'
CASNumber
335­
67­
1,
3825­
26­
1,
335­
95­
5
3M
Company
6/
8/
2000
Voluntary
Use
and
Exposure
Information
Profile
Perfluorooctanoic
Acid
and
Salts
I.
CHEMICAL
IDENTIFICATION
Chemical
Name:
CAS
Number:
Perfluorooctanoic
Acid
&
Salts
Various,
including:
335­
67­
l
(acid)
3
825­
26­
1
(ammonium
salt)
335­
95­
5
(sodium
salt)

II.
COMPANY
IDENTIFICATION
Company
Name:
3M
Site
Locations:
10746
Innovation
Road
Cottage
Grove,
MN
55016
2)
1400
State
Docks
Road
Decatur,
AL
3
560
1
Technical
Contact:
W.
A.
Weppner
Phone:
6511733­
6374
Address:
3M
Center,
Building
236­
l
B­
10
St.
Paul,
MN
55144
III.
ON­
SITE
ACTIVITIES
#
CAS
335­
67­
l
3825­
26­
l
335­
95­
5
I
&
(1997)
Imported
(1997)

Less
Than
Less
than
1
,
100,000
lb/
yr.
200,000
lbs.

Estimate
the
amount
of
subject
chemical
distributed
off­
site:
48.5%

3
'
CA$
Number
335­
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26­
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3M
Company
6/
g/
2000
Narrative
DescriDtion
and
Process
Flow
Schematic:

Perfluorooctanoic
acid
and
its
salts
are
produced
from
perfluorooctanoyl
fluoride
that
has
been
synthesized
via
the
Simons
Electra
Chemical
Fluorination
(ECF)
process.
The
starting
feedstock
is
octane
chloride.

C7H1&
OC1
+
16HF
­em
­
­
­­
­
­>
cgF~$
oF
+
1
5H2
+
HCl
ECF
Perfluorooctanoyl
fluoride
is
not
itself
a
commercially
viable
product,
but
is
100%
used
as
an
on­
site
intermediate
in
the
manufacture
of
perfluorooctanoic
acid
(PFOA)
and
the
salts
of
the
acid.
The
PFOA
is
manufactured
by
base
hydrolyzing
the
perfluorooctanoyl
fluoride
to
the
corresponding
octanoic
acid
in
batch
reactors.
The
salts
are
manufactured
by
base
neutralization
of
the
acid
to
the
salt
in
a
separate
reactor.

The
following
block
flow
diagram
describes
the
process
discussed
above.

BLOCK
FLOW
DIAGRAM
FOR
PERFLUOROOCTANOIC
ACID
(PFOS)

Electra­
Chemical
Fluorination
Cells
(Octanoyl
chloride
+
HF
+
electrical
energy)

I
Perfluorooctanoyl
fluoride
I
y
Secondary
Reactors
Treatment
with
Strong
Base
and
Acid
I
*
Perfluorooctanoic
acid
I
and
various
salts
I
'
CASNumber
335­
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3M
Company
6/
g/
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
of
a
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
with
respect
to
fluorochemicals
because
fluorochemical
losses
were
not
always
included
in
the
analysis
of
each
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
of
these
compounds
cause
them
to
behave
differently
from
conventional
compounds,
and
physical
chemical
data
properties
are
not
available
for
all
intermediate
reaction
steps.

Production
of
perfluorooctanoyl
compounds
began
in
Decatur
in
1999.
In
prior
years
Decatur's
emissions
result
from
byproduct
formation.

A.
ON­
SITE
AIR
RELEASES
ALL
PLANTS
­
Fugitive
emissions
may
occur
from
vacuum
charging
from
drums,
sampling
from
reactors,
drumming
of
product/
intermediate,
flaking
monomer,
drying
operations.
Materials
may
be
handled
in
a
molten
or
solid
state;
vapors
are
produced
from
molten
material.

Industrial
Hygiene
monitoring
has
been
conducted
for
some
compounds.
Some
minor
amounts
of
these
compounds
have
been
detected
as
fugitive
emissions
during
industrial
hygiene
exposure
testing.

DECATUR,
ALABAMA
ONLY:

Wastewater
fugitive
emission
data
was
based
upon
1999
wastewater
testing.

Fugitive
emissions
may
have
occurred
during
some
handling
steps
but
have
not
been
quantified.
'
CAS'Number
335­
67­
1,3825­
26­
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3M
Company
6/
S/
2000
Decatur,
AL
Estimated
Total
Annual
Releases
(Ibs.
1999)
Estimated
%
Accuracy
of
Estimate
(optional)
#
days/
years
release
occurs
Fugitive
­
wastewater
<l
in1999
250
Stack
(point)

Engineering
calculations
and
models
of
process
vent
emissions
are
used
for
estimates
of
point
source
emissions.

Estimated
Total
Annual
Releases
(lbs.
1997)
Estimated
%
Accuracy
of
Estimate
(optional)
#
days/
years
release
occurs
PFOA
compounds
No
data
available
Cottage
Grove,
MN
Emissions
estimates
are
from
process
engineer's
estimates
and
emission
models.

Estimated
Total
Annual
Releases
(Ibs.
1997)
Estimated
%
Accuracy
of
Estimate
(optional)
#
days/
years
release
occurs
Fugitive
(non­
point)
No
data
available
Stack
(point)

PFOA
compounds
Comments:
1950
6
100­
200
'
CAS'
Number
335­
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1,3825­
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3M
Company
6/
8/
2000
B.
WATER
RELEASES
FROM
SITE
Decatur,
AL
The
data
presented
was
determined
during
wastewater
testing
conducted
during
1998­
l
999.

Production
of
perfluorooctanoyl
compounds
began
in
Decatur
in
1999.
In
prior
years
Decatur's
emissions
result
from
byproduct.

Estimated
Total
Estimated
%
Annual
Releases
Accuracy
of
(total
annual)
Estimate
(optional)

Water
releases:
<
30,000
Number
of
days/
year
release
occurs:
Releases
are
estimated
at
250
days
per
year
Receiving
Water
Name:
Baker's
Creek
at
the
junction
with
the
Tennessee
River
NPDES
Number:
ALD004023
164
Comments:

Cottage
Grove,
MN
Engineering
calculations
were
used
to
estimate
the
amount
of
material
discharged
to
wastewater.
The
amount
of
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
1998.

Estimated
Total
Annual
Releases
(lbs.
1999)
Estimated
%
Accuracy
of
Estimate
(optional)

Water
releases:
<
15,000
Number
of
days/
year
release
occurs:
100­
200
Receiving
Water
Name:
Mississippi
NPDES
Number:
MN0000
1449
Comments:

7
'
CAiNumber
335­
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6/
8/
2000
C.
ON­
SITE
LAND
RELEASES
Decatur,
AL
The
land
treatment
of
Decatur
sludge
was
discontinued
in
mid­
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.

Levels
of
PFOA
in
the
sludge
were
determined
from
wastewater
data.

Estimated
Total
Annual
Releases
(lbs.
1997)
Estimated
%
Accuracy
of
Estimate
(optional)

Landfill
Land
Treatment/
Land
Amendment
Surface
Impoundments
Underground
Injection
Other
(specify):
0
~500
­
No
longer
used
No
data
available/
No
longer
used
0
Comments:

D.
OFF­
SITE
TRANSFERS
Decatur.
AL
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:

Annual
Transfer
(lb):
0
Estimated
%
Accuracy
of
Transfer
Estimate
(optional)
(%):

POTW
Name:
Street
Address:
City:
Country:
State:
Zip:
NPDES
Number:
Not
Applicable
Comments:
'
CAiNumber
335­
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1,3825­
26­
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3M
Company
6/
8/
2000
Cottage
Grove,
MN
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:

Annual
Transfer
(lb):
0
Estimated
%
Accuracy
of
Transfer
Estimate
(optional)
(%):

POTW
Name:
Street
Address:
City:
Country:
State:
Zip:
NPDES
Number:
Not
Applicable
Comments:

9
,,.._.,_"
CAS
Number
335­
67­
1,
3825­
26­
1,335­
95­
5
3M
Company
6/
8/
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
review
of
1998
plant
records
regarding
waste
disposal
locations
for
Decatur
fluoridecontaining
(not
CAS
number
specific)
wastes
indicates
that
70%
was
disposed
through
incineration
at
various
off­
site
locations
and
approximately
30%
was
landfilled
at
a
hazardous
waste
landfill.
Incineration
is
now
the
primary
disposal
method
for
these
materials.

Estimated
Total
Annual
Releases
(Ibs.
1997)
Estimated
%
Accuracy
of
Estimate
(optional)

Incineration:

Wastewater
Treatment
(Excluding
POTW)
No
specific
CAS
number
data
available.

0
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
0
Comments:

/O
'
CA$
Number
335­
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3M
Company
6/
8/
2000
Cottage
Grove,
MN
Cottage
Grove
facility
utilizes
incineration
for
all
their
drummed
wastes.

Sludge
from
the
Cottage
Grove
facility
is
sent
to
an
industrial
landfill.

Incineration:

Wastewater
Treatment
(Excluding
POTW)
Estimated
Total
Annual
Releases
(lbs.
1997)

4500
0
Estimated
%
Accuracy
of
Estimate
(optional)

Underground
Injection
Hazardous
Waste
(RCRA
Subtitle
C)
landfill
Other
Landfill
Recycle
or
Recovery
0
0
0
0
Unknown
or
Other
Comments:
CAS
Number
335­
67­
1,3825­
26­
l,
335­
95­
5
3M
Company
6/
S/
2000
1
0
VI.
ON­
SITE
WORKPLACE
EXPOSURE
CAS
Number
335­
67­
l
Company:
3M
Company.
Specialtv
Materials
Manufacturing
Division,
Cottage
Grove,
MN
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.
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
c.
25
.25­
l
1
­8
2
<lo
4
4
Days/
Year
10­
100
loo­
250
4
4
4
>250
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:

Molten
(ca
130F)
material
ranging
in
concentration
from
35­
75%
is
vacuum
charged
into
fractionation
equipment.
Various
concentrated
(ranging
up
to
100%)
molten
"fractions"
are
drummed
and
later
vacuum­
charged
to
other
process
equipment.
Other
exposure
opportunities
involve
quality
sampling,
process
area
cleanup,
and
maintenance
activities
(e.
g.,
changing
flange,
hose,
pipe,
valve,
filter,
pump
or
sight
glass).
CA$
Number
335­
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3M
Company
6/
8/
2000
1
1
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
area/
source
monitoring
data
for
this
specific
material
at
this
facility.
Recent
qualitative
assessment
of
potential
exposure
to
this
material
under
3M's
ongoing
industrial
hygiene
program
has
identified
significant
exposure
tasks,
and
appropriate
engineering,
administrative
and
personal
protective
equipment
controls
have
been
established.

Each
3M
plant
that
produces
fluorochemical
carboxylates
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.

4.
Briefly
describe
the
engineering
controls
used
to
minimize
exposure
to
this
chemical:

Materials
are
transferred
using
closed
piping
(where
possible)
from
reactor
vessels
to
other
containers.
Vacuum
charging
of
materials
from
drums
is
a
standard
practice.
Positionable
local
exhaust
ventilation
hoods
are
situated
at
significant
point
sources
such
as
at
drum
bangs
when
drumming.
General
room
air
provides
for
dilution
of
airborne
materials.

5.
Briefly
list
the
personal
protective
equipment
your
workers
regularly
wear
to
prevent
exposure
of
this
chemical:

Process
operating
standards
list
the
respirator
(e.
g.,
supplied
air,
half
mask
or
full
facepiece
organic
vapor
cartridge
with
particulate
prefilter,
or
particulate
filtering),
glove
by
elastomer
(e.
g.,
neoprene
or
nitrile),
chemical
protective
clothing
(e.
g.,
2­
piece
PVC
disposable
coveralls),
eye
protection
(e.
g.,
chemical
splash
goggles
with
or
without
full
faceshield
depending
on
type
of
respirator
used)
to
be
used
by
the
employee
when
the
task
involves
exposure
to
a
particular
fluorochemical
material.

Comments:
(This
section
is
available
to
clarify
the
responses
given.
Attach
additional
pages
if
desired.)

/3
CAS
Number
335­
67­
1,3825­
26­
l,
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5
3M
Company
6/
8/
2000
12
CAS
Number
335­
67­
l
Company:
3M
Company,
Specialty
Materials
Manufacturing
Division,
Decatur,
AL
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.
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.

)
H
o
u
r
s
/D
a
y
)
Days/
Year
<lo
10­
100
loo­
250
>250
c.
25
4
4
.25­
l
4
4
3
2
l­
8
4
~8
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:

This
material
is
a
solid
at
room
temperature
(melting
point
=
120
F)
which
is
drummed
as
a
molten
liquid
(concentration
35­
75%).
Other
exposure
opportunities
involve
quality
sampling,
process
area
cleanup,
and
maintenance
activities
(e.
g.,
changing
flange,
hose,
pipe,
valve,
filter,
pump
or
sight
glass).
Products
containing
335­
67­
l
at
concentrations
ranging
from
75%
to
100%
are
melted
and
added
to
process
reactors
as
raw
materials.

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
area/
source
monitoring
data
for
this
specific
material
at
this
facility.
Recent
qualitative
assessment
of
potential
exposure
to
this
material
under
3M's
ongoing
industrial
hygiene
program
has
identified
significant
exposure
tasks
and
appropriate
engineering,
administrative
and
personal
protective
equipment
controls
have
been
established.

Each
3M
plant
that
produces
fluorochemical
carboxylates
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
feasihle.

14
­._"­.
l
­l­~­_­­
.,
­
CAS
Number
335­
67­
1,3825­
26­
l,
335­
95­
5
3M
Company
6/
8/
2000
13
4.
Briefly
describe
the
engineering
controls
used
to
minimize
exposure
to
this
chemical:

During
draining
and
charging,
the
operators
use
local
exhaust
to
control
any
mists
or
vapors.

5.
Briefly
list
the
personal
protective
equipment
your
workers
regularly
wear
to
prevent
exposure
of
this
chemical:

The
required
PPE
for
draining,
charging
and
sampling
consists
of
respiratory
protection
(full
face
supplied
air
for
draining
and
organic
vapor
cartridge
respirators
with
P
100
prefilters
for
charging
and
sampling)
rubber
gloves
and
splash
resistant,
disposable
clothing.

Comments:
(This
section
is
available
to
clarify
the
responses
given.
Attach
additional
pages
if
desired.)
I
'

CAS
Number
33.5­
67­
1,3825­
26­
l,
335­
95­
5
3M
Company
6/
8/
2000
14
CAS
Number
3825­
26­
l
Company:
3M
Company.
Specialty
Materials
Manufacturing
Division,
Cottage
Grove,
MN
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.
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
c.
25
.25­
l
1
­8
>8
<lo
2
2
2
Days/
Year
10­
100
loo­
250
4
8
4
2
>250
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
material
(3825­
26­
1)
is
produced
in
a
slurry
form
and
close­
transferred
to
spray
drying
equipment.
The
powdered
product
(ca
100%
concentration)
is
drummed.
In
this
form
the
material
is
entrainable
as
an
airborne
dust.
It
is
also
hygroscopic.
The
powder
may
be
shipped
as
a
product
or
dissolved
in
water.
Drumming
powder,
transferring
powder
from
one
container
to
another,
and
dissolving
powder
in
water
represent
significant
inhalation
and
dermal
exposure
tasks.
Handling
the
material
dissolved
in
water
presents
mainly
dermal
exposure
potential.
Maintenance
activities
(e.
g.,
changing
flange,
hose,
pipe,
valve,
filter,
pump
or
sight
glass)
provide
additional
opportunity
for
mainly
dermal
exposure.

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
identiliers
such
as
a
worker's
name
or
social
security
number
with
any
data
submitted
to
EPA.

Personal
sampling
for
this
material
is
currently
(late
1999
to
present)
done
using
OSHA
Versatile
Sampler
tubes
with
XAD­
4
resin
and
mixed
cellulose
ester
or
glass
fiber
prefilter.
Sample
analysis
is
by
GC­
ECD.
See
attached
table
for
air
sample
results.

There
has
been
area/
source
air
monitoring
data
and/
or
surface
wipe
sampling
data
collected
for
this
material
at
the
plant.
Area/
source
sample
results
and/
or
surface
wipe
sample
results
are
used
to
identify
areas
with
employee
exposure
potential
as
part
of
exposure
assessment
under
3M's
industrial
hygiene
program
and
are
not
measurements
of
actual
employee
exposures.
Hence,
they
are
not
included
with
this
submission.
Prior
to
1999,
these
samples
were
considered
to
be
semi­
validated.
bAi
Number
335­
67­
1,3825­
26­
l,
335­
95­
5
3M
Company
6/
8/
2000
1
5
Surfaces
in
production
and
administration
areas
were
sampled
beginning
in
1994
and
most
recently
in
2000.
Results
indicated
the
presence
of
these
materials
on
floors
and
equipment
surfaces
in
production
areas.
This
resulted
in
improvements
to
Hazard
Communication
practices,
personal
hygiene
emphasis,
personal
protective
equipment
emphasis,
and
several
engineering
and
administrative
changes.

The
sample
results
of
any
air
monitoring
are
compared
to
the
ACGIH
TLV­
TWA
of
0.01
mg/
m3
[skin]
for
3825­
26­
l.

Each
3M
plant
that
produces
fluorochemical
carboxylates
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.
CAi
Number
335­
67­
1,3825­
26­
l,
335­
95­
5
3M
Company
6/
8/
2000
Exposure
Sample
Concentration
Geom
Exposure
Task
Number
3825­
26­
l
Yr­
Number
mg/
m3*
Minimum
Maximum
Geom
Std
mean
Dev
Manual
transfer
of
97­
075
32.1**
4.1
32.1
11.5
4.3
powdered
material
97­
076
4.1
Operate
spray
dryer
91­
001
0.04
0.001
0.04
0.009
6.8
92­
034
0.016
93­
017
0.001
Dissolving
powdered
98­
075
0.559
0.11
4
0.7
3.4
material
in
drums
98­
076
1.51
00­
7841
4
00­
7841
0.9
00­
7398
0.11
00­
7403
0.35
Operate
spray
dryer
sampling
product
Operate
spray
dryer
change
drums
98­
055
1.87
co.
002
1.87
0.91
2.8
95­
030
co.
002
98­
l
06
0.443
16
Operate
other
91­
003
0.04
0.004
co.
1
0.063
1.9
process
Washing
filters
95026
co.
1
*
All
exposure
concentrations
represent
task­
based
personal
samples.

**
The
TWA
exposure
concentration
was
11.4
mg/
m3.
This
was
a
one­
time
task
that
was
not
repeated.

4.
Briefly
describe
the
engineering
controls
used
to
minimize
exposure
to
this
chemical:

Materials
are
transferred
using
closed
piping
(where
possible)
from
reactor
vessels
to
other
containers.
Vacuum
charging
of
materials
from
drums
is
a
standard
practice.
Positionable
local
exhaust
ventilation
hoods
are
situated
at
significant
point
sources
such
as
at
drum
openings
when
drumming.
The
drumming
process
areas
are
enclosed
from
other
process
areas.
Facilities
have
been
established
for
employees
to
decontaminate
(doff
and
containerize
contaminated
chemical
protective
clothing,
remove
respiratory
protection
for
decontamination,
and
wash
hands
and
other
skin
surfaces
that
may
have
been
exposed)
after
performing
significant
powder
exposure
tasks.

A?
CA$
Number
335­
67­
1,3825­
26­
l,
335­
95­
5
3M
Company
6/
8/
2000
17
5.
Briefly
list
the
personal
protective
equipment
your
workers
regularly
wear
to
prevent
exposure
of
this
chemical:

Process
operating
standards
list
the
respirator
(e.
g.,
full
face
supplied
air
[for
exposures
up
to
1000x
OEL],
half
mask
[up
to
1
Ox
the
OEL]
or
full
facepiece
[up
to
50x
the
OEL]
organic
vapor
cartridge
with
P
100
particulate
prefilter),
glove
by
elastomer
(e.
g.,
neoprene
or
nitrile),
chemical
protective
clothing
(e.
g.,
2­
piece
PVC
or
plain
tyvekTM
disposable
coveralls),
eye
protection
(e.
g.,
chemical
splash
goggles
with
or
without
full
faceshield
depending
on
type
of
respirator
used)
to
be
used
by
the
employee
when
the
task
involves
exposure
to
a
particular
fluorochemical
material.

Comments:
(This
section
is
available
to
clarify
the
responses
given.
Attach
additional
pages
if
desired.)

Process
tasks
involving
exposure
to
3825­
26­
1
in
particulate
form
currently
require
rigorous
decontamination
using
decontamination
facilities
attached
to
process
areas.
3M
has
recently
(2000)
established
a
Biological
Limit
Value
of
5
ppm
for
perfluorooctanoate
anion
in
blood
serum.
Biological
monitoring
was
voluntary
in
1995
and
1997.
In
several
cases,
employees
with
higher
serum
levels
were
removed
from
further
exposure.
All
employees
with
potential
for
significant
exposure
to
3825­
26­
1,335­
67­
l,
or
335­
95­
5
are
required
to
participate
in
the
biomonitoring
program
to
work
in
such
areas.
CAS
Number
335­
67­
1,3825­
26­
l,
335­
95­
5
3M
Company
6/
g/
2000
1
8
CAS
Number
3825­
26­
l
Company:
3M
Company,
Specialty
Materials
Manufacturing
Division,
Decatur.
AL
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.
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
c.
25
.25­
l
1
­8
~8
40
Days/
Year
10­
100
loo­
250
52
>250
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:

This
material
is
added
by
vacuum
charge
or
poured
into
process
vessels
as
a
raw
material
in
aqueous
solution
(concentration
30%).
Exposure
is
primarily
via
skin
contact.
Other
exposure
opportunities
involve
quality
sampling,
process
area
cleanup,
and
maintenance
activities
(e.
g.,
changing
flange,
hose,
pipe,
valve,
filter,
pump
or
sight
glass).
Resultant
products
contain
0.5%
3825­
26­
l)
which
is
removed
(to
less
than
10
ppm)
by
subsequent
process
steps.

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
area/
source
monitoring
data
for
this
specific
material
at
this
facility.
Recent
qualitative
assessment
of
potential
exposure
to
this
material
under
3M's
ongoing
industrial
hygiene
program
has
identified
significant
exposure
tasks
and
appropriate
engineering,
administrative
and
personal
protective
equipment
controls
have
been
established.
CAS
Number
335­
67­
1,3825­
26­
l,
335­
95­
5
3M
Company
6/
8/
2000
19
Each
3M
plant
that
produces
fluorochemical
carboxylates
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.
CAS
Number
335­
67­
1,3825­
26­
l,
335­
95­
5
3M
Company
6/
8/
2000
20
4.
Briefly
describe
the
engineering
controls
used
to
minimize
exposure
to
this
chemical:

Positionable
local
exhaust
ventilation
hoods
are
situated
at
significant
point
sources
such
as
at
drum
openings
when
drumming.
General
room
air
provides
for
dilution
of
airborne
materials.

5.
Briefly
list
the
personal
protective
equipment
your
workers
regularly
wear
to
prevent
exposure
of
this
chemical:

Process
operating
standards
list
the
respirator
(e.
g.,
supplied
air,
half
mask
or
full
facepiece
organic
vapor
cartridge
with
P
100
particulate
prefilter),
glove
by
elastomer
(e.
g.,
neoprene
or
nitrile),
chemical
protective
clothing
(e.
g.,
2­
piece
PVC
disposable
coveralls),
eye
protection
(e.
g.,
chemical
splash
goggles
with
or
without
full
faceshield
depending
on
type
of
respirator
used)
to
be
used
by
the
employee
when
the
task
involves
exposure
to
a
particular
fluorochemical
material.

Comments:
(This
section
is
available
to
clarify
the
responses
given.
Attach
additional
pages
if
desired.)
CAS
Number
335­
67­
1,3825­
26­
l,
335­
95­
5
3M
Company
6/
g/
2000
21
CAS
Number
335­
95­
5
Company:
3M
Company.
Specialtv
Materials
Manufacturing
Division,
Cottage
Grove,
MN
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.
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
1
Days/
Year
<lo
10­
100
loo­
250
>250
c.
25
2
.25­
l
4
l­
8
>8
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:

This
material
is
produced
in
an
aqueous
solution
at
20%
concentration.
The
material
is
not
volatile
in
this
form
and
exposure
is
primarily
to
skin
during
sampling,
drumming
of
the
solution,
and
maintenance
activities.

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
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
for
this
material.
Nonetheless,
3M
has
identified
exposure
tasks
and
appropriate
engineering,
administrative
and
personal
protective
equipment
controls
have
been
established.

Each
3M
plant
that
produces
fluorochemical
carboxylates
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.
CA$
Number
335­
67­
1,3825­
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5
3M
Company
6/
8/
2000
22
4.
Briefly
describe
the
engineering
controls
used
to
minimize
exposure
to
this
chemical:

During
draining,
the
operators
use
local
exhaust
to
control
any
mists
or
vapors,

5.
Briefly
list
the
personal
protective
equipment
your
workers
regularly
wear
to
prevent
exposure
of
this
chemical:

The
required
PPE
for
sampling
and
draining
consists
of
rubber
gloves,
safety
glasses,
and
splash
resistant,
disposable
coveralls.

Comments:
(This
section
is
available
to
clarify
the
responses
given.
Attach
additional
pages
if
desired.)
`kA$
Number
335­
67­
1,3825­
26­
l,
335­
9.5­
S
3M
Company
6/
8/
2000
23
VII.
CHEMICAL
END
USES
A.
END
USE
AS
AN
INTERMEDIATE
CONSUMED
TO
MARE
OTHER
CHEMICALS
Al.
On­
Site
Use
as
a
Intermediate:

Product
chemical
class
or
product
chemical
(Include
CAS
number
if
appropriate)

1.
The
vast
majority
of
perfluorooctanoic
acid
(335­
67­
l)
is
consumed
to
make
the
ammonium
(3825­
26­
1)
or
sodium
salts
(3356­
95­
5)

2
.

3
.

4
.

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
50%

*As
reported
in
Part
III,
p.
2
%
of
total
volume
of
subject
chemical
manufactured
or
imported*

1.

2
.

3
.

4
.

*As
reported
in
Part
III,
p.
2
`CAS
Number
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3M
Company
6/
8/
2000
24
B.
END
USES
OTHER
THAN
AS
A
CONSUMED
INTERMEDIATE
The
following
two
tables
present
a
summary
of
the
information
contained
in
VI1.
B.

Table
1
details
the
end
applications
in
which
a
particular
CAS
Number
is
used.
For
each
CAS
number,
the
percent
used
in
each
application
totals
to
100%.

Table
1.
CAS
Number
by
Application
CAS
APPLICATION
NUMBER
335­
67­
l
335­
95­
5
3825­
26­
l
1.
Reactive
intermediate
for
synthesis
of
fluoroacrylate
ester
used
in
coating
applications
1.
Processing
aid
in
the
industrial
synthesis
of
fluoropolymers
and
fluoroelastomers
1.
Processing
aid
in
the
industrial
synthesis
of
fluoropolymers
and
fluoroelastomers
2
.
Post
Polymerization
aid
to
stabilize
fluoropolymer
and
fluoroelastomer
suspensions
3
.
Processing
aid
for
factory
applied
fluoropolymer
coatings
Table
2
details
the
multiple
CAS
Numbers
which
may
be
used
in
any
one
application.

Table
2.
Application
by
CAS
Number
CAS
NUMBER
335­
67­
l
335­
95­
5
3825­
26­
l
3825­
26­
l
APPLICATION
Reactive
intermediate
Processing
aid
for
fluoropolymer
and
fluoroelastomer
polymerizations
Post­
polymerization
aid
to
stabilize
fluoropolymer
and
fluoroelastomer
suspensions
3825­
26­
1
Processing
aid
in
coating
fluoropolymers
'
`CAb
Number
335­
67­
1,3825­
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Company
6/
8/
2000
25
CAS
Number
3825­
26­
1,
Ammonium
Perfluorooctanoate
Use
Number
1
of
3
Description
of
Chemical
End
Use:
Used
as
a
processing
aid
in
the
industrial
synthesis
of
fluoropolymers
and
fluoroelastomers
which
have
a
variety
of
industrial
and
commercial
uses.
These
fluoropolymers
and
fluoroelastomers
have
use
in
consumer
products.

Percent
of
total
manufactured
or
imported
Check
all
physical
forms
of
the
Volume
going
to
this
use:
98
f
1
.O
chemical
during
this
use:

If
used
in
a
mixture
check
appropriate
box
To
indicate
weight
fraction.
Average
Values
are
acceptable:

_zL
4
*
l­
30%
30­
60%
60­
90%
>90%
Aerosol
Dry
Powder
Pellets
or
large
crystals
Water
or
solvent
­
wet
solid
Gas
or
vapor
X
3­
Liquid
solution
Other
(Explain)
Asdry
coatings
on
metal
implements;
as
molded
parts;
as
fabricated
articles.

Use
Number
2
of
3
Description
of
Chemical
End
Use:
Used
as
post
polymerization
processing
aid
to
stabilize
fluoropolymer
and
fluoroelastomer
suspensions
prior
to
further
industrial
processing.

Percent
of
total
manufactured
or
imported
Volume
going
to
this
use:
1
f
0.5
Check
all
physical
forms
of
the
chemical
during
this
use:

If
used
in
a
mixture
check
appropriate
box
To
indicate
Weight
fraction,
Average
Values
are
acceptable:

x
4%
*
l­
30%
30­
60%
60­
90%
>90%
­
A
e
r
o
s
o
l
Dry
Powder
Pellets
or
large
crystals
Water
or
solvent
­
wet
solid
Gas
or
vapor
X
T
Liquid
solution
Other
(Explain)
Asdry
coating
on
metal
implements,
as
molded
parts,
as
fabricated
articles.

*<
0.5%
in
liquid
solution,
<O.
OOOl%
(1
ppm)
in
dry
coatings.
'
`CAS
Number
335­
67­
1,3825­
26­
l,
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95­
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3M
Company
6/
8/
2000
26
Use
Number
3
of
3
Description
of
Chemical
End
Use:
Used
as
processing
aid
for
factory
applied
fluoropolymer
coatings
on
fabrics,
metal
surfaces
and
fabricated
or
molded
parts.

Percent
of
total
manufactured
or
imported
Check
all
physical
forms
of
the
Volume
going
to
this
use:
1
*
0.5
chemical
during
this
use:

If
used
in
a
mixture
check
appropriate
box
To
indicate
Weight
fraction.
Average
Values
are
acceptable:

_1(_
cl%
*
l­
30%
30­
60%
60­
90%
>90%
Aerosol
Dry
Powder
Pellets
or
large
crystals
Water
or
solvent
­
wet
solid
x
Gas
or
vapor
­3c
Liquid
solution
Other
(Explain)
gcoating
on
metal
implements,
as
molded
parts,
as
fabricated
articles.

*<
0.5%
in
liquid
solution,
<O.
OOOl%
(1
ppm)
in
dry
coatings.
,

'
`CAi
Number
335­
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3M
Company
6/
8/
2000
CAS
#335­
95­
5
Sodium
Perfluorooctanoate
Use
Number
1
of
1
Description
of
Chemical
End
Use:
Used
as
a
processing
aid
in
the
industrial
synthesis
of
fluoropolymers
which
have
a
variety
of
uses
commercially
and
in
consumer
products.

Percent
of
total
manufactured
or
imported
Check
all
physical
forms
of
the
Volume
going
to
this
use:
100%
chemical
during
this
use:

If
used
in
a
mixture
check
appropriate
box
To
indicate
Weight
fraction.
Average
Values
are
acceptable:

_3(,
cl%
*
l­
30%
30­
60%
60­
90%
>90%
__
A
e
r
o
s
o
l
___
Dry
Powder
Pellets
or
large
crystals
Water
or
solvent
­
wet
solid
Gas
or
vapor
X
Liquid
solution
x
Other
(Explain)
As
dry
coating
on
metal
implements,
as
molded
parts,
as
fabricated
articles.

*<
0.5%
in
liquid
solution,
<O.
OOOl%
(1
ppm)
in
dry
coatings.
27
,

`CAS
Number
335­
67­
1,
3825­
26­
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95­
5
3M
Company
6/
8/
2000
28
CAS
#335­
67­
l
Perfluorooctanoic
Acid
Use
Number
1
of
1
Description
of
Chemical
End
Use:
Used
as
a
reactive
intermediate
in
the
industrial
synthesis
of
a
fluoroacrylic
ester.
This
latter
material
is
subsequently
used
in
an
industrial
coating
application.

Percent
of
total
manufactured
or
imported
Volume
going
to
this
use:
100%
Check
all
physical
forms
of
the
chemical
during
this
use:

If
used
in
a
mixture
check
appropriate
box
To
indicate
Weight
fraction.
Average
Values
are
acceptable:

1<_
cl%
l­
30%
30­
60%
60­
90%
>90%
__
A
e
r
o
s
o
l
Dry
Powder
Pellets
or
large
crystals
Water
or
solvent
­
wet
solid
Gas
or
vapor
L
Liquid
solution
Other
(Explain)

_­­..
.­
­
31)
