Document JvDnzY340zdLQ4bpR4LD6mpnr

; . 2M Speci Marit StPChSoLMreN 55144-1000 AR Saniitized 5Co1p9y 3 3M May 28, 1999 opps bark 000 1176gw Frank D. Kover, Chief Chemical Information and Testing Branch Chemical Control Division Officeof Pollution Prevention and Toxics U.S. Environmental Protection Agency 401 M Sweet, S.W. `Washington, D.C. 20460 RE: Fluorochemical Use, Distributainodn Release Overview Dear Mr. Kover: MR 23055 As previously discussed, 3M is enclosing an overview paper and supporting appendices that `provide detailed information regarding the manufacture, use, distribution and environmental release present ofsulfonyl-ba a preliminary sed fluorochemicals (FCs) produced by 3M. These materials life-cycle assessmoefFnCt pathways for humanand environ are intended mental to exposure disposal. from This thetimethesematerialsleave the controlof3M assessment is primarily qualitative and is based through their end-use and/or on available information within 3M andtheexperience and judgment of 3M marketing andtechnical support staff. 3M is augmenting this preliminary exposure assessment with a varietyofadditional actions, including several stewardship initiatives and a comprehensive exposure assessment plan. Implementationofthese actions is ongoing. 3M's stewardship and exposure assessment activities are summarizedinthe enclosed overviewpaper and willbedescribed 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 of PFOS health effects and background chemistry paper submitted in February 1999, enclosed preliminary exposure assessment. 3M scientists various Section are availabtloe 8(e) submissions and meetwiththe EPA the technicalstaffat the Agency's convenience to discuss the information we have submited to the Agency. We will bein touchshortly to schedule this meeting. Please note that portionsofthe enclosed overview paper and appendices contain proprietary and confidential business information (CBI) protectedfrom disclosure under Section 14 ofTSCA. Release ofthis information would be harmful to 3M's competitive. position. We are therefore providing EPA with sanitized andunsanitized versionsof both documents. Werequestthat EPA `maintain the confidentialityof the unsanitized version in accordance with TSCA Section 14 and EPA regulations. The sanitized vercasnbi eploacn edinthe public docket. 006001 -- 0/20 %2ON JO:OL 66. 2/90 REAL $C) 1.9 Al. C7 NeWI uA i Page2 c Frank D. Kover 3M appreciates your cooperation. Sincerely yours, Molo O. Hogans `William A. Weppner, PhD. Director Environmental, Health, Safety & Regulatory Affairs Speciality Materials Group 3M Ceater, Bldg. 236-1B-10 St. Paul, MN 55144 651/733-6374 Enclosures . o rH OscarHernandez 8 () Dk. Nos. 8EHQ-1180-373, 1180-374 and 0381-0394 caren curon incon ce caron 000002 -- ockt ce ica a1 ac wus wan