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Biennial Report for the Manufacture of APFO
Calendar Years of 2002 and 2003
DuPont Company — Fayetteville Work
Biennial Report for the Manufacture of APFO
Calendar Years of 2002 and 2003
DuPont Company — Fayetteville Works
Page 1 of 5
Note: The information contained in this document is submitted voluntarily and may be subject to future revision
andlor 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
following, 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. 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
Contains Confidential Business Information
Biennial Report for the Manufacture of APFO
Calendar Years of 2002 and 2003
DuPont Company — Fayetteville Works
1. Annual production volume of APFO
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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 � � Confidential
Business
2003 Information
2. Emission per facility (air, water, waste);
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 = less than the practical analytical quantification limit of 0.05 µg1L
3. Summary report of groundwater monitoring results
In 2002, the DuPont Company — Fayetteville Works performed air dispersion modeling to
While APFO is the substance manufactured at the facility, the substance measured by analytical techniques is the
perfluorooctanoate anion (PFOA)
Contains Confidential Business Information
Biennial Report for the Manufacture of APFO
Calendar Years of 2002 and 2003
DuPont Company — Fayetteville Works
Page 3 of 5
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-01, SWM -02, and MW -1S 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 µg/L, 1.530 µg/L, and 0.123 gg/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.
The following table shows the groundwater monitoring analytical results for 2003 and 2004:
Contains Confidential Business Information
Biennial Report for the Manufacture of APFO
Calendar Years of 2002 and 2003
DuPont Company — Fayetteville Works
Page 4 of 5
Sample Name
(Monitoring Well Description)
Monitoring
Date
PFOA
SMU-01
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
SMU-02
01/27/03
<0.01
(New well at Construction Gate entrance; Southwest
03/27/03
<0.01
of APFO Facility)
02/04/04
<0.01
MW -1S
01/28/03
<0.05
(Existing well at Old Biosludge Lagoon SWMU by
01/28/03
_
<0.05
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
02/04/04
0.303
Sump; Southeast of APFO Facility)
NAF -03
(Existing well downgradient of Nafion® Common
02/04/04
1.530
Sump; Southeast of APFO Facility)
NAF -04
(Existing well downgradient of Nafion(P Common
02/04/04
0.123
Sump; Southeast of APFO Facility)
4. 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 µg/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.
5. 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 and dermal personnel protection. The analytical results
Contains Confidential Business Information
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Biennial Report for the Manufacture of APFO Page 5 of 5
Calendar Years of 2002 and 2003
DuPont Company — Fayetteville Works
reported in the following table are the 12 -hour time weighted average (TWA) PFOA
concentration values.
Mg/M3 = milligrams per cubic meter
6. 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
Sample
Number
Minimum
Maximum
Average
Year
Type
of
Cone.
Cone.
Cone.
2002 17
0.004
Samples
(mg/m3
m m3
m m3
2002
Area 12 -hr
TWA
4
0.008
0.024
0.017
2003
105 0.000 0.292
0.010
Mg/M3 = milligrams per cubic meter
6. 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
Year Samples
Concentration
Concentration
Concentration
(ppm)m
m)
2002 17
0.004
0.020
0.011
2003 44
0.008
2.280
0.217
ppm = parts per million
Contains Confidential Business Information