Document rpBEk7BqE0ZEN5yEE7RLNaJna

Lo CAS Number 335-77-3 (acid) & 67906-42-7 (ammonium salt) 3M Company AR 226 0577 Voluntary Use and Exposure Information Profile Perfluorodecane sulfonate L CHEMICAL IDENTIFICATION `Chemical Name: `CAS Number: Perfluorodecane sulfonate (PDSF) 335-77-3 (acid) 67906-42-7 (ammonium salt) IL COMPANY IDENTIFICATION Company Name: 3M Site Location: 10746 Innovation Road Cottage Grove, MN 55016 Technical Contact: Phone: Address: W.A. Weppner 651/733-6374 3M Center, Building 236-1B-10 St. Paul, MN 55144 HL ON-SITE ACTIVITIES CAS#* Mfg. (1997) Imported 335-773 0 0 67906-42-7 0 0 Estimate the amount of subject chemical distributed off-site: % of manufacture/import *These materials are not produced during POSF (CAS #307-35-7) manufacture. Manufacturing did not occur in 1997 but did occur in1998 and 1999 at < 100,000 Ibs. Ifyou have already provided the above information to EPA and it is still representative please reference that submission here: CAS Number 335-77-3 (acid) & 67906-42-7 (ammonium salt) 3M Company 2 Narrative Description and Process Flow Schematic: Perfluorodecane sulfonates are synthesized via the Simons Electro-Chemical Fluorination (ECF) process. The starting feedstock for this reaction is Decane Sufonyl Fluoride CuHaSOF + 21 HF rEerneergy ECF CFuSOF + 21H, PDSF is not itselaf commercially viable product, but is used as an intermediate in the manufacture: for Perfluorodecane sulfonates. The perfluorodecane sulfonic acid is manufactured by hydrolyzing perfluorodecane sulfonyl fluoride to the corresponding sulfonic acid in batch reactors. The salts are `manufactured by base neutralizationofthe acid to the salt in a separate reactor. The low sales `volume and reactor availability dictate an infrequent production schedule for these chemicals. cas Number 335-77-3 (acid) & 67906-42-7 (ammonium salt) 3M Company 3 The following block flow diagram describes the process discussed above. BLOCK FLOW DIAGRAM Electro-Chemical Fluorination Cells (Decanesulfony! fluoride + HF + electrical energy) Perfluorodecane sulfonyl fluoride Secondary Reactors Hydrolysis & Base Neutralization Perfluorodecane sulfonic acid And various salt forms CAS Number 335-77-3 (acid)& 67906-42-7 (ammonium salt) 3M Company 4 IV. SITE RELEASE AND TRANSFER INFORMATION FOR TRI CHEMICALS Not applicable. Vv. 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 ofa 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 withrespectto fluorochemicals because fluorochemical losses were not always included in the analysis ofeach 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 ofthese `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 Cottage Grove, MN. Engineering calculations and modelsofprocess vent emissions are used for estimates. Existing process emission information shows only minor losses through point source vents. Fugitive emissions may have occurred during some handling steps but have not been quantified. Fugitive (non-point) Estimated Total Annual Releases (Ibs) No data available. Estimated % Accuracy of Estimate (optional) # dayslyears release occurs Stack (point) <1 Comments: B. `WATER RELEASES FROM SITE Cottage Grove,MN 1000 pounds of PDSF were estimated discharged to the wastewater treatment system in 1998. No data is available for 1997. The levelofthis compound discharged, based upon behavior of POSF in Decatur, is believed to be close to zero (<1%of total discharge). Continued improvements in reducing material to theriver are being undertaken by a `wastewater emission reduction team and engineers at the facility. 5q Estimated Total Estimated % CAS Number 335-77-3 (acid) & 67906-42-7 (ammonium salt) 3M Company s Annual Releases ~~ Accuracy of (Ibs) Estimate (options) Water releases: <10 Number of days/year release occurs: 6/year Receiving Water Name: Mississippi NPDES Number: MN00001449 Comments: C. ON-SITE LAND RELEASES CottageGrove,MN Estimated Total Annual Releases [eS Landfill 0 Land Treatment/Land Amendment ~~ 0 Surface Impoundments 0 Underground Injection 0 Other (specify): Comments: Estimated % Accuracy of Estimate (options D. OFF-SITE TRANSFERS Cottage Grove, MN Process wastewaters are managed in an on-site wastewater treatment facility and are not sent to the POTW. DIL. Transfer to Publicly Owned Treatment Works (POTW) Number of days/year the release occurs: Annual Transfer (1b): 0 Estimated% Accuracy of Transfer Estimate (optional) (%): POTW Name: Street Address: City: State: NPDES Number: Country: Zip Code: `Comments: 60 CAS Number 335-77-3 (acid) & 67906-42-7 (ammonium salt) 3M Company 6 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 finlculourdoecdh.emIinccailnecraattegioorniiess.noWwhetrheepwraismtaersyadriestproascaklemdebtyhoCdAfSorntuhmebseerw,astthees.amounts have been Cottage Grove, MN Cottage Grove facility ilizes incineration for alltheirdrummed wastes. Sludge from the Cottage Grove facility is sent to an industrial landfill Estimated Total Annual Releases (ibs) Estimated % Accuracy of Estimate optional) Incineration: 2,100 Wastewater Treatment 0 (Excluding POTW) Underground Injection 0 Hazardous Waste (RCRA 0 Subtitle C) landfill Other Landfill 0 Recycle or Recovery 0 Unknown or Other Comments: CAS Number 335-77-3 (acid) & 67906-42-7 (ammonium salt) 3M Company 7 VL ON-SITE WORKPLACE EXPOSURE (335-77-3) `This information will assist EPA in characterizing the number ofworkers 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 ofworkers potentially exposed routinely to the subject chemical for each of the exposure duration times. Ifaworker 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 numberofworkers potentially exposed. Days/Year Hours/Day <10 10-100 100-250 5250 [os | T T TT| Le oo[oe 1] Le oe eT] =1[TT 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 (335-77-3) is a produced in an aqueous slurry, drained into drums. The material is vacuum charged as an aqueous slurry to produce other materials. Employees take quality samples during the process. The liquid product contains 33-43% 335-773. CAS Number 335-773 (acid) & 67906-42-7 (ammonium salt) 3M Company 3 3. Provide industrial hygiene monitoring data,ifavailable, with abriefdescription of the sampling method and exposure scenario monitored, e.g, describe the specific worker nacottiviintcilesudpeearnfyorpmeerdsobnyalthiedeinntdiifviierdsuasluschmoansitaowroerdk.erF'osrnparmiveacoyr csoocnisaildesreactuirointsy,npulmebaseerdwoith 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 onstaffand is supported by a corporate industrial hygiene group. 3M' 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 resultsofthe 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: Local exhaust ventilation is used at the drum tops during charging and drumming. 5. Briefly list the this chemical: personal protective equipment your workers regularly wear to prevent exposure of During sampling, employees wear full faceshields, rubber suits and boots, and PVC gloves. During charging and draining employees wear either full face supplied air respirators or full facepiece OVAG air-purifying respirators, butyl gloves, and rubberjackets. Comments: (This section is availableto clarify the responses given. Attach additional pages if desired.) CAS Number 335-77-3 (acid) & 67906-42-7 (ammonium salt) 3M Company 9 VI. ON-SITE WORKPLACE EXPOSURE (67906-42-7) `This information will assist EPA in characterizing the numberof 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. Ifaworkeirs 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. Days/Year Ce eT |=[77 T Hours/Day <10 10-100 100-250 >250 CT = TT] 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 (67906-42-7) is a produced in an alcohol-aqueous solution, drained into drums. Employees take quality samples during the process. The liquid product contains 25% 67906427. 3. Provide industrial hygiene monitoring data,if available, with abrief descriptionofthe 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 areasofthe facility, recent qualitative assessment ofpotential exposure to this material under 3M's ongoing industrial hygiene program indicates a low exposure potential to this material. CAS Number 335-77-3 (acid) & 67906-42-7 (ammonium salt) 3M Company. 10 Each 3M plant that produces sulfonated fluorochemicals has an industrial hygienist onstaffand is supported by a corporate industrial hygiene group. 3M' industrial hygiene program focuses on task-based exposure assessment and control. Exposuresare 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 resultsofthe 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: Local exhaust ventilation is used at the drum tops during charging and drumming. 5. Briefly list the personal protective equipment your workers regularly wearto prevent exposure of this chemical: During sampling, employees wear full faceshields, rubberjackets and boots, and PVC gloves. During draining employees wear full facepiece OVAG air-purifying respirators, butyl gloves, and rubber jackets. Comments: (This section is available to clarify the responses given. Attach additional pages if desired.) CAS Number 335-77-3 (acid) & 67906-42-7 (ammonium salt) 3M Company n VIL CHEMICAL END USES A. END USE AS AN INTERMEDIATE CONSUMED TO MAKE OTHER CHEMICALS AL On-Site Use as a Intermediate: Perfluorodecane sulfonic acid (CAS #335-77-3) is used as an intermediate to make perfluorodecane sulfonate, ammonium salt (CAS #6790642-7). Product chemical class or product chemical (Include CAS number if appropriate) % of total volumeof subject chemical manufactured or imported 1. Perfluorodecane sulfonate, ammonium salt 50 As reported in Part III, p2 A2. Off-Site Use as an Intermediate Product chemical class or product chemical (Include CAS number if appropriate) % of total volume of subject chemical manufactured or imported 1. Not Applicable CAS Number B. 3E3N5-D77U-S3E(SaciOd)T&HE67R90T6H-4A2N-7A(SamAmoCnOiNumSUsalMt)ED3MINCoTmEpRaMnEyDIATE 2 Use Number 1 of 2 DtoesicmrpirpotvieonweotftiCnhgemanidcallevEelnidngUosfe:proCdhuecmtiscsaolldfoarsmuflloaotrorpsoluissehetsh.isJcahnietmoirciaall saesrvaiscuerffaicrtmasnatre the end users. Pveorlcuemnetogfotiontgaltomtahnusfuascet:ur1e0d +or2imported Itfo uisnedidcaitneawmeiixgthutrefrcachteicokn.apApvreoprraigaete box values are acceptable: X <1% (001-0.02%) 130% 3060% Et 60-90% cChheemcikcaalll dpuhryisnigcatlhifsoursmes:ofthe __ Aerosol Dry Powder WaPetlelertsoorrslarogeler--vyswteeatlssnoltid --_ Gasorvapor X_ Liquid solution __ Other (Explain) Use Number 2 of 2 DtoesicmrpirpotvieonweotftiCnhgemanidcallevEelnidngUosfep:roCdhuecmtiscsaolldfoarsmuflloaotrorpsoluissheest.hisJcahnietmoirciaall saesrvaiscuerffiacrtmasnatre the end users. Pveorlcuemnetogfoitnotgaltomtahnusfuasce:tur4e0d+or5 imported I0f uisndeidcaitneawmeiixgthutrefrcachteicokn.apApvreoprraigaete box values are acceptable: X <I% (0.010.02%) 130% -- 3060% 60-90% >o% Check all physical formsofthe chemical during this use: Aerosol "Dry Powder Pellets or large crystals --_ Water orsolv~ weetnsoltid Gasorvapor X_ Liquid solution ~~ Other (Explain)