Document KQ7J0G7Jo8Qzyj3nQ1krEGro

CAS Number 25268-77-3 3M Company A fe - T * Voluntary Use and Exposure Information Profile N-Methyl perfluorooctanesulfonamido ethyl acrylate , I. CHEMICAL IDENTIFICATION Chemical Name: N-Methyl perfluorooctanesulfonamidoethyl acrylate (MeFOSEA) CAS Number: 25268-77-3 II. COMPANY IDENTIFICATION Company Name: 3M Site Location: 10746 Innovation Road Cottage Grove, MN 55016 1400 State Docks Road Decatur, AL 35601 Technical Contact: Phone: Address: W.A. Weppner 651/733-6374 3M Center, Building 236-IB-10 St. Paul, MN 55144 III. ON-SITE ACTIVITIES CAS# Mfe. 11997) Imported 25268-77-3* < 1MM lbs. 0 Estimate the amount of subject chemical distributed off-site: <1% *Submitted in 1998 TSCAIUR. |R7 CAS Number 25268-77-3 3M Company 2 Narrative Description and Process Flow Schematic: 3M Company utilizes a process known as Simons Electro-Chemical Fluorination (ECF) to synthesize organofluorine molecules. In this process, organic feedstocks are dispersed in liquid, anhydrous hydrogen fluoride, and an electric current is passed through the solution, causing the hydrogen atoms on the molecule to be replaced with fluorine. The predominant components of the products created by this process have the same carbon skeletal arrangement as the feedstock used, but with all of the hydrogen atoms replaced by fluorine. However, fragmentation and rearrangement of the carbon skeleton can also occur and significant amounts of cleaved, branched and cyclic structures may be formed. The degree of fluorination of the organic feedstock is also dependent upon the specific carbon chain length of the feedstock and parameters of the ECF process such as electrical current and the length of time the process is run. It is possible to synthesize fully fluorinated or perfluoroorganic molecules where all of the hydrogen atoms of the hydrocarbon feedstock have been replaced by fluorine atoms. Using these perfluoroorganic molecules as basic building blocks, unique chemistries can be created by further reactions with functionalized hydrocarbon molecules. 3M has produced sulfonyl based fluorochemicals commercially for over 40 years using the ECF process. A basic building block of such products and the highest production volume fluorochemical 3M manufactures is perfluorooctanesulfonyl fluoride (POSF). The starting feedstock for this reaction is 1-octanesulfonyl fluoride. (Reaction 1) Reaction 1 C8Hi7S02F + 17 HF 1-Octanesulfonyl fluoride Energy -------- > C8Fi7S02F + 17 H2 ECF Perfluorooctanesulfonyl fluoride The electrochemical fluorination process yields about 35%-40% straight chain (normal) POSF, and a mixture of biproducts and waste of unknown and variable composition comprised of the following: 1) higher and lower straight-chain homologs, i.e., n-CnF2n+iS02F, e.g., CeFi3S02F, C7Fi5S02F, C9F19S 0 2F which comprise about 7% of the process output 2) branched-chain, perfluoroalkylsulfonyl fluorides with various chain lengths, about 18-20% of the output 3) straight-chain, branched, and cyclic (non-functional) perfluoroalkanes and ethers, which comprise about 20-25% of the output 4) "tars" (high molecular weight fluorochemical byproducts) and other byproducts, including molecular hydrogen, which comprise about 10-15% of the output. Because of slight differences in process conditions, raw materials, and equipment, the mixture produced by the electrochemical fluorination process varies somewhat from lot-to-lot and from plantto-plant. The product that results from electrochemical fluorination is thus not a pure chemical but rather a mix of isomers and homologues. The commercialized POSF derived products are a mixture of approximately 70% linear POSF derivatives and 30% branched POSF derived impurities. CAS Number 25268-77-3 3M Company 3 During production, byproducts and waste products are formed. The volatile waste products, such as perfluoromethane, have been vented to the atmosphere in the past, but plans are being implemented to capture and destroy these releases by thermal oxidation over the next few years. The tars have been landfilled in a hazardous waste landfill in the past, but are all currently being incinerated at an in-house or external hazardous waste incinerator. The byproducts, many of which are incompletely fluorinated with hydrogen atoms still present, can be recycled back into the ECF process or are partially degraded in stabilization processes and discharged to controlled, in-house, wastewater treatment systems. The treatment sludge associated with the ECF process has been either landfilled or land-incorporated in the past, but all of this treatment sludge is being landfilled off-site since early 1998. POSF is itself a commercially viable product, but is primarily an important intermediate in the synthesis of substances used in many other 3M fluorochemical products. The majority is used to produce functionally derivatized fluorochemicals and high molecular weight polymeric products. Unique chemistries can be created by derivatizing POSF through the sulfonyl fluoride moiety of the molecule using conventional hydrocarbon reactions. POSF is reacted with methyl or ethyl amine to produce either N-methyl or N-ethylperfluorooctanesulfonamide (MeFOSA or EtFOSA). Some of the MeFOSA and EtFOSA is isolated to be used as intermediates to be reacted to form other materials. The majority of the MeFOSA and EtFOSA is not isolated and subsequently reacted with ethylene carbonate to form either N-methyl or N-ethylperfluorooctane sulfonamido ethanol. These are the principal building blocks of the 3M product lines. CAS Number 25268-77-3 3M Company The following block flow diagram describes the process discussed above. BLOCK FLOW DIAGRAM Electro-Chemical Fluorination Cells (Octanesulfonyl fluoride + HF + electrical energy) 4 Perfluorooctane sulfonyl fluoride (POSF) Perfluorooctane sulfonic acid (PSOF) Secondary Reactors l Surfactants l. Various commercialized intermediates and surfactants Amphoteric surfactants (Fire Fighting Foams) Phosphate Esters and Acrylate/polymers (Paper & Packaging) T Acrylate polymers Adipate adducts Urethane polymers (Carpet and Textile Protection) N-ethyl (and methyl) perfluorooctanesulfonamide J N-ethyl (and methyl) perfluorooctane- sulfonamido ethanol Additional Secondary Reactors Various commercialized intermediates and surfactants 200 CAS Number 25268-77-3 3M Company IV. SITE RELEASE AND TRANSFER INFORMATION FOR TRI CHEMICALS 5 Not applicable. V. SITE RELEASE AND TRANSFER INFORMATION FOR NON-TRI CHEMICALS While analytical methods have improved over time, large variability still exists for certain matrices and compounds, so data available for this report is mostly of a qualitative nature. Although limited monitoring data exists, most emission and waste estimates are based upon process models and engineering calculations. Engineering calculations, however, have limitations with respect to fluorochemicals because fluorochemical losses were not always included in the analysis of each intermediate step. The accuracy of the emissions data submitted varies due to several factors. Batch process systems are difficult to measure due to quickly changing process conditions, venting pressures and difficulty in isolating processes to take measurements. Additionally, the unique characteristics of these compounds cause them to behave differently from conventional compounds, and physical chemical data properties are not available for all intermediate reaction steps in the past. A. ON-SITE AIR RELEASES ALL PLANTS Fugitive emissions may occur from vacuum charging from drums, sampling from reactors, drumming of product/intermediate, flaking monomer, drying operations. Materials may be handled in a molten or solid state; vapors are produced from molten material. Industrial hygiene monitoring has been conducted for some compounds. Some minor amounts of these compounds have been detected as fugitive emissions during industrial hygiene exposure testing. Decatur. AL Emission estimates are based upon existing process models and engineering calculations. Fugitive emissions may have occurred during some handling steps but have not been quantified. Estimated Total Annual Releases (lbs.) Estimated % Accuracy of Estimate (optional) # days/years release occurs Fugitive - (non-point) Not quantified. Stack (point) Estimated Total Annual Releases (lbs.) (1997) Estimated % Accuracy of Estimate (optional) # days/years release occurs <1 V)\ CAS Number 25268-77-3 3M Company 6 Cottage Grove Fugitive emissions may have occurred during some handling steps but have not been quantified. Estimated Total Annual Releases (lbs.) (1 9 9 7 ) Estimated % Accuracy of Estimate (optional) # days/years release occurs Fugitive (non-point) No data available. Stack (point) No data available. Comments: 10X CAS Number 25268-77-3 3M Company B. WATER RELEASES FROM SITE Decatur. AL This compound was not part of analyte list in wastewater studies. Estimated Total Annual Releases (lbs.) (1 9 9 7 ) Estimated % Accuracy of Estimate (optional) Water releases: No data available. Number of days/year release occurs: Receiving Water Name: NPDES Number. Comments: Cottage Grove. MN Engineering calculations are used to estimate the amount of material discharged to wastewater. Estimated Total Annual Releases (lbs.) (1 9 9 7 ) Estimated % Accuracy of Estimate (optional) Water releases: 0 Number of days/year release occurs: Receiving Water Name: NPDES Number: Comments: 7 2-3 CAS Number 25268-77-3 3M Company C. ON-SITE LAND RELEASES 8 Decatur. AL The land treatment of Decatur sludge was discontinued in early 1998. Sludge is now transported to an offsite landfill, after passing through a thickener and a sludge press. An impoundment was used in 1997 as part of the wastewater treatment operation but is now only used for back-up operation. Estimated Total Annual Releases (lbs.) (1 9 9 7 ) Estimated % Accuracy of Estimate (optional) Landfill Land Treatment/Land Amendment Surface Impoundments Underground Injection Other (specify): 0 Not quantified/No longer used Not quantified/No longerused 0 Comments: Cottage Grove. MN Sludge from the Cottage Grove facility is sent to an off-site industrial landfill Estimated Total Annual Releases (lbs.) (1 9 9 7 ) Estimated % Accuracy of Estimate (optional) Landfill Land Treatment/Land Amendment Surface Impoundments Underground Injection Other (specify): 0 0 0 0 Comments: CAS Number 25268-77-3 3M Company 9 D. OFF-SITE TRANSFERS Decatur. AL Process wastewaters are managed in an on-site wastewater treatment facility and are not sent to the POTW. D l. Transfer to Publicly Owned Treatment Works (POTW) Number of days/year the release occurs: Annual Transfer (lb): 0 Estimated % Accuracy of Transfer Estimate (optional) (%): POTW Name: Street Address: City: State: NPDES Number: Country: Zip Code: Comments: lob CAS Number 25268-77-3 3M Company 10 Cottage Grove. MN Process wastewaters are managed in an on-site wastewater treatment facility and are not sent to the POTW. D l. Transfer to Publicly Owned Treatment Works (POTW) Number of days/year the release occurs: Annual Transfer (lb): 0 Estimated % Accuracy of Transfer Estimate (optional) (%): POTW Name: Street Address: City: State: NPDES Number: Country: Zip Code: Comments: CAS Number 25268-77-3 3M Company D2. TRANSFERS TO OTHER OFF-SITE LOCATIONS 12 General Waste Information: There is limited information by CAS number for compound specific reporting and off-site transfers cannot be readily verified. Rather wastes are classified by halogen content, regulatory waste codes, physical properties and non-specific fluorochemical categories. Where wastes are tracked by CAS number, the amounts have been included. Decatur. AL A review of plant records regarding waste disposal locations for Decatur fluoride-containing wastes indicates that 70% is disposed through incineration at various off-site locations and approximately 30% is landfilled at a hazardous waste landfill. Incineration is now the predominant disposal method for these materials. Estimated Total Annual Releases (lbs.) Estimated % Accuracy of Estimate (optional) Incineration: No specific CAS number data available. Wastewater Treatment (Excluding POTW) 0 Underground Injection 0 Hazardous Waste (RCRA Subtitle C) landfill No specific CAS number data available. Other Landfill No specific CAS number data available. Recycle or Recovery Unknown or Other Comments: w CAS Number 25268-77-3 3M Company Cottage Grove facility utilizes incineration for all their drummed wastes. Cottage Grove. MN Estimated Total Annual Releases (lbs.) Estimated % Accuracy of Estimate (optional) Incineration: 130 Wastewater Treatment (Excluding POTW) 0 Underground Injection 0 Hazardous Waste (RCRA Subtitle C) landfill 0 Other Landfill 0 Recycle or Recovery 0 Unknown or Other 0 Comments: 12 lS)% CAS Number 25268-77-3 3M Company VI. ON-SITE WORKPLACE EXPOSURE 13 3M Company. Specialty Materials Manufacturing Division. Cordova. IL This information will assist EPA in characterizing the number of workers potentially exposed and the magnitude, frequency, and duration of potential exposure. When providing monitoring data, ensure that data is linked with worker activities described in question 2. 1. Estimate the number of workers potentially exposed routinely to the subject chemical for each of the exposure duration times. If a worker is involved in more than one activity, enter only his/her most typical activity in the table. Don't count a worker more than once. The total number in the table should equal the total number of workers potentially exposed. H ours/D ay <25 .25-1 1-8 >8 D ays/Y e a r <10 10-100 100-250 >250 4 2. Describe the routine worker activities to which the workers in question 1 are exposed: sampling, removal of filter cake, and drumming of liquids, manufacture an article, etc. For these activities, describe the physical state of the subject chemical (liquid, gas, particulate, or aerosol, etc.) and, if in a mixture, the chemical's concentration: The chemical (25268-77-3) is an ingredient in the form of a non-dusting, solid, waxy flake (80% concentration) that is charged from fiber drums into a process vessel where it is consumed in a reaction leaving less than 1% residual in the final product. CAS Number 25268-77-3 3M Company 14 3. Provide industrial hygiene monitoring data, if available, with a brief description of the sampling method and exposure scenario monitored, e.g., describe the specific worker activities performed by the individuals monitored. For privacy considerations, please do not include any personal identifiers such as a worker's name or social security number with any data submitted to EPA. There is no chemical-specific personal industrial hygiene monitoring data or area/source monitoring data for this specific material at this facility. For most areas of the facility, recent qualitative assessment of potential exposure to this material under 3M's ongoing industrial hygiene program indicates a low exposure potential to this material. Each 3M plant that produces sulfonated fluorochemicals has an industrial hygienist on staff and is supported by a corporate industrial hygiene group. 3M's industrial hygiene program focuses on task-based exposure assessment and control. Exposures are identified and assessed qualitatively and/or quantitatively. Qualitative assessments are performed by an industrial hygienist. Quantitative assessments include task-based personal sampling for certain, specific fluorochemicals and/or source or area sampling. The results of the assessments support decisions on exposure control. Engineering controls are preferred, but personal protective equipment may be used on an interim basis or when effective engineering control is not feasible. 4. Briefly describe the engineering controls used to minimize exposure to this chemical: No additional engineering controls are used. 5. Briefly list the personal protective equipment your workers regularly wear to prevent exposure of this chemical: During charging employees wear safety glasses and hard hats, and gloves. Comments: (This section is available to clarify the responses given. Attach additional pages if desired.) CAS Number 25268-77-3 3M Company 15 3M Company. Specialty Materials Manufacturing Division. Cottage Grove. MN This information will assist EPA in characterizing the number of workers potentially exposed and the magnitude, frequency, and duration of potential exposure. When providing monitoring data, ensure that data is linked with worker activities described in question 2. 1. Estimate the number of workers potentially exposed routinely to the subject chemical for each of the exposure duration times. If a worker is involved in more than one activity, enter only his/her most typical activity in the table. Don't count a worker more than once. The total number in the table should equal the total number of workers potentially exposed. H o u rs/D ay <.25 .25-1 1-8 >8 <10 4 4 4 D ays/Y ear 10-100 100-250 >250 2. Describe the routine worker activities to which the workers in question 1 are exposed: sampling, removal of filter cake, and drumming of liquids, manufacture an article, etc. For these activities, describe the physical state of the subject chemical (liquid, gas, particulate, or aerosol, etc.) and, if in a mixture, the chemical's concentration: Vacuum charging from drums, sampling from reactor, drumming of product/intermediate, maintenance (changing flange, hose, pipe, valve, filter, pump or sight glass); materials may be handled in a molten or solid state or dissolved in organic solvents; vapors are produced from molten material; approximate concentration ranges from <1% to 80%. Ill CAS Number 25268-77-3 3M Company 16 3. Provide industrial hygiene monitoring data, if available, with a brief description of the sampling method and exposure scenario monitored, e.g., describe the specific worker activities performed by the individuals monitored. For privacy considerations, please do not include any personal identifiers such as a worker's name or social security number with any data submitted to EPA. There is no chemical-specific personal industrial hygiene monitoring data or area/source monitoring data for this specific material at this facility. For most areas of the facility, recent qualitative assessment of potential exposure to this material under 3M's ongoing industrial hygiene program indicates a low exposure potential to this material. Each 3M plant that produces sulfonated fluorochemicals has an industrial hygienist on staff and is supported by a corporate industrial hygiene group. 3M's industrial hygiene program focuses on task-based exposure assessment and control. Exposures are identified and assessed qualitatively and/or quantitatively. Qualitative assessments are performed by an industrial hygienist. Quantitative assessments include task-based personal sampling for certain, specific fluorochemicals and/or source or area sampling. The results of the assessments support decisions on exposure control. Engineering controls are preferred, but personal protective equipment may be used on an interim basis or when effective engineering control is not feasible. 4. Briefly describe the engineering controls used to minimize exposure to this chemical: Materials are transferred using closed piping (where possible) from reactor vessels to other containers. Vacuum charging of materials from drums is a standard practice. Positionable local exhaust ventilation hoods are situated at significant point sources such as at drum bungs when drumming. General room air provides for dilution of airborne materials. 5. Briefly list the personal protective equipment your workers regularly wear to prevent exposure of this chemical: Process operating standards list the respirator (e.g., supplied air, organic vapor cartridge with particulate prefilter, or particulate filtering), glove by elastomer (e.g., neoprene or nitrile), chemical protective clothing (e.g., 2-piece PVC rainsuit), eye protection (e.g., chemical splash goggles with or without full faceshield depending on type of respirator used) to be used by the employee when the task involves exposure to a particular fluorochemical material. Comments: (This section is available to clarify the responses given. Attach additional pages if desired.) CAS Number 25268-77-3 3M Company 17 3M Company. Specialty Materials Manufacturing Division. Decatur. AL This information will assist EPA in characterizing the number of workers potentially exposed and the magnitude, frequency, and duration of potential exposure. When providing monitoring data, ensure that data is linked with worker activities described in question 2. 1. Estimate the number of workers potentially exposed routinely to the subject chemical for each of the exposure duration times. If a worker is involved in more than one activity, enter only his/her most typical activity in the table. Don't count a worker more than once. The total number in the table should equal the total number of workers potentially exposed. H ours/D ay <0.25 0.25-1 1-8 >8 <10 4 D ays/Y ear 10-100 100-250 4 48 24 >250 2. Describe the routine worker activities to which the workers in question 1 are exposed: sampling, removal of filter cake, and drumming of liquids, manufacture an article, etc. For these activities, describe the physical state of the subject chemical (liquid, gas, particulate, or aerosol, etc.) and, if in a mixture, the chemical's concentration: Vacuum charging from drums, sampling from reactor, drumming of product/intermediate, flaking monomer, maintenance (changing flange, hose, pipe, valve, filter, pump or sight glass); materials may be handled in a molten or solid state; vapors are produced from molten material; material concentration ranges up to 85%. Wastewater treatment operations: collecting and analyzing QC samples, operating filter press, monitoring process, and maintenance activities; material typically present in waste stream at less than 1%. CAS Number 25268-77-3 3M Company 18 3. Provide industrial hygiene monitoring data, if available, with a brief description of the sampling method and exposure scenario monitored, e.g., describe the specific worker activities performed by the individuals monitored. For privacy considerations, please do not include any personal identifiers such as a worker's name or social security number with any data submitted to EPA. Personal sampler tubes with XAD-4 resin and mixed cellulose ester or glass fiber prefilter. Sample analysis is by LC-MS. Previous sampling had employed silica gel acid mist tubes with GC-ECD analysis. See attached table for air sample results. There has been area/source air monitoring data and/or surface wipe sampling data collected for this material at the plant. Area/source sample results and/or surface wipe sample results are used to identify areas with employee exposure potential as part of exposure assessment under 3M's industrial hygiene program and are not measurements of actual employee exposures. Hence, they are not included with this submission. Prior to 1999, these samples were considered to be semivalidated. Surfaces in production and administration areas were sampled in 1998. A glass fiber filter wetted with methyl alcohol was wiped inside a 10 cm x 10 cm square with analysis by LC-MS. Results indicated the presence of these materials on floors and equipment surfaces in production areas. This resulted in improvements to Hazard Communication practices, personal hygiene emphasis, personal protective equipment emphasis, and several engineering and administrative changes. The sample results of any air monitoring are compared to 3M's voluntary exposure guideline (EG) of 0.1 mg/m3 (milligrams of fluorochemical per cubic meter of air) for various fluorochemical compounds, including compounds covered in this submittal. The EG is an 8-hour time-weighted average (TWA) personal breathing zone exposure chosen to minimize potential for uptake. Each 3M plant that produces sulfonated fluorochemicals has an industrial hygienist on staff and is supported by a corporate industrial hygiene group. 3M's industrial hygiene program focuses on task-based exposure assessment and control. Exposures are identified and assessed qualitatively and/or quantitatively. Qualitative assessments are performed by an industrial hygienist. Quantitative assessments include task-based personal sampling for certain, specific fluorochemicals and/or source or area sampling. The results of the assessments support decisions on exposure control. Engineering controls are preferred, but personal protective equipment may be used on an interim basis or when effective engineering control is not feasible. CAS Number 25268-77-3 3M Company Air Sampling Data for 25268-77-3 Job Sample Concentration Classification number (mg/m3) ________________________ Totals C h e m ical 90-080 0.12 Operator 92-060 0.06 Building 3 92-061 0.27 94-031* <0.01 94-032* <0.01 94-034* <0.01 94-037* <0.01 94-038* <0.01 94-039* <0.006 94-041* <0.01 94-046* <0.01 94-050 <0.01 94-075 <0.006 94-078 <0.008 95-006* 0.012 95-007* 0.007 95-014* 0.27 95-040* 0.46 95-041* 0.019 C h e m ical Operator Flaker 95-024* 97-091* 0.28 0.15 Team Leader 92-060 0.06 Building 3 92-061 0.27 94-036* <0.003 94-047* <0.02 94-051* <0.005 94-054* <0.005 94-055* <0.005 96-069 0.16 98-481* 0.05 Team Leader 98-098* Flaker 0.049 Minimum Maximum Geometric (mg/m3) (mg/m3) Mean <0.003 0.46 0.025 Geometric Standard Deviation 4.6 * The value for this sample is one of several fluorochemical analytes collected on the sample. Sam ples are all personal breathing zone samples taken over the duration of a specific task. 19 115 CAS Number 25268-77-3 3M Company 4. Briefly describe the engineering controls used to minimize exposure to this chemical: 20 Materials are transferred using closed piping (where possible) from reactor vessels to other containers. Vacuum charging of materials from drums is a standard practice. Local exhaust ventilation hoods are situated at significant point sources such as at drum bungs when drumming. Some equipment, such as the flaker, is equipped with local exhaust ventilation. General room air provides for dilution of airborne materials. 5. Briefly list the personal protective equipment your workers regularly wear to prevent exposure of this chemical: Specific personal protective equipment is indicated on written operating procedures used by process operators. Respiratory protection: Tasks with significant exposure potential (charging, drumming, some maintenance tasks) are performed using positive pressure, pressure demand full face supplied air respirators. Tasks with moderate exposure potential (short term sampling from taps or drums, and some maintenance tasks) are performed using full face air-purifying respirators with organic vapor cartridges and P I00 prefilters. Hand protection: All tasks identified as having potential for hand contact require neoprene (Scorpio) or nitrile industrial gloves. Body protection: Exposure significant tasks use one or two-piece PVC suits. Aprons may be worn for some low exposure potential tasks such as sampling. Foot protection: Tasks identified as posing a significant foot exposure potential require chemical resistant boots. Comments: (This section is available to clarify the responses given. Attach additional pages if desired.) Current exposures are expected to be less than those measured in the recent past. Significant sources have been identified and eliminated. In 1998 an extensive area air sampling of the production areas was performed. Areas with higher levels of airborne materials were investigated further to identify sources. These sources, which include the flaking equipment, are in the process of being eliminated or reduced through replacement with better ventilated equipment. In addition, the ventilation system in the primary production building (3) is being upgraded. The fluorochemical hazard communication program was improved upon in 1998. This has resulted in improved exposure avoidance behaviors among production employees and better use of with personal protective equipment requirements. Additional hand wash facilities have been installed in primary process buildings. Food consumption and other hand-to-mouth activities are prohibited. There is no smoking in process buildings. Process employees are instructed to remove and leave their work boots and work coveralls at the plant. Work coveralls are professionally laundered. Non-production equipment surfaces such as floors, doorknobs and stair rails are cleaned frequently. CAS Number 25268-77-3 3M Company 21 VII. CHEMICAL END USES A. END USE AS AN INTERMEDIATE CONSUMED TO MAKE OTHER CHEMICALS A l. On-Site Use as a Intermediate: Intermediate consumed in the production of several polymeric products which are used as protective treatments for circuit boards, nonwovens, apparel and leather. Product chemical class or product chemical (Include CAS number if appropriate) % of total volume of subject chemical manufactured or imported 1. Fluoroaliphatic Acrylates 90-95% 2. Fluorochemical Acrylates CAS 92265-81-1 3-8% A2. Off-Site Use as an Intermediate Product chemical class or product chemical (Include CAS number if appropriate) 1. Not applicable. As reported in Part III, p.2 % of total volume of subject chemical manufactured or imported As reported in Part III, p.2 CAS Number 25268-77-3 3M Company B. END USES OTHER THAN AS A CONSUMED INTERMEDIATE 22 Use Number 1 of 8 Description of Chemical End Use: This CAS number is used as an intermediate to manufacture polymers that are sold to industrial users to be mill applied as protective, repellent treatments for apparel substrates. These substrates will be made into apparel products to be used by consumers and commercial industry. This CAS number itself will be present in these products at low levels as a residual. Percent of total manufactured or imported Volume going to this use: 1-2 Check all physical forms of the chemical during this use: If used in a mixture check appropriate box to indicate weight fraction. Average values are acceptable: ___ < 1% X 1-30% (0.1-2%) ___ 30-60% ___ 60-90% >90% ___ Aerosol ___ Dry Powder ___ Pellets or large crystals ___ Water or solvent - wet solid ___ Gas or vapor X Liquid solution ___ Other (Explain) Use Number 2 of 8 Description of Chemical End Use: This CAS number is used as an intermediate to manufacture polymers that are sold to industrial users to be mill applied as protective, repellent treatments for carpeting. The carpeting will be used by consumers and commercial industry. This CAS number itself will be present in these products at low levels as a residual. Percent of total manufactured or imported volume going to this use: <1 Check all physical forms of the chemical during this use: If used in a mixture check appropriate box to indicate weight fraction. Average values are acceptable: X <1% (<5000 ppm) ___ 1-30% ___ 30-60% ___ 60-90% >90% __ Aerosol __ Dry Powder __ Pellets or large crystals __ Water or solvent - wet solid __ Gas or vapor X Liquid solution __ Other (Explain) CAS Number 25268-77-3 3M Company 23 Use Number 3 of 8 Description of Chemical End Use: This CAS number is used as an intermediate to manufacture polymers that are sold to industrial users to be mill applied as protective, repellent treatments for nonwoven substrates. These substrates will be made into industrial workwear or medical garments to be used by commercial industry. This CAS number itself will be present in these products at low levels as a residual. Percent of total manufactured or imported volume going to this use: <1 Check all physical forms of the chemical during this use: If used in a mixture check appropriate box to indicate weight fraction. Average values are acceptable: X <1% ___ 1-30% ___ 30-60% ___ 60-90% >90% ___ Aerosol ___ Dry Powder ___ Pellets or large crystals ___ Water or solvent - wet solid ___ Gas or vapor X Liquid solution ___ Other (Explain) Use Number 4 of 8 Description of Chemical End Use: This CAS number is used as an intermediate to manufacture polymers that are sold to industrial users to be mill applied as protective, repellent treatments for upholstery. The upholstery will be used by consumers and commercial industry. This CAS number itself will be present in these products at low levels as a residual. Percent of total manufactured or imported volume going to this use: <1 Check all physical forms of the chemical during this use: If used in a mixture check appropriate box to indicate Weight fraction. Average values are acceptable: X <1% ___ 1-30% ___ 30-60% ___ 60-90% ___ >90% >90% ___ Aerosol ___ Dry Powder ___ Pellets or large crystals ___ Water or solvent - wet solid ___ Gas or vapor X Liquid solution ___ Other (Explain) 119 CAS Number 25268-77-3 3M Company 24 Use Number 5 of 8 Description of Chemical End Use: This CAS number is used as an intermediate to manufacture materials that are regulated by the Food and Drug Administration as indirect food additives used to impart grease and oil resistance to paper and paperboard. Paper or paperboard are used in food packaging products such as bags, wrappers, cartons, or trays. This CAS number itself will be present in these products at low levels as a residual. Percent of total manufactured or imported volume going to this use: <1 Check all physical forms of the chemical during this use: If used in a mixture check appropriate box to indicate weight fraction. Average values are acceptable: X <1% (< 4000 ppm) ___ 1-30% ___ 30-60% ___ 60-90% >90% ___ Aerosol ___ Dry Powder ___ Pellets or large crystals ___ Water or solvent - wet solid ___ Gas or vapor X Liquid solution ___ Other (Explain) Use Number 6 of 8 Description of Chemical End Use: This CAS number is used as an intermediate to manufacture materials that are sold to industrial users to be mill applied as protective treatments for carbonless paper (business forms). This CAS number itself will be present in these products at low levels as a residual. Percent of total manufactured or imported volume going to this use: <1 Check all physical forms of the chemical during this use: If used in a mixture check appropriate box to indicate Weight fraction. Average values are acceptable: < 1% X 1-30% (0.1-2%) 30-60% 60-90% >90% >90% __ Aerosol __ Dry Powder __ Pellets or large crystals __ Water or solvent - wet solid __ Gas or vapor X Liquid solution __ Other (Explain) ITO CAS Number 25268-77-3 3M Company 25 Use Number 7 of 8 Description of Chemical End Use: This CAS number is used as an intermediate to manufacture materials that are sold to industrial users to be applied as protective treatments for porous surfaces. This CAS number itself will be present in these products at low levels as a residual. Percent of total manufactured or imported volume going to this use: <1 Check all physical forms of the chemical during this use: If used in a mixture check appropriate box to indicate weight fraction. Average values are acceptable: ___ < 1% ___ 1-30% (0.1-2%) ___ 30-60% ___ 60-90% >90% ___ Aerosol ___ Dry Powder ___ Pellets or large crystals ___ Water or solvent - wet solid ___ Gas or vapor X Liquid solution ___ Other (Explain) Use Number 8 of 8 Description of Chemical End Use: This CAS number is used as an intermediate to manufacture polymers that are incorporated into products for consumer use as protective, repellent treatments for upholstery. This CAS number itself will be present in these products at low levels as a residual. Percent of total manufactured or imported volume going to this use: <1 Check all physical forms of the chemical during this use: If used in a mixture check appropriate box to indicate Weight fraction. Average values are acceptable: X <1% ___ 1-30% ___ 30-60% ___ 60-90% ___ >90% >90% ___ Aerosol ___ Dry Powder ___ Pellets or large crystals ___ Water or solvent - wet solid ___ Gas or vapor X Liquid solution ___ Other (Explain)