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

Third Quarter 2006 Progress Report October 23, 2006 

Page 1 of 5 

3rd Quarter 2006 Progress Report 

July 1, 2006 to September 30, 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 October 31, 2006 satisfies said 

requirement. 

1. Description of Activities Undertaken

A. Progress Toward a Purification Procedure Agreement 

Section I.E.2.a. of SEP A provides that “On or before February 1, 2006, DuPont and EPA will agree on 

the procedure(s) that DuPont will use to purify the Fluorotelomer Products to produce Purified 

Fluorotelomer Products, taking into consideration the need to optimize various factors, including the 

appropriate duration of extraction and re-dispersion processes, the desired purity of the Purified 

Fluorotelomer Products, the schedule for delivery of the Purified Fluorotelomer Products to the 

laboratories for characterization, testing, and the overall schedule for completing this biodegradation 

SEP.” 

The time for the parties to reach agreement on the purification procedure was first extended to March 02, 

2006 (CD-2006-05) and then extended a second time on March 01, 2006 to April 17, 2006 (CD-2006-14). 

On March 23, 2006 after additional experimentation, DuPont and EPA, teleconferenced to discussed the 

progress toward the purification of the Fluorotelomer-based Commercial Products using the “Mabury 

Method”. On March 27, 2006, EPA provided DuPont with a request for additional information. On April 

7, 2006 DuPont provided a response (CD-2006-18) to the March 27, 2006 request from the EPA. The 

response included the following: 1) DuPont’s response to specific questions posed by the EPA, 2) copies 

of available DuPont analytical methods used to measure target compounds and 3) requested analytical 

data. 

Between February 7, 2006 and April 12, 2006 a series of progress reports were submitted outlining the 

progress DuPont made with the exploratory studies on the applicability of the “Mabury Method” for the 

purification of Fluorotelomers-based Commercial Products (CD-2006-14, 16, 17 and 20). Based upon 

evaluation of the results from the first three purification progress reports (CD-2006-14, 16 and 17), on 

March 27, 2006, the EPA proposed additional experiments to conduct on two test substances. 

The EPA determined that two additional experiments may provide further relevant information on the 

appropriate purification procedure. As such, a third extension of time was necessary for the experiments 

to be conducted and for the parties to reach agreement on the purification procedure. Section II.L.3. of 

SEP A provides that extensions of time beyond a first extension are subject to EPA’s discretion and are 

granted for good cause shown. 

Progress toward establishing a purification method was presented to show that good cause existed for the 

granting of the third extension of time. The time period for the third extension was based upon the length 

of time needed to conduct additional experiments. A request for a third extension was submitted to the 

EPA on April 12, 2006 (CD-2006-21). On April 14, the EPA granted an extension for agreement on the 

Purification Procedure to June 30, 2006 and requested a conference call to discuss the details of the 

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

Third Quarter 2006 Progress Report October 23, 2006 

Page 2 of 5 

On May 03, 2006, EPA and DuPont teleconferenced to discuss the details of the two additional 

experiments. As part of the path forward experiments, EPA required DuPont to collect the off gas during 

the two additional sparging experiments. DuPont worked with the EPA to identify and outside laboratory 

capable of developing methods for the analysis of the air cartridges (Exygen) and a vendor to fabricate the 

air sampling cartridges (SKC, Inc.). Details which include the Exygen and SKC quotes were included in 

the June 26, 2006 (CD-2006-24) DuPont submission entitled “Path Forward Agreement from May 03, 

2006 Meeting”. 

Pending the approval of the path forward agreement which was submitted to EPA on June 26, 2006 (CD2006-24) but prior to the June 30 deadline, DuPont submitted a forth request for extension for the 

purification procedure agreement (CD-2006-25). The request for extension by DuPont from June 30, 

2006 to September 30, 2006 was taken under consideration by the EPA pending consideration of the 

timeline of the path forward agreement. 

After much negotiation and engaging discussion between June 26, 2006 and August 21, 2006, 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. 

Since August 23, 2006, DuPont has been working with Exygen Research to develop methods, establish 

protocol and reach interlaboratory equivalency. Periodic progress reports will be submitted to the EPA in 

compliance with the path forward agreement described above. 

B. Panel Administrator Contract Negotiation 

Section V.E.2 of the SEP provides that by March 15, 2006, DuPont must provide EPA with a final draft 

of the proposed contract that DuPont and the Panel Administrator have negotiated. Since the Panel 

Administrator was not chosen and agreed upon by the EPA and DuPont until February 22, 2006, a first 

request for extension (CD-2006-15) was requested by DuPont on March 13, 2006 and granted by the 

EPA. The deadline for Panel Administrator Contract submission to the EPA was extended to April 14, 

2006. 

On February 27, 2006, contract negotiations began between International Life Sciences Institute (ISLI) 

and DuPont and concluded successfully on April 10, 2006. The first draft of the negotiated Panel 

Administrator Contract, both CBI (CD-2006-19) and public versions (CD-2006-19a) was submitted to the 

EPA for review on April 12, 2006. 

Since April 12, 2006, EPA and DuPont have met by teleconference numerous times (May 12, 2006, May 

17, 2006, May 22, 2006, May 25, 2006, June 08, 2006, July 13, 2006, July 27, 2006, August 20, 2006, 

August 23, 2006, September 20, 2006, September 21, 2006, September 25 and October 12, 2006) to 

address questions regarding the contract documents. The discussion was somewhat extended due to a 

request for a Biodegradation Consultant by ILSI. A Biodegradation Consultant Contract will be included 

as part of the original contract documents submitted to the EPA on April 12, 2006 (CD-2006-19). 

As of October 12, 2006, all Panel Administrator Contract documents have been reviewed by EPA, 

DuPont and ILSI. Once the documents are acceptable to the EPA, EPA will request DuPont to submit the 

contract documents in final form as a formal submission for final EPA approval. The date of submission 

of the ILSI contract is anticipated before the end of October 2006. 
TSCA-HQ-2004-0016, et. al. 

Third Quarter 2006 Progress Report October 23, 2006 

Page 3 of 5 

C. Submission of Second Quarter 2006 Progress Report Describing Progress from April 01, 2005 to 

June 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 July 14, 2006, the second quarter 2006 progress report covering the time period from April 01, 2005 

to June 30, 2006 was submitted to the EPA (CD-2006-26). 

D. Additional Progress 

Appendix A - Table 1 shows the progress DuPont has made toward the synthesis of the nine Commercial 

Fluorotelomer-based Products, nine Lab Synthesized Commercial Fluorotelomer-based Products and the 

nine Lab Synthesized Fluorotelomer-based Commercial Products made from high purity raw material. 

Appendix A - Table 1 also shows the quantities of the material required and the material currently 

available. All test substances have been synthesized and are available for shipment. 

2. Pending Issues and Document Reviews

 A. Requests for Proposals to the EPA for Approval 

Section III. B. of the SEP provides that “By February 1, 2006, DuPont shall submit to EPA one or more 

draft Requests for Proposals (RFPs) to be sent to all of the laboratories identified in Attachment G to 

solicit proposals for (1) characterizing the Fluorotelomer Products and any Corresponding Polymers, and 

(2) conducting the OECD Guideline 303A and SCAS studies on the Fluorotelomer Products and any 

Corresponding Polymers (including pilot testing).” On January 27, 2006, DuPont requested and was 

granted a first extension (CD-2006-05) to March 2, 2006. 

The Analytical Laboratory Request for Proposal (both CBI and Public versions, CD-2006-12, CD 2006-

12a and CD-2006 12b) was submitted to the EPA on February 22, 2006. Similarly, the Biodegradation 

Laboratory Request for Proposal (both CBI and Public versions, CD-2006-11 and CD 2006-11a) was 

submitted to the EPA on March 1, 2006. The Biodegradation Laboratory and Analytical Laboratory 

RFPs are under review by the EPA. 

B. Panel Administrator Contract Status 

Section V.E.2 of the SEP provides that by March 15, 2006, DuPont must provide EPA with a final draft 

of the proposed contract that DuPont and the Panel Administrator have negotiated. Since the Panel 

Administrator was not chosen and agreed upon by the EPA and DuPont until February 22, 2006, the 

deadline for Panel Administrator Contract submission to the EPA was extended to April 14, 2006. The 

first draft of the negotiated Panel Administrator Contract (both CBI and public versions, CD-2006-19 and 
TSCA-HQ-2004-0016, et. al. 

Third Quarter 2006 Progress Report October 23, 2006 

Page 4 of 5 

CD-2006-19a) was submitted to the EPA for review on April 12, 2006. The panel administrator contract 

while under review by EPA, has been discussed on numerous teleconferences between EPA, ILSI and 

DuPont. 

As of October 12, 2006, the Panel Administrator Contract documents have been reviewed by EPA, 

DuPont and ILSI. Once the documents are acceptable to the EPA, EPA will request DuPont to initiate a 

formal submission for final approval. The submission is anticipated before the end of October 2006. 

There is no pending deadline for this submission. 

 C. Agreement on the Mabury Method of Purification 

Pending the approval from EPA on the path forward agreement for two additional sparging experiments 

which was submitted to EPA on June 26, 2006, DuPont submitted a fourth request for extension for the 

purification procedure agreement. 

After much negotiation and engaging discussion between June 26, 2006 and August 21, 2006, 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. 

DuPont is currently working with Exygen Research to develop methods and reach interlaboratory 

equivalency. Periodic progress reports will be submitted to the EPA in compliance with the path forward 

agreement described above. 

3. Compliance with Schedules or Milestones

This section outlines the various requests for extension granted between July 01, 2006 and September 30, 

2006. All deadlines in the third quarter were met. Pending deadlines and open issues are described below. 

A. Purification Procedure 

The deadline to reach agreement on the purification procedure was extended a forth time on August 23, 

2006 (CD-2006-25) to November 27, 2006 pending completion of the path forward experiments. 

B. Panel Administrator Contract Submission to the EPA 

The first draft of the negotiated Panel Administrator Contract (both CBI and public versions, CD-2006-19 

and CD-2006-19a) was submitted to the EPA for review on April 12, 2006. Between April 12, 2006 and 

October 12, 2006, ILSI, DuPont and EPA met on numerous occasions to discuss the conditions of the 

Panel Administrator Contract. 

As of October 12, 2006, the Panel Administrator Contract documents have undergone complete review by 

EPA, DuPont and ILSI. Once the documents are acceptable to the EPA, EPA will request DuPont to 

initiate a formal submission for final EPA approval. The submission of the final ILSI contract documents 

is anticipated before the end of October 2006. 

 C. Quarterly Progress Reports 
TSCA-HQ-2004-0016, et. al. 

Third Quarter 2006 Progress Report October 23, 2006 

Page 5 of 5 

On July 14, 2006, the second quarter 2006 progress report covering the time period from April 1, 2006 to 

Jun 30, 2006 was submitted to the EPA (CD-2006-26). 

 D. Pending Deadline Summary 

All deadlines were met in the third quarter of 2006. The only pending deadline is for the Agreement of 

the Purification Method which is now November 27, 2006. 

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 July 01, 2006 to September 30, 2006 as it was accounted on cost ledger is 

shown in Attachment B. 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 $206,250 and $107,107 for the SEP Biodegradation Main and the SEP Biodegradation Synthesis 

accounts, respectively. Attachment B also shows cost corrections for the first and second quarters of 

2006. Adjustments were made in October and justifications for the adjustments are described at the 

bottom of the cost tables in Attachment B. 

Attachment B Page 2, shows the breakdown of staff hours for the third quarter from July 01, 2006 to 

September 30, 2006. Barley Mill and Chambers Works are staff locations. 

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. 

Going forward the analyses will be changed on a monthly basis to the SEP accounts. It is anticipated that 

the remainder of the costs associated with the Exygen Research quote will be spent in the forth quarter 

2006. 

5. Attachments

 Title Number of Pages

Attachment A. Synthesis Status of Test Substances 1 

Attachment B. SEP Cost Summary for 3Q 2006 2
TSCA-HQ-2004-0016, et. al. Third Quarter 2006 Progress Report 

Attachment A

Table 1. Quantity of Test Substance Calculated and Actual for Each Test Substance Actual Quantity Made and Available

Pilot Test 

Group Test Sequence Order % active

Calculated 

Test 

Quantity (L)* Comments

Commercial 

Product

Lab Made 

Commercial

Lab Made 

S1 Purified

Control 1 96

30 L 4.5 L 4.5 L A1 Group 1 Substance 2 39.5-42.5 4.5 based on 39.5%

A2 Group 1 Substance 3 12.0-13.0 8.5 based on12 %

36 L 10 L 10.5 L

A3 Group 1 Substance 1 32.0 - 34.0 4.5 based on 32%

33 L 5.3 L 5.5 L

B Group 2 Substance 1 10.0 - 20.0 9.3 based on 10%

32.5 L 11 L 10.5 L

C1 Group 3 Substance 3 21.5 - 22.5 5.5 based on 21.5%

34 L 7.0 L 5.5 L

C2 Group 3 Substance 2 17 - 18 6.5 based on 17%

34 L 6.5 L 6.5 L

C3 Group 3 Substance 1 18 - 19 6.5 based on 18%

34 L 6.5 L 6.5 L

D1 Group 4 Substance 1 17 - 20 6.5 based on 17%

34 L 7 L 7 L

D2 Group 4 Substance 2 29 - 30 4.2 based on 29%

34 L 4.6 L 4.3 L

* rounded up to the nearest 1/2 L
TSCA-HQ-2004-0016, et.al. Third Quarterly 2006 Progress 

RED or YELLOW indicates excluded or corrected 

from previous Progress Reports

SEP Biodegradation: Synthesis Account - VZ78101073 SEP Biodegradation: Synthesis Account - VZ78101073 SEP Biodegradation: Sy

JAN FEB MAR YTD April May June YTD 

Salaries Salaries Salaries 

Chambers Works 529 3,055 6,502 10,086 Chambers Works 11,962 8,987 19,886 50,921 Chambers Works 

Barley Mill 1,288 205 1,493 Barley Mill 245 291 0 2,029 Barley Mill 

Travel Travel 0000 Travel 

Operating Supplies 0 Operating Supplies# 360 0 0 360 Operating Supplies# 

RAS Analytical 945 15279 16,224 RAS Analytical 6,331 2,940 420 25,915 RAS Analytical 

Overheads Overheads Overheads 

Chambers Works 126 444 694 1,264 Chambers Works 1,168 997 3,365 6,794 Chambers Works Barley Mill 147 24 171 BMP 30 34 0 235 BMP 

TOTAL 5,879 22,704 29,238 TOTAL 20,096 13,249 23,671 86,254 TOTAL 

SEP Biodegradation: Main Account - VZ78911724 SEP Biodegradation: Main Account - VZ78911724 SEP Biodegradation: Ma

JAN FEB MAR YTD April May June YTD 

Salaries Salaries Salaries 

Chambers Works 12,341 11,080 9,052 32,473 Chambers Works 21,569 882 12,890 67,814 Chambers Works Barley Mill 1399^ 3,373 405# 3,373 Barley Mill 518 0 882 4,773 Barley Mill 

Travel# Travel 866 Travel 

Franchina 219 219

Stephans$ 437 437Bryndza 210 210

Operating Supplies Operating Supplies 0 0 0 61 Operating Supplies 

Stephans 61 61 Exygen Exygen 

Overheads Overheads Overheads 

Chambers Works 3,860 3,800 3,288 10,948 Chambers Works 604 765 1,575 13,892 Chambers Works Barley Mill 189 201 61 451 BMP 80 0 128 659 BMP 

TOTAL 16,390 19,381 12,401 48,172 TOTAL 22,771 1,647 15,475 88,065 TOTAL 

YTD totals include 1Q corrected data i.e., Jan though June

# Costs for Shipping Documents to EPA, cost for purchasing 

O

^1,399 was 3,373, # 405 was 610

Feb $945 RAS charges not billed June salary charge included $16224 of RAS charges. $945 should have been billed March RAS charges of $15279 included in the salary line in February, $15,279 was already included in the March bill (as salaries)

June - Barley Mill salary and benefits billed in error to both accounts - should have been 

billed to 911724

Cost Corrections for 1Q 2006 January 1, 2006 to March 31, 2006 Cost Analysis 

Attachment

B

Cost Corrections for 2Q 2006 April 1, 2006 to June 30, 2006
TSCA-HQ-2006-0016, et. al. Third Quarter 2006 Progress Report October 20, 2006

SEP Main Account

Name Function Location Time (hours)

L. Wrightson Sourcng BMP 3

L. Stephans SEP Manager JL 128

J. Quinn Finance JL 1

E. King Finance-DCSE BMP 2

Month Total Charged to SEP Main Account 134

SEP-Synthesis Account

Name Function Location Time (hours)

P. Fitzgerald DCSE-R&D JL 18

J. Bowers DCSE-R&D JL 90

Month Total Charged to DuPont SEP Synthesis Account 108

 

SEP Main Account

Name Function Location Time (hours)

L. Wrightson Sourcng BMP 1

J. Quinn Finance JL 1

E. King Finance-DCSE BMP 1

L. Stephans SEP Manager JL 120

Month Total Charged to SEP Main Account 123

SEP-Synthesis Account

Name Function Location Time (hours)

J. Sworen DCSE-R&D JL 4

L. Stephans DCSE-SEP Manager JL 10

F. D'amico DCSE-R&D JL 16

Month Total Charged to DuPont SEP Synthesis Account 30

SEP Main Account

Name Function Location Time (hours)

L. Stephans SEP Manager JL 120

J. Quinn Finance JL 2

L. King DCSE Finance BMP 3

Month Total Charged to SEP Main Account 125

SEP-Synthesis Account

Name Function Location Time (hours)

L. Stephans DCSE-SEP Manager JL 20

Month Total Charged to DuPont SEP Synthesis Account 20

June 2006 SEP Time Summary

Third Quarterly 2006 Progress Report, Hours Summary

Attachment B Page 2 of 2

April 2006 SEP Time Summary

May 2006 SEP Time Summary