Document 3Q1J3D4K1x4LENEwMxq4BwB0y

3M Specialty Materials 3M Center St. Paul, MN 55144-1000 0S3Lf-651 733 1100 FVT-OloOO-I7 June 8, 2000 Contain FYI-00-001378 cCz>9 Q Dr. Charles Auer Director Chemical Control Division Office of Pollution Prevention and Toxics United States Environmental Protection Agency 401 M Street, Southwest Room 403 East Tower (Mail Code 7405) Washington, D.C. 20460 FYI-00-001378 3*7 7 l 8500000002 Re: Information of Perfluorooctanoic Acid & Salts - UEIP Form Dear Charlie: 3M is enclosing the completed "Use and Exposure Information Profile" or "UEIP" for perfluorooctanoic acid and salts. With respect to industrial hygiene information, you should be aware that each 3M plant that produces perfluorooctanoic acid and salts has an industrial hygienist on staff and is supported by a corporate industrial hygiene group. 3M's industrial hygiene program focuses on task-based exposure assessment and control. Exposures are identified and assessed qualitatively and/or quantitatively. Qualitative assessments are performed by an industrial hygienist. Quantitative assessments include task-based personal sampling for certain, specific fluorochemicals and/or source or area sampling. The results of the assessments support decisions on exposure control. Engineering controls are preferred, but personal protective equipment may be used on an interim basis or when effective engineering control is not feasible. In certain situations, 3M has gathered personal industrial hygiene and area/source monitoring data for a specific compound and has included the personal industrial hygiene data in the profile. The area/source sample results and/or surface wipe sample results are used to target areas with employee exposure potential as part of exposure assessment under 3M's industrial hygiene program and are not measurements of actual employee exposures. Hence, they are not included with this submission. In other situations, neither personal sampling data nor area/source data have been collected for a specific chemical. The sample results of any air monitoring are compared to the ACGIH TLV-TWA of 0.01 mg/m3 [skin] for the ammonium salt and to 3M's voluntary exposure guideline (EG) of 0.1 mg/m3 (milligrams of fluorochemical per cubic meter of air) for the acid and sodium salt. The EG is an 8hour time-weighted average (TWA) personal breathing zone exposure chosen to minimize potential for uptake. Page 2 Dr. Charles Auer Similar to the industrial hygiene program, each 3M facility that produces fluorochemicals has one or more environmental engineers on-site and is also supported by a corporate and division level environmental organization. The environmental engineers assist the process engineers with calculations and emission estimates. The corporate environmental organization develops methods for analyzing emissions. In addition to these resources, several teams were established in recent years to identify, characterize and reduce specific fluorochemical emissions from the manufacturing sites. While analytical methods have improved over time, large variability still exists for certain matrices and compounds, so data available for this report is mostly of a qualitative nature. Although limited monitoring data exists, most emission and waste estimates are based upon process models and engineering calculations. Engineering calculations, however, have limitations with respect to fluorochemicals because fluorochemical losses were not always included in the analysis of each intermediate step. The accuracy of the emissions data submitted varies due to several factors. Batch process system emissions are difficult to measure due to quickly changing process conditions, venting pressures and difficulty in isolating processes to take measurements. Additionally, the unique characteristics of these compounds cause them to behave differently from conventional compounds, and physical chemical data properties are not available for all intermediate reaction steps. Please do not hesitate to contact me at 651-733-6374 should you have any questions. Very truly yours, William A. Weppner, Ph.D. Director Environmental, Health, Safety and Regulatory Affairs 3M Specialty Material Markets Group 3M Center, Building 236-1B-10 St. Paul, MN 55144-1000 651/733-6374 651/733-1958 (fax) wavveppner@mmm.com Attachments