Document qdNLdmnBdODEMemOG5vo96poj

5/23/84 PERSONAL U CONFIDENTIAL cc. R. E. PUTNAM TO: T. M. KEMP T. L. SCHRENK FROM! J. A. SCHMID C-9 MEETING SUMMARY 3/22/04 - WILMINGTON THE REVIEW WAS HELD WITH BESPERKA, BENNETT, RIDDICK. GLEASON. HEGENBARTH, SERENBETZ, RAINES. KENNEDY, VON SCHRILTZ. AND INGALLS IN ATTENDENCE. COPIES OF THE CHARTS USED ARE ATTACHED. THERE WAS A CONSENSUS THAT C-9, BASED ON ALL THE INFORMATION AVAILABLE FROM WITHIN THE COMPANY AND FROM 3Mr DOES NOT POSE A HEALTH HAZARD AT LOW LEVEL CHRONIC EXPOSURE. THERE WAS AGREEMENT THAT A DEPARTMENTAL POSITION NEEDED TO BE DEVELOPED CONCERNING THE CONTINUATION OF WORK DIRECTED AT ELIMINATION OF C-S EXPOSURES OFF PLANT AS WELL AS TO OUR CUSTOMERS AND THE COMMUNITIES IN WHICH THEY OPERATE. THERE WAS CONSENSUS REACHED THAT THE ISSUE WHICH WILL DECIDE FUTURE ACTION IS ONE OF CORPORATE IMAGE. AND CORPORATE LIABILITY. LIABILITY WAS FURTHER DEFINED AS THE INCREMENTAL LIABILITY FROM THIS POINT ON IF WE DO NOTHING AS WE ARE ALREADY LIABLE FOR THE PAST 32 YEARS OF OPERATION. CORPORATE IMAGE DISCUSSION CENTERED AROUND THE PERCEIVED DILIGENCE VERSUS OUR POLICIES IF WE ELECTED TO STOP WORK. CURRENTLY.'NONE OF THE OPTIONS DEVELOPED ARE. FROM A FINE POWDER BUSSINESS STANDPOINT, ECONOMICALY ATTRACTIVE AND WOULD ESSENTIALLY PUT THE LONG TERM VIABILITY OF THIS BUSSINESS S E G M E N T ON THE LINE. FROM A BROADER CORPORATE VIEWPOINT THE COSTS ARE SMALL. THE BASIS FOR A DECISION AT THIS POINT IS SUBJECTIVE a n c IS MADE MORE DIFFICULT BY OUR CURRENT UNDERSTANDING OF TECHNOLOGY AND COST. AND THE IMPACT ON THE FINE POWDER BUSSINESS. IT'S NOT AN EASY AND OBVIOUS DICISIOn AS FOR EXAMPLE TBSA WAS. 000252 EID602999 RJZ009986 PAGE 2 LOCKING AHEAD. LEGAL AND MEDICAL WILL MOST LIKELY TAKE A POSITION OF TOTAL ELIMINATION. THEY HAVE NO INCENTIVE TO TAKE ANY OTHER -POSITION. THE PRODUCT GROUP WILL TAKE A POSITION THAT THE BUSSINESS CANNOT AFFORD IT. THE END RESULT, IN MY OPPINON.WILL BE THAT WE ELIMINATE ALL C-0 EMMISIONS AT OUR MANUFACTURING SITES IN A WAY YET TO BE DEVELOPED WHICH DOES NOT ECONOMICALLY PENALIZE THE BUSSINESS. AND ADDRESSES THE C-0 EMISSION AND EXPOSURES OF OUR DISPERSION CUSTOMERS. SOME INFORMATION WHICH WE JUST DEVELOPED 5/21/04 IS T H A T DETECTIBLE LEVELS OF C-0 ARE IN BOTH THE LUBECK, W.V. AND THE LITTLE HOCKING, OHIO WATER SYSTEMS. WE SHOULD HAVE QUANTITATIVE NUMBERS IN THE NEXT TWO WEEKS. ALSO WITH THE DEVELOPMENT OF OUR CURRENT FINE POWDER EXPANSION PLAN, WHICH TAKES CAPACITY UP TO 0.2 MMAP, THROUGH A COMBINATION OF EQUIPMENT AND RECIPE CHANGES. C-9 AIR EMMISIONS WILL RISE FROM FROM THE CURRENT 12,000 LBS./YR. TO 25,200 LBS./YR.. THE INCREASE FOR THE COMBINED DIVISIONS WILL INCREASE FROM A CURRENT 16.000 TO 25,200 LBS./YR. OR A NET 9,200 LBS. DUE TO A 4,000 LB. OFFSET WITH THE IMPLEMENTATION OF THE TBSA PROGRAM. THIS WILL INCREASE FURTHER WITH THE INSTALLATION OF THE THIRD DRYER < 12MMAP FINE POWDER ) TO ABOUT 37,000 LBS./YR.. C-0 WILL NOW BECOME A MAJOR ISSUE ON ALL FURTHER PROJECT WORK IN THE FINE POWDER AREA, STARTING WITH THE WILMINGTON SCOPE REVIEW 6/29/84. IN PREPERATION FOR THAT REVIEW I HAVE REQUESTED THE ESD GROUND LEVEL CONCENTRATION STUDY BE REDONE USING THE NEW PRODUCTION VOLUMES AND RECIPE (457. SOLIDS). ALSO WE HAVE INCLUDED IN THE DRAFT SCOPE OF WORK A NEW SMALL EXHAUST SYSTEM In THE FRONT END OF THE DRYER BED TO TRY TO CATCH MOST OF THE C-0 IN A MUCH LOWER VOLUME AIR STREAM. THE FROJECT WILL PUT THIS STREAM TO THE EXHAUST STACK. THE INTENT IS TO FIRST REDUCE IN PLANT EXPOSURE, AND SECOND LEAVE A FUTURE CAPABILITY FOR TREATMENT OF THIS RELATIVELY CONCENTRATED STREAM. I BELIEVE WE NEED TO SIT BACH DOWN W I T H THE NEW INFORMATION WE NOW HAVE . AND THE FEEDBACK WE HAVE GOTTEN FROM THESE MEETINGS AND JOINTLY WITH PUTNAM REVIEW DuR PLANT POSITION. RAINES AT ONE POINT H A D REJECTED PEDUCTION A S A N OPTION. THIS NEEDS TO BE INCLUDED IN CUR THINK ING AGAIN. 000253 EID603000 RJZ009987 C-8 HISTORY 8/51 BEGAN USE OF C-8 IN DISPERSION POLYMERIZATION. FEW PRECAUTIONS IN HANDLING- 6/27/78 ADVISED PERSONNEL THAT 3M FOUND ELEVATED ORGANIC FLUORINE LEVELS IN BLOOD OF WORKERS EXPOSED TO FLUORINATED SURFACTANTS. STARTED INTERNAL REVIEW AND MONITORING- 9/79 PROVISIONAL AEL ESTABLISHED BY HASKEL- 3/20/81 3M ADVISED THAT C-8 CAUSED BIRTH DEFECTS IN THE UNBORN WHEN FED BY STOMACH TUBE TO FEMALE RATS- ALL FEMALE EMPLOYEES WITH POTENTIAL C-8 EXPOSURE WERE PROMPTLY TRANSFERED TO OTHER PLANT AREAS- 4/10/81 C-8 SPECIFIC BLOOD TEST DEVELOPED AND PUT IN USE- 3/1/82 STUDIES COMPLETE WHICH FIND C-8 NOT TO BE A TERATOGEN AND NO ADVERSE HEALTH EFFECTS- 5/17/82 FINAL AEL ESTABLISHED- |f |/(MI'I'IH<! J A S / nsw 2717W-1 000254 ffc/i/ RJZ009988 EID603001 0 8 EXPOSURE LIMITS AEL IN AIR BLOOD LEVELS PUBLIC EXPOSURE LIMITS 0.55 MOLES PER BILLION OR .55 ppb OR 10 MICR0GRAMS/m3 NONE ESTABLISHED NONE ESTABLISHED AEL OF .01 3m g / m BASED ON REVERSIBLE LIVER CHANGES SEEN IN RATS EXPOSED TO 8 k g /3 FOR A HOURS/DAY FOR 5 DAYS/WEEK FOR 2 WEEKS. ((>(lo/j fj JAS/n s w 2717W-2 000255 RJZ009989 EID603002 C-8 WASHINGTON WORKS POLICY ESTABLISHED 6/80 I REDUCE EXPOSURE BELOW AEL BY ENGINEERING CONTROLS AND PROTECTIVE EQUIPMENT. I REDUCE EXPOSURE BY ENGINEERING CONTROLS AND PROTECTIVE EQUIPMENT SO THAT ELEVATED ORGANIC FLUORINE LEVELS IN BLOOD WILL DECREASE AND ACCUMULATION OF ORGANIC FLUORIDES IN NEW WORKERS WILL BE LIMITED. RESULTS I EXPOSURES HAVE BEEN REDUCED AND MAINTAINED 3ELQW AEL LEVELS- C-8 LEVELS IN THE BLCCD ARE DECPEA3IN JAS/n s w 2717W-3 o 000256 RJZ009990 EID603003 C-8 DATA TO-DATE o IT IS NOT A TERATOGEN o IT IS NOT A MUTAGEN 0 IT IS NOT AN EMBRYOTOXIN o IT IS NOT A CARCINOGEN o IT IS MODERATELY TOXIC o IT HAS A*1BIOLOGICAL HALF LIFE OF TWO YEARS " 0 A lc c t> 0002S7 RJZ009991 EID6030C4 OFF PLANT EMISSIONS WATER - 16.000 LBS. PER YEAR AIR - 15.000 LBS. PER YEAR PRODUCT - 5.000 LBS. PER YEAR |ii/nn'i'nj 000258 RJZ009992 EID603005 BLOOD DATA VIA WATER VIA AIR VIA PRODUCT UNKNOWN 026 PPM (NON-TEFLON*) 027 PPM (SPRUANCE PLANT) l<((.t;U/| JAS/nsw 2717W-6 000259 RJZ009993 EID603006 C-8 PROGRAM WATER - TBSA AIR - DECISION ON ENGINEERING STUDY I(.(,(,1111/1 /I JAS/nsw 2717W-7 000260 *7*$ O / W t* RJZ009994 EID603007 .r- ENGINEERING STUDY DEFINE METHODS OF REMOVING C-R FROM THE FINE POWDER DRYER EXHAUSTS STACKS: I TRAILER. PARK NEAR PLANT SITE ESTIMATED TO HAVE ANNUAL MEAN C-8 CONCENTRATION OF .0056 ppb ( OT"ACL>- ( j / / c A & L ) . ESTIMATE OF PROBABILITY OF EXPOSURE AT THIS LOCATION TO C-8 LEVELS ABOVE THE AEL IS -0002. 2 717 W - 8 000261 RJZ009995 EID603CC8 ENGINEERING STUDY RESULTS THERMAL DESTRUCTION - ECONOMICS SIMM + INVESTMENT SIMM ANNUAL OPERATING COST (APPROXIMATELY S0.15/LB. OF PRODUCT) SCRUBBING AND RECOVERY - S3.5MM + INVESTMENT - S2.5MM ANNUAL OPERATING COST (APPROXIMATELY SO.AO/LB. OF PRODUCT) - S1.5MM DEVELOPMENT COST - POTENTIAL BREAK-EVEN IF RECOVERED C-8 IS USABLE 000262 J * * s h in RJZ009996 EID603009 CURRENT ACTIVE PROGRAM ITEMS C-8 FATE IN PROCESS WILL DEPEND ON WHETHER TFE DIMER IS USED TO REDUCE TFE EXPLOSIBILITY IN DISPERSIQN/FINE POWDER POLYMERIZATION. DIELECTRIC DRYING OF FINE POWDER IS BEING INVESTIGATED FOR ITS POTENTIAL BENEFIT IN C-8 RECOVERY. LLU<M)/i a U00263 RJZ009997 E ID 6 0 3 0 1 0