Document 7MEeqjb70b04eGjn1My4m6EZ6

K L U L i VC.U 3M Specialty Materials 3fP September 20, 2000 3M Center St. Paul, MN 55144-1000 651 733 1100 pnKsr-o g ft#326- 0 1 3 2 s 3M Charles Auer (E403C) Director, Chemical Control Division Office of Pollution Prevention and Toxics Office of Prevention, Pesticides and Toxic Substances US Environmental Protection Agency 401 M Street, SW Washington, DC 20460-0001 no 3> 3 Re: Response to 8/1/00 note from Ward Penberthy, EPA Dear Mr. Auer: This letter is to formalize the e-mail response provided by Teresa Borzcik, 3M, on 8/1/00 to Ward Penberthy, EPA. Mr. Penberthy's initiating e-mail was also dated 8/1/00. 1. 3M does not consider chemical names (of any nomenclature convention) associated with PMN numbers listed in the attachment of Bill Weppner's letter to Charlie Auer dated July 18, 2000 to be CBI. The attachment was titled Listing o f Chemistries Impacted by 3M's PhaseOut Decision. The July 18th letter is CBI. 2. The 9th Collective Index version of the chemical name for any CAS number or PMN number listed in this same memo is not considered by 3M to be CBI. 3. The complete phase-out date of 12/31/02 for Industrial Surfactants and 6/1/02 for Fire Fighting Foams that meet the proposed extended uses presented in attachment 3 (July 7 document) is not CBI when connected to the CAS/PMN numbers present in both attachment 4 (July 7 document) and the Listing o f Chemistries Impacted by 3M's Phase-Out Decision (July 18 attachment). Thank you. Sincerely, William A. Weppner, Ph.D. Director Environmental, Health, Safety & Regulatory Affairs Specialty Material Markets Group 3M Center, Bldg. 236-1B-10 St. Paul, MN 55144 Contain NO CBI $ ^A7> "5 o ,VC--7 <A I Teresa R. Borzcik 08/29/2000 10:04 AM Specialty Materials Markets Group Regulatory Affairs____________________ 236-1B-10 651/736-2032 Fax: 651/737-9909 To: Bill Weppner/US-Corporate/3M/US@3M-Corporate cScu:bject: Response to 8/1/00 note from Ward Penberthy, EPA The attachment: ------------------------Forwarded by Teresa R. Borzcik/US-Corporate/3M/US on 08/29/2000 07:03 AM Teresa R. Borzcik 08/01/2000 03:50 PM Specialty Materials Markets Group Regulatory Affairs __ __ 236-1 B-10 651/736-2032 Fax: 651/737-9909 To: Penberthy.Ward@epamail.epa.gov cc: Bill Weppner/US-Corporate/3M/US@3M-Corporate Thomas J. DiPasquale/LA-Legal/3M/US@3M-Corporate bob.sussman@lw.com (bcc: Teresa R. Borzcik/US-Corporate/3M/US) Subject: Response to 8/1/00 note from Ward Penberthy, EPA J-j I agree with your understanding of our conversation with the following clarifications to items 1 and 3: 1. 3M does not consider chemical names (of any nomenclature convention) associated with PMN numbers listed in the attachment of Bill Weppner's letter to Charlie Auer dated July 18, 2000. The attachment was titled Listing of Chemistries impacted by 3M's Phase-Out Decision. The letter is CBI. 3. The complete phase-out date of 12/31/02 for Industrial Surfactants and 6/1/02 for Fire Fighting Foams that meet the proposed extended uses presented in attachment 3 (July 7 document) is not CBI when connected to the CAS/PMN numbers present in both attachment 4 (July 7 document) and the Listing of Chemistries Impacted by 3M's Phase-Out Decisio(July 18 attachment ). Thank you. Penberthy.Ward@epamail.epa.gov on 08/01/2000 10:57:07 AM Penberthy.Ward@epamail.epa.gov on 08/01/2000 10:57:07 AM Tcco:: Subject: ATLLDeueaorecnemrzns.CyiaonnnhiaRsa.Kkk.r.ila.BMeBrsoeaa@rnrrzyb@ce@aipkeraea/pUmp@aSamaem-iCapl.aeiaoli.pmlre.paepao.pagirla.a.oge.tvgoepov/a3v.Mgo/Uv S@3M-Corporate This e-mail is to confirm the results of our phone conversation of 7/25/00. In this conversation you confirmed to me that: 1. 3M does not consider chemical names (of any nomenclature convention) associated with PMN numbers listed in Bill Weppner's letter to Charlie Auer dated July 18, 2000 and titled CAS names for POSF-Based Productsas CBI. 2. The 9th Collective Index version of the chemical name for any CAS number or PMN number listed in this same memo is not considered by 3M to be CBI. 3. The specific phase out dates cited in the CBI document July 7, 2000 describing 3M's POSF Phase Out Plan are not considered CBI for any of the chemicals listed in the July 18th letter. Please confirm to me email and in a signed letter that this record of our conversation is accurate. In addition it has come to our attention that there are some minor differences in the chemicals listed in the CBI Phase Out Plan and the non-CBI Phase Out Plan -- could you provide an explanation of this as well . 3