Document b51mQaw4MEbO6YqaMLKxjv8Dk

CAS Number 335-67-1,3825-26-1,335-95-5 3M Company 6/8/2000 Voluntary Use and Exposure Information Profile Perfluorooctanoic Acid and Salts I. CHEMICAL IDENTIFICATION Chemical Name: CAS Number: Perfluorooctanoic Acid & Salts Various, including: 335-67-1 (acid) 3825-26-1 (ammonium salt) 335-95-5 (sodium salt) II. COMPANY IDENTIFICATION Company Name: 3M Site Locations: 1) 10746 Innovation Road Cottage Grove, MN 55016 2) 1400 State Docks Road Decatur, AL 35601 Technical Contact: W.A. Weppner Phone: 651/733-6374 Address: 3M Center, Building 236-1B-10 St. Paul, MN 55144 III. ON-SITE ACTIVITIES CAS# M fe (1997) Imported (1997) 335-67-1 3825-26-1 335-95-5 Less Than 1,100,000 lb/yr. Less than 200,000 lbs. Estimate the amount of subject chemical distributed off-site: 48.5% 3 CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company Narrative Description and Process Flow Schematic: 6/8/2000 2 Perfluorooctanoic acid and its salts are produced from perfluorooctanoyl fluoride that has been synthesized via the Simons Electro Chemical Fluorination (ECF) process. The starting feedstock is octane chloride. C 7H 15C O C I + 16 H F ............... > ECF CgFnCOF + 15H2 + H C 1 Perfluorooctanoyl fluoride is not itself a commercially viable product, but is 100% used as an on-site intermediate in the manufacture of perfluorooctanoic acid (PFOA) and the salts of the acid. The PFOA is manufactured by base hydrolyzing the perfluorooctanoyl fluoride to the corresponding octanoic acid in batch reactors. The salts are manufactured by base neutralization of the acid to the salt in a separate reactor. The following block flow diagram describes the process discussed above. BLOCK FLOW DIAGRAM FOR PERFLUOROOCTANOIC ACID (PFOS) CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 3 IV. SITE RELEASE AND TRANSFER INFORMATION FOR TRI CHEMICALS 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. Production of perfluorooctanoyl compounds began in Decatur in 1999. In prior years Decatur's emissions result from byproduct formation. 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, ALABAMA ONLY: Wastewater fugitive emission data was based upon 1999 wastewater testing. Fugitive emissions may have occurred during some handling steps but have not been quantified. <r CAS'Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 4 Decatur. AL Estimated Total Annual Releases (lbs. 1999) Estimated % Accuracy of Estimate (optional) # days/years release occurs Fugitive - wastewater < 1 in 1999 250 Stack (point) Engineering calculations and models of process vent emissions are used for estimates of point source emissions. Estimated Total Annual Releases (lbs. 1997) Estimated % Accuracy of Estimate (optional) # days/years release occurs PFOA compounds No data available Cottage Grove. MN Emissions estimates are from process engineer's estimates and emission models. 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) PFOA compounds Comments: 1950 100-200 CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 5 B. WATER RELEASES FROM SITE Decatur, AL The data presented was determined during wastewater testing conducted during 1998-1999. Production of perfluorooctanoyl compounds began in Decatur in 1999. In prior years Decatur's emissions result from byproduct. Estimated Total Annual Releases (total annual) Estimated % Accuracy of Estimate (optional) Water releases: < 30,000 Number of days/year release occurs: Releases are estimated at 250 days per year Receiving Water Name: Baker's Creek at the junction with the Tennessee River NPDES Number: ALD004023164 Comments: Cottage Grove, MN Engineering calculations were used to estimate the amount of material discharged to wastewater. The amount of material discharged to the river was determined through use of existing removal efficiency testing results from another facility. Estimates were based upon 1999 production information since no wastewater data was available for 1997 or 1998. Estimated Total Annual Releases (lbs. 1999) Estimated % Accuracy of Estimate (optional) Water releases: < 15,000 Number of days/year release occurs: 100-200 Receiving Water Name: Mississippi NPDES Number: MN00001449 Comments: 7 CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 6 C. ON-SITE LAND RELEASES Decatur. AL The land treatment of Decatur sludge was discontinued in mid-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. Levels of PFOA in the sludge were determined from wastewater data. 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 <500 - No longer used No data available/No longer used 0 Comments: 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: Country: State: Zip: NPDES Number: Not Applicable Comments: S CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 7 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: Country: State: Zip: NPDES Number: Not Applicable Comments: 9 CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 8 D2. TRANSFERS TO OTHER OFF-SITE LOCATIONS 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 1998 plant records regarding waste disposal locations for Decatur fluoridecontaining (not CAS number specific) wastes indicates that 70% was disposed through incineration at various off-site locations and approximately 30% was landfilled at a hazardous waste landfill. Incineration is now the primary disposal method for these materials. Estimated Total Annual Releases (lbs. 1 9 9 7 ) 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 0 Unknown or Other 0 Comments: /O CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 Cottage Grove. MN Cottage Grove facility utilizes incineration for all their drummed wastes. Sludge from the Cottage Grove facility is sent to an industrial landfill. Estimated Total Annual Releases (lbs. 1 9 9 7 ) Estimated % Accuracy of Estimate (optional) Incineration: 4500 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 Comments: 9 // CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 10 VI. ON-SITE WORKPLACE EXPOSURE CAS Number 335-67-1 Company: 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. Hours/Day <.25 .25-1 1-8 >8 <10 4 4 Days/Year 10-100 100-250 4 4 4 >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: Molten (ca 130F) material ranging in concentration from 35-75% is vacuum charged into fractionation equipment. Various concentrated (ranging up to 100%) molten "fractions" are drummed and later vacuum-charged to other process equipment. Other exposure opportunities involve quality sampling, process area cleanup, and maintenance activities (e.g., changing flange, hose, pipe, valve, filter, pump or sight glass). CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 11 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. Recent qualitative assessment of potential exposure to this material under 3M's ongoing industrial hygiene program has identified significant exposure tasks, and appropriate engineering, administrative and personal protective equipment controls have been established. Each 3M plant that produces fluorochemical carboxylates 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 bangs 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, half mask or full facepiece 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 disposable coveralls), 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.) A3 CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 12 CAS Number 335-67-1 Company: 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. Hours/Day <25 .25-1 1-8 >8 <10 4 4 Days/Year 10-100 100-250 4 4 32 4 >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: This material is a solid at room temperature (melting point = 120 F) which is drummed as a molten liquid (concentration 35-75%). Other exposure opportunities involve quality sampling, process area cleanup, and maintenance activities (e.g., changing flange, hose, pipe, valve, filter, pump or sight glass). Products containing 335-67-1 at concentrations ranging from 75% to 100% are melted and added to process reactors as raw materials. 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. Recent qualitative assessment of potential exposure to this material under 3M's ongoing industrial hygiene program has identified significant exposure tasks and appropriate engineering, administrative and personal protective equipment controls have been established. Each 3M plant that produces fluorochemical carboxylates 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 335-67-1,3825-26-1,335-95-5 3M Company 6/8/2000 13 4. Briefly describe the engineering controls used to minimize exposure to this chemical: During draining and charging, the operators use local exhaust to control any mists or vapors. 5. Briefly list the personal protective equipment your workers regularly wear to prevent exposure of this chemical: The required PPE for draining, charging and sampling consists of respiratory protection (full face supplied air for draining and organic vapor cartridge respirators with P 100 prefilters for charging and sampling) rubber gloves and splash resistant, disposable clothing. Comments: (This section is available to clarify the responses given. Attach additional pages if desired.) /5 CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 14 CAS Number 3825-26-1 Company: 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. Hours/Day <.25 .25-1 1-8 >8 <10 2 2 2 Days/Year 10-100 100-250 4 8 42 >250 2. Describe the routine worker activities to which the workers in question 1 are exposed: sampling, removal of Alter 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 material (3825-26-1) is produced in a slurry form and close-transferred to spray drying equipment. The powdered product (ca 100% concentration) is drummed. In this form the material is entrainable as an airborne dust. It is also hygroscopic. The powder may be shipped as a product or dissolved in water. Drumming powder, transferring powder from one container to another, and dissolving powder in water represent significant inhalation and dermal exposure tasks. Handling the material dissolved in water presents mainly dermal exposure potential. Maintenance activities (e.g., changing flange, hose, pipe, valve, filter, pump or sight glass) provide additional opportunity for mainly dermal exposure. 3. Provide industrial hygiene monitoring data, if available, with a brief description of the sampling method and exposure scenario monitored, e.g., describe the speciAc worker activities performed by the individuals monitored. For privacy considerations, please do not include any personal identiAers such as a worker's name or social security number with any data submitted to EPA. Personal sampling for this material is currently (late 1999 to present) done using OSHA Versatile Sampler tubes with XAD-4 resin and mixed cellulose ester or glass fiber prefilter. Sample analysis is by GC-ECD. 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 semi-validated. CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 15 Surfaces in production and administration areas were sampled beginning in 1994 and most recently in 2000. 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 the ACGIH TLV-TWA of 0.01 mg/m3[skin] for 3825-26-1. Each 3M plant that produces fluorochemical carboxylates 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. /7 CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 16 Exposure Task Exposure Sample Concentration Number Yr-Number 3825-26-1 mg/m3* Minimum Maximum Qeom mean Geom Std Dev Manual transfer of powdered material 97-075 32.1** 4.1 32.1 11.5 4.3 97-076 4.1 Operate spray dryer 91-001 0.04 0.001 0.04 0.009 6.8 92-034 0.016 93-017 0.001 Dissolving powdered 98-075 0.559 0.11 4 0.7 3.4 material in drums 98-076 1.51 00-7841 4 00-7841 0.9 00-7398 0.11 00-7403 0.35 Operate spray dryer sampling product 98-055 1.87 <0.002 1.87 0.91 2.8 Operate spray dryer change drums 95-030 <0.002 98-106 0.443 Operate other process 91-003 0.04 0.004 <0.1 0.063 1.9 Washing filters 95-026 <0.1 * All exposure concentrations represent task-based personal samples. ** The TW A exposure concentration was 11.4 mg/m3. This was a one-time task that was not repeated. 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 openings when drumming. The drumming process areas are enclosed from other process areas. Facilities have been established for employees to decontaminate (doff and containerize contaminated chemical protective clothing, remove respiratory protection for decontamination, and wash hands and other skin surfaces that may have been exposed) after performing significant powder exposure tasks. /g CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 17 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., full face supplied air [for exposures up to lOOOx OEL], half mask [up to lOx the OEL] or full facepiece [up to 50x the OEL] organic vapor cartridge with P I00 particulate prefilter), glove by elastomer (e.g., neoprene or nitrile), chemical protective clothing (e.g., 2-piece PVC or plain tyvekTM disposable coveralls), 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.) Process tasks involving exposure to 3825-26-1 in particulate form currently require rigorous decontamination using decontamination facilities attached to process areas. 3M has recently (2000) established a Biological Limit Value of 5 ppm for perfluorooctanoate anion in blood serum. Biological monitoring was voluntary in 1995 and 1997. In several cases, employees with higher serum levels were removed from further exposure. All employees with potential for significant exposure to 3825-26-1, 335-67-1, or 335-95-5 are required to participate in the biomonitoring program to work in such areas. CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 18 CAS Number 3825-26-1 Company: 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. Hours/Day <.25 .25-1 1-8 >8 <10 Days/Year 10-100 100-250 52 >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: This material is added by vacuum charge or poured into process vessels as a raw material in aqueous solution (concentration 30%). Exposure is primarily via skin contact. Other exposure opportunities involve quality sampling, process area cleanup, and maintenance activities (e.g., changing flange, hose, pipe, valve, filter, pump or sight glass). Resultant products contain 0.5% 3825-26-1, which is removed (to less than 10 ppm) by subsequent process steps. 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. Recent qualitative assessment of potential exposure to this material under 3M's ongoing industrial hygiene program has identified significant exposure tasks and appropriate engineering, administrative and personal protective equipment controls have been established. CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 19 Each 3M plant that produces fluorochemical carboxylates 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 335-67-1, 3825-26-1,335-95-5 3M Company 6/8/2000 20 4. Briefly describe the engineering controls used to minimize exposure to this chemical: Positionable local exhaust ventilation hoods are situated at significant point sources such as at drum openings 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, half mask or full facepiece organic vapor cartridge with P I00 particulate prefilter), glove by elastomer (e.g., neoprene or nitrile), chemical protective clothing (e.g., 2-piece PVC disposable coveralls), 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 335-67-1,3825-26-1,335-95-5 3M Company 6/8/2000 CAS Number 335-95-5 Company: 3M Company, Specialty Materials Manufacturing Division, Cottage Grove, MN 21 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. Hours/Day <.25 .25-1 1-8 >8 <10 2 4 Days/Year 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: This material is produced in an aqueous solution at 20% concentration. The material is not volatile in this form and exposure is primarily to skin during sampling, drumming of the solution, and maintenance activities. 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 for this material. Nonetheless, 3M has identified exposure tasks and appropriate engineering, administrative and personal protective equipment controls have been established. Each 3M plant that produces fluorochemical carboxylates 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. c23 CAS Number 335-67-1,3825-26-1,335-95-5 3M Company 6/8/2000 22 4. Briefly describe the engineering controls used to minimize exposure to this chemical: During draining, the operators use local exhaust to control any mists or vapors. 5. Briefly list the personal protective equipment your workers regularly wear to prevent exposure of this chemical: The required PPE for sampling and draining consists of rubber gloves, safety glasses, and splash resistant, disposable coveralls. Comments: (This section is available to clarify the responses given. Attach additional pages if desired.) 0. ^ CAS Number 335-67-1, 3825-26-1, 335-95-5 VII. CHEMICAL END USES 3M Company 6/8/2000 23 A. END USE AS AN INTERMEDIATE CONSUMED TO MAKE OTHER CHEMICALS A l. On-Site Use as a Intermediate: Product chemical class or product chemical (Include CAS number if appropriate) % of total* volume of subject chemical manufactured or imported 1. The vast majority of perfluorooctanoic acid (335-67-1) is consumed to make the ammonium (3825-26-1) or sodium salts (3356-95-5) 50% 3. 4. A2. Off-Site Use as an Intermediate: Product chemical class or product chemical (Include CAS number if appropriate) 1. 2. 3. 4. *As reported in Part III, p.2 % of total volume of subject chemical manufactured or imported* *As reported in Part III, p.2 5 CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 24 B. END USES OTHER THAN AS A CONSUMED INTERMEDIATE The following two tables present a summary of the information contained in VII.B. Table 1 details the end applications in which a particular CAS Number is used. For each CAS number, the percent used in each application totals to 100%. Table 1. CAS Number by Application CAS NUMBER 335-67-1 335-95-5 3825-26-1 APPLICATION 1. Reactive intermediate for synthesis of fluoroacrylate ester used in coating applications 1. Processing aid in the industrial synthesis of fluoropolymers and fluoroelastomers 1. Processing aid in the industrial synthesis of fluoropolymers and fluoroelastomers 2. Post Polymerization aid to stabilize fluoropolymer and fluoroelastomer suspensions 3. Processing aid for factory applied fluoropolymer coatings Table 2 details the multiple CAS Numbers which may be used in any one application. Table 2. Application by CAS Number CAS NUMBER 335-67-1 335-95-5 3825-26-1 3825-26-1 3825-26-1 APPLICATION Reactive intermediate Processing aid for fluoropolymer and fluoroelastomer polymerizations Post-polymerization aid to stabilize fluoropolymer and fluoroelastomer suspensions Processing aid in coating fluoropolymers Lb CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 25 CAS Number 3825-26-1, Ammonium Perfluorooctanoate Use Number 1 of 3 Description of Chemical End Use: Used as a processing aid in the industrial synthesis of fluoropolymers and fluoroelastomers which have a variety of industrial and commercial uses. These fluoropolymers and fluoroelastomers have use in consumer products. Percent of total manufactured or imported Volume going to this use: 98 1.0 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 X Other (Explain) As dry coatings on metal implements; as molded parts; as fabricated articles. Use Number 2 of 3 Description of Chemical End Use: Used as post polymerization processing aid to stabilize fluoropolymer and fluoroelastomer suspensions prior to further industrial processing. Percent of total manufactured or imported Volume going to this use: 1 0.5 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 X Other (Explain) As dry coating on metal implements, as molded parts, as fabricated articles. *<0.5% in liquid solution, <0.0001% (1 ppm) in dry coatings. CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/ 8/2000 26 Use Number 3 of 3 Description of Chemical End Use: Used as processing aid for factory applied fluoropolymer coatings on fabrics, metal surfaces and fabricated or molded parts. Percent of total manufactured or imported Volume going to this use: 1 0.5 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 X Other (Explain) Dry coating on metal implements, as molded parts, as fabricated articles. *<0.5% in liquid solution, <0.0001% (1 ppm) in dry coatings. 8 CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 27 CAS #335-95-5 Sodium Perfluorooctanoate Use Number 1 of 1 Description of Chemical End Use: Used as a processing aid in the industrial synthesis of fluoropolymers which have a variety of uses commercially and in consumer products. Percent of total manufactured or imported Volume going to this use: 100% 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 X Other (Explain) As dry coating on metal implements, as molded parts, as fabricated articles. *<0.5% in liquid solution, <0.0001% (1 ppm) in dry coatings. & CAS Number 335-67-1, 3825-26-1, 335-95-5 3M Company 6/8/2000 28 CAS #335-67-1 Perfluorooctanoic Acid Use Number 1 of 1 Description of Chemical End Use: Used as a reactive intermediate in the industrial synthesis of a fluoroacrylic ester. This latter material is subsequently used in an industrial coating application. Percent of total manufactured or imported Volume going to this use: 100% 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) 30