Document per6mrMgkDzMRGK4JxVogOkZ6

3(f 3M Specialty Materials 3M Center St. Paul, MN 55144-1000 651 733 1100 HHTXrW May 11,2000 FYI-00-001378 FVI-0 0 -0 0 1 3 7 8 Mr. Charles Auer US EPA/OPPT/CCD (7405) 401 M Street, SW Room 403 (East Tower) Washington, DC 20460 <$ 4/f //. *5 - /37S Dear Charlie: Pursuant to our recent communications, 3M is sending you this additional information relating to perfluorooctylsulfonate (PFOS) salts. We are providing this information to you on a voluntary basis as part of our continuing discussions with EPA regarding fluorochemistry. TABLE 1 --rCCC-sOOOa CAS Number 29081-56-9 29457-72-5 2795-39-3 3M Product Designation FC-93 FC-94 and FC-96 FC-95 Chemical Description Ammonium Perfluorooctylsulfonate Lithium Perfluorooctylsulfonate Potassium Perfluorooctylsulfonate -V m <U> o '--di no X * : 2 rn no 70225-14-8 FC-99 Diethylamino Perfluorooctylsulfonate CD The products listed above are all sold as the salts. None are used as reactive intermediates in other 3M products nor are they deliberately added, except as noted below. The applications made of the CAS Numbers listed in Table 1 are detailed in Table 2. Table 2 CAS NUMBER 2795-39-3 29457-72-5 70225-14-8 29081-56-9 APPLICATION 1. Film former in Fire Fighting Foams 2. Mist suppressant for acid baths in metal plating factories 3. Surfactant in acid etching processes for production of circuit boards 1. Surfactant in alkaline cleaners 2. Emulsifier in commercial floor polish 3. Mist suppressant for acid baths in metal plating factories 4. Surfactant in acid etching processes for production of circuit boards 5. Registered active ingredient for insect control. Used in formulations used in bait traps 1. Emulsifier in commercial floor polishes 2. Mist suppressant for acid baths in metal plating factories 3. Surfactant in acid etching processes for production of circuit boards 1. Surfactant in acid etching processes for production of circuit boards 85000000007 l Jt C j ( I Page 2 Mr. Charles Auer It is apparent from Table 2 that multiple uses may be made of any one product. Table 3 details the multiple CAS Numbers which may be used in any one application. Table 3 CAS NUMBER 2795-39-3 2795-39-3 29457-72-5 70225-14-8 2795-39-3 29457-72-5 70225-14-8 29081-56-9 29457-72-5 70225-14-8 29457-72-5 29457-72-5 APPLICATION Film former in Fire Fighting Foams Mist suppressant for acid baths in metal plating factories Surfactant in acid etching processes for production of circuit boards Emulsifier in commercial floor polishes Surfactant in alkaline cleaners Registered active ingredient for insect control. Used in formulations used in bait traps Potassium perfluorooctylsulfonate is deliberately added to 3M aqueous fire fighting foams (AFFF). These are described in Table 4. Table 4 3M AFFF Product FC-201F FC-203 FC-203CF FC-206CF FC-401 FC-600 FC-600F FC-602 FC-603F FC-783F FC-786F FC-4040 FX-9162 % PFOS Potassium Salt per Dry Pound 3.0 1.34 1.0 0.67 23.5 1.0 1.0 0.5 0.5 0.5 0.25 3.0 1.0 Direct 3M customers significantly dilute the above products before final use. Page 3 Mr. Charles Auer No other products produced from the functional derivatization of POSF contain perfluorooctane sulfonate as a deliberately added ingredient. 3M does not routinely analyze these final products for PFOS. In addition, recent analytical studies on core fluorochemical intermediates used in the manufacture of the majority of POSF-based products demonstrate the presence of trace levels of PFOS ranging from .00071% to .0042%. As these intermediates are further reacted and formulated into final products, the trace concentrations of PFOS could be further diluted. However, recently four of the highest volume POSF-based products were analyzed for the presence of PFOS in the final commercialized product. The results are listed in Table 5. TABLE 5 Product Paper Protector Textile Protector Carpet Protector Carpet Protector # of Lots Analyzed 15 3 3 2 % PFOS in Final Product 0.00005% 0.000025 0.0008% 0.0002 0.0003% 0.00007 0.001% 0.001 Please let me know if you need further information. Regards, William A. Weppner, Ph.D. Director Environmental, Health, Safety and Regulatory Affairs 3M Specialty Material Markets Group 3M Center, Building 236-1B-10 St. Paul, MN 55144 651/733-6374 3