TRP ( 9 May 03)

TELOMER RESEARCH PROGRAM Response to EPA Follow up Questions Regarding TRP LOI Commitments The members of the Telomer Research Program ( TRP) 1 submitted a Letter of Intent ( LOI) 2 to EPA dated March 14, 2003 that outlined our voluntary commitment to investigate whether and how telomer based products can transform or break down into perfluorooctanoic acid ( PFOA) or its salts, and whether articles treated with such products contribute to significant human or environmental exposure to PFOA. The focus of the LOI is on research, analysis and product stewardship activities that can be conducted in the near term with expected results in 2003 and 2004.

In a letter dated April 30, 2003, EPA requested the TRP to provide a detailed description of the various testing activities that are described in the LOI. In particular, EPA requested clarification on the items listed below ( EPA questions are in italics). The TRP is providing responses to each of the follow up questions in addition to reference documents that provide additional detail.

Product and Article Analysis ( LOI Item 1, page 3)

The TRP is conducting a study to analyze for the presence of PFOA in representative, major end use telomer based polymeric products in commerce and articles treated with those products. We have contracted with an outside research laboratory to perform this work. This screening study will investigate levels of PFOA in articles for three major end use categories: carpets, textiles and paper. The primary products that TRP members market for these applications are polymers, which represent approximately 85% of the telomer based products that the TRP members manufacture and sell. The product types to be tested are those that the TRP member companies manufacture as actual items of commerce. The treated articles to be tested are actual carpet, textile, and paper substrates treated under representative mill conditions with the subject telomer based polymeric products.

Product Types: acrylate and urethane polymers ( 12 representative products)

The TRP prepared a study plan describing the scope and rationale for the " Analysis of Telomer Based Products and Telomer Treated Articles." The study plan was submitted to EPA on March 31, 2003. The TRP also developed a document on " LC/ MS/ MS Analysis of Articles and Products: Samples and Suggested Sampling Procedures" ( submitted to EPA on February 14, 2003). Much of the information provided below is drawn from these two reference documents with further elaboration as appropriate to incorporate new developments in the study and modifications to the study plan as the work progresses. A more detailed description or explana tion can be provided to EPA staff if desired.

1 The companies participating in the TRP include Asahi Glass, Clariant GmbH, Daikin Industries, and E. I. duPont de Nemours & Company. These companies produce or import fluorotelomer based products, which are used as fluorosurfactants and surface protection chemicals. Telomers are not made from PFOA, nor is PFOA added during the manufacture or use of telomer products.

2 TRP Letter of Intent   EPA Docket # OPPT 2003 0012 0013.

1 TRP ( 9 May 03)

Significance / Expected Outcome: The results from this screening study will provide a compre hensive initial picture of exposure potential by focusing on these major end use telomer based polymeric products and the corresponding articles of commerce.

How will representative products and articles be selected? What criteria will determine which products and articles are " representative"?

Representative major telomer based polymeric products in commerce and articles treated with those products will be tested. Investigations will be conducted on 12 telomer based polymeric end use products used to treat three major end use product categories: carpet, textile and paper. Four of the 12 telomer based polymeric products will be used to treat carpet; six of the 12 telomer based products will be used to treat textiles and two of the 12 telomer based products will be used to treat paper. Six sub samples from each of the 12 treated articles will be prepared using a random block approach or alternatively six individual samples will be prepared using identical lots of telomer based polymeric products and articles of commerce.

While there are many potential telomer based polymeric products, a relatively small number represent the primary product classes in commerce ( 12 representative products). The selected 12 products represent the product types used to serve the designated market end uses of carpet, textile and paper. The treated articles to be tested are actual carpet, textile, and paper substrates treated under representative or actual mill conditions with the subject telomer based polymeric products.

Will the number of products and articles analyzed be sufficient to make a judgment about the overall contribution of telomer products and articles to PFOA in the environment?

The number of products and articles chosen to be analyzed will provide an important basis for evaluating the level of PFOA in products and articles. If the results of these tests show no significant level of PFOA, then it is a reasonable assumption that neither products nor articles are contributing PFOA to the environment. However, when the accuracy and variability of the method is established and actual levels of PFOA are quantified, then the TRP data will be sufficient to make a judgment about the overall contribution of telomer based product and articles to PFOA in the environment.

What are the chemical identities of the products?

The chemical identities of the selected representative polymers, volumes, and their relative market share are consistent with information provided to EPA in the submissions from TRP member companies in March 2003. TRP companies will also provide EPA ( under CBI) specific information  such as structures, CAS numbers, chemical names, 2002 uses and volumes in commerce  on other telomer products used in the United States ( including non polymeric products) by the end of May 2003.

We have received test methods from TRP for both products ( chemicals) and articles. Has either method ever been used before?

2 TRP ( 9 May 03)

The TRP developed a document on " LC/ MS/ MS Analysis of Articles and Products: Samples and Suggested Sampling Procedures" ( submitted to EPA on February 14, 2003). This document is an outline for the development of test methods for PFOA for both products and articles.

The test method for PFOA in articles is under development and should be completed by June 2003. The test method development for PFOA in telomer based polymeric products will be initiated after completion of the method for telomer treated articles. Neither method has been used before for the analysis of PFOA in treated articles and telomer based polymeric product.

Can you update us on the validation status and accuracy and precision of each test method?

Our current target is recovery of PFOA from actual article samples at the 1 ppb level of quantitation ( LOQ). This quantitation level has not yet been achieved due to problems encountered with contamination, the requirement to include differentiation of linear and branched PFOA in the quantitation, and refinement of overall chromatographic conditions. Given the difficulties encountered, we are contacting other laboratories for potential involvement in this work.

Method development for products will be initiated as soon as the issues for articles have been resolved. The learnings from the method development for articles are expected to be applicable for product analysis.

Will PFOA precursors such as free telomer alcohols be analyzed for in addition to PFOA? If so, which ones?

At this time, our current focus is on determining if PFOA is present in telomer based polymeric products and articles treated with those products.

Do you have a consolidated written description of the procedures that will be followed with this testing? If so, please provide a copy. If these procedures have already been identified in a submission to the Agency ( ie. to AR226 or 8( e)), please identify the submission.

The TRP developed a document on " LC/ MS/ MS Analysis of Articles and Products: Samples and Suggested Sampling Procedures" ( submitted to EPA on February 14, 2003). This document provides guidance for the sampling and analysis of samples.

What is the timing of this work?

During the months of January and February 2003, appropriate sampling shipment and analysis procedures as well as primary and internal standards for this work were prepared while contract laboratory selection made. After characterization of the internal standard and arrival of the samples, method development was initiated in March 2003. Method development efforts were unexpectedly diverted to address apparent PFOA contamination which prohibited achieving low level LOQ for PFOA in untreated articles. Additional samples of untreated articles needed to be prepared and shipped. Subsequently, efforts focused on separating branched from linear PFOA as well as optimizing chromatographic conditions for 1 ppb LOQ. New sets of untreated articles ( controls) are scheduled to arrive early May 2003.

3 TRP ( 9 May 03)

By June 2003, method development and method validation on articles will be completed. Article analysis will be completed in early July 2003. Method evaluation on products and actual product analyses will be conducted in early August 2003. Final reports for these projects will be available in September 2003.

Analysis of " Aged" Products and " In Use" Articles ( LOI Item 2, page 3)

The TRP will commission a study in May / June 2003 to examine transformation of end use telomer based polymeric products for potential PFOA generation that might occur through storage of the product over time or through normal use of treated articles. TRP has developed a draft work plan for conducting PFOA " aging" and " in use" analyses of the specific products and treated articles that are the subject of the TRP sponsored work in LOI Item 1 above ( submitted separately to EPA for review and comment on May 9, 2003). For these analyses, " aged" means the likely conditions our products will see under normal storage and distribution. " In use" means the conditions treated articles will see under normal distribution and use. Potential contract labs with processing capabilities and relevant experience are being investigated. Study protocols, analytical methods and appropriate test conditions still need to be developed for this work Significance / Expected Outcome: This work is expected to give a further understanding of potential changes in PFOA levels in both:   Telomer based polymeric products while stored prior to application on articles, and   Treated articles under normal use conditions.

How many products and articles will be analyzed?

Following the rationale developed for Product and Article Analysis ( LOI Item 1), twelve ( 12) telomer based polymeric products will be tested. These 12 products are those marketed and sold for use in three major end use article categories: carpets, textiles, and paper. The telomer based polymeric product classes to be tested are those that the respective TRP member companies manufacture as actual items of commerce.

The current work plan calls for " in use" articles representative of the 12 telomer based polymeric products to be initially evaluated by elevated temperature and photolysis. This representation consists of 12 different article samples: carpet ( 4 articles), textiles ( 6 articles) and paper ( 2 articles). The current work plan also calls for triplicate analyses of each article sample.

How will representative products and articles be selected?

This LOI item uses the same rationale for selection of representative telomer based polymeric products and treated articles as for LOI Item 1. That is, at the respective TRP member manufacturing sites, representative telomer based polymeric product samples will be collected and sealed immediately and sent to the selected contractor for laboratory analysis.

Samples of the 12 telomer treated articles will be collected from pilot plant facilities or from commercial manufacturing facilities.

4 TRP ( 9 May 03)

Will the number of products and articles analyzed be sufficient to make a judgment about the overall contribution of telomer products and articles to PFOA in the environment through this pathway?

The number of products and articles chosen to be analyzed will provide an important basis for evaluating the level of PFOA in products and articles. If the results of these tests show no significant level of PFOA, then it is a reasonable assumption that neither products nor articles are contributing PFOA to the environment. However, when the accuracy and variability of the method is established and actual levels of PFOA are quantified, then the TRP data will be sufficient to make a judgment about the overall contribution of telomer based products and articles to PFOA in the environment.

What are the chemical identities of the products?

The telomer based polymeric products being tested in the " Aging and In Use Study" are the same as in the " Product and Article Analysis" under LOI Item 1. Information on the chemical identities of the products has been provided to EPA by the TRP member companies ( under CBI); completed in March 2003.

How will products and articles be " aged"?

The selected telomer based polymeric products will be " aged" by storage at 45 ° C and triplicate samples will be analyzed at the following time intervals: 0 day, 2 weeks, 6 weeks, and 12 weeks.

The temperature of 45 ° C was selected to accelerate the aging process by simulating 12 months of room temperature shelf conditions using higher temperatures for a shorter period of time. The assumption is that the fairly moderate temperature of 45 ° C will create degradation patterns similar to those typical at room temperature. Samples of each product will be held at ambient temperature and/ or at 4 ° C as a potential reference points should they be required.

As telomer based polymeric products are typically stored in drums which allow no exposure to light, photolytic degradation of sales products will not be tested.

In order to simulate " use" in treated articles, a variety of tests will be conducted.

1. Temperature aging on treated carpet, textiles and paper ( see below and Section 3.4 of the work plan for more detail) 2. Photolytic aging on treated carpet, textiles and paper ( see below and Section 3.5 of the work plan for more detail) 3. Abrasion on treated carpet and textiles ( see below and Section 3.6 of the work plan for more detail) 4. Washing on treated textiles ( see below and Section 3.7 of the work plan for more detail) 5. Dry cleaning on treated textiles ( see below and Section 3.8 of the work plan for more detail) 6. Hot water extraction cleaning on treated carpet ( see below and Section 3.9 of the work plan for more detail)

5 TRP ( 9 May 03)

What test method will be used to analyze the samples? ( Will it be the same test method as in item 1?)

The same PFOA test methods developed and validated under Product and Article Analysis ( LOI Item 1) will be used for these studies.

What is the test method's validation status and its accuracy and precision?

Our current target is recovery of PFOA from actual article samples at the 1 ppb level of quantita tion ( LOQ). This quantitation level has not yet been achieved due to problems encountered with contamination, the requirement to include differentiation of linear and branched PFOA in the quantitation, and refining overall chromatographic conditions. Given the difficulties encountered, we are contacting other laboratories for potential involvement with this work.

Method development for products will be initiated as soon as the issues for articles have been resolved. The learnings from the method development for articles are expected to be applicable. for products.

Will PFOA precursors such as free telomer alcohols be analyzed for in addition to PFOA? If so, which ones?

At this time, our current focus is to determine if PFOA is present in telomer based polymeric product and articles treated with those products.

Do you have a consolidated written description of the procedures that will be followed with this testing? If so, please provide a copy. If these procedures have already been identified in a submission to the Agency ( ie. to AR226 or 8( e)), please identify the submission.

A consolidated overview of the procedures is given in the proposed work plan, " Analysis of " Aged" Telomer Based Polymeric Products and " In Use" Treated Articles" ( submitted to EPA on May 9, 2003). The detailed descriptions of each of the eight proposed procedures will be submitted separately as the work progresses. Briefly, the basic procedures are as follows.

1. PFOA analysis in telomer based polymeric products before and after accelerated aging via elevated temperature will be conducted. ( See Section 2.3 of the work plan for more detail) 2. PFOA analysis before and after temperature aging on treated carpet, textiles and paper will be conducted. Treated samples of carpet, textiles and paper will be analyzed for detectable levels of PFOA. Samples will then be subject to accelerated aging in closed containers at 45 ° C with periodic " whole container" analysis for PFOA over a time period of 12 weeks ( equivalent to approximately 1 year at 25 ° C). The use of closed, whole container analysis should represent the cumulative effect of aging over time. At each sampling interval, control samples stored at ambient temperature, will be fortified with PFOA; both control samples and fortified samples will be analyzed to demonstrate that acceptable recoveries are obtained, proving the method is working correctly. ( See Section 3.4 of the work plan for more detail)

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3. PFOA analysis before and after photolytic aging on treated carpet, textiles and paper will be conducted. Treated samples of carpet, textiles and paper will be analyzed for detectable levels of PFOA. Samples will then be subject to Xenon lamp irradiation in closed containers at 25 ° C with whole container analysis for PFOA. Non irradiated untreated samples will be fortified with PFOA; these fortifications along with the non irradiated, untreated controls will be analyzed simultaneously with the samples ( both non irradiated and irradiated) to demonstrate that acceptable recoveries are obtained. The " ASTM's Paper Aging Research Program" ( report March 12, 2002 version) found that natural sunlight paper brightness loss ( yellowing) could be correlated with that of the Xenon lamp when the Xenon lamp time scale was multiplied by 300. Therefore one Xenon lamp irradiation day is equivalent to about 1 year of natural sunlight. ( See Section 3.5 of the work plan for more detail) 4. PFOA analysis before and after abrasion on treated carpet and textiles will be conducted if sufficiently quantifiable levels of PFOA are present. The AATCC Test Method 119 1994 using the Screen Wire method is currently proposed to simulate abrasion on textiles. The Vetterman Drum test is currently proposed for simulating abrasion on carpet. ( See Section 3.6 of the work plan for more detail) ( Note: AATCC = American Association of Textile Chemists and Colorists) 5. PFOA analysis before and after washing of treated textiles will be conducted using one set of conditions described in the AATCC Test Method 135 1995, " Dimensional Changes in Automatic Home Laundering of Woven and Knit Fabrics", if sufficiently quantifiable levels of PFOA are present. ( See Section 3.7 of the work plan for more detail) 6. PFOA analysis before and after dry cleaning of treated textiles will be conducted using conditions described in the AATCC Test Method 132 1995 if sufficiently quantifiable levels of PFOA are present. ( See Section 3.8 of the work plan for more detail) 7. PFOA analysis before and after hot water extraction cleaning on treated carpet will be conducted using conditions described in the AATCC Test Method 171 1995 if sufficiently quantifiable levels of PFOA are present. ( See Section 3.9 of the work plan for more detail) 8. PFOA volatility will not be specifically tested as part of this LOI Item unless dramatic unexplained PFOA losses are observed; other sections of the LOI are designed to explore volatility further.

What is the timing of this work?

April   May 2003   Developed draft work plan for telomer based polymeric product aging and treated article " in use" simulation May   June 2003   Prepare individual draft protocols for PFOA analysis on aged telomer based polymeric products and treated article " in use" and locate suitable laboratories July   August 2003   Initiate elevated temperature studies on telomer based polymeric products and treated articles 7 TRP ( 9 May 03)

  Review data on PFOA in treated articles prior to in use simulation and assess the need and viability of conducting abrasion, dry cleaning, washing, steam cleaning, and volatility studies,   Initiate article " in use" studies if appropriate September 2003   Initiate photolysis study on treated articles.   Complete validation of procedures to be used at the " in use" laboratories November 2003   Submit Photolysis report January 2004   Submit Elevated Temperature reports   Submit " in use" reports Characterizing Potential Releases of PFOA from Telomer Treated Article Manufacture ( LOI Item 4, page 4)

The TRP members will examine the potential for PFOA releases and/ or occupational exposures at US facilities that manufacture telomer treated articles. This information will be assembled through a release estimate model analysis directed at manufacture of the three primary telomer treated article types   carpet, textiles and paper   that are addressed in other TRP workstreams.

Work is underway to develop estimates of potential release of PFOA related to manufacture of the primary article types ( carpet, textiles and paper). In this analysis we will attempt to identify potential release points, exposure pathways, and ultimate environmental compartments ( air, land, water) for potential PFOA emissions from telomer treated article manufacturing processes. The TRP is using the 3M product use / exposure template ( Ref. AR226 0554). Release scenarios will be developed based on these results.

The release estimate analysis will be used to first design and then conduct mill simulations of the potential release of PFOA from telomer treated article manufacturing operations. The required sampling and analytical methods for PFOA in the mill simulations must first be developed and demonstrated. A contract laboratory capable of simulating the actual mill environment under defined and known conditions will be used to verify the data generated in the above release estimate study. The results from the analysis and simulations will be used to estimate the potential occupational and environmental exposure to PFOA from the specified telomer treated article manufacturing processes.

Significance / Expected Outcome: Together with the Product and Article Analysis ( Item 1), this work is expected to provide a more comprehensive picture to aid in the understanding of the potential occupational and environmental exposure to PFOA from telomer treated article manufacturing processes.

How many samples will be analyzed?

8 TRP ( 9 May 03)

Following the rationale developed for LOI Item 1, the TRP is currently considering testing the twelve ( 12) telomer based polymeric products. These 12 product types are those marketed and sold for use in three major end use article categories: carpets, textiles, and paper. The product types to be tested are those that the respective TRP member companies manufacture as actual items of commerce.

How will representative articles be selected?

Under this LOI item, the same rationale is used for selection of representative sales products and treated articles as for Product and Article Analysis ( LOI Item 1). That is, at the respective TRP member manufacturing sites, representative telomer based polymeric product samples will be collected and sealed immediately, and then shipped to the designated contractor for laboratory analysis.

Will the number of articles analyzed be sufficient to make a judgment about the overall contribution of telomer treated articles to PFOA in the environment?

The number of articles chosen to be analyzed will provide important base values for the level of PFOA in the articles, and their contribution, if any, to the PFOA levels in the environment. If the results of these tests show no significant level of PFOA, then it is a reasonable assumption that these articles are contributing PFOA to the environment. The TRP expects that this initial set of tests will indeed allow us to make an initial judgment about the overall contribution from the treated articles. However, until actual levels of PFOA can be quantified and until the accuracy and variability of the method can be established, no " certified" judgment can be rendered.

What test method will be used to analyze the samples? ( Will it be the same test method as in item 1?)

Test methods to conduct these mill analyses have not yet been developed. The TRP is working to develop the appropriate validated methods to conduct these studies.

What is the accuracy and precision of the test method?

The accuracy and precision of the test method will be determined once the subject test methods are developed and validated.

Will PFOA precursors such as free telomer alcohols be analyzed for in addition to PFOA? If so, which ones?

No. At this time, our current focus is to determine if PFOA is present in telomer based polymeric products and articles treated with those products.

Do you have a consolidated written description of the procedures that will be followed with this testing? If so, please provide a copy. If these procedures have already been identified in a submission to the Agency ( i. e., to AR226 or 8( e)), please identify the submission.

This plan is under development and will be submitted to the Agency as soon as it is available.

9 TRP ( 9 May 03)

What is the timing of this work?

March / April 2003: Preliminary study design for release estimate analysis May   July 2003: Release estimate analysis; develop release scenarios May   July 2003: Method development / demonstration for PFOA determination in mill simulations August 2003: Results expected from release estimate analysis; identify and solicit bids from potential contract labs to conduct mill simulations September   December 2003: Conduct mill simulations and report results to EPA Biodegradation Analysis ( LOI Item 5, page 5)

8 2 Telomer Alcohol Method development work has been conducted with 8 2 Telomer Alcohol ( C8 F17 CH2 CH2 OH) to be able conduct biodegradation studies and investigate the potential for generation of PFOA under biodegradation study conditions. A preliminary screening study with cold test material conducted by DuPont used the concept of OECD Guideline for Testing of Chemicals; Section 3: Inherent Biodegradability ( 1992). This test generates environmental fate information potentially relevant to the persistence of the test substance. The final report from this accelerated biodegra daion study was submitted by DuPont to EPA on March 21, 2003 ( DuPont Report # EMSER 15 03). A follow on study sponsored by the TRP using 14 C labeled test material is underway. This is a 28 day OECD 301D, Closed bottle, Ready Biodegradation study ( under Good Laboratory Practices) utilizing unacclimated municipal sludge with [ 3 14 C] 8 2 Telomer B Alcohol. In addition, a study has been initiated by the TRP to determine the adsorption desorption behavior of 14 C labeled 8 2 Telomer B Alcohol for a range of solids and sediments. These two studies will provide essential data for design and protocol development for long term, higher tier studies on 8 2 Telomer B Alcohol. The scope and rationale for the 8 2 Telomer B Alcohol Biodegradation Research under the TRP, which was provided to EPA on March 31, 2003, contains more details on the completed and planned biodegradation work.

Telomer Based Polymeric Products The TRP proposes to conduct further studies to determine whether telomer based polymeric products might transform to perfluorooctanoic acid ( PFOA) or its salts under environmentally relevant laboratory study conditions.

The telomer based polymeric products are generally 20% aqueous dispersions of telomer containing polymeric particles. The telomer functionality F( CF2 CF2 ) n CH2 CH2  is covalently bound to the polymer backbone.

This proposal considers both biotic and abiotic transformation processes that may be relevant. It is expected that results from ongoing Telomer Research Program ( TRP) studies on 8 2 Telomer B Alcohol ( C8 F17 CH2 CH2 OH) will provide helpful information to enable this work to be accomplished, specifically, sampling and analysis methods. However, as the polymeric products are substantially more complex, it is possible that difficulties may be encountered in developing and validating an analytical method or methods to sufficiently recover and thereby quantitatively determine PFOA in these complex matrices.

10 TRP ( 9 May 03)

Significance / Expected Outcome: This study work will provide important information regarding whether telomer based polymer products may transform or break down into PFOA or its salts.

How many products will be studied and how will they be selected?

The TRP proposes to conduct initial biodegradation screening studies on the 12 telomer based polymeric products which are part of the Product and Article Analysis studies ( LOI Item 1) previously submitted to EPA. The selected products represent the majority of global product types used for textile, carpet and paper treatment. The TRP proposes to conduct studies on these substances following a modified OECD 302 28 day Inherent Biodegradation protocol ( a draft outline of the protocol is attached to the work plan). The quantitative determination of PFOA is the key study endpoint. Additional proposed endpoints to be monitored include measurement of dissolved organic carbon ( DOC) or carbon dioxide ( CO2 ) evolution and fluoride ( F ). The OECD 302 inherent studies are proposed because the study design would represent the " most favorable" conditions under which biotransformation may occur. The innoculum to be used for the study will be municipal sludge.

The polymers ( acrylates and urethanes), which are the major component of the products, have molecular weights above 1000 ranging to well above 100,000 daltons, are non polar and of no   low water solubility. It is widely reported in the literature that polymers of this type are not bioavailable to microorganisms and would not be expected to undergo transformation. Should a significant amount of PFOA be generated as a result of biotransformation in these initial studies on the product in its entirely, TRP will consider disaggregating the polymeric product to explore and identify specific components from which PFOA may originate Abiotic Degradation Three predominant abiotic degradation pathways are expected for telomer based polymeric products: ( 1) photolytic, ( 2) thermal and ( 3) incineration. Studies to explore these potential pathways are already included in the TRP Letter of Intent. Photolytic and thermal degradation of polymeric products and articles treated with them is described in LOI Appendix 4, Item 2. Incineration is described in Appendix 4, Item 6. These studies will provide information relevant to these abiotic transformation processes. Pending the results of these studies, additional work may be planned to explore these pathways by other study methodologies.

What are the chemical identities of the products?

The TRP member companies have individually submitted the chemical identity of the polymeric products to be tested as confidential business information to the agency.

What test method will be used?

8 2 Telomer B Alcohol Studies:   Accelerated Biodegradation Test / Preliminary Screening Study: Modified OECD 302 Guidelines   Aerobic Biodegradation: 28 day OECD 301D, Closed bottle, Ready Biodegradation study ( under Good Laboratory Practices) with [ 3 14 C] 8 2 Telomer B Alcohol 11 TRP ( 9 May 03)

  Adsorption / Desorption Using a Batch Equilibrium Method: Soils   OECD Guideline 106; Activated Sludge Sorption Isotherm   OPPTS 835.1110 Telomer Based Polymeric Products: Modified OECD 302 B: Zahn Wellens/ EMPA Test What is the accuracy and precision of the test method?

The study test method, OECD 302B is well known. The specific study protocol was provided separately to EPA on May 9, 2003 for review and comment. The analytical method for determination of PFOA has been described in the DuPont report above. The specific method, its accuracy and precision for the proposed studies will need to be demonstrated and validated as part of the study work.

Will PFOA precursors such as free telomer alcohols be analyzed for in addition to PFOA? If so, which ones?

The TRP studies are focused on identification and quantitation of PFOA. The results of these studies will be reviewed to determine what, if any, additional study work to pursue.

Do you have a consolidated written description of the procedures that will be followed with this testing? If so, please provide a copy. If these procedures have already been identified in a submission to the Agency ( i. e.,. to AR226 or 8( e)), please identify the submission.

A draft study protocol was submitted to EPA along with the rationale for the biodegradation studies on telomer based polymeric products ( submitted May 9, 2003).

What is the timing of this work?

May 2003   Finalize study protocols June 2003   Review study rationale and protocols with EPA June Sept 2003   Conduct studies Submit study reports as they become available.

Incineration Analysis ( LOI Item 6, page 5)

The TRP is planning to conduct a desk study on the ultimate fate and disposal routes ( incineration versus landfill) of the telomer based polymeric products and articles treated in the United States. Available information will be compiled and reviewed; the results will be provided to EPA. Concurrently, TRP will examine information available on types of incineration tests that may be applicable. An independent consultant will be retained to review and analyze such tests. EPA may also have some information that is relevant.

In addition, the TRP has identified and initiated discussions with a research laboratory known for their capability to conduct studies to determine the outcome from incineration.

Significance / Expected Outcome: Prior to conducting analysis of incineration methods and actual incineration tests, information is need to determine if incineration is a significant disposal 12 TRP ( 9 May 03)

13 route for telomer based polymeric products and articles treated in the United States. The out come of the " Incineration versus Landfill Study" will provide critical information on whether to pursue incineration tests.

Note: Most of the questions posed by EPA in the April 30 letter regarding incineration are not relevant to TRP's current research plans as described in the LOI. EPA's questions follow.

How many products and articles will be analyzed?

How will representative products and articles be selected?

What are the chemical identities of the products?

What test method will be used to analyze the samples?

Has the test method ever been validated?

What is the accuracy and precision of the test method?

Will PFOA precursors such as free telomer alcohols be analyzed for in addition to PFOA? If so, which ones?

Do you have a consolidated written description of the procedures that will be followed with this testing? If so, please provide a copy. If these procedures have already been identified in a submission to the Agency ( ie. to AR226 or 8( e)), please identify the submission.

What is the timing of this work?

May   July 2003   Compile information on telomer based polymeric products and uses to understand the ultimate fate and disposal routes ( landfill versus incineration) for telomer treated articles in the United States.

  Review information on types of incineration tests that may be applicable and provide this information to EPA.


[Federal Register Volume 77, Number 215 (Tuesday, November 6, 2012)]
[Notices]
[Page 66608]
[FR Doc No: 2012-27018]

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DEPARTMENT OF ENERGY

Federal Energy Regulatory Commission

 [Project No. 14460-000]

 New England Hydropower Company, LLC; Notice of Preliminary
Permit Application Accepted for Filing and Soliciting Comments, Motions
To Intervene, and Competing Applications

    On October 15, 2012, New England Hydropower Company, LLC filed an
application for a preliminary permit, pursuant to section 4(f) of the
Federal Power Act (FPA), proposing to study the feasibility of the
Hemlock Gorge Spillway Dike Project to be located on the Charles River,
in the City of Newton, in Middlesex County, Massachusetts. The sole
purpose of a preliminary permit, if issued, is to grant the permit
holder priority to file a license application during the permit term. A
preliminary permit does not authorize the permit holder to perform any
land-disturbing activities or otherwise enter upon lands or waters
owned by others without the owners' express permission.
    The proposed project would consist of: (1) The existing 31-foot-
high, 69-foot-long Hemlock Gorge Spillway Dike with an 8-foot-long
stop-log slot; (2) an existing 31-foot-long, 42-inch-diameter low level
penstock; (3) an existing 0.13 acre impoundment with a normal maximum
water surface elevation of 66.3 feet National Geodetic Vertical Datum;
(4) a proposed 6-foot-high, 8-foot-wide head box structure equipped
with a 15-foot-high, 8.5-foot-wide trashrack with 4-inch bar spacing,
and a 5.9-foot-high, 7.9-foot-wide sluice gate; (5) a proposed 8-foot-
long, 8-foot-wide powerhouse equipped with a 36-foot-long, 8-foot-wide
Archimedes screw generator unit with an installed capacity of 30
kilowatts; (6) an existing 90-foot-long, 8-foot-wide, 4-foot-deep
tailrace; and (7) a proposed 35 kilovolt, 170-foot-long transmission
line connected to the NSTAR regional grid. The project would have an
estimated average annual generation of 211 megawatt-hours.
    Applicant Contact: Carol Wasserman, New England Hydropower Company,
LLC, P.O. Box 5524, Beverly Farms, Massachusetts 01915;<PHONE_NUMBER>.
    FERC Contact: Tom Dean;<PHONE_NUMBER> or<EMAIL_ADDRESS>    Deadline for filing comments, motions to intervene, competing
applications (without notices of intent), or notices of intent to file
competing applications: 60 days from the issuance date of this notice.
Competing applications and notices of intent must meet the requirements
of 18 CFR 4.36. Comments, motions to intervene, notices of intent, and
competing applications may be filed electronically via the Internet.
See 18 CFR 385.2001(a)(1)(iii) and the instructions on the Commission's
Web site http://www.ferc.gov/docs-filing/efiling.asp. Commenters can
submit brief comments up to 6,000 characters, without prior
registration, using the eComment system at http://www.ferc.gov/docs-filing/ecomment.asp. You must include your name and contact information
at the end of your comments. For assistance, please contact FERC Online
Support at<EMAIL_ADDRESS>or toll free at 1-866-208-3676,
or for TTY,<PHONE_NUMBER>. Although the Commission strongly encourages
electronic filing, documents may also be paper-filed. To paper-file,
mail an original and seven copies to: Kimberly D. Bose, Secretary,
Federal Energy Regulatory Commission, 888 First Street NE., Washington,
DC 20426.
    More information about this project, including a copy of the
application, can be viewed or printed on the ``eLibrary'' link of
Commission's Web site at http://www.ferc.gov/docs-filing/elibrary.asp.
Enter the docket number (P-14460) in the docket number field to access
the document. For assistance, contact FERC Online Support.

    Dated: October 25, 2012.
 Kimberly D. Bose,
 Secretary.
[FR Doc. 2012-27018 Filed 11-5-12; 8:45 am]
BILLING CODE 6717-01-P