Document 2qZD1dzQzRZXQVy3QNDo7Zy57

ii> Polymer Pro d u cts Chestnut Run Plaza P.O. Box 80713 Wilmington, Delaware 19880-0713 May 31, 1991 Mr. Robert Wilson Arlon 1100 Governor Lea Road Bear, DE 19701 Dear Bob: Enclosed you will find copies of the documents I faxed to you earlier. These documents give a summary of the exhaust gas composition and volumetric exhaust rates from a coating tower that Du Pont operated in Fairfield, CT. The temperatures that the oven zones were operating at during the test were 180 degrees F in zone 1, 530 degrees F in zone 2, and 730 degrees F in zone 3. I have also enclosed a portion of our revised MSDS for TEFLON(R)* dispersions. I have highlighted the section titled "Hazardous Decomposition Products" which deals with PTFE resins. Hopefully this information will enable you to meet the requirements of the State of Delaware. If not, and you need additional information, please contact me and we can discuss how to proceed. tc noni cc: C. I. Haznedar, Du J M. A. Cardona, Du Pont Teflon(R) is the Du Pont Company's registered trademark for its fluorocarbon resins. 000157 Better Things t<y Befter Living EID902003 CC: M. E. HERMES R. C. DILL FAIRFIELD, CONNECTICUT MAY 13, 1977 TO: F. A. FLUEGGE FROM: M. W WESTLEY ARMALON TCGF * TOWER #3 STACK SAMPLING Air samples were taken from both exhaust stacks of Tower #3 on 4/28/77 during a run on Armalon TG-4060 Teflon TFE coated glass fabric. Stack #1 exhausts Zones 1 and 2, while stack #2 exhausts Zone 3. Air sampling and exhaust stack velocity profiles were taken by M. Westley and M. Miller. ^- Physical dimensions, average velocity profiles and corresponding exhaust volume calculations re summarized as follows: T ~ TOWER #3 STACK 1 STACK 2 Exhaust- from zones Diameter, inches Average Air Velocity, Ft/min Exhaust Volume,ACFM Exhaust Volume, Ft3/hr. 1 and 2.40 7600 ( 3 i V * f ) 4.56 x 105 -3 24 1520 oj 4800 ( S o F ) 2.88 x 105 Recirculation dampers were set at fully open for stack 1 and fully closed for stack 2, which is the normal TCGF operating condition. The run in progress at the time of sampling was Armalon TG-406038", job no. T-39520101A. Two coats had previously been applied and fused. Sampling was conducted during the third pass, which was being coated at a line speed of 10 ypm. Adjacent 1 yard samples of the coated fabric before and after the third coat were taken, and 12 replicate area weight determination made on 3.81" x 4.00" specimens cut from each sample.Prior to the third coat, the average weight was 5.006 ozs/sq.yd., with a standard deviation of 0.039. After the third coat, the measured average weight was 6.156 ozs/sq.yd. with a standard deviation of 0.114. Thus, weight pickup was 1.150 ozs/lineal yard at the measured width of 38-1/16". At a line speed of 10 ypm, this is equivalent to a Teflon"5 solids application rate of 45.60#/hour. EID902004 The coating solution being applied (3010 cement) had been made from ......... 0 0 0 1 ^ 8 k.K '<){>(>! -2- Teflon 30 dispersion, blend No. 74^. Measured properties were 59.0% TFE solids, and 6.5% Triton X100 (based on TFE solids). Assuming no TFE solids are volatized during processing, and assuming complete removal of all other constituents of 3010 cement, the feed rate * was as follows: FEED RATE. #/H0PR- TFE solids Rohm & Baas Triton XLOO* Union Carbide L77** - Water - - . ~. 45.60 2.97 0.33 28.72 Alkylarylpolyether alcohol ** Qryethylene Methyl Siloxane Attached is a copy of the exhaust gas analysis performed at the PP&a department laboratory at the experimenatal station. The exhaust gasses would contain combustion products of each zone's heating burner in additon to any pyrolysis products of the organic coxsrtituend of the cement feed- . A summary of the exhaust gas composition and .volumetric exhaust rates are as followsr STACK 1 PPM* Ft3/hour STACK 2 PPM* Ft3/hour Carbon Dioxide Carbon Monoxide Methane 2500 5 2 1140 2-- 3 0.9 3000 2 6 8640.6 1.7 By volume M. E. Hermes had expressed concern that dioxane might be a toxic product of pyrolysis of Triton X100. As noted in the attached report. No measurable quantities of dioxane were detected. I suggested we have a meeting with R. C. Dill and M. E. Hermes to determine if the data reported in this memo will allow us to legally continue manufacture of Armalon TCGF under existing State of Connecticut EPA laws, or if some further action is required. X -i'Ooo. jj7 MWW/cmh Attch. oooir-y EID902005 \ ^ rr- ^ ? .'., r C n f . V h o * *4*4 w i yf+f. c a n n i * **#M% si_ i A 4 A * ' 1 i ' A * 7 1 * i .J . ' r ^ - ' ^ v ? ._rat z : 1 R i - ^ . ' . ^ '/ j ^ y . ; `1 J 'i-:;;-:- F. Raniszewski CTTCR t h in g s ro w s c t t c w liv in g . . . th w ow gh CM CM isrjrr.- -' - -r- 0 1 6 0 ... EID902006 9t'0()ojr Cf^f /// Z>uJ /y/cu/ *aternerit cveriimcl if es tnirigs aria causes many ions from customers, air pollutiori agencies and state cr federal OSHA personnel. F-rorn the data availaDle to the questions appear to be caused by the following: HF, COF, nd perf 1uorool ef ins are not given off at the same temperature as particulate matter, whicn may cause pel y'""123* fllM fever (PFF). _________ _________ Our safe handling bulletin says: o COF arid PFIB have been reported at aoout 500 C. o Trace amounts of HF are liberated as low as 400 C. o Up to A 50 C the principal toxic ingredient is part iculate matter. 2. The decomposition temperatures used in our MSDSs have been conservatively taken as the temperature at which the initial weight loss is 0.001 %/hr (data from Safe Handling Bulletin), which is sometimes below the melting point of the resin, where there is little or no hazard. PROPOSED CHANGES Following is a draft of statements agreed to at tne 3ad /9i meeting of the SPD Plastics Toxicity Committee meeting. If no oDject ion is received by 4/10, tnese statements will be incorporated into all of our TEFLON MSDSss 1. For resins for which the rat Al T is higner than the melting point (PTFE and FEP resins): HAZARDOUS DECOMPOSITION PRODUCTS Above the melting point, small amounts, of particulate matter evolved from prolonged heating may cause polymer fume fever (see INHALATIUN below). Trace amounts of hydrogen fluorioe and carbonyl fluoriae may be evolved at temperatures above 400 deg C <750 deg F). 2. For resins for which the rat ALT is lower than the melting point (PFA and FPFA): HAZARDOUS DECOMPOSITION PRODUCTS Prolonged heating in unventilated areas at ternDenatures as low a s __ oeo C <___ deg F) may cause evolution of small amounts of particulate matter which may cause polymer fume fever (see In h h l AVIUN below). Trace amounts of hydrogen fluoriae ana carDonyl fluoride may be evolved at temperatures aoove 4U0 aeg C (/So deg F). (The temperatures used in the blanks aoove will be tne rat ALT, which is 300 deg C (570 deg F) for PFA and 00 deg C (390 deg F) for FPFA.) 3. Irradiated resins are special cases. For these we will follow the convention above for polymer fume fever, but will use the following temperatures for evolution of Hr, as at present: r{y^ ^ 000161 EID902007