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

Third Quarter 2007 Progress Report October 23, 2007

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3rd Quarter 2007 Progress Report 

July 1, 2007 - September 30, 2007 

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 30, 2007 satisfies said 

requirement. 

1. Description of Activities Undertaken

A. Progress Toward a Purification Procedure Agreement 

All protocol, correspondences, and data for the PFOA validation study performed on two fluorotelomer 

commercial products by MPI were submitted to EPA for review on June 26, 2007. On July 30, 2007, 

EPA, MPI and DuPont discussed the validation protocol and results by conference call. As a follow up 

to the conference call, DuPont provided EPA by email (09/04/2007, 09:04 AM from Lori E. Stephans) a 

request for guidance by providing an updated path forward agreement (original version dated August 23, 

2006, Ilana Saltzbart). On September 21, 2007, EPA provided revised path forward agreement by email 

(Mark Garvey 09/21/2007, 11:59 AM). Between September 21, 2007 and October 1, 2007, DuPont 

reviewed the path forward agreement and assessed our ability to begin the sparging and off gas analysis 

as proposed in the path forward agreement provided by EPA. 

New Deadline: On August 21, 2007 DuPont submitted a 7th request for extension for the date for which 

the parties much agree on a purification procedure (email dated 08/21/2007, 8:38 AM from Lori. E. 

Stephans). EPA responded on August 22, 2007 (email from Mark Garvey, 08/22/2007 02:41 PM) with a 

new extension deadline of December 31, 2007 for which the parties much agree on a purification 

procedure. 

B. EPA and DuPont Conference Call 

On September 05, 2007, EPA and DuPont met by teleconference to discuss some issues associated with 

the purification path forward and the need to extend the overall deadline of the SEP. The action items 

from the September 05, 2007 meeting to be provide to EPA were: 1) MPI validation protocol for the 

measurement of acid and alcohol on the air sampling cartridges, 2) high spot estimate for the SEP from 

the 6 biodegradation and analytical laboratories, 3) results of the DuPont SCAS test, 4) cartridge 

fabrication information, 5) shelf life information on the fluorotelomer products, 6) a summary of our 

ability to provide commercial products in the future, and 7) potential cartridge and sparging method 

uncertainties. On September 07, 2007, DuPont provided EPA with an Ariba request for the high spot 

estimates which was to be sent to the potential laboratories. The EPA provided a non-objection to the 

Ariba request as written. The Ariba event to solicit high spot estimates was launched in the Ariba on line 

system on September 14, 2007 and the laboratories were given to September 28, 2007 (two weeks) to 

respond. One laboratory responded with a request for an extension, as a result the entire Ariba event (for 

all laboratories) was extended one week to Octoberr 05, 2007. On September 17, 2007, DuPont provided 

EPA with the following remaining responses to the September 05, 2007 meeting action items: 1) MPI 

validation protocol for the measurement of acid and alcohol on the air sampling cartridges, 2) cartridge 

fabrication information, 3) shelf life information on the fluorotelomer products and their manufacture 

status, 4) an assessment of our ability to provide commercial products in the future, and 5) potential 

cartridge and sparging method uncertainties. As of September 30, 2007, DuPont had not provided EPA 

with the DuPont SCAS results and the high spot estimates from the Biodegradation and Analytical 

laboratories. The high spot cost estimates and the DuPont SCAS results are expected to be submitted to 

EPA on October 15 and October 23, 2007, respectively. 
TSCA-HQ-2004-0016, et. al. 

Third Quarter 2007 Progress Report October 23, 2007

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C. Panel Administrator Work Plan and DuPont Review of Work Plan 

The official contract execution date for ILSI-RF and DuPont Panel Administrator Contract was January 

18, 2007. ILSI-RF was required to submit their work-plan to EPA within 60 days from contract 

execution. On March 16, 2007, ILSI-RF submitted their work-plan to DuPont and to EPA. DuPont 

received the ILSI-RF work-plan on March 19, 2007. Within 14 business days, on March 30, 2007, 

DuPont responded with comments to the ILSI-RF Panel Administrator Contract (CD-2006-38). The 

Panel Administrator work-plan and DuPont comments to the ILSI-RF work-plan are still currently under 

review by EPA. 

D. Submission of Second Quarter 2007 Progress Report Describing Progress from April 1, 2007 to 

June 30, 2007. 

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 16, 2007, a second quarter 2007 progress report covering the time period from April 1, 2007 to 

June 30, 2007 was submitted to the EPA (CD-2006-40). 

E. Biodegradation and Characterization RFPs 

On December 28, 2006, EPA sent via email (see attached email from Ilana Saltzbart, 12/28/2006, 01:00 

PM) a request for DuPont to resubmit the Biodegradation and Analytical Requests for Proposals. The 

resubmission will include review, modification and incorporation of the language as it was negotiated in 

the Panel Administrator contracts where applicable. The deadline for this submission was set for 

February 01, 2007. 

On January 29, 2007, the Biodegradation and Analytical Requests for Proposals were submitted to EPA 

(CD-2006-34a, 34b, 35a and 35b). The Biodegradation and Analytical Requests for Proposals remain 

under review by EPA. 

F. Addendum to Appendix A 

On September 25, 2007, DuPont filed an addendum to Appendix A to note the name change of Severn 

Trent Laboratories, an original Characterization and Analytical Support Laboratory initially defined in the 

SEP to TestAmerica Analytical Testing Corporation. 

2. Pending Deadlines and Document Reviews 

 A. Requests for Proposals to the EPA for Approval 

The Biodegradation and Analytical Requests for Proposals remain under review by EPA. 

B. Panel Administrator Contract and Work Plan Status 

Both the ILSI-RF work-plan the DuPont comments are still under review with EPA. 

 C. Agreement on the Mabury Method of Purification 
TSCA-HQ-2004-0016, et. al. 

Third Quarter 2007 Progress Report October 23, 2007

Page 3 of 4 

The new deadline for agreement on a purification procedure is December 31, 2007 (per email notification 

from Mark Garvey, 08/22/2007 02:41 PM).

3. Compliance with Schedules or Milestones

This section outlines the various requests for extension granted between July 1, 2007 and September 31, 

2007. 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 seventh time on August 21, 

2007. EPA granted the extension (email from Mark Garvey, 08/22/2007 02:41 PM) and the new 

extension deadline is December 31, 2007. 

B. Panel Administrator Contract and Work Plan 

The Panel Administrator Contract Documents were approved by EPA on January 11, 2007. DuPont 

launched the Panel Administrator contract in the DuPont Ariba System. ILSI accepted the contract and 

all signed contracts were received on January 18, 2007. The official contract execution date for ILSI-RF 

and DuPont Panel Administrator Contract was January 18, 2007. 

ILSI-RF was required to submit their work-plan to EPA within 60 days from contract execution. On 

March 16, 2007, ILSI-RF submitted their work-plan to DuPont and to EPA. Within 14 business days, 

DuPont responded on March 30, 2007 with comments to the ILSI-RF Panel Administrator Contract. The 

Panel Administrator work-plan and DuPont comments to the ILSI-RF work-plan are currently under 

review by EPA. 

 C. Quarterly Progress Reports 

On July 16, 2007, a second quarter 2007 progress report covering the time period from April 1, 2007 to 

June 30, 2007 was submitted to the EPA (CD-2006-40). The next quarterly progress report (4Q2007) is 

due January 30, 2008. 

 D. Pending Deadline Summary 

All deadlines were met in the third quarter of 2007. There are only two pending deadlines at this time: 

December 31, 2007 to reach Agreement of the Purification Method and January 30, 2008 to submit the 4th

Quarter 2007 Progress Report. 

4. Summary of Costs Incurred

The cost of the SEP from July 1, 2007 to September 30, 2007 as it was accounted on cost ledger is shown 

in Attachment A. The table shows the costs from both accounts (SEP Eligible account and the DuPont 

Synthesis account) and breaks the cost distribution down into salaries, overheads, travel, operating 

supplies and analytical costs. The 3rd quarter 2007 SEP eligible (Biodegradation Main account) cost were 

$26,926 for the 3rd quarter while the total project to date cost is $388,226. 

Correction to 2nd Quarter Progress report. The total eligible project costs as of June 30, 2007 were 

reported as $417, 096, this number was in error and should have been $361,300 in the test and in the table 

found in attachment A of the 2nd Quarter progress report (CD-2006-40). 
TSCA-HQ-2004-0016, et. al. 

Third Quarter 2007 Progress Report October 23, 2007

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5. Attachment

 Title Number of Pages

Attachment A SEP Cost Summary for 3Q2007 1