Document 6R9wjk1oEJq8ZyYYR0v0bbZX9

r- fi ' The Plastics Industry Trade Association April 24,2001 Tracy G. W illiam son, Ph.D. Chemist, Industrial Chemistry Branch O ffice o f Pollution Prevention and Toxics (OPPT US Environmental Protection Agency 401 M Street, S.W. W ashington, DC 20460 o: 7 \>\ji cI--r n ' V" rV1"'>!I'- _ io!a 'loo 3 e> I oooeo ( Dear Dr. W illiamson: On behalf o f the Fluoropolymer Manufacturers Group (FMG), I would like to extend my appreciation to you and your associates for the opportunity to continue the dialogue on fluoropolymers and APFO. 1. As we promised during our m eeting, I have included in this package copies o f our presentation slides. a. One copy is marked "Company Sanitized, Does not contain TSCA CBI." b. The other copy is marked "Contains TSCA CBI" and is contained in an inner envelope marked "Company confidential, contains CBI." This inner envelope is addressed to you. 2. Please note this letter does not contain confidential business information. I hope that this information is sufficient for your needs as this time. If there are any other questions, please do not hesitate to contact the Society o f Plastics Industry. We are committed to working with the EPA in this important matter. Executive Director Fluoropolymer Manufacturers Group ro cz) ~Oo -rTn) I no "O O r- ro KO The Society of the Plastics Industry, Inc. 1801 K Street, N W , Suite 600K W ashington, D C 20006-1 301 tel 2 0 2 .9 7 4 .5 2 0 0 fax 2 0 2 .2 9 6 .7 0 0 5 http://www.plasticsindustry.org Contain NG CBI I EPA/SPI-FMG/DuPont Fluoropolvmers and APFO: Discussion of Value in Use April 23, Washington O.C SU DuFont/SFn^articipants Don Duncan: President, Society of the PlasticsTndustry Subhash Gangal: Global Technology Manager, DuPo Dave Rurak: Global Business Manager, DuPont > Meeting-Goals Recognize the technological and societaPhenefits of fluoropolymers. Provide a clear understanding of the fluoropolymers manufacturing process, critical technical issues and,the role and importance of fluorosurfactants. \ Share work DuPont has done over the past 30+ years to, identify and evaluate non-APFO surfactants, and why no suitable replacements have been found. \ Clarify industry needs to maintain APFO use and develop new supply. 4 Agn4a Follow-up from March 7 MeetrX%Nx' Value of Fluoropolymers APFO Substitution Efforts - Business Incentive - Technical Discussion Industry Needs Going Forward r Follow -up from Mqrch 7 M eeting EPA Requests: \ .. Discussion of Possible APFO Substitutes Discussion of Bio-monitoring \ Additional Sharing on Containment and\ Exposure - APFO Risk vs. Benefits Fluoropolymers: Value to Society Through Unique Properties in ^Critical Uses  Discovered by "serendipity" in' 1938 Limited use in aerospace/military during World War II \ Cookware first major use in early 1960sx Primary use today in industrial markets Advance technology and system performance wherever they are used Flulopplymers: "Super" Polymers Chemical resistance across brohd temperature range \ "Slipperiest substance known to mank\ Unique properties/High value in use \ 1 Fluoropolymers 2000 Global Market Deman Billions) 0.2 -- 0.4^/ ROW Japan Western Europe \ 0.61 North America 1.33 Total Demand $2.5 billion Fl uoinpoly mer s : A Diverse PTFE Homopolymers Melt Processible Copolymers Fluoroelastomers and Perfluoroelastomers h PTFE Homopolymers Highest performance materialsv About 35% of total market \ - Granular: molded parts, thick extruded tubing - Fine Powder: thin extrusion \\ - Dispersion: coatings, fabric impregnation \ i* Copolymers About 40% of total market Melt-processible Can be molded or extruded - FEP - PVDF/PVF - PFA/MFA - ETFE/ECTFE/PCTFE - CTFE-VDF 1}  About 24% of total market Products sold raw or cured Three basic chemistries - vinylidene fluoride (VF2) - hexafluoropropylene (HFP) - tetrafluoroethylene (TFE) Major Ini ies wServed by Fluoropolymers/elastomers Aerospace/Military Automotive/Transportation Chemical/Petrochemical Processing Semiconductor/Electronics Manufacturi Telecommunications Power Generation/Pollution Control Consumer Housewares Aerospace/M i1itary Key requirements: Temperature chemical resistance; electrical performance; low flammability Major uses: Wire and cable insulation Fuel and hydraulic hoses Seals/bushing Space apparel Societal Benefits: Passenger protection; aircraft reliability 16 Key requirements: Chemical and temperature resistance; electrical performance; lubricity Major uses: Seals,bushings Fuel and brake hoses/tubing Control cables Underhood wire Societal Benefits: Lower vehicle weight and emissions; reliability Chemiea s Key requirements: Chemical and applications temperature resistance; non-stick Major uses: Lined pipes,valves, pumps Tank and reactor linings Gaskets, seals Wire insulation Societal benefits: Worker and public safety; industry productivity trochemicals Semiconducti Key requirements: Chemical and temperature resistance; purity; electrical performance Major uses: High-purity fluid handling equipment Silicon wafer carriers Clean room garments Societal benefits: Consumer product quality and cost; industry productivity Powef^Generation/ Pollution^Jitrol Key requirements: Chemical and temperature resistance; flexibility Major uses: Acid resistant filter bags Radiation resistant wire insulation Expansion joints Societal benefits: Fewer emissions to the environment; worker and public safety; process reliability 10 I elecomrttiaications Key requirements: Electrical performance; fire resistance; optical properties Major uses: LAN Cable Mainframe wiring Satellite wiring Fiber optic cladding and cable Societal benefits: Public safety; critical systems reliability JU Consumer Houses Key requirements: Non-stick; temperature resistance; easy to clean; hydrophobic Major uses: Non-stick cookware and bakeware Waterproof/breathable clothing Appliance wiring Societal benefits: Enables low-fat cooking; supports healthy lifestyle; consumer convenience i.2 yares/Apparei Fluoropolytncr Applications Sumnmi Fluoroplastics and fluoroelastomers provide unique and critical performance properties in "system critical" applications thaFproteet and benefit people and the environment For virtually all applications, fluoropolymers are the only materials thaf meet system performance needs. Application design and best-available technology based on fluoropolymers. Fluoropolymer Applications Summary (bontd.) OEM technology and investment based on fluoropolymers. \ Fluoropolymers have high value-in-use; am only used where there are no other options. Not-in-kind technologies for some \ applications have negative environmental \ impact and/or are cost prohibitive. \ Very Few Suppliers High Raw Material Cost Manufacturing Complexity Importance of APFO in Dispersion Polymerization Research on Global Technology Manager, DuPont *7 ENDA > Background - Commercial Fluoropolymere, processes used to produce them and major applications of each fam ily^nroducts. > Dispersion Polymerization Process and why it is important. > Sequence of events in the Dispersion Polymerization Reacthr. > Classes of Surfactants and limitations of their use in Perfluoropolymerization. \ \ > Efforts to replace APFO > Incentives > Evaluation Procedure > Research Efforts \ \ ^ JU g ss Information. Does Not Contain National Security Information Contains FLUOROPOLYMERS. POLYMERIZATION PROCESS AND>PPLICATIONS DISPERSION POLYMERIZATION PROCESS INGREDIENTS >Monomer(s) with extremely high purity > Water (demineralized) >Initiator (an oxidizing agent with high purity) > Surfactant (non-telogenic, high purity) > Optional other ingredients EQUIPMENT > Gently stirred heated reactor OF AQUEOUS ^MERIZATION > Very high heat of polymerization requires r^pid heat removal capability. > An ability to develop a specific particle architecture fhr a particular application. \ > An ability to maintain individual particle identity for fine \ powder applications. \ > Ease of availability of pure water. *1 KEY POLYMEIT6IIARACTERISTICS TAILORED FOR SPECHTC APPLICATIONS Dispersion particle size and morph Particle architecture Molecular weight and its distribution Comonomer content and its distribution High to extremely high molecular weight SEQUENCE VENTS IN THE REACTOR POLYMERIZATION MODEL EFFEC^OF TELOGENS (COMPOUNDSTTHAT LOWER MW) SURFACTA OR POLYMERIZATION Ionic Typically salts with a hydrophobic segment (hydrocarbon or fluorocarbon organic chain segment) and hydrophilic anion. e.g., R - CH2COO- NH4+ The dispersion stability is achieved by the particle to particle repulsiomdue to electrical charge. \\ Non-Ionic \ Typically alcohols with a hydrophobic segment (hydrocarbon, silicon or fluorocarbon chain segment) and hydrophilic segment made up ethoxylates which extend into water phase. \ The dispersion stability is achieved by the steric balance between hydrophobic and \ hydrophilic segments. The ethoxylates having number of hydrogens in the segmentlhave telogenic effect on the molecular weight, and therefore, adversely affect the molecular weight. ContainsDu nfidential Business Information. Does Not Contain National SecurityInformation. EFFORTsTO REPLACE APFO Contains DuPonTConfidential Business Information. Does Not Contain National Security Information. POTENTIAl ANT CANDIDATES TED (1971-19] if /fi > The majority of DuPont's products are dispersioirpdl merized and require very pure ingredients, including the surfactan toaghieve high molecular weight. > Impurities containing hydrogen cause a significant reduction In molecular weight. \ > All of the above create a limit in the choice of surfactant. \ > Over the last 30 years, DuPont has invested substantial resources to find an alternative to APFO but has been unsuccessful. Meetin^Goals Recognize the technological and societahhenefits of fluoropolymers. \ Provide a clear understanding of the fhioropolyhiers manufacturing process, critical technical issues and the role and importance of fluorosurfactants. \ Share work DuPont has done over the past 30+ years to identify and evaluate non-APFO surfactants, and why no suitable replacements have been found. \ Clarify industry needs to maintain APFO use and develop new supply.