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Page 1 of 5 2 nd Quarter 2011 Progress Report April 1, 2011

– June 30 , 2011 Biodegradation Supplemental Environmental Project (SEP A )

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 calend ar

- year quarter. This report which is due July 31 , 2011 satisfies said requirement.

1. Description of Activities Undertaken

A. Panel Administrator

As reported in the previous Quarterly Report, the SEP Panel submitted its “Preliminary Conclusions and

Recommend ations” report on the biodegradation pilot studies to EPA and DuPont on December 9 , 2010

. In its Preliminary Conclusions and Recommendations Report, the Panel noted that it would need to see the Certificates of Analysis for the test materials before it co uld make specific recommendations on the test substance(s) or the analytes to be measured in the long

- term study, as required by the SEP (Appendix A, Sect. V.A.2.c & d). Shortly thereafter, it was agreed to by EPA and DuPont that the Panel’s Final Repor t on these studies should be deferred until the characterization report from MPI Research was received and that the Panel’s Final Report would encompass its assessment of both the biodegradation pilot studies and the an alytical characterization data.

In April 2011 a revised draft of the SEP Panel’s Final Report on the biodegradation pilot studies was prepared and distributed to the Panel, incorporating Panel member comments on the previous draft. The Panel also was informed of modifications to the protoc ol for the long

- term biodegradation studies that had been agreed to between EPA and DuPont since submission of the Panel’s “Preliminary Conclusions and Recommendations Report” report in December.

During this Quarter, ILSI RF provided monthly updates to th e Panel on the status of the analytical characterization work and the estimated completion date of the Analytical Characterization Lab’s report, based on input received from DuPont. ILSI RF is expecting to receive the report from the Analytical

Characteri zation Lab in late August 2011.

B. MPI Research Characterization Work

DuPont continued to host monthly conference calls/webmeetings with MPI and EPA to address technical issues and answer any questions EPA may have on the monthly progress report s submitted b y the laboratory. On March 25, 2011, DuPont submitted a scope of work modification document to EPA for review and approval (Email from Robert Tucker 3/25/11 10:28AM). MPI is not realizing the economies of scale they had expected when they originally subm itted their proposal for the SEP work, as a result of the reduced scope of work. They also had not planned for modifications to the extraction procedure and the effort associated with it. Their proposed changes were outlined in the document submitted to EPA. DuPont sought EPA's approval, so that DuPont may process the changes and allow MPI to be paid for the work they are performing. EPA approved the scope of work modifications on June 7, 2011 (Email from Mark Garvey 6/7/11 11:43 AM).

MPI’s technical w ork this quarter focused on characterization of the A3 pilot test group

. A proposal to conduct testing to determine if an adjustment in sample size would improve the extractability and increase

the amount of extraction solvent recovered was submitted to E PA for approval on February 9, 2011 (Email from Paul Connolly 2/9/11 11:48AM). With some modifications proposed by EPA, the proposal was approved on March 21, 2011 (Email from Mark Garvey 3/21/11 5:10 PM). This work was carried

out and indicated there wa s a lack of separation between the MTBE and the aqueous dispersion in water when the volume of water was 15 mL. Following additional discussions with the team, it was decided toTSCA

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Page 2 of 5 change the amount of aqueous dispersion to approximately 1.455 mg and the vol ume of water to 1 mL. The results of this work in conjunction with discussions held with DuPont and WLI led the team to suspect that the GC/MS inlet te mperature may have c a u sed thermal degradation of the polymer into the 8

- 2 FTOH. MPI re

- injected the pre viously generated MTBE extract s at a lower inlet temperature. The

results provided info rmation on the effect of reducing the GC inlet temperature from 200 to 150 degrees

C on 8

- 2 FTOH concentrations in the MTBE e xtracts. Initial results showed an 80% con centration

reduction of 8

- 2 FTOH in the first three MTBE extracts (A, B, C1) from the two polymers in two trials (i.e., C0479706 Trial 2 and C0479715 Trial 3 )

. As a result, proposals for additional method development work were submitted by MPI to EPA and DuPont.

On May 16, 2011, MPI proposals for additional development work were submitted to EPA for review and approval (Email from Bill Berti 5/16/11 4:37 PM) . One involved Tetrahydrofuran (THF) dissolutions of the two samples from the A3 pilot test group in duplicate and only for the analytes PFOA by LC/MS/MS

and 8

- 2 FTOH also by LC/MS/MS. The second involved MTBE Extracts of the two samples from the A3 pilot test group in duplicate and only for the analytes PFOA by LC/MS/MS and 8

- 2 FTOH also by

LC/MS/MS. EPA approved these proposals on May 25, 2011 (Email from Mark Garvey 5/25/11 12:54 PM). MPI, DuPont, and EPA agreed to evaluate the THF preparations of the A3 pilot test group samples rather then perform MTBE extractions. MPI developed preliminary chro matographic and mass spec

conditions for the 8

- 2 FTOH compound and presented the data to DuPont and EPA. On June 22 , a conference call was held to discuss the data. At that time, a request was made to include the 6

- 2 and 10

- 2 FTOH compounds in the analys is. MPI is continuing towards the goal of analyzing A3 samples dissolved

in THF. As of the end of the quarter, MPI was tasked with constructing a time

- line and estimated costs for: 1) LC/MS method development for 6:2, 8:2, and 10:2 FTOH 2) validation pr otocol amendment and approval, 3) validation study, 3) new COA protocol or protocol amendment and revised QAPP and approvals, 4) perform study, 5) write draft report, 6) QA review and approvals. A complete COA for the A3 test substance is expected August 26, 2011.

Additional details regarding MPI’s pr ogress can be found in the three technical progress reports that were submitted by MPI directl y to EPA on 4/29/2011, 5/27 /2011

, and 6/29/2011

.

C. Wildlife International Biodegradation Work

DuPont continued to host monthly conference call s /webmeeting s with WLI and EPA to address technical issues and answer any questions EPA may have on the monthly progress repor ts submitted by the laboratory

. Work conducted over the period consisted of the review and discussio n of data from test

substance characterization and discussion of Task E items with stakeholders. Technical work also consisted of a method installation trial to demonstrate quantitative acid analyte procedural recovery using the revised activated sludge m ixed

- liquor procedure. In addition, revisions of draft method validation protocols, and preparation of a Scope of Work to evaluate the analysis of 6

- 2 FTOH, 8

- 2 FTOH and 10

- 2

FTOH in MTBE extracts of an activated sludge matrix by liquid chromatography mas s spectrometry in the presence and absence of the Group A1 polymer were started.

On December 17, 2010, the Wildlife Draft QAPP and Draft Analytical Method Validation Protocol were submitted to EPA for review and approval (Email from Robert Tucker 12/17/ 10 10:26 AM). WLI revised the QAPP based on EPA review; however, revisions may be needed based on the need to complete all analysis using a LC/MS/MS instead of using GC/MS for alcohols due to potential for polymer degradation in the GC inlet at elevated t emperature. As of the end of the quarter, WLI was cha rged with outlining an LC/MS/MS method (including cost and timing) to measure FTOH in the SCAS test MTBE extracts instead of using GC/MS as a result of the potential for polymer degradation in the GC in let at elevated temperature. Issues such as number of replicates, frequency of draw and fill, analytical method and validation, etc. need to be resolved prior to completing final protocol for QAPP. David Lynch of

EPA and Bill Berti of DuPont were to conv ene a conference call the week of July 11, 2011, to discuss aTSCA

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Page 3 of 5 SCAS strawman that addresses the number of replicates, frequency of draw and fill, etc. Participants will include Wildlife, EPA, and DuPont.

Additional technical details regarding WLI’s progre ss can be found in the three technical progress reports
that were submi tted by WLI directly to EPA on 4/29/2011, 5/31/2011, and 6 /29 /11

.

D. Submitted Quarterly Progress Report Describing Progress

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 at a minimum, a narrative description of activities undertaken, compliance with the schedules or milestones set forth in the applic able appendix, and a summary of costs incurred since the previous report.”

On April 20, 2011, a 1 st Quarter 2011 progress report cov er ing the time period from January 01, 2011 to

March 31 , 2011 was submitted to the EPA (CD

- 2011

- 2 ).

2. Document Reviews

A

. Review and Approval of Wildlife Pilot Study Report

An unaudited draft report for the initial biodegradation pilot study (Group 1, Substance 1) was sent to EPA, DuPont and the Panel Administrator on October 25, 2010. A revised unaudited draft repor t for the initial pilot study (Group 1, Substance 1) was sent to the EPA, DuPont and the Panel Administrator on November 5, 2010. An audited draft report was sent to the EPA, DuPont and the Panel Administrator on December 2, 2010 and the raw data was sent on December 13, 2010

. Final comments from DuPont and EPA were to be submitted by June 17, 2011. WLI will issue the report.

B. Review and Approval of Wildlife Draft QAPP and Analytical Method Validation Protocol

On December 17, 2010, the Wildlife Draft QAPP and Draft Analytical Method Validation Protocol were submitted to EPA for review and approval (Email from Robert Tucker 12/17/10 10:26 AM)

. WLI has revised the QAPP based on EPA review. Issues such as number of replicates, frequency of draw and fil l, analytical method and validation, etc. need to be resolved prior to com pleting final protocol for QAPP. Protocol revisions may now be needed based on the need to complete all analysis using a LC/MS/MS instead of using GC/MS for alcohols due to potentia l for polymer degradation in the GC inlet at elevated

temperature.

C

. Review and Approval of the ILSI SEP Panel Preliminary Report

On December 9, 2010, the ILSI SEP Panel report was sent to EPA and DuPont; its title is “Preliminary

Conclusions and R ecommendations: Evaluation of the Biodegradation Pilot Studies by the ILSI Research Foundation Biodegradation SEP Panel.” On December 16, 2010, EPA accepted it to satisfy the final report required under the SEP on the condition that the panel revises the document in light of information

obtained after the characterization data becomes available (Email from Mark Garvey 12/16/10 5:31 PM). As of the end of 1Q2011, the Panel is still awaiting characterization data from MPI so they may finalize the report.TSCA

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Page 4 of 5 3. Compliance with Schedules or Milestones

Th is section outlines compliance with schedules or milestones as well as requests for extension s granted

between April 01, 2011 and June 30 , 2 011. All deadlines in the second quarter were met. Pending

deadlines a nd open issues are also described below.

A

. Quarterly Progress Reports

On April 20, 2011, a 1 st Quarter 2011 progress report cover ing the time period from January 01, 2011 to March 31, 2011 was submitted to the EPA (CD

- 2011

- 2 ). The next quarterly progre ss report (3 Q2011 ) is

due October 30 , 2011

.

B

. Pending Deadline Summary

All deadlines were met in the second qu arter of 2011

. There is one pending deadline at this time:

1) October 30 , 2011 to sub mit the 3 Q2011 progress report

4. Summary of Costs In curred

The cost of the SEP from April 1, 2011 to June 30 , 20 1 1 as it was accounted on cost ledger is show n in

Attachment A

. The table shows the costs from both accounts (SEP Eligible account and the DuPont Synthesis account) and breaks the cost distribut ion down into salaries, overheads, travel, operating supplies and an alytical costs. The 2 nd quarter 2011 SEP eligible ( Biodegradation Main account) cost s

were $ 155,685 and the Total SEP eligible project costs to date are $ 2,499,981

.

5. Attachment

Titl e Number of Pages

Attachment A SEP Cost Summary for 2 Q2011 1TSCA

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