Document wDBEaL29dVxRy2d8gnnNp9MX3

cL AR 226 - 0928 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 1 Revised: 7/2000 Voluntary Use and Exposure Information Profile Perfluorooctane Sulfonic Acid and Various Salt Forms I. CHEMICAL IDENTIFICATION Chemical Name: CAS Number: Perfluorooctane Sulfonates Various, including: 21970683-12-35-61-9(a(caidm)monium salt) 70225-14-8 (DEA salt) 2795393 (K-salt) 29457725 (Li Salt) TshumempaerrifzleuotrhoeocdteasniegnsautlefdonTaiteeraInpieornf(luPoFrOoSc)hehmaiscanlostshpaectiafriec CalAl Sconnsuimdbeerre.d pTehreflluiosrtoeodctsaalntes: sulfonates. IL COMPANYIDENTIFICATION Company Name: 3M Site Locations: 1) C1o0t7t4a6geInGnroovvaet,ioMnNRoa5d5016 2) 1400 State Docks Road Decatur, AL 35601 Technical Contact: W.A. Weppner Phone: Address: 651/733-6374 3M Center, Building 236-1B-10 St. Paul, MN 55144 IL ON-SITE ACTIVITIES CAS# Mfg. (1997) 1763-231 29081-56-9 70225-14-8 2795-39-3% 29457725 Less Than 200,000 Iblyr. Estimate the amount of subject chemical distributed off-site: Imported 0 0 0 0 0 95% of manufacture/import *Submitted in 1998 TSCA IUR additional information. 000002 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-393, 29457-72-5 / 3M Compan/y 2 Revised: 7/2000 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 hoyndtrhoegmeonlfelcuuolreitdeo,baendreapnlaelceecdtrwiictchufrlrueonrtinse.pTahsseedprtehrdooumgihnatnhte csoolmuptioonne,nctasuosfintghethperhodyudcrtosgecnreaatteodms 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 rearrangementofthe carbon skeleton can also occur and significant amountsofcleaved, branched and cyclic structures may be formed. The degreeoffluorinationofthe organic feedstock is also dependent upon the specific carbon chain length of the feedstock and parametersofthe ECF process such as electrical current and the lengthof time the process is run. It is possible to synthesize fully fluorinated or perfluoroorganic `molecules where allofthe hydrogen atomsofthe hydrocarbon feedstock have been replaced by fluorine atoms.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. Abasic building blockofsuch 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 CyHSOF + 17HF 1-Octanesulfonyl fluoride Energy > CiFiSOF + 17H ECF Perfluorooctanesulfonyl fluoride `The electrochemical fluorination process yields about 35%-40% straight chain (normal) POSF, and a `mixtureofbiproducts and wasteof unknown and variable composition comprisedof the following: 1) higher and lower straight-chain homologs, i, n-CnFannSOF, .g, CeF1:SOF, CrF1sSOF, CoF15SO,F which comprise about 7%of the process output 2) branched-chain, perfluoroalkylsulfonyl fluorides with various chain lengths, about 18-20%ofthe output 3) straight-chain, branched, and cyclic (non-functional) perfluoroalkanes and ethers, which comprise about 20-25%ofthe output 4) "tars" (high molecular weight fluorochemical byproducts) and other byproducts, including molecular hydrogen, which comprise about 10-15%ofthe output. Bpreocdauucseedobfysltihgehteldeicftferroecnhceemsicianlprfolucoersisnactoinodnitpirooncse,srsavwarmiaetsersioamlse,whanadt efqruoimpmloetn-tt,o-tlohteamnidxtfurroem plantto-plant. The product that results from electrochemical fluorination is thus not a pure chemical but rather amixofisomers and homologues. The commercialized POSF derived products are amixture ofapproximately 70% linear POSF derivatives and 30% branched POSF derived impurities. 000003 `CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 3 Revised: 7/2000 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 10 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 currently being incineratedatan inhouse 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 ofthi treatment sludge is being landfilled offsite since early 1998. POSF isitself a commercially viable product, but is primarily an important intermediate in the synthesisof substances used in many other 3M fluorochemical products. The majority is used to produce functionally derivatized fluorochemicals and high molecular weight polymeric products. `The perfluorooctane sulfonic acid manufactured by hydrolyzing POSF intermediates to the sulfonic acid. The various salts ofperfluorooctane sulfonate are manufactured by base neutralization of the acid to the appropriate salt in a batch reaction. `The following block flow diagram describes the process discussed above. BLOCK FLOW DIAGRAM FOR PERFLUOROSULFONIC ACID AND ITS SALTS Electro-Chemical Fluorination Cells (Octanesulfonyl fluoride + HF + electrical energy) Perfluorooctane sulfonyl fluoride SecoHnyddraorlyysRiesa&ctors Base Neutralization Functionally Derivatized Fluorochemicals Perfluorooctane sulfonic acid and various salt forms 000004 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 4 Revised: 7/2000 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 ofa qualitative nature. Although limited `monitoring data exists, most emission and waste estimatesare 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 ofeach intermediate step. `The accuracy of the emissions data submitted varies due to several factors. Batch process systems are difficultto 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. A. ALL PLANTS - Fugitive emissions may occur from vacuum charging from drums, sampling from reactors, drummingofproduct/intermediate, flaking monomer, drying operations. Industrial Hygiene monitoring has been conducted for some compounds. These compounds have been detected as fugitive emissions during industrial hygiene exposure testing, Fugitive emissions may have occurred during some handling steps but have not been quantified. DECATUR, ALABAMA ONLY: Wastewater fugitive emission data was based upon 1999 wastewater testing. Fugitive (wastewater) Estimated Total Estimated% Annual Releases ~~ Accuracy of (Ibs. 1997) Estimate options) <100 #dayslyears release occurs Engineering calculations and modelsofprocess vent Emissions are used for estimatesofpoint source emissions. Stack (point) 0 Comments: 000005 CAS Number 1763-23-1, 20081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Company / s Revised: 7/2000 COTTAGE GROVE, MN ONLY: Estimated Total Annual Releases (bs. 1997) Estimated% Accuracy of Estimate optional) #dayslyears release occurs Fugitive (wastewater) ~~ Negligible, Not quantified Stack (point) 0 Comments: 000006 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 6 Revised: 7/2000 B. WATER RELEASES FROM SITE PFOS in wastewater discharge is not measured as specific salt compounds, but instead reflects the total amountofdissociated salts and other compounds that hydrolyze to PFOS. This is considered a qualitative measure du to the short time frameofthe sampling event given operational variability, the statusofanalytical method development and sample handling and holding procedures at this time. DECATUR, AL Estimated Total ~~ Estimated % Annual Releases ~~ Accuracy of (Ibs. 1997) Estimate (optional) Water releases: 10,000 Number of days/year release occurs: Although manufacturing of the salts listed on this form is associated with 4 to 6 wastewater discharge events per year, the hydrolysis of other sulfonated compounds to PFOS in the wastewater treatment system result in an ongoing dischargeofthe PFOS compounds. The calculated discharge amount therefore is not attributed to just the salt production. Receiving Water Name: Baker's Creek at thejunction with the Tennessee River NPDES Number: ALD004023164 Comments COTTAGE GROVE, MN Estimated Total Estimated % Annual Releases ~~ Accuracy of (Ibs. 1997) Estimate (optional) Water releases: 1000 Numberofdays/year release occurs: 11 times per year Receiving Water Name: Mississippi NPDES Number: MN00001449 Comments: Engineering calculations were used to estimate the amount of material discharged to wastewater. The amountof 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 199%0,00.0'7 `CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-393, 29457-72-5 / 3M Company/ 7 Revised: 7/2000 C. ON-SITE LAND RELEASES DECATUR, AL The land treatmentofDecatur 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. Levelsofthe compound in the sludge were determined from wastewater data. Wastewater data from 1999 shows about 20,000 pounds per year to the sludge which is now landfilled offsite. Estimated Total ~~ Estimated % Annual Releases ~~ Accuracy of (Ibs. 1997) Estimate optional) Landfill Land Treatment/Land Amendment Surface Impoundments Underground Injection Other (specify): 9 40.000 -- No longer used N0o data available Comments: COTTAGE GROVE, MN Sludge from the Cottage Grove facility is sent to an off-site industrial landfill Estimated Total ~~ Estimated % Annual Releases Accuracy of (Ibs. 1997) Estimate options) Landfill Land Treatment/Land Amendment Surface Impoundments 00 Underground Injection 0 Other (specify): Comments: 000008 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 8 Revised: 7/2000 D. OFF-SITE TRANSFERS - Decatur, AL and Cottage Grove, MN (1997) Process wastewaters are managed in an on-site wastewater treatment facility and are not sent to the POTW. DL Transfer to Publicly Owned Treatment Works (POTW) Number of days/year the release occurs: Not applicable Annual Transfer (b): 0 Estimated % Accuracy of Transfer Estimate (optional) (%): POTW Name: CiSttrye:et Address: State: NPDES Number: Country: Zip Code: Comments: 000003 CAS Number 1763-23-1, 20081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 9 Revised: 7/2000 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 reviewofplant records regarding waste disposal locations for Decatur fluoride-containing (not CAS number specific) wastes indicates that 70% was disposed through incineration at various offsite locations and approximately 30% was landfilled at a hazardous waste landfill. Incineration is now the primary disposal method for these materials. Estimated Total ~~ Estimated % Annual Releases Accuracy of (ibs. 1997) Estimate options) Incineration: No specific CAS number data available. Wastewater Treatment 0 (Excluding POTW) 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 Comments: 000010 CAS Number 1763-23-1, Revised: 7/2000 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Company / 0 COTTAGE GROVE, MN Cottage Grove facility utilizes incineration for all their drummed wastes. does not show any drummed salt wastes in 1997. Waste summary Incineration: Estimated Total ~~ Estimated % Annual Releases Accuracy of (Ibs. 1997) Estimate pions) 0 Wastewater Treatment 0 (Excluding POTW) Underground Injection 0 Hazardous Waste (RCRA 0 Subtitle C) landfill Other Landfill 7400 Recycle or Recovery 0 Unknown or Other Comments: 000011 `CAS Number 1763-231, Revised: 7/2000 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y un VI. ON-SITE WORKPLACE EXPOSURE CAS Number: 2795-39-3 Cottage Grove, MN Company: 3M Company, Specialty Materials Manufacturing Division, (potassium perfluorooctane sulfonate) a`Tnhdistihnefmoargmnaititoundew,ilflraesqsuiesntcEyP, Aanidn dcuhraraatcitoenroifzipnogtetnhteianluemxbpeorsuorfe.woWrkheerns pprootveindtiinagl.ly exposed monitoring data, ensure that data is linked with worker activities described in question 2. 1. fEosrtiemaacthoeftthehenuemxpboesruorfewdourrkaetirosnptoitmeenst.ialIlfyaewxoprokseerd irsouitnivnoellvyedtointhmeosruebjtehcatnchoenmeical tachtainviotyn,cee.ntTehreontloytahlins/uhmebremrositn ttyhpeitcaabllaecstihvoiutlydineqtuhaeltatbhlee.totDaolnn'utmcboeunrtofawwoorrkkeerrsmore potentially exposed. [Foaa n omeo aw | Hours/Day Days/Year [ [= B= C1T 7r s T C [ = 1 s 1 17 1 e 1] ] 2. Dsaemspclriinbge,trheemroovuatilnoefwfoilrtkerercaakcet,ivaitnidesdtrouwmhmiicnhgthoef wlioqrukidesr,smiannquufeascttiuorne1aanrearetxipcolseeedt:c. pFaorrtitchuelsaetea,ctoirviatcierso,sodle,scetrci.b)eatnhde,pihfyisniacamlisxttautreeo,ftthheecshuebmjieccatl'cshecmoinccaelnt(rlaitqiuoidn,: gas, s`Tlhuerrcyh(ewmiitchailn a(2r7e9a5c-t3or9)-3a)ndisias tlihgehnt,tfrranesef-efrlroewdintgo dproywidnegr.eqIuniiptimaelnlyt, ftohrefmiantaelrpiraolciessasiwnegtand psaacmkpalgeisn,g.andTahlesoabpoavcekaegmepl(obyyegersavoipteyroartebaynhdamnadisnctoaoipnitnhge)ddrryyinpgowedqueirpfmernotm,tchoelldercytinqugality equipment into drums, pails, and cans. 000012 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-393, 29457-72-5 / 3M Compan/y 2 Revised: 7/2000 3. Provide industrial hygiene monitoring data, if available, with a brief descriptionof 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. See the attached table for personalair monitoring data. These samples were collected during operationofdrying equipment and packaging activities. Past sample collection and analysis has utilized 37-mm Nucleopore filter cassettes with either gravimetric, ICP (for K+), or LC analysis. The current method is an OSHA Versatile Sampler (OVS) tube analyzed by LC/MS. Wipe sample data for the chemical does exist and has indicated significant levels of this material on surfaces in the production area. The results were used for focusing decontamination and exposure control efforts. `There has been area/source air monitoring data and/or surface wipe sampling data collected for this material attheplant. Area/source sample results and/or surface wipe sample results are used to identify areas with employee exposure potential as part of the exposure assessment under 3M' industrial hygiene program and are not measurementsofactual employee exposures. Hence, they are not included with this submission. Prior to 1999, these samples were considered to be semi-validated. `The sample resultsofany air monitoring are compared to 3M's voluntary exposure guideline (EG) of 0.1 mg/m' (milligrams of fluorochemical compound per cubic meterofair) for PFOS homologues, such as FC-95. 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. 3's industrial hygiene program focuses on task-based exposure assessment and control. Exposures are identified and assessed qualitatively and/or quantitatively. Qualitative assessmentsare 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. PCeArSsHon2a7l95A-lr39M-o3ni(tpoortiansgsiRuemsupletrsfluorooctane sulfonate) En |To]Rc Classification ree | Concentration Standard || Deviation Operator [PotTePcahnnitc:ian (Sample Time mg/m3 Range: = CTT ER 17PartiT al Shi T 7 045 mT gm3 | 045T mgim3 | T NA NA 1 (S7a0mmpilneutTeism)e: 000013 `CAS Number 1763-23-1, Revised: 7/2000 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Company/ 5 4. Briefly describe chemical: the engineering controls used to minimize exposure to this nTehgeatdirvyeinpgreasnsdurpeaacnkdagfiinltgeraecdtievxithiaeussatrveecnotinltaatiinoen.d wLiotchailnesxmhaaluls-tromoamyebneclporseusreenstwith directly at the point of packaging. 5. pBrrieevfelnytleisxtptohseurpeerosfontahilspcrhoetmeicctailv:e equipment your workers regularly wear to cEhmepmliocyale-epsrowtoercktiivnegcwoivtehrianlltshe(Taybvoevke),smbaololt-croovoemrse,ncalnodsuglroevsesu.se airline respirators, Comments: ifdesired.) (This section is available to clarify the responses given. Attach additional pages 000014 CAS Number 1763-23-1, Revised: 7/2000 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 14 CAS Number: 1763-231 Cottage Grove, MN Company: 3M Company, Specialty Material Manufacturing Division, {Perfluorooctane sulfonic acid CAS No. 1763-23-1 a`Tnhdistihnefmoargmnatiitoundew,ilflraesqsuiesntcEy,PAanidn dchuarraatcitoenriozfipnogtetnhteianluemxbpeorsourfe.woWrkheerns pportoevnitdiianllgy exposed `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. Ifa 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 [<2 [250 [8 C= Days/Year <10 10-100 100-250 >250 7 1 T T 6| T ] 1m [TT 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 formulation containing 1763-23-1 is a clear colorless liquid solution (32-38% concentration). Employee activities include operation and maintenance of process equipment, product quality sampling and drumming as an intermediate or final product liquid solution containing 1763-23-1. 000015 CAS Number 1763-23-1, Revised: 7/2000 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Company / 15 3. Provide industrial hygiene monitoring data, if available, with a brief 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 assessmentofpotential 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 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 used at product container openings during container filling. 5. Briefly list the personal protective equipment your workers regularly wear to prevent exposureof this chemical: Employees wear PVC jackets and pants, neoprene gloves, and face shield and chemical splash goggles for containerizationof solutions containing 1763-23-1. Comments: (This section is available to clarify the responses given. Attach additional ages if desired.) 000016 (CAS Number 1763-231, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Company / 16 Revised: 7/2000 CAS Number: 70225-14-8 Company: 3M Company, Specialty Materials Manufacturing Division, Cottage Grove, MN ChemicalName Diethanolamine saltofperfluorooctane sulfonate [CASNa. | 0225-14-8 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. Ifa 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 numberofworkers potentially exposed. `Hours/Day | <10 10100Days/YeaTr0050 5250 Cs=er1= 7 1| 1 CC s1 1 a 1 1 | 2. Dexepsocsreidb:e tshaemrpoluitnign,erweomrokvearl aocftifviltriescatkoew,haincdh dthreuwmomriknegrsofinliqquueisdst,ion 1 are 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 product is a clear, light colored solution containing 19-23% 70225-14-8. This `material is a salt with a very low vapor pressure, which is not typically handled dry. `Employee activities include operation and maintenanceofprocess equipment, product quality sampling and drumming of final liquid solution containing 70225-14-8. 000017 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 1" Revised: 7/2000 3. Provide industrial hygiene monitoring data, ifavailable, 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 assessmentof 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 staffand 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: Local exhaust ventilation used at product container openings during packaging. 5. Briefly list the personal protective equipment your workers regularly wear to prevent exposure of this chemical: Employees wear PVC gloves and chemical splash goggles for containerization of product. Comments: (This section is available to clarify the responses given. Attach additional pages if desired.) 000018 `CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-393, 29457-72-5 / 3M Compan/y 18 Revised: 7/2000 CAS Number: 29081-56-9 Company: 3M Company, Specialty Materials Manufacturing Division, Cottage Grove, MN. Ammonium perfluorooctane sulfonate 9081-560 This information will assist EPA in characterizing the number of workers potentially exposed and the magnitude, frequency, and durationofpotential 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 Days/Year [oCss m 1f 11 ] <10 10-100 100-250 >250 C we 1 1 11 e ] 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 ofthe subject chemical (liquid, gas, particulate, or aerosol, etc.) and, if in a mixture, the chemical's concentration: "The chemical formulation containing 29081-56-9 is a clear amber solution (19-23% concentration). This material is a salt with a very low vapor pressure, which is not typically handled dry. Employee activities include transferring wet slurry to filter `press, operating filter press, transferring filter cake to reactor, and drumming final liquid solution containing 29081-56-9. The above employees also operate and `maintain process equipment and collect quality samples. 000019 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 1 Revised: 7/2000 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 arealsource monitoring data for this specific material at this facility. For most areas of the facility, recent qualitative assessmentofpotential 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 staffand 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 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 available at the filter press, at the reactor opening and at the product container openings. 5. Briefly list the personal protective equipment your workers regularly wear to prevent exposure of this chemical: Employees wear PVCjackets and pants, neoprene gloves, and chemical splash. goggles. Half mask dust-mist respirators are used for handlingofwet filter cake. Comments: (This section is available to clarify the responses given. Attach additional pages if desired.) 000020 (CAS Number 1763-231, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 20 Revised: 7/2000 CAS Number: 20457-72-5 Company: 3M Company, Specialty Materials Manufacturing Division, Cottage Grove, MN (ChiemiealName ithium perfluorooctane sulfonate [CASNo._| 9357-725 `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. Ifa 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 Days/Year Cs 1-- <10 71 1 10-100 1 100-250 >250 1 C [ ee= [1 17 e 1 [= 1|] C= 11 T-- 71 1 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 formulation containing concentration). This material is a salt 29457-72-5 with a very is a low clear vapo a r mber solution (24-26% pressure, which is not typically handled dry. Employee activities include operation and maintenance of process equipment, product quality sampling and drumming of final liquid solution `containing 29457-72-5. 000021 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Company / 2 Revised: 7/2000 3. Provide industrial hygiene monitoring data, if available, with abrief 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 arealsource monitoring data for this specific material at this facility. For most areas of the facility, recent qualitative assessmentofpotential exposure to this material under 3M' 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 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 used at product container openings during packaging. 5. Briefly list the personal protective equipment your workers regularly wear to prevent exposure of this chemical: Employees wear PVCjackets, neoprene gloves, and chemical splash goggles for containerizationof product. Comments: (This section is available to clarify the responses given. Attach additional pagesif desired.) 000022 (CAS Number 1763-231, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Company / 22 Revised: 7/2000 (CAS Number: 2795-39-3 Company: 3M Company, Specialty Materials Manufacturing Division, Decatur, AL C[ hemCNaA me SNa._| Potassium perfluorooctane sulfonate P795-39-3 Sesion. 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 1 Estimate the number of workers potentially exposed routinely to the subject chemical for each of the exposure duration times. If a workeirs 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 numberof workers potentially exposed. Hours/Day Days/Year C o -- 1 r T 1m 1 || <10 10-100 100-250 >250 Cs s1[ r 1 1 2. Describe the routine worker activities to which the workers in question 1 are exposed: sampling, removalof 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 chemicals concentration: `The chemical (2795-39-3) is in an aqueous solution (ca. 25%). Employees operate and `maintain the production equipment and collect quality samples. Material is produced, stored, and metered into product container in a closed system. 000023 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 2 Revised: 7/2000 3. Provide industrial hygiene monitoring data, if available, with abriefdescription of the sampling method and exposure scenario monitored, e.g, deseribe 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 submited 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 assessmentof 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 data available. 4. Briefly describe the engineering controls used to minimize exposure to this chemical: Enclosed process. 5. Briefly list the personal protective equipment your workers regularly wear to prevent exposure of this chemical: Employees use safety glasses and neoprene gloves. Comments: (This section is available to clarify the responses given. Attach additional pages if desired.) 000024 (CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Company / 24 Revised: 7/2000 CAS Number: 1763-23-1, 29081-56-9, 29457-72-5, 70225-14-8 Company: [Perfluorooctane sulfonic acid Ammonium perfluorooctane sulfonate [Cithium perfluorooctane sulfonate [Diethanolamine saltof perfluorooctane sulfonate CAS No. 1763-23-1 [29081-56-9 p9457-725 70225-14-8 3M --Decatur, AL Noneofthese materials are manufactured at 3M-Decatur. 000025 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-393, 20457-72-5 / 3M Compan/y 2 Revised: 7/2000 VIL. CHEMICAL END USES A. END USE AS AN INTERMEDIATE CONSUMED TO MAKE OTHER CHEMICALS AL On-Site Use as a Intermediate: CAS #1763-23-1 Perfluorooctane sulfonic acid is used as an intermediate while the salts are not used as intermediates. The perfluorooctane sulfonate salts are only used as finished products. Product chemical class or product chemical (Include CAS number if appropriate) %of total* volume of subject chemical manufactured or imported 1. Fluorochemical trivalent chromium 15 compound 2. Perfluorooctane sulfonate salt 15 *As reported in Part III, p.2 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 Not Applicable *As reported in Part IIL, p.2 000026 (CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Company / 26 Revised: 7/2000 B. END USES OTHER THAN AS A CONSUMED INTERMEDIATE `The following two tables present a summaryofthe information contained in VILB regarding uses of perfluorooctane sulfonic acid and its salt forms. `Table 1 details the end applications in which a particular CAS Number is used. For each CAS Number, the % used in each application totals to 100%. Table 1. CAS Number by Application 2795-393 29457-72-5 70225-14-8 T. Film former in Fire Fighting Foams 2. Mist suppressant for acid baths in metal plating factories 3. Surfactant in acid etching processes for productionofcircuit boards T. 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 productionofcircuit boards 5. Registered active ingredient for insect control. Used in formulations used in bait traps T. Emulsifier in commercial floor polishes 2. Mist suppressant for acid baths in metal plating factories 3. Surfactant in acid etching processes for productionofcircuit boards boards "Table 2 details the multiple CAS Numbers which may be used in any one application. Table 2. Application by CAS Number 2795-39-3 "Mist suppressant for acid baths in metal plating factories 29457-72-5 70225-14-8 2795-393 "Surfactant in acid etching processes for production of circuit 29457-72-5 `boards 70225-14-8 o[raocmemmesiens| 29081-56-9 29457-72-5 Emulsifier in commercial floor polishes 29457-72-5 Rfoergmiusltaetrieodnasctuisveediinngrbeaditietnrtapfsor insect control. Used in . 000027 `CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 27 Revised: 7/2000 CAS Number 2795-39-3, Potassium perfluorooctane sulfonate Use Number 1 of3 Description ofChemical End Use: Chemical used as film former which is blended into fire fighting foams. These products are designed for primary use by fire fighting professionals. Percentoftotal manufactured or imported Volume going to this use: 92+ 2 Check all physical formsofthe chemical during this use: Ifused in a mixture check appropriate box To indicate weight fraction. Average Valuesareacceptable: LX <1% (600-1200 ppm) 1% 30.60% 60-90% 90% __ Aerosol __ DryPowder Pellets or large crystals Water or solvent-- wet solid --_ Gasorvapor X_ Liquid solution "Other (Explain) Use Number 2 of3 Description ofChemical End Use: Metal plating factories use this chemical to suppress oxidizing acid mist in order to protecttheir workers' health. Percentof total manufactured or imported Volume going to this use: 6+ 2 Check all physical formsofthe chemical during this use: Ifused in a mixture check appropriate box To indicate Weight fraction. Average Values are acceptable: _X_ <1%(1000 ppm) 130% 30.60% 0600-%90% __ Aerosol __ DryPowder Pellets or large crystals Water or solvent ~ wet solid -- Gasorvapor X_ Liquid solution Other (Explain) 000028 CAS Number 1763-23-1,29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Company / Ed Revised: 7/2000 Use Number 3 of3 Description of Chemical End Use: Electronic factories add this chemical as a surfactant to improve the wettingof strong acids used in the etchingofprecise patterns in a silicon water or a printed circuit board. Percentoftotal manufactured or imported Volume going to this use: 2+ 0.5 Check all physical formsof the chemical during this use: Ifused in a mixture check appropriate box To indicate Weight fraction. Average Values are acceptable: _X_ <1%(<1000 ppm) 130% 30-60% J om __ Aerosol Dry Powder Pellets or large crystals Wateror solvent ~ wet solid _ Gasorvapor X_ Liquid solution Other (Explain) 000029 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 2 Revised: 7/2000 CAS Number 29457-72-5, Lithium perfluorooctane sulfonate Use Number 1 of 5 DescriptionofChemical End Use: Chemical formulators use this chemical as a surfactant to improve the wettingofwater-based products that are sold as alkaline cleancrs. These cleaners are then diluted and sold to the consumer or contract cleaner. Percentof total manufactured or imported Volume going to this use: 23.5% 0.5 Check all physical formsofthe chemical during this use: ITfousienddiciantae mWiexitguhrte fcrhaectcikona.ppArvoperriaagtee box Values are acceptable: X_ <1% (30 ppm) 130% 30.60% -- 60-90% so0% __ Aerosol __ DryPowder Pellets or large crystals Water or solvent-- wet solid __ Gasorvapor X_ Liquid solution Other (Explain) Use Number 2 of 5 Description of Chemical End Use: Metal plating factories use this chemical as a surfactant to suppress oxidizing acid mist in ordetro protect their workers" health. Percentoftotal manufactured or imported Volume going to this use: 1 1 Check all physical formsofthe chemical during this use: If used ina mixture check appropriate box To indicate Weight fraction. Average Values are acceptable: _X_ <1% (30-50 ppm) 130% 3060% 60-90% 0% __ Aerosol __ DiyPowder Pellets or large crystals Water or solvent ~ wet solid __ Gasorvapor X_ Liquid solution Other (Explain) 000030 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 30 Revised: 7/2000 Use Number 3 of 5 Description ofChemical End Use: Electronics factories add this chemical as a surfactantto improve the wettingofstrong acids used in the etchingofprecise patterns ina silicon water or a printed circuit board. Percentof total manufactured or imported Volume going to this use: 1+ 1 Check all physical formsof the chemical during this use: Ifused in a mixture check appropriate box To indicate Weight fraction. Average Values are acceptable: _X_ <1% (30-50 ppm) 130% 3060% 60.90% -- __ Aerosol Dry Powder Pellets or large crystals Water or solve--wnett solid. __ Gasorvapor X_ Liquid solution Other (Explain) `Use Number 4 of Description of Chemical End Use: Chemical formulators use this chemical as a surfactant to improve the wetting ofwater-based products that are sold as commercial floor polishes. Percentof total manufactured or imported Volume going to this use: 23.5% 0.5 Check all physical formsof the chemical during this use: Ifused in a mixture check appropriate box To indicate Weight fraction. Average Values are acceptable: X_ <1%(15 ppm) 13% 3060% ZZ 6090% 00% __ Aerosol __ DryPowder Pellets or large crystals _ GWaatseorrvorapsoolrvent ~ wet solid X_ Liquid solution Other (Explain) 000031 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y a Revised: 7/2000 Use Number Description 5 of 5 of Chemical End Use: Chemical formulators use this chemical as a registered active ingredient for insect control. It is blended with bait that is attractive to insects and placed in bait stations. Either commercial facilities or consumers can use these bait stations. Percentof total manufactured or imported Volume going to this use: 53+ 0.5 Check all physical formsofthe chemical during this use: Ifused in a mixture check appropriate box To indicate Weight fraction. Average Values are acceptable: xX <a% 130% 30-60% 60-90% 0% __ Aerosol __ DryPowder Pellets or large crystals Water or solve--wnett solid. __ Gasorvapor X_ Liquid solution Other (Explain) 000032 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-393, 29457-72-5 / 3M Company / 2 Revised: 7/2000 CAS Number 29081-56-9, Ammonium perfluorooctane sulfonate Use Number 1 of 1 Description of Chemical End Use: Electronics factories add this chemical as a surfactant to improve the settingofstrong acids used in the etchingof precise patterns ina silicon wafer or a printed circuit board. Percent of total manufactured or imported Volume going to this use: 100 Check all physical forms of the chemical during ths use: TIfousienddiciantae mWiexitguhrte fcrhaectcikona.ppArvoperriaagtee box Values are acceptable: LX <1% (~100 ppm) 10% 30.60% 60-90% ow __ Aerosol "Dry Powder Pellets or large crystals T Wateror solvent ~ wet solid --_ Gasorvapor X_ Liquid solution Other (Explain) 000033 CAS Number 1763-23-1, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 3 Revised: 7/2000 CAS Number 70225-14-8, Diethanol amine perfluorooctane sulfonate Use Number 1 of 3 Description of Chemical End Use: Chemical formulators use this chemical as a surfactant to improve the emulsificationof materials used in commercial and consumer floor polishes. Percentoftotal manufactured or imported Volume going to this use: 35+ 2 Check all physical formsofthe chemical during this use: TIfousineddiciantae mWiexitguhrtefcrhaectcikona.ppArvoperriaagtee box Values are acceptable: X_ <1% (~15 ppm) 10% 30.60% J 0% __ Aerosol __ DryPowder Pellets or large crystals Water or solvent ~ wet solid __ Gasorvapor X_ Liquid solution Other (Explain) Use Number 2 of 3 Description of Chemical End Use: Metal plating factories use this chemical to suppress. oxidizing acid mist in order to protect their workers" health. PVeorlcuenmteogfotiontgaltmoatnhuisfaucset:ur4e8d.o5r+im3ported Check all physical formsofthe chemical during this use: Ifused in a mixture check appropriate box To indicate Weight fraction. Average Values are acceptable: X_ <1% (~100-1000ppm) 3103.06%0% 60-90% 00% __ Aerosol __ DryPowder Pellets or large crystals Water or solvent ~wet solid. -- Gasorvapor X_ Liquid solution Other (Explain) 000034 `CAS Number 1763-231, 29081-56-9, 70225-14-8, 2795-39-3, 29457-72-5 / 3M Compan/y 34 Revised: 7/2000 Use Number 3 of 3 Description of Chemical End Use: Electronic factoriesaddthis chemical as a surfactant to improve the wettingof strong acids used in the etchingofprecise patterns in a silicon water or a printed circuit board. Percentof total manufactured or imported Volume going to this use: 16.5% 2 Check all physical formsofthe chemical during this use: ITfousienddiciantae mWiexitguhrte fcrhaectcikona.ppArvoperriaagtee box Values are acceptable: _X_ <1% (~100-1000 ppm) 130% 30.60% 090% 0% __ Aerosol Dry Powder Pellets or large crystals "Water or solvent ~ wet solid T_ Gasorvapor TX Liquid solution Other (Explain) 000035