 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
PFOA PFOA PFOA 

Number of Minimum Maximum Average 

Year Samples Concentration Concentration Concentration 

(ppm) (ppm) (ppm) 

2004 56 0.0027 1 .87 0.437 

2005 64 0.0031 4.54 0.504 

ppm =parts per million 

Additional monitoring information 

Additional APFO monitoring information that is not specified by the LOI is being 

reported in Appendix A of the site's Phase II RCRA Facility Investigation (RFI) Report . 

This additional information will be the analytical results for APFO concentrations of 

samples taken of soil, sediment, ambient air, and the Cape Fear River. A copy of the 

Phase II RFI Report was submitted to the N.C. Division of Waste Management on June 

30, 2006 and will be provided to EPA Docket OPPT-2003-0012 as a separate submission. 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 201t0 
ATTACHMENT 3A 

Claimed as Confidential Business Information 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 20 LO 
ATTACHMENT 3B 

Claimed as Confidential Business Information 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
ATTACHMENT 4 

Claimed as Confidential Business Information 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
ATTACHMENT 5 

Claimed as Confidential Business Information 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010 
ATTACHMENT 6 

Claimed as Confidential Business Information 

COMPANY SANITIZED PUBLIC COPY OCTOBER 29, 2010