Document 6EBEyLVGN88oEbkrmX8d6V1o

3M Specialty Materials 3M Center St. Piu, MN 55144-1000 651 733 1110 Sanitized Copy May 28, 1999 3M Frank D. Kover, Chief Chemical Information and Testing Branch Chemical Control Division Office o f Pollution Prevention and Toxics U.S. Environmental Protection Agency 401 M Street, S.W. Washington, D.C. 20460 RE: Fluorochemical Use, Distribution and Release Overview Dear Mr. Kover: As previously discussed, 3M is enclosing an overview paper and supporting appendices that provide detailed information regarding the manufacture, use, distribution and environmental release o f sulfonyl-based fluorochemicals (FCs) produced by 3M. These materials are intended to present a preliminary life-cycle assessment o f FC pathways for human and environmental exposure from the time these materials leave the control o f 3M through their end-use and/or disposal. This assessment is primarily qualitative and is based on available information within 3M and the experience and judgment of 3M marketing and technical support staff. 3M is augmenting this preliminary exposure assessment with a variety o f additional actions, including several stewardship initiatives and a comprehensive exposure assessment plan. Implementation o f these actions is ongoing. 3M's stewardship and exposure assessment activities are summarized in the enclosed overview paper and will be described more fully in future submissions to EPA. EPA now possesses considerable information about the health and environmental issues associated with 3M's FC product line. These include the comprehensive review o f PFOS health effects and background chemistry paper submitted in February 1999, various Section 8(e) submissions and the enclosed preliminary exposure assessment. 3M scientists are available to meet with the EPA technical staff at the Agency's convenience to discuss the information we have submitted to the Agency. We will be in touch shortly to schedule this meeting. Please note that portions o f the enclosed overview paper and appendices contain proprietary and confidential business information (CBI) protected from disclosure under Section 14 o f TSCA. Release o f this information would be harmful to 3M's competitive position. We are therefore providing EPA with sanitized and unsanitized versions o f both documents. We request that EPA maintain the confidentiality o f the unsanitized version in accordance with TSCA Section 14 and EPA regulations. The sanitized version can be placed in the public docket 000001 0 /2 0 *7?'ON 0.`0 l 6 6 , 2 /9 0 9C 6L / I.C9 9t. QC7 x s u a uau- Page 2 Frank D. Kover 3M appreciates your cooperation. Sincerely yours, W illiam A. Weppner, Ph.D. D irector Environmental, Health, Safety & Regulatory Affairs Speciality Materials Group 3M Center, Bldg. 236-1B-10 St. Paul, MN 55144 651/733-6374 Enclosures c: Oscar Hernandez David Williams 8 ( c) Dkt. Nos. 8EHQ-1180-373,1180-374 and 0381-0394 cn/cn 000002 in mi c7fon OCA I c c ; tCQ fll OC7 WCU3 I.HUI