United States
Environmental Protection
Agency

If you want to know more

I 'or ijcncml inl'ormalion ahonl ihis
order.

N\\ hoi line — SOO-575-S54.1

The consent order is
a\ ai lahle nl

www epa uo\ red on 5 water uwd
w diipont index him

The 2'in(i consent order is
a\ ailable ill:

www epa uo\ reuio'i.i cnlbrceme
ill dupol order.pelf

I or information 011 llie PI-OA
Slewarclship Prouram and 011 lhe
risk assessment acti\it\ see
www epa uo\ oppt plba

I'or reference materials and
information 011 the C-S I leallh
Project, residents and physicians
can refer to the documents
a\ailaMe 011 these W eb sites
www odli oliio uo\ odhProurams

eh 111 ill as cheml'sl asp.x and
w w w. c S h ea 11 h p roj ec t o ru

DuPont Agrees to Lower Limit
Of PFOA in Drinking Water

DuPont Washington Works

Parkersburg, West Virginia

March 2009

A new legal agreement between U.S. Environmental Protection Agency and
E.I. du Pont de Nemours & Co. will lower the limit of PFOA in drinking
water for people who live near DuPont's Washington Works facility in
Parkersburg, W.Va. Under terms of the agreement - known as a "consent
order" - DuPont will offer water treatment or bottled water to people on
public or private water systems when the level of a chemical called PFOA -
also known as perfluorooctanoic acid or C-8 ~ in water supplies reaches 0.40
parts per billion (ppb).

EPA's Office of Water issued a Provisional Health Advisory (PHA) in
January for PFOA that establishes a reasonable, health-based value above
which action should be taken to reduce exposure to PFOA in drinking water.
The time frame for action is short-term - meaning weeks to months. This
PHA prompted the new agreement to lower the allowable concentration of
PFOA in drinking water from 0.50 ppb to 0.40 ppb in communities near the
Washington Works facility. If affected homes cannot be connected to a public
water system or a treatment system within 30 days, DuPont must offer bottled
water. People who live in the PFOA-contaminated water areas affected by the
new action level may reduce their exposure by not drinking the water until
treatment systems are installed, or they are connected to a public water
system.

EPA expects a limited number of residents will be affected by the new action
level. Current data identifies about 14 private residences that may need a
treatment system installed or connection to a public water system. If these
residences cannot be connected to a public water system or treatment system
within 14 days after the order is signed, then DuPont must offer alternative
water. In addition, there may be a small number of private drinking water
wells, installed after 2006, that need to be tested for PFOA. EPA is also
assessing monitoring data and other information to determine if there are any
previously untested areas that need to be surveyed.

Under a 2006 consent order, all public and private water systems that had
PFOA levels above 0.50 ppb were offered alternative water or treatment, and
DuPont is maintaining the alternative water or treatment at those systems
today.

EPA issued the 2006 order in response to a study available at the time that
evaluated about 340 residents living in the most heavily affected communities
in Ohio near DuPont's Washington Works plant. That study showed residents
had an average PFOA level of 298 to 369 ppb in their bloodstreams. More
recent data gathered under a PFOA health study involving some 64,000
people, indicates the average PFOA levels in the bloodstreams of everyone in
the affected communities to be about 28 ppb. These values are still much
higher than the average 5 ppb level found in the national population.

-------
The 2006 order also relied on other studies that
demonstrated various kinds of toxic effects on
experimental animals. EPA believed the results were a
concern for public health. EPA's Office of Water used
new information, an advanced risk assessment technique
and a different principal study from the one used in 2006
to establish the new national limit for PFOA of 0.4 ppb.

Boiling does not remove PFOA from water. That is done
by treatment with granular activated carbon. Where this
treatment has been installed in a water system, consumers
are receiving water with either undetectable PFOA levels
or very low concentrations of .003 ppb, well below the
0.40 ppb action level. All of the area's large public water
systems, including Belpre, Little Hocking, Lubeck,
Mason County, Tupper Plains/Chester and Pomeroy, are
already treating water for PFOA.

As for private water systems - primarily water wells for
private homes - since 2006 DuPont tested a large number
of systems and either connected them to a public water
system or installed treatment equipment on 50 systems
that had PFOA levels of 0.50 ppb or above.

Order requires expanded survey

DuPont is required under the terms of the new consent
order to survey geographical areas defined by EPA to
determine if additional public or private water systems
contain water that exceeds the new 0.40 ppb PFOA
action level. These areas will be further evaluated and
refined in consultation with Ohio and West Virginia
officials as analytical data become available. Residents
with newly drilled drinking water wells or wells not
previously tested for PFOA may be eligible for sampling.
They should contact EPA at 866-575-8543.

EPA does not certify labs for analysis of PFOA. Due to
the complex nature of analytical procedures for this
substance, EPA strongly encourages residents to allow
DuPont to sample their water.

There is no consensus on how PFOA may affect people.
However, concerns have been raised because of data
from animal experiments and data from blood samples
from people who live near the Washington Works
facility. More studies are in progress but results may not
be available for several more years. In the meantime, the
new action level will reduce local exposure to PFOA
from drinking water and reduce the possibility of adverse
health effects.

Technical background: What is PFOA?

PFOA, or C-8, is a man-made chemical that resists heat,
water, oil, grease and stains. It has been used in making
common household and industrial items such as non-stick
pots and pans, flame resistant and water-proof clothing,
wire coatings, and chemical resistant tubing. PFOA can
also be formed by the breakdown of other highly
fluorinated chemicals used in stain-resistant carpets and
fabrics, stain-resistant paints, fire fighting foam, and oil-
and grease-resistant food cartons and wrappers. PFOA
does not occur naturally in the environment and is highly
persistent, with little or no degradation occurring in air,
water or soil.

History of legal orders

This order supersedes the Emergency Administrative
Order on Consent that was issued in 2006 under the
authority of the Safe Drinking Water Act. Section 1431
of the Act requires a finding that "a contaminant is
present in or is likely to enter a public water system or
underground source of drinking water ... which may
present an imminent and substantial endangerment to the
health of persons." It does not require a conclusive
finding that a contaminant has, or definitely will, cause
harm.

The 2006 order contained a temporary threshold value of
0.50 ppb PFOA based on information available at the
time about blood serum levels of the chemical in the local
population and scientific studies. The 2006 order was a
revision to a 2002 order, which established an action
level of 150 ppb. The new order's revised action level of
0.40 ppb PFOA is based on new and different
information than what was used to calculate the 2006
action level. The former 0.50 ppb site-specific action
level for PFOA was a threshold for DuPont to provide
treatment or alternate water to public and private water
users in the vicinity of the facility, and the new action
level of 0.40 ppb is an updated threshold. The Agency
continues to conduct its risk assessment under the
authority of the federal Toxic Substances Control Act.
Until that process is complete there will not be a
reference dose or an official maximum contaminant level
for drinking water.

West Virginia and Ohio authorities have relied on EPA to
review the existing 2006 order and have requested EPA's
assistance with this matter.

2

-------
PFOA levels in drinking water and human
blood

The average human blood serum PFOA concentration in
the United States is around 5 ppb. PFOA can be absorbed
though swallowing, breathing and skin exposure. We do
not know which exposure routes account for the
background levels of PFOA in the general population.

Some residents in the vicinity of the Washington Works
plant had median blood serum levels ranging from around
298 to 369 ppb PFOA. Data from a more recent study
indicate the average has dropped to about 28 ppb. The
high blood serum levels in residents are attributed to
accumulation of PFOA in the bloodstream and its slow
elimination from the human body. The half-life of PFOA
in humans is approximately 3.8 years. Half-life is the
time required to reduce the chemical to one-half the
initial concentration. For example, with no additional
PFOA input it will take approximately four years for
blood values of 100 ppb to be reduced to 50 ppb.
Ingestion of PFOA through drinking water is considered
a major source of the chemical found in the blood of
residents in the vicinity of the DuPont facility. Reducing
exposure to PFOA in drinking water will reduce the
accumulation of the chemical in residents.

The drinking water levels in nearby water systems have
historically averaged from 1 to 20 ppb PFOA. For the six
public water systems in the area and for private
residences that accepted treatment, PFOA levels in
drinking water have been significantly reduced to
undetectable concentrations and most often less than .003
ppb. While much is known about the occurrence of
PFOA in the vicinity of this DuPont facility, the
substance is not a regulated drinking water contaminant.
Therefore, public water systems are not required to
monitor for PFOA.

Recent scientific information

EPA's Office of Water used new scientific information,
an advanced risk assessment technique, and a different
principal study from the one used in 2006 to develop the
PHA. The principal study the Office of Water used
involves peer-reviewed research in mice that looked at
developmental effects of PFOA as the toxicological
endpoint. The 2006 calculation used an earlier study of
monkeys that looked at mortality rates as the
toxicological endpoint. Additionally, since the 2006
order was issued new information and data has become
available on PFOA half-lives in some animal species that
the Office of Water used in its calculation. The Office of
Water also applied a more advanced risk assessment

technique that resulted in an update to some of the values
used to calculate the new Provisional Health Advisory from
those used in 2006. EPA continues to monitor emerging
scientific information regarding PFOA in the interest of
public health. EPA and DuPont agreed to revise the existing
order.

Other legal actions

In 2001 DuPont, the West Virginia Department of
Environmental Protection and the West Virginia Department
of Health and Human Resources entered into a consent
agreement. The legal order required a toxicological and
human health risk assessment of C-8 be conducted under the
supervision of a C-8 assessment of toxicity team. Ground-
water and surface-water monitoring and plume identification
in West Virginia and Ohio were conducted under the
supervision of a ground-water investigation team.

An order issued in 2005 in response to a 2001 civil suit in
Wood County, W.Va., {Leach, etal v. E.I. DuPont de
Nemours & Company) required collection of blood serum and
health data from about 70,000 people who live near DuPont's
Washington Works facility. The collection of blood serum
and health data is known as the Brookmar Study. It also
provided for the installation of carbon filters for six public
water service districts in West Virginia and Ohio. EPA was
not a party to the civil action or the settlement. EPA will,
however, evaluate data produced by these studies as well as
other information generated as part of its ongoing review in
the risk assessment process.

Major human health studies in progress

PFOA Health Project: In 2006 about 64,000 people
completed questionnaires and had blood drawn. Brookmar
Inc. has been hired to collect and compile the health data and
blood serum levels. Then a three-member science panel will
assess whether there are adverse health effects to humans
associated with elevated levels of PFOA in the blood serum.
Although the full results of the study are not expected until
about 2011, the blood serum concentrations are available to
the people who participated. Ohio Department of Health, the
federal Agency for Toxic Substances and Disease Registry,
Ohio Environmental Protection Agency, West Virginia
Department of Environmental Protection and West Virginia
Department of Health Human Resources wanted to have
reference materials available to local physicians as their
patients received data. Information is available at:
www.odh.ohio.gov/odhPrograms/eh/hlth_as/chemfs 1 .aspx

3

-------
Status of EPA risk assessment

Under the Toxic Substances Control Act, EPA is
evaluating PFOA and related perfluorochemicals. A
formal risk assessment process is under way. EPA's
Science Advisory Board completed a review of a draft
risk assessment of PFOA in 2006, and the board made
recommendations for the further development of the
assessment. A final risk assessment may not be
completed for several years. Once a final risk
assessment is completed, or if further information
about the health effects of PFOA indicates it is
necessary , the action level of 0.40 ppb PFOA
established in the latest legal order with DuPont will be
re-evaluated. The Agency is funding additional
research regarding the toxicity of PFOA and other
perfluorochemicals, as well as research to help identify
where these chemicals are coming from and how
people may be exposed to them.

Other EPA actions on PFOA

The EPA risk assessment activity on PFOA and its
salts will take time to complete, but the Agency has
already taken action to reduce the amount of PFOA
getting into the environment. In 2006 EPA invited
major companies in the industry to commit to a
voluntary, global PFOA Stewardship Program. All
invited companies, including DuPont, have committed
to the goals of the program, which include reducing
facility emissions and product content of PFOA and
related chemicals by 95 percent by 2010 and working
toward elimination of releases and product content of
these chemicals by 2015. As of the end of 2006,
DuPont had reduced annual air discharges of the
chemical from the Washington Works facility by 99.1
percent and had reduced annual water discharges by
99.2 percent since 2000. DuPont and the other
companies are submitting reports to EPA on their past
activities and on their progress toward the Stewardship
Program goals.

4

-------