Document 6wxe6nQr6ppD3VkEw4E44RBgo

Dynax Corporation 29, Hemlock Hill Road Poun^ Ridge, NY 10576 Tel 914 764 0202 Fax 914 764 0553 Ad S.&& . 0612 dynax August 2, 2000 . ~v ' T i / . V r \ f'Jr- r 1 CP CP T CT. CD 'm -o O' RECEIVED Charles Auer, Esq. US EPA Ariel Rios Building 1200 Pennsylvania Avenue Mail Stop 7405 Washington, D.C. 20460 RE: Phase-Out of 3M A FFF Agents Dear Mr. Auer: cce=sr>>a 72a* cC"ci cn 23 3: o I am the president of Dynax Corporation, a producer of specially fluorochemicals, including fluorochemicals for use in AFFF and other fire fighting agents as described in the enclosed bulletin. After the EPA published its news release of May 16, 2000 entitled, "EPA and 3M," I learned that 3M would phase out the sales of its Simons cell derived fluorochemicals by the end of 2000. Included in this phase-out were 3M 's Light W ater brand AFFF agents. It has now come to our attention that 3M is petitioning the EPA to extend the phase-out for their A FFF agents to the end of 2002, claiming that a phase-out by the end of 2000 would create a shortage in the A FFF agent market, a claim with which I disagree. There are worldwide five major chemical manufacturers, namely DuPont (USA), Asahi and Dainippon (Japan), Clariant (Germany) and Atochem (France), which produce perfluoroalkyl chemical raw materials via the TFE Telomerization process. From these telomerization raw materials (Perfluoroalkyl iodides), fluorochemicals can be produced which do not contain any PFOS (Perfluorooctanyl sulfonates) nor any PFO S derivatives. Companies such as Dynax, Ciba Specialty Chemicals, and Atochem produce fluorochemical surfactants and foam stabilizers for AFFF agent producers such as Ansul, National Foam and others, which are all derived from such "Telomerization" raw materials and which are availble in sufficient quantities. Charles Auer, Esq. US EPA August 2, 2000 Page 2 In addition to the PFOS problem, 3M A FFF agents have another environmental problem, namely a fluorochemical or fluorine content which is much higher than the fluorine content in A FFF agents based on "telomerization" type fluorochemicals, as the following comparison of 3% A FFF agents meeting M IL-F-24385F specications shows: 3M Light W ater FC203CF: Ansul Ansulite AFC-5A: National Foam Aer-O-Water 3EM: Angus Fire Tridol M: 1,80%F 1.20%F 0 .8 5 % F 0.91 %F Based on R+D carried out by Dynax for the US Air Force from 1994 to 1996 (SBIR Phase I and Phase II AF93-009 Contract), Dynax has proposed new M IL-F-24385 specifications, which would limit the fluorine content in 3% AFFF agents to a maximum of 0.85%, as indicated in the attached cover sheet of the above Phase II Final Report. Such new specifications would not be met by 3M AFFF agents. AFFF agent producers can confirm to the EPA that they can supply the US industry and government with the required quantities of AFFF agents after 3M 's phase-out by the end of 2000; therefore, I am confident that the EPA will not need to grant 3M a phase-out extension. Please let me know if you require any further information Sincerely, Eduard K. Kleiner President end. <4 Dynax Corporation 29 Hemlock Hill Road Pound Ridge, NY 10576 Tel 914 764 0202 Fax 914 764 0553 DYNAX FLUOROCHEMICALS FOR FIRE FIGHTING FOAM AGENTS (FX-AGENTS) Dynax Corporation, founded in 1991, is a specialty chemical company, involved in the development, production and marketing of fluorochemicals such as fluorochemical surfactants and foam stabilizers for use in AFFF, ARAFFF, FFFP and AR-FFFP agents. Dr. Eduard Kleiner, President, prior to founding Dynax, was responsible as R+D Director and VP Corporate Research of former Ciba-Geigy Corporation for the development of the Lodyne family of fluorochemical oil and water repellent finishes and fluorochemical surfactants for FX-Agents In 1993, the US Air Force awarded Dynax the SBIR Phase IA F93-009 research contract to develop an "Improved Formulation of Fire Fighting Agents for Hydrocarbon Fuel Fires." and in 1994, awarded Dynax the SBIR Phase II A F93-009 contract which was concluded in April 1996. Dynax was successful developing a class of environmentally more benign AFFF agents, so-called EMB AFFF agents which outperformed the current US M IL-F-24385F AFFF specifications with regard to extinguishment and burnback resistance, while having a 65% lower fluorine content than the leading 3% AFFF agent on the Qualified Product List, 3M 's Light Water FC203CF. In 1994, Dynax introduced D X3001. a highly efficient amphoteric fluorochemical surfactant, as well as D X4302. a fluorochemical foam stabilizer, which was replaced in 1995 with the higher efficiency DX5Q11 foam stabilizer. 3 The introduction of D X5011 made it possible to produce A R-A FFF and AR-FFFP agents with reduced polysaccharide contents having lower viscosity and improved extinguishment and burnback properties even on the most difficult polar solvent fires, such as acetone fires. In September 2000, Dynax will introduce a next generation foam stabilizer, D X 6011. providing improved burnback resistance; and in the first quarter 2001, D X4001. a new high efficiency fluorochemical surfactant is scheduled to be introduced. All Dynax fluorochemicals are derived from fluorochemical intermediates produced by the so-called "Telomerization Process," and do not contain any PFOS (Perfluorooctanyl sulfonates) or PFOS derivatives. In addition to its patented fluorochemical surfactants and foam stabilizers for use in FX-Agents, Dynax offers FX-agent producers so-called Dynax Superconcentrates containing fluorochemicals as well as select hydrocarbon surfactants which can readily be converted into FX-agents meeting current US and international specifications. For further information regarding Dynax fluorochemicals for use in FX-agents, please contact: Eduard K. Kleiner, Ph.D Dynax Corporation 29 Hemlock Hill Road Pound Ridge, NY 10576 USA Tel: 914 764 0202 Fax: 914 764 0553 email: DynaxCorp1@aol.com brochure, bui i+ The introduction of DX5011 made it possible to produce AR-AFFF and AR-FFFP agents with reduced polysaccharide contents having lower viscosity and improved extinguishment and burnback properties even on the most difficult polar solvent fires, such as acetone fires. In September 2000, Dynax will introduce a next generation foam stabilizer, D X 6011. providing improved burnback resistance; and in the first quarter 2001, D X4001. a new high efficiency fluorochemical surfactant is scheduled to be introduced. All Dynax fluorochemicals are derived from fluorochemical intermediates produced by the so-called "Telomerization Process," and do not contain any PFO S (Perfluorooctanyl sulfonates) or PFO S derivatives. In addition to its patented fluorochemical surfactants and foam stabilizers for use in FX-Agents, Dynax offers FX-agent producers so-called Dynax Superconcentrates containing fluorochemicals as well as select hydrocarbon surfactants which can readily be converted into FX-agents meeting current US and international specifications. For further information regarding Dynax fluorochemicals for use in. FX-agents, please contact: Eduard K. Kleiner, Ph.D Dynax Corporation 29 Hemlock Hill Road Pound Ridge, NY 10576 USA Tel: 914 764 0202 Fax: 914 764 0553 email: DynaxCorp1@aol.com REPORT DOCUMENTATION PAGE VC-'TT. A p p r C V -3 OMB No. 0704-0188 Pubicreporting burden for thrcollectionof mtormatonn animated to aver9e \ hour perleoone. moudmgthe time for Nvewnq mnructiOm. earoung existing data otwev gathennq andmnnunwigthe data needed,nocomrfetmganorrnewmg thecoecPonof ncrmaccn. Senocomments reoardmg thnbuiden enimateor anyother aioecr of coAecsonof kifocimuuft.mdudinguggesoomfor reiayon thn burden, to Wttfangton twaoouaranSenncei.Directorate tor information Operabom andAepciru. UISJeffmon OrraHighway,Suite U04,Arlington.VA 2220J-4302. andtotheOfficeorfManagementanduagclPiperwcr* deductionProject(070*"01MiWa*hmgtorv. DC 20S03. 1. AGENCY USE ONLY (Leave bink) 2. REPORT DATE 15 August 1996 3. REPORT TYPE ANO OATES COVERED Phase I I F i n a l , 4 Aug. 94 - 15 Apr. 96 4. TITLE AND SUBTITLE 5. FUNDING NUMBERS Improved Formulation of F i r e Fighting Agents for Hydrocarbon Fuel F i r e s , Phase I I Final Report. F08637-94-C6038 6. AUTHOR(S) Eduard K. K l e i n e r , Ph.D. 7. PERFORMING ORGANIZATION NAME(S) AND ADDRESS(ES) Dynax Corporation 103 F a irview Park Drive Elm sford, NY 10523 8. PERFORMING ORGANIZATION REPORT NUM8ER AF93-009/DX101 Phase I I 9. SPONSORING/MONITORING AGENCY NAME(S) AND AODRESS(ES) 325th Contracting Squadron WL/F1VCF 10. SPONSORING/MONITORING AGENCY REPORT NUMBER 501 I l l i n o i s Avenue, S u ite 5 139 Barnes Drive Tyndall AFB, FL 32403-5526 Suite 2 Tyndall AFB, FL 32403-5822 11. SUPPLEMENTARY ROTES This i s a Small Business Innovation Research (SBIR) Phase I I Report 12a. DISTRIBUTION /AVAILABILITY STATEMENT D istribution authorized to U.S. Govt. Agencies only, P ro p rie ta ry Inform ation; Aug. 1995 ' S B I F ' . Other requests fo r t h i s document s h a ll be refe rred to Tyndall AFB, FL 32403-5323 12b. DISTRIBUTION CODE 13. abstract (M axim um 2 0 0 w o r d s ) agents are today's most e f f i c i e n t f i r e f i g h t i n g foams for e x tin g u ish in g hydrocarbon f i r e s ; however, they have lim it e d foam l i f e and burnback r e s i s t a n c e , co n tain butyl c a r b it o l solvent su b je c t to SARA T i t l e I I I S ectio n 313 r e g u la t io n , contain high l e v e l s of non-biodegradable fluorochem ical s u r f a c t a n t s and have t o x ic e f f e c t s on a q u a tic l i f e forms. Environm entally more benign ag e n ts, r e f e r r e d to as 3% AFFF-EMB ag e n ts, were developed with reduced contents of novel and commercial fluo ro chem ical s u r fa c t a n t s containing s o lv e n t s not su b je c t to the above . a g n a t i o n . These agents out-perform MIL-F-24385F s p e c i f i c a t i o n s with regard to extinguishm ent, burnback r e s i s t a n c e , foam expansion, foam d rain time and f i s h t o x i c i t y . A p ro p o sa l, based on 3 % AFFF-EMB agents with maximum f lu o r in e contents of 0.85% was prepared to up-grade MIL-F-24385F s p e c i f i c a t i o n s , in c lu d in g a recom- mendation to use h a lf-stre n g th agent solutions as e f f e c t iv e tra in in g agents thereby reducing costs^_and agent waste streams. Comparative e v a l u a t io n s , c a r r i e d out with s i x 3% and 6%~AFFF agents on the QPL and analogous agents co n ta in in g butyl c a r b it o l s u b s t it u t e s o lv e n ts derived from stock s o lu t io n s , provided by agent producers, demonstrated th a t d i r e c t s o lv e n t su b s t itu t io n was p o s s ib le without f u r t h e r reformu l a t i o n with the th ree best performing agents on the QPL, w h ile three oth er agents r e q u ir e refo rm u la tio n in ord er to improve foam p r o p e r t ie s . 14. SUBJECT TERMS AFFF Improvements Solvent Replacement Burnback Biodegradability Aquatic Toxicity 17. SECURITY CLASSIFICATION OF REPORT Linciassi fied 18. SECURITY CLASSIFICATION OF THIS PAGE linciassi fied 19. SECURITY CLASSIFICATION OF ABSTRACT Unci a s s i f ie d 15. NUMBER OF PAGES 196 16. PRICE CODE 20TLIMITATION OF ABSTRACT SAR NSN 7540-01-280-5500 G Standard Form 298 (Rev. 2-89) ^ r f x n o r d b ANSI S td . 3 9 * H