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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
February 25, 2000
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3M Company, Inc. Attn: William A Weppner, Ph.D. Director, Environmental, Health, Safety & Regulatory Affairs Specialty Materials Group 3M Center, Bldg. 236-1B-10 St. Paul, MN 55144
SUBJECT: 8EHQ-1180-00373; 8EHQ-1180-00374 Dear Dr. Weppner:
OFFICE OF
PREVENTION. PESTICIDES
AND TOXIC SUBSTANCES
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The EPA Office of Pollution Prevention and Toxics is requesting additional information on 3M's perfluoroalkyl submissions at this time.
With regard to 8EHQ-1180-00374, please clarify whether the composition of the test material FC-95 (a/k/a T-3351) is entirely potassium perfluorooctane sulfonate or a homologous mixture of potassium perfluoroalkylsulfonates, as in the case of the ammonium carboxylate mixture comprising FC-143 (8EHQ-0381-00394). In 8EHQ-1180-00374, the chemical identities of five homologs of "potassium salts of perfluoroalkyl sulfonates" were claimed TSCA Confidential Business Information (CBI). Since then, only the identity of the perfluorooctane homolog has been declassified. Does 3M wish to maintain its TSCA confidentiality claim for the other four chemicals. If so, please substantiate this claim.
Also, please provide the identity of the perfluoroalkyl alcohol tested in the rat teratology study reported in your 5/15/84 supplementary submission (8EHQ-0584-00373). In your initial 8(e) submission, the test material was reported to be a mixture of two perfluoroalkyl alcohols, but the 5/15/84 supplement refers to the1test material only as perfluoroalkyl alcohol.
EPA-OTS 000811778W
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Enclosed are the first pages of the submission referred to above and a copy of "Support Information for Confidentiality Claims". Please cite the assigned 8EHQ numbers and address your response to:
Document Control Office (7407) Room <399 East Tower Attn: Section 8(e) Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency 401 M Street, S.W. Washington, D.C. 20460-0001 Questions regarding this request should be directed to Mr. Terry O'Bryan of my staff at (202) 260-3483 or E-Mail OBRYAN.TERRY@EPA.GOV
Richard H. Hefter, Chief High Production Volume Chemicals Branch Enclosures
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