Sulforna2ed Perfluorochemieals in the Environment: Sources, Dispersion, Fate and Effects Prepared by 3M March 1,2000 1 Table of Contents . " . I .

1.0 PREFACE 4 2.0  XECUTIVE SUMMARY 5 3.0 INTRODUCTION TO FLUOROCHEMICALS 9 4.0 PWYSICALICHEMICAL PROPERTIES OF FLUOROCHEMICALS 5.0 ANALYTICAL TEST METHODS f OR FLUORUCHEMICALS 17 6.0 SOURCES OF FLUOROCH& UICALS 19 6.1 Manufaetaring Waste Streams 6.1 1 Waste Stream Cbmcteriza~ oon 6.12 Air 6.13 Wastcwatcr 6.14 Solid Waste 20 22 22 22 23 6.2 Supply Chain Waste Streams 24 6.3 Releases from Waste Treatment and DhposaI Methods 24 7.0 ENVIRONMENTAL TRANSPORT AND DISTRIBUTION .25 8.0 ENVIRONMENTAL` SAMPLING FOR FLUOROCHEMICALS d. 1 Environmental Leveb 8.1 1 Historical Data 8. f 2 Recent Analyses of Wild Birds and Fish 8.13. Testing of Fishmeal Used in Rat Studies 8.14 Plant Site Analyses 8.15\  3iosphere Sampling 27 27 ` 27 27 31 3' 1 32 8.2 Human Expoanre Levels 8.21 Mdti cities Sampling 8.22 Carpet Use Studies 8.23 Paper and Packaging Studies 8.24. Exposure ScGnarios 32 . 33. 33 33 33 2 ,

9.0 ENVIRONMENTAL . T ~ N S F O ~ A ~ ~ N I D E G ~ D A T I O N OF FLUOROCHEMICALS 34 36 9.1 HydroIyshr Studies 9.2 Photo ysis 37 9.3 Atmospheric Studia ,_ 37 9.4 Biodmdatioa Studks 9.41 Microbid Studies 00 Pdluorochwnicals 9.42 Biological TrrursformatiOn 9.43 Optimizing Conditions for Biodegradation 38 38 39 39 10.0 ECOTOXiClN TESTlNG OF FLUOROCHEMICALS .40 11.0 COMPREHENSIVE PLAN TO ASSESS ENVIRONMENTAL EXPOSURE ,' 45 11.1 Ptan Overview 45 11.2 Component 1: Characterize Fate and Transport Properties 48 48 11.3 Component 2: Estimate Releases 11.4 COUI~ PUCIIL 3: Chrnslrrkcl: Dktrlbullun In the Environment 48 11.5 Component 4: Estimate exposun!

12.0 ECOTOXJCITY PETERMJNATIONS 13.0 ECOLOGICAL RISK EVALUATION 14.0 REFERENCES 3 49'

49 50 51 1 0 Preface \

This paper provides an overview of 3M's c m t knowledge about the sources, dispersion, fate and effects of some of its fluorinated chemical products. It specifically addresses sulfoaated perfluoronated chemistry and products, with the major focus on those compounds with an eight carbon chain structure. There are other fluonhated chemical products but these are not covered in this white paper.

The paper presents the past testing nf these chemicals for environmentally relevant properties aud assesses the quality and adequacy of past testing. It also presents recent results of environmental sampling, estimates of quantities of wastes generated at manufacturing plantti and timom produd UJC, and XICW data 011 physical, chcmicd and ecotoxicological piroperties of sulfonated perfluomhemicals. It describes in detail the comprehensive exposure assessment plan currently being hpkmentted. This plan is aimed at providing a better understanding of the transport, hte and effects of these chemicals in the envirommnt and will helR the company determine appropriate @ me actions.

, As these studies return data, test plans will be revised to incorporate new Wormation. For this reason. the results of present testing should be treated cau~ ously Some data represent first attempts at characterization of complex chemicals in very difEcult and dynamic environmental test matrices. The program incorporates new analytical technology, domplex models and many variables. Thoso initid finding3 aru subjcct to change as results fitom cunrently planned testing on degradation, biological receptors, wastes from manufacturing facilities and other exposure data are obtained.

This paper shouId be read in conjmcdon with previous submittals about the health and environmental issues associated with 3M's sulfonated perfluorochedd product line. In January 1999,3M submitted to the Environmental Protection Agency (  ? PA) a report, Perfluorooctane Sulfonate: Current Summary of Kman Sera, Health d'Toxicology:  Datz that provided details of analyses of pool4 hlfnnd s m samptes that demonstrated the presence of perfluomoctane sulfonate ( PFOS) at very low levels. Jn February 1999,3M provided a comprehensive review, The Science of Organic Fluorochemistry, describing the health effccts and backepund chemistry atisociated with PFOS. hotha report submitted to EPA in May 1999, Fluorochemical Use, Didbution, and Release Overview, describes how 3M produces sulfonated perfluorochemicals, which product iines incorporate them, and the uses for these products. Finally, various Section 8( e) \

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submissions have been f o d e d to EPA relative to these sulfonated perfIuorochemicals.

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............... ____, . . . . . . . . . 4 ... . . . . . ! . . IIL . L ...... . i I 2.0 Executive Summary 3M produces sulfonated perfluorochemicals by an electrochemical fluorination process. This process creates a complex and variable mix of chemicals in which fluorine atoms replace hydrogen atoms on the organic feedstock and carbon carbn bon& are rearranged. Because of the carborkdluorine bond formed by this process, the compounds created are considered to be very stable. Perfluorochernicals have complete   . gf fluorine for hydrogen Fluomchemicals can repel both water and oils, reduce SUrface tension dramatically, act as catalystsfor oligomerization and poiymerization, and function under extreme conditions. Major uses for sulfonated Perfluorochemicals me surface protectors and suri8ctanrs.

 Fluorine's high elektrmegativity confers a strong polarity to carbon fluorine bonds, contributing tu the stability and nonreacfive character of perfluorochernick molecdes. They are unusual as that perfbmalkyl chains are both oleophobic and hydrophobic. The addition of charged moieties to the chain m y affect the water solubility of the shorter Chains.

The highest volume sulfonated pduorochemical produced by 3M is perfluorooctanesulfonyf fluoride ( POSF). M e r synthesis, it is used to create several product lines. During their me cycles, POSF and POSF based products may degrade. If degradation occurs, current research suggests peduorooctane sulfonate, ( FFOS) and a few other perfluorinated forms are degradation products. Timchcs for & gradation am variable, with some polymeric products apparently stable for very long periods of time.

The idenMcadon and quandfi cation of s" onased pertluorochemicals pose dLfticult d f i c a l challenges. Reliable methods for extraction, separation and identification of sulfonated perfluorochemicals in tissues and environtnental matrices have evolved and have been developed only h the last few years. New d f l c a l technology is providing capabilities of detection in wide Meties of matrices at parts per trillion ( ppt) levels and identification of metabolites and breakdown products.

As fully desdbed throughout this p 3M is pursUing an aggressive program to reduce releases to the env'konment while that scientific research is being conducted. It is not the purpose of this paper to describe the n a ~ r e and extent of that undertaking. Readers should be made awm, however, that 3M hw initiated a wide range of activities to utilize available opportu& ies for rtductions in releases. These have included installation of new controls to reduce waste streams in 3M mufhcming hilities. They have also included product slewarchhip efforts to comu& ate to customers and downstream users, information regarding fluorochemicals and the need to exert careful management over these substances. In addition. 3M has undertaken major efforts to reinvent its products tbrough the use of alternative chemistry to reduce the volume of fluorochemicals used in those products. All of these efforts will I 4 r, completion of a comprehensive exposure assessment and related scientific stu % f" ' es will q u i r e many years of intensive research.

5 I . . **+ . . a . . . , .. . . . . . I be continued with htdty while the scientific research described in this paper is being carried out.

3M i s examining the M e cycle of its sulfonated perfluorrochemid prodwts to idcntif$ releases to the environment & om manllfacturig processes, supply chains, product use and disposal. First it is debmnhhg waste streams generated throughout the life cycle. This informathn will be used to csthatc cllVin0nrm; nlaI releases. This approach is necessary since not all waste produced is released to the mvironment. M a n d i waste studies are underway at the 3M plant in Decatur, Alabama on POSF based processes. PFOS based waste streams generated Born these manufacturing processes are conservatively estimated to be about 1.1 million pounds per year, about 90% as solid waste, most of which i, s incinerated and destroyed. Recent wastewater controls have reduced amounts of PFOS actually discharged to the river by half since 1998.

Data from business units have identified key products that contain the majority of the fluorochemical solids sold in the United States in 1997. Using this sales ioformation, 3M estimated customer and end user waste stseams. Motit of the waste generated from these sources is in the form of solid w e . Releases to the en* ment from product disposal to landfills, wastewater treatment plants and incineration are all being investigated.

Scvtral = xnt fate d tiauspurimtxhdsms have been identified as important to study. Initially models are being used for screexing level assessments of potential & e mechanisms. Multi media fugacity models are under development to incorporate the unique properties of fluorochemicals.

Sulfonated perfiuorochcmicals have been detected at low levels in some species of eagles and wild birds. Low levels were detected in bird plasma and bird livers. 3M believes that these sets of data are hsuf6Cient to draw conclusions with any statistical merit. In screening sampling of the river and sediments near the Decalxu manufachving plant, PFOS was present in a few samples collected near the outfall. All this Mixmation was used in the design of a more comprehensive program of biosphere sampling. The goal of the biosphere samplttg plan k to SC~ CCIZ for PPOS across a range of species, Mbilttls d geographic IOCZA~~ OIB and to identify mas on which to focus scientific investigation to develop a better understanding of any patentiid environmental effects.

A multi cities study will determine envkonmental distribution and potential sources of human and ecological exposure. The rnulti cities study pairs cities with significant rnanu & urhg or commercial use of fluomchemical phducts with cities of the same size without signiscant use. Levels of PFOS and its precursors will be measured in food, air, water, sedirnen$ and disposd facilities. Additionally, levels are being measured arising from carpet use, product uses and potential migration into food from packaging.

The role of hydrolysis, photolyeis and biological proos~ se~ in the degrndation of sulfonated perfluorochemicals is being studied. Research suggests that the biodegradation of fluorinated sulfonates requires the presence of hydrogen at the alpha 6 . _ . . . ..! .. I . . , . . . . . . . . carbon on the fluorinated chain and that perfJmrinaterl malecnles are susceptible to breakdown ody at non ftuorinatd side chains. Degradation of & med perfluorochemicals is not complete but results in production of other fluom&~ c&. Studies suggest that compounds made from POSF, tl oommcrcially important perfluorochemical product and hWr~~ ediate, are bmsfanned during metabolism to another sulfonated perfluomchemical, PFOS. PFOS does not appear to further degrade except by incbemtion. 7 Several sulfonated p~ uorochedcds have been subjected to basic scmning tests for environmental toxicity. Different species varied significantly in their response t0, t. h same chemical even when ushg the same hboratory procedure. New testing is underway using purified sulfonated perfluorochemi& is. m d test concentratinna, and a wide variety of test organisms. Results of these studies are reported in this white paper.

The research projects that are yielding new infomation on sulfonated perfluomchemicals are part of a comprehensive plan to assess the potential pathways of emrironmental exposure associated with the m8xlllfacture, use and && sal of sulfonated perfluomchemical products. Figure 1 portrays the plan components. Work on the plan is now underway using a combination of 3M resources and outside expexts. Recent analytical advances and this extensive research effort are expected to contribute significantly to a better understanding of environmental fate and effects.

The findings resulting & om the comprehensive pian, along with new ecotoxicological test data, will be used to evaluate ecological fisk. W e this evaluation is underway, 3M is implementing actions to reduce generation of waste in m m e g processes and to reduce releases of sulfonated perfluorochemicals into the environment through process improvements, waste reduction and engineering redesign.

. . . . . . . . . . ,,.,_ ._. . . . . , .. ~

. . . ... Figure I. Diagram of Fluorochemicai Assessment Plan.

Ecological Evaluation Ecotoxicity ta etermlnati ons . .. . . 8 r . ... .  . .. . : . . ""_... . . _ , ". . ....._ 3.0 Introduction to Fluorochsmicals FIuoroehedcaIs my; components of scvcral hportaut 3M product lines due to their unique and useful properties. They are stable, chemically inert and generally nonreactive. AS components of products, they repel both water and 05 n?& ce& tension much lower than other su&& m@, act  85 catalysts for oligomerization and polymerization, and function where other compounds would rapidly degrade.

3M has produced fluomchemicals commercially for over 413 years. 3M produces fluorochemicds by combining anhydrous hydrogen fluoride with hydrocarbon stock in produced by 3M is perfluorooCtandfony1 fluoride ( POSF). i the presence of electrim1 energy. The highest volume sulfonatc? d fluomchemical 1  0ctanesulfonyl fluoride Perfluoroocmaonyl fluoride ( POSF)

The fluorination process o v d yieIds about 3540% straight chain ( normal) POSF, and a mjxture of byproducts and waste of ucharacterized and variable composition conti&& g:

 higher or lower straight chain homologues, Q CJ?~, SO, F, of various chain lengths ( 7% of process output)

e. g. C, F,, SO, F, C, FIsSOzF, C&?,, SO, F  branched chain perfluoroalkyl products of various chain lengths ( 18 200/, of CF3CFcF2CF2CFCFzSO$ output) CF3 CF3 CF3 I I I e.%. CF, CF2CF2CF, CF2CFcF, SOzF  straight chain, branched and cyclic perfluoroalkanes and ethers ( 20 25% of '" tars" ( high molecular weight fluomchemical byproducts) and other byproducts, including molecular hydrogen ( 10 15% of output).

Because of slight differences in pracess conditions, raw materids, and equipment, the mixture produced by the electrochemid fluorination process varies somewhat from lot to lot and fiom plant to plant. Numxous process steps are used to convert the fluorinated mixture into final products: ,

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, . . I ' fie largest production of flwrochemicals occurs at the 3M mmufkctwing plant in Decatur, Alabama, and this plant is the focus of current studies. During productioa, marry byproductc and wasti? pmd1xts are formed. The volatile waste products have been vankd to the atmosphere in tfie past but hprovemenQ are underway to capture and desmy releases by thennal oxidation. The tars ate disposed at hazardous waste t a t d i l l s or treated by incin~ tion, Thc byproducts, many of which arc inr; Ompletely fluorinated with hydrogen atoms still present, are recycled back into processes or partidy in stabilization processes and discharged to wastewater treatment systerqs. The ' treatment sludge is landslled. Some of the non POSF based brprdlucts are recovered and sold for secondary uses.

The product of the. electrochemical fluorination process is thus not a pure chemhl but rather a mixture of isomers and homologues. P d u o r o c h ~ d s have coplpIete substitution of fluorine fm hydrogen. The commercialized POSF derived products are a mixture of approbtely 70% hear POSF derivatives and 30% bianched POSF derived impurities. POSF is used as a product and is also an important intermediate in the synthesis of substances used in many other 3M products, To a lesser extent, homologues of POSF, [ CJ?,,, SO, F where n= 2 9, exclusive of 81, are also components used in the formation of other 3M products.

Some of the POSF derived products are surface active materials and monomers of relatively low molecular weight ( 500 daItons). These monomers are used as low molecular weight surfactants or are joined with other monomers to form higher molecular weight oligomers and polymers with a mix of fluorinated and unfluorinated portions. Fluomchemical momers can also be joined to phosphates, to polymeric and oligomeric urkthane, or to acrylate hckbones through ester and other linkages. The majority of 3M's sulfonated perfluomchemicals produced are used in polymeric form for treatmmt of swfaces and materials. For example, fluomchemical contnining polymers ( urethanes, acrylics and esters) can provide soil, stain, and water resistance to persod apparel and home furnishings.

Some products synthesized from POSF and its homologues are sold as raw materials to customers who use them as intermediates or components of their products. The intcmediates can be covalently bound to a variety of polymeric hydrocarbon backbones.

The 3M product l i e s that use sulfonated perfluomchemicals are summarized below. ( product lines using fluorochemicals that Contain no sulfonyl'groups 8re not listed.)

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. , . " 1.. ___.. ..,. : ..... . . Surface Treatments FabricKJphoMery Protector ( High molecular weight 0 polymers) Carpet Proteotor ( High M W polymers) Leather Protector ( High MW polymers) Paper and Packaging Protector ( High MW phosphate esters or high MW PolY=@

Surfactants ( Low MW chemical substances) specialty sufactrmts Househofd additives ElectmpMng and etching bath surfactants Coating and coating additives \

Chemical intermediates carpet spot cleaners Fire Extinguishing Foam Concentrates Mining and Oil Surfactap'. ts Other Uses Insecticide Raw Materials ( Low MW chemical substances)

Typically a fluomchemical product contabs a small amount of fluorochetnical residuals: unreactedor partially reacted starting materids or intermediates. Residuals which are common to formuiations of sulfonated perfluorochmical products include: perfluorooctane sulfonate ( PFOS), N ethyl ( or N methyl) perfluorooebne sulfonamide ( N EtFOSA or N MeFOSA) , N ethyl ( or N methyl) perfluorooctane sulfonamidoethyl alcohol ( N Et FOSE alcohol or N MeFOSE alcohol) aad peduorooctanoic acid ( PFOA). Table 1 identifies some sulfonated perfluorochemicals, their acronyms, chemical name, and formulas.

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DfSlgUattOD POSF PFOS I Name Formula perfluorooctancsulfmyl fluoride W, 7SOP p ~ u o r ~ e ~ ~ t 8 . c; pltSO3

PFOSH perfhiorwctPlesulfonic acid \

PFOS.", salt C; F,, Sqrr PFOS. DEA salt PF0S. K salt PF0S. Li salt I 12 Perfluorooctancsulfonate C $ , 7 ~ 0 3 W C % C ~ O ~ diethanolamine sdt potassium prrfluorooctanasullbnate C, F,, SO, K lithium pertIuomoct& subnate C;; F,, SO, Li PFDS ( ethyi) acetote perfluom& canesuIfona. te CI$,, SO3 4.0 Physical Chemical Properties of Fluorachemicalo Fluorinated organics are less well described in the science literature than organic ~ ltu; ulw bearing other halogens, i. e. bromine and chlorine; whidh have been more thoroughly investigated by many researchefs in published reports. To understand the properties of fluorinated organics, it is necessary to describe the properties of fluorine. Fluorh~ has several characteristics that differ h m the other halogens and c o d b m to the unusual properties of fluorochemids.

Fluorine hac a van der WaaIs radius of 1.35 4 more comparable to that of oxygen than other halogens, and isosterically similar to a hydroxyl group. Fluorine has the highest electronegativity ( 4.0  Pauling scale) of dl the halogem, indccd & e highcst in tIrc periodic table. This coders a strong polarity to the carbon fluorine bond. The carbon fluorine bond is one of the strongest in nature ( 1 10 kcal/~ l). This very strong, high energy bond confqibutes to the stability of fluorochemicals.

The high ionization potential of fluorine ( 401.8 kcal/ mole) and its low polarkability leads to weak inter and intramolecular intemtions. This is demonstrated by the low boiling points of fluorochemicds relative to molecuIar weight, and their extremely low surfke tension and low refrzlctive index. The partitioning behavior of perfluoroalkanes is unusual. Some perfluomalkanes when mixed with hydrocarbons and water form three immiscible phases, dimonstrating that perfluorjnated chains are both oleophobic and hydrophobic. A charged moiety, such as carboxylio mid, sulfonid mid, phosphatc or a quaternary ammonium group, when attached to the perfluorinated chain, makes die moIecule more water soluble because o f the hydrophilic nature of these charged moieties. Therefore, such fiu~ ctionalized fluomchemicals & n have mfbctht propertids. Typically, the presence of these charged groups on short chain perfluorbated compouuds ( cC6) noticeably increases the solubility of the compound in water.

Physical data available on fluomchemicals at 3M have been principally those parameters needed for quality contrql use and material handling. TabIe 2 summariles the physical data for 1ow. molecular weight, POSF based fluorochemical products that have been developed for use on Maten4 Safety, Data Sheets ( MSDS).

Some of these perfluorochemical produtits am primarily used as surfactants; others & e primarily used as intermediates in the formation of polymeric or oligomeric products. Some of these'low molecular weight fluomchemicals are also likely intermediates in the degradation of polymeric compounds. Some can also result fiom environmeftal transformation af other low molecular weight fluomchemical products. It is important to remember that these data were obtained using produds that were not highly refined, and products may have more than one fluorochemical component. Some may have nonfluorochdcal components that enter into determination of the! valiies. Beckwe of improvements in analytical techniques and product refinement, these data are in the process of being replaced by better quality dah 13 Table 2. Physical Dab on Fluorochernical Products ( Developed for Use on MSDS Sheets)

Product Principal boilmg vapor vapor maprate sotub specific PH Use Fluorocbemical pt@) pressura dwsity BuOAc in Grav. Watepl meltin$ & g d o .  1 wabr " C @ trU= A b 1 pC( m) calc. @ OoC Interned. POSF 154b < IO > 1.0 < 1 . o neglig  1 8 NIA nCg&  1.7 . NIA . Interned. N EtFOSE alcohol  1 18 b* 4 0 s1.0 4.0 * Surfactant N EtFOSA  11oMc 4 0 > I NiD  1.6 NIA Interned. N BtFO! XA  150b' < IO .> LO < I . Q nil  1.5 N/ A lntermed  N EtFOSEMA  150b* 4 0 > 1.0 < LO* ncglig  1.5 NIA htermed. N McFOSEalcohol 75 95111 NR) N/ D N/ D neglig  1.7 N/ A  90m

 SurfactanrFFOs r q + salt  82b  34  1.0 c1.0 moderap  1.1  7 SUI Iticranr PFOS Drn salt  9Sb  31 4.62 4.0 camplete  1.1  7 . sutfactant ClyGinG derivative of  100b  1s  0.87 Cl. 0 comglere  1.3  1 1 Surfactant PFOS Li s t  100 b N/ D < I complete  1.1 6 8 Surfactant PFOS K salt NIA N/ A NIA N/ A slight  0.6 7 8 Surfactant PerfluoroClO sulfonic * 96 b  16  1.08 4 modem 1.08 8.5 9.5 acid,

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salt FOSA ethylene oxide adduct 1.34 ' S & i t N FitFOSEd~ ohol, 210b  18 0.64 e1 appmc 1.31 5.5 8.4 L Source: MSDS Sheers Abbreviations: N/ D: not determined; N/ A: not applicable; : approximately * measured at lmm Hg # measured at 2 mm Hg Additional physical data were developed in the mid 1970s and early 1980s on a few, high volume products. Typically these data are related to developing an understanding of environmental fate, e. g. data on soil mobility and partitionins coefficientc They art? s m d in Table 3. 3M has evaluated tbese data for reliability and the reliability codes are included 8s part of the table. Pragress in analytical techniques has significantly improved the reliability of current dnta compared to the reliability of thcse historical data. Current physical/ chemid data are found h Table 4.

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. . __ . , . . . ._. I Product SoMility octanol/ watcr FC Watet coefficient mgn PrincipIe m partition PFOS ICsaIt 1080 ( 2A) lO( 2B)

N MeFOSE 0.82 56,800 ( 2B)

Computer models used in conjunction with empixid sampling can be used to predict environmental fate and transport of these substances. Existing models can require the following physicaVchemical data for operation: molecular weight; boiliig/ meIting point, pK, OatanoYwater partition coefiicient, vapor pressure, solubility, Henry's law cons& nt, density, evaporation rate, heat of vaporization, bioconcentration' factor, and degradation mechanisms in air and watcr ( hydrolysis, photolysis, and biodcgxadation). Pnxisc values for the parent fluorochemid compound, its intermediates, and the end degradation product@) are essential for comprehensive predictions about environmental fate and transport. logn soil . Organic Vapor OctanoYwater adsorption carbon Pr partition coefficient adsorption coefticient ( K) coefficient  m 1 0.99 66 NID 0 C2B) ( 2B) ND 77 3,500 N/ D 15 I alcohol ( 2B) N EtPOSP, 0.03 6,600,000 3.60 ~

alcohol ( 2B) ( 4) . OB) N EtFOSEA 0.89( 2B) NID ( 2B)

, . . , . . . . . " .._ . , . . , .. . . , ... ,.^&.~ . . . . . ... .. "_ ... .... .., ..._ . 111_.. I' ( 2B) ( 2B) 33u 17, IJOU 1.22 mmHg ( 1B) ( ZB) 0. B) 0. JP@ O0C ( 1A) N/ D N/ D 6.0 x 10 1 Pa ( 1 A) POSF lest( 2A) Nil3 N/ D NKI N EtFOSA N D N/ D N/ D NtD N/ D 1.6 tor@ 20 ° C ( 4) NLD 0.16 Pa@ O" C ( I N 3M is developing the missing physicavchemical data on indivicid fltiorochemids! the assistance of several consultants. While labomtory studies are underway on physiCaVchemical properties of PFOS, EtFOSE alcohol and MeFOSE alcohol, models me being developed to estimate the phy& xd/ cbmioal propertics of other sulfonated perfluorochemicals. The data an: being determined using the Guidalines for the Testine, of Chemicals developed by the Organization for Ecommic Co operation and Development ( OECD) for phydcallchemical testing ( 3) where available. WheE possible, melting points, boiling points, vapor p~~~ sures, dissociation canstants, water solubility, n octanol/ water partition coefficients, airhat& partition coefficients, and soil adsorptioddesorption will be determined. This informtion is needed for both environmental fate, models and mandacturing emission models. Current modeling efforts are hampered by lack of data on physical/ Chemical properties.

Data are being colIected according to Good Labratory Practice ( GLP) standards. The &/ water partition test is non standard, This test protocol was developed jointly by 3M and an outside expert. Results will be reviewed by several techaical experts, both within the 3M Environmental Laboratory, and outside & e company. , '

3M is g e n w ' t h e information on soil sorptioddesorption charact& stics as non GLP, screening studies. These data will & d in the evaluation of the transport process and parhtioning. For example, , will a fluorochemical be retained by the soil matrix or remain in the water phase? The bioconcentration potential of PFOS and EtFOSE alcohol will be examined through empirical testing that determines the extent of the uptake of these chemicals by fish. Work on degradation including hydrolysis, photodegradation and biodegradation is described in mother section. ( See Environmental Transfonnatioflegradation.)

The physicdchemical testing is proceeding in order of PFOS, EtEOSE alcohol, and MeFOSE alcohol. The results to date are reported in Table 4. The inability to determine an octanoYwater partition coefficient makes it difficdt to do predictive modeling. \

Table 4, New PhyslcallChemkat Testing Results on PFOS, potassium s. att Parameter Results 570 m@ Solubility: pure water Solubility: fresh water 370 m a * SolubiliQ: unfiltered sea w@ er 4 5 mg&* estimated Solubility: filtered sea water 25 m@* Vapor Pressure 3.31 x 104 rn @ zooc Melting Point > 4OOOC Boilhg Point 1 notdculable OctanoWater partition L)

* Data developed in support of other studies; not developed using GLP standards.

>

I not calculable; three phpsoo AirfWatter Partition Coefficient 1 o( a x io4)

16 ' I ,

The methods used in these cwrent pbysicdchemical tests will provide mIues reposed in consistqnt formats that are intemationslly fiuniliar and accepted. This statdardization WiIl aid in the review and comparison of data on iadividual fluomchemic& and in model operation and prediction. The data Will oontribute to d y t i c a l mcthod devclopmwt 4 overall improvements in sample handling, sbiming and storage as well as manuf8cturing.

5.0 Analytical Test Methods for Fluorochemieats Procedures for detecting and identifyins fluomchemicals in the environment require a very high level oftechnieal expertise, Most genBral analytical methods do not pmvidc enough sensitivityor selectivity. The complex mixture of possible compo~ mts in a product, the multiple matrices in which they could reside ( e. g. the atmosphere, soils, surface water, groundwater, wastewater, Werent animal tissues, dif erent animal species, plant species, foods, etc.), and trace level detection require selective extraction and diverse analytical W h k p s .

Each fluorochemicd requires a unique analytical methodology. Separate methods may be needed for every matrix. Validation of each method is time intensive. Often. standards are not available. Reliable qwtitative methods for extraction, separation and identification have been developed only within the last few years. Prior to that, relaiively ' wen used. insensitive find non specific m. dyticd methods, such as " total organic fluoride ( TOF+),''

The analytical technology ysed in extraction, separation, identification and quantitation includes combinations of:

 High Performance Liquid Chromatography ( WLC);  High Pressure Solvent Extraction ( HPSE);

 Gas Chromatography ( GC) with a Flame Ionization Detector ( FID), a Mass Spectrometer ( MS), a Photo Ionization Deteotor ( PID), or an Electron Capture Detector @ CD)  ElC& oSpmy Tandem MBS SPWWOSCOPY ( ESMSMS);

 HPLC QuadrapoIe Time O f Flight mass spectrometer ( QTOF)

For example, analysis of PFOS extracted from tissues requires ESMSMS analysis. This technique focuses quintitation on three secondary ions of one primtry ion at a specific WLC retention time.

To proyide positive identification oftarget d y t e s in complicated matrices, the 3M Environmentd Laboratory uses a quadrapole thne of flight mass spectrom& er. The instrument provides hi& mass 8ccwacy ( to 0.0005 mu) and so is useful in iden L J fluomchemical metabolites and intermediates for wbich standards are not available. Compound identification is bsed cm reasonable HPLC retention time as compared to standard compounds of similar structure, reasonable interpretation of fragment ions associated with the prime ion, hteqmktion of the accurate ma86 spectnmt, md agreement between the experimental and theoretical molecular weight (+ O. OOOS mu).

The addition of ncw tCcbl0g. y hns psrmi# cd 3M aualysts lu intxeise the numbers of sulfonated p e r f l u o r o c ~ ~ that can be identified, expand the matrices in which theJr can be detected, and lower the levels at which thiy are detected. The technology has '

expanded rhe volwnes of analyses that can be done. Nonetheless, capacity limits require analyses to be prioritized. When samples cannot be analyzed soon after collection, w e is taken to store the samples appropriately for the matrix and the analytical method, both to prevent sample deterioration and contamination.

3M now has in place several methods for analysis of sulfonated peduorochemicals in several matrices. The methods produce data of varying quality. They may be used in combination to produce test data. The method perfonnance can be categorized as follows:

1.

2.

3.

4< Quantitative methods that have been vdidated by studies conducted according to Good Laboratoiy Practices ( OLP). These exist for analyses of samples of blood, liver, and several animal tissues of certain species, drinking water, and certain types of fwd.

Quantitative methods that typically m based on methodologies that have undergone significant amdflcd c h a r a e t i o ~ during development. These methods are validated by extensiW: quality conQo1 testing, but validation studies may not have been conducted according to GLP requirements. These exist for wastewater, sludge, and air, for exampie.

Semi quantitative methods that Bically are based on the quantitative methods but for WE& v& dation atudics orc lacking or quality assurance m o t be* demonstrated because, for example, standards are unobtainable or sample matrix is extremely l i i t e d .

Screening methods that typically are under development or a result of exploratory studies. These methods yield only qualitative data, is. fhey reliably detect the presence or absence of an analyte.

Method development is conthuhg, not only at the 3M En~ mental Laboratory but also at independent laboratories in consultation ~ 4th 3M Environmental Laboratmy scientists. For some uutrices, the detection l i b sought are at lower levels. Method validation of low level analyses may be confirmed at a university or other contraot laboratories, as appropriate. When samples are sent to consulting laboratories, 3M supplies the methodology or shares expertise to develop the method. Quality assutance is 18 ,

required, along with method validation and oversight at levels comparable to those in the 3M Environmental Laboratory.

Continual improvements are sought in analyEi0al methods as thc ability to dctcct traa quantities is essential for a number of reasons such as: screening laboratory suppiies and environments prior to initiating toxicity testing, for detecting environmental exposure, for de* ' g sources of perflwrochemicals, and for u. n& p d w r o c h d d . metabolism kinetics,

6.0 Sources of Fluorochemicals A few fluorochemicals occur natudy in the biosphere, produced by biological and geochemical processes. Several green plants prodwe xnonoflwroaceticwid ( CH, FCOOrr). Some fungi produce monofluorinated organics. All flubmhdcals produced biolo@ cally contain only one fluorine atom. Vobanoes and otber gedogicd processes produce tetrduomthylene, sulfur hexafluoride, perfluoromethane and some chlorofluorocarbom in small quantities. .

Most fluorochemicds h the environment are present as a result of human man and use. Releases of fluorochemicals into the mvimmntzut can occur at each stage of the fliinrochemksl product's life cycle. " hey can be released when the ffuorochemid is syntheskzed, continue during incorporation of the ff uorochemical into a product, during the distribution of the product to users, during the use of the product by comers, and ' during disposal practices at all of these stages.

3M is using a two step approach to estimate envhmnentd releases of fluorochernicals. The initial efforts have focused on determining waste generated; the second step will focus on determhing releases. This two step approach is necessary since not all waste produced will result in a release to the environment. Much of the waste that is generated is destroyed through treatmeat or othemise actively managed to pvmt release into the environment. Efforts are also being made to further tighten such controls.

3M has estimated waste generation fiom each of the following Iife cycle stages: the manufactcving processes, the supply and distribution chains,' customer uses and productlwaste disposal. r For ease in comparing waste sbream data, wastes are described in term of" PF0S equivalents." PFOS equivalents are the weight of C&, SO, present in a sulfonated perfluorochemicd product. It is the mass of PFOS molecules that would be formed in.& breakdown of the product. The assumptions of complete breakdown to PFOS of each sulfonated perfluomchemical product, in the year in which the product was sold, are unlikely " worst case" ~ ssumptions. Various degradation testing finds a broad range of product degradation rates. Some polymeric products a p p r to be quite stabie in & g environment, with long half lives; other polymers hydrolyze quickly.

6. f Manufacturing Waste Shams The assessment of the release of sulfonated perfluorochemicals into the environment begins Wiih manufkturhg waste generation. Some vask streams, such as wtistava@ discharge or disposal of off spec products, can be anticipated and controls provided. . Other waste can be generated during any of the steps required toproduce the fl uorochemicals and manufacture the product The greatest production of the parent fluorochemical pmdiict, POSF, occurs at the Decatur, Alabamaplant. Here POSF is created in electrocbdical cells and yndergoes numer0Us" steps to convert it into fin14 products. Salts of PFOS are also xnm at the facility. Because of its production volume, the De& kiIity has been the focus of manufacturing waste stteam studies. Understanding waste generation and how wastes are managed and disposed of pvides'a better uoderstanding of potential releases into the environment. That undemhnding will help to identify opportunities for reductions in such releases. .

The manufacturing process for donated perf. luorochemicaIs is complicated. There are more than 600 intermediate manufacturing steps associated kith th~ production of POSF and POSF based products. This translates into hundreds of process steps that require venting or that generate wastewater or solid waste. AIthough the manufixturing process attempts to capture, reuse, and recycle most 5uorochemicals as desired product material, until recently, the unique chemisbcies created in each step of the process could not bg analyzed precisely to confirm composition and to quantify amounts.' The rnandacturing process is dynamic, with rapidly changing matrices and many process steps. Ongoing process optimization activities continuously change the waste stream profile.

Progress has been made inanalytical techniques. In 1997, analytical laboratory I techniques and methods could quantitatiwdy identify the presence of only one fluorochemical analyte in awastewater mattiX, In 1999, improved analytical techniques and methods were developed for additional fluorochemical analytes in a =* water matrix.

Advanced field monitoxhg technology has been developed based on Fourier Transform Infrared spectroscopy ( FTR). This field tool has been used to detect where emissions to air are occurribg during the manufacturing process and. to evaluate whether a process change or a control technology can decrease the release. As better analytical techniques become available, efforts are being made to:  characterize the mjor manufaclmhg processes generating fiuorochemical I evaluate the effiveness of flwrochemical xemoval technologies; and  provide better estimates of the amounts and kinds of flumochdcals released to waste streams;

~

processes and from waste treatment and the envhment from ' disposal.

Idormation currently available on waste streams generated during manufbtwing processes at Deca; tcu is derived fkom. calculations, air emiSsionS modeling, and limited testing. An overall site d n a l s bafance was developed in the mid 1990' s using the amount of POSF based solids initially created in the electrochemical cell and the amount of POSF contained in ilnal products sold. The difference was an estimate of total waste streams generated during processing. The emission factors derivedfkom this balance are used to calculate waste streams h m production thoughput. They are the . basis for the estimates in Table 5. These eStimates derived from the material balance are not precise, as this methodology can produce only rough approximations.

The e b $ s in Table 5 reflect the most c m t information available and combine data derived from several sources: information from the mid 90s site balance, wastewater testing, waste disposal records, process models and supplemental information fiom 1997, 1998 and 1999. Several changes in waste disposal and processing have been implemented since the mid 199Os in order to reduce potential releases to the environment. Wastewater sludges that were once land applied on site are now sent to a municipai landfill for disppsd. Off spec materials that were discharged to wasbwater are now shipped off site to be incinerated.

Table 5 helps to demonstrate the vast difference between volumes of wastes generated and volumes of releases to the envirOnment, since the vast majority of wastes sent to incineration are destroyed in the incineration process and most material sent off site to Iandfilis will be effectively managed to prevent release to the environment.

Table 5. Estirnatied 1998 Wastes Generated ( in PFOS Equivalents) at the Decatur Manufacturing Plant Waste Type . Estimated PFOS Equivalents, lbs Air Emissions 19,000 657,000 Wastes sent off site to Incineration Wastes sent off site to Laadfills 380,000 Total Wastes 1,066,000 Note: The 10,000 lbSryr of PFOS equivdants in the discharge to the river an: estimated releases to the environment after wastewater treatment, not the lbsfyr generated prim to treatment. .

Discharge to River after W astewater Treatment l0, oOo '

21 , , ., . . ,,,%..,.. .. .  ..... .. I .

_. . .. .. ., _,. . I More explanation of the estimates and efforts currently underway in air, wastewater and waste management follows.

6.11 Waste Stream Characterization Updating material balances forthe mauufbturhg process is an ongoing effort. Today process engineers use a model of process steps to calculate air emissions. New information is being Compiled to aid with model operation and waste calculations. The effort to determine physidchemical properties for sulfonated perfluomchemicals will improve model inputs and waste stream calculations. Analytical technology is improving understanding of process chemistry Data from the process engineers' available material balances h the plants reporting system have been used to supplement the e; arlie? site balance in esthating ah emksions. Initial reports fiom this system indicate that most site waste and air emissions result from fewer than 10 key steps in the early stages of POSF production. Process experts are examining these steps for ways to reduce or eliminate the impurities and wastes generated intlzesteps.

h 1999, the Decatur plant installed a discotbm unit which heats the process materials, vaporizing and capturing the fluorochemicals. It will significantIy reduce the orgmofluorides in the waste'bater. This technology will operate tn rednce emissions and waste at the source. It will make it easier to segregate waste streams and recycle fluorochemical wastes back into the process. *

6.12 Air 3M engineers have reviewed specific process steps to determine what air emissions testing is feasible and appropriate. Testing of complex batch processing system is difficult due to quickly changbg process conditions, venting pressures, and difficulty in isolating processes; however, characterization testing m y be possible. The technical feasibility of performing this testing for two major processes is now under evaluation. Any emissions testing will require modIficatons to process venta and mitigation of potential safety hazards. About 80 separate venting points are associated with the equipment used to make sulfonated perfluoroc; hemicals. \

. . ~ . 6.13 Waslewaltr Anatytical methods have been developed during the past year to better characterize the wastewater discharge from the site. The firse testing of wastewater before and & er treatment for specific flmrochdcals occurred at Decatur early in 1998. The testing was 22 . . . . I . . I ~" limited and reflectd aperating condition0 for a relatively short period of time ( 24 how composite! samples of influent and effluent for one week) Some ofthe campom& that were identified in the wastewater were: a diester of EtFOSE alcohol, EtFOSE alcohol, MeFOSE alcohol, PFOS, FOSA, PFOSAA, PFOA PPHS.  l In 1998 an interim carbon adsorption treatment system was installed as part of wastewater treatment. Data for the efnuent estimate in Table 5 reflects this change. This treatment system treats the lagat single source of fluorochemical contahbg wastewafer in order to remove PFOS and other sltlfonatRd ~ uorochemicals fiorn the wastewater. Comparison of the results from sampling done in February 1998 with sampling done in the end of 1998 indicates the quantity of PFOS discharged to the Tennessee River declined by about half. Tn additinn to the wbon adsorption system, in proesss operational changes were made inoff spec product discharge procedures that also contributed to the reduction in PFOS content of the discharge to the river.

The carbon system has been incorporated 85 a permanent. upgrade of the wtemter treatment system. Monitoring indicates k t with proper operation, carbon adsorption removes better than 990% of PFOS. Removal efficiency of other sulfonated perfluorochemicds varies, but the treatment appears to provide a high degree of removal for most, A number of w85tewBteT stre'ams currently going to sewers are in the process of being diverted to t h e d treatment facilities for disposal. This will r e d t in a reduction in the values listed in Table 5. 3M has conducted an extensive review of state of the art technology for wastewater treatment. Varims nppdes are cmrently be evaluated. The long term goal of wastewater treatment at the plant is to utili source control and end of pipe treatment to remove nearly all sulfonated perfluorochemicals from wastewater prior to discharge to the river.

6.14 Solid Waste An effort to identify all waste streams and their disposal methods is undemy. Existing waste tracking is done on a site basis, so it is difficult to distinguish the particula streams with PdSF chemistry. The mid 1990s emission estimates did not distinguish fTinal disposal of the material lost % om proddon, so s i b records were used in combination with the existing emission estimates to create the current picture af potential releases resuIting fiom disposal.

A review of plant records for 1998 has been completed to determine primary waste disposal locations for the site. According to Decatur plant records, 63% of the thlorochemicai containing wastes are sent to incinerators, 33% of the wastes are disposed in hazardous waste landfills and 4% in non hazardous waste landfills.

' j 23 . I . . ,.>. 1. , ,

1 Waste Stream I SuppIyChain .,, . r Use 1 Disposal 6.2 Supply Chain Was& Stt?? ams Air Wastewater . Solid Waste Using sales data, 3M i d w e d key products that Contain a majority of the fluor&&^ solids uscd in products. Thcsc products rcpment 39% O f PPOS equivalents sold by 3~ in 1997 in the United States. Most comonly, these products were sold to commercial users who applied them or incorporated them into their products.

Using the information developed from sales, 3M estimated customez and end user waste streams ( Table 6). These estimates are hnprecise and based on several assumptions, but provide qualitative inf'ormation. Using the chemical formulafor PFOS, the fluorochemical solids were converted to " PFOS equivalents" for ease in estimating and cornpariug total losses of & onat& l perflunrochemieals and in comparing Iossea. The assumptions of complete breakdown to PFOS of each suEonated perfluorochemical produck in the year in which the product was sold, are unlikely " worst case" assumptions. Product waste stream estimates axe based on conservative, worst case asgumPtions about the generation of waste streams at supply chain facilities. These are often based on , operator experience or engiueering estimates rather than laboratory tests and c8n redt in wi& raugtls in waste stream calculations. In estimating wastes, these data do not include loss of product residuals in the waste streams because information on the properties of residuals and processes at suppiy chain kiIities and end user locations is inadequate to estimate this loss. _  _

2,600 3,300 0 112,000 181,000 . 0 59,000 . ,377,000 1,262,000 Initial estimates ~ ssociate waste streams generated fiom ws and disposal of the products by customers of each business Unit. These estimates are helping to focus efforts in improving customer stewardship practices and 3M product reengheering. As is evident, most ofthe waste generated is in the form of solid waste.

Table 6. Customer and End User Waste Stm" n Estimates, PFOS equivalents, ibs in 1997 6.3 Releases fmm Wesfe Treatment and Disp& al Methods 3M and its consultant a r ~ gathwhg Mhsnati~ n on trebat and waste handling at several landfills and wastewater treatment plants which receive wastes containing sulfonated pduomchemicds k m the supply chain facilities and 3M manufblmhg 24 *

. . facilities. Information is also being compiled on some of the largest wastewater treatment facilities and landfills in the United States in order to bstimate the potential perfluomchemical releases to the environment from municipal disposal facilties not associated with the si~ pply chin or manufhtr; rin&.

Incineration is a hvored disposal method because of its high rates of destruction of sulfonated compounds. 3M and ita cdnsultant arc f& Gr evaluating the effecdveness of incineration for this purpose. The basic bond breaking chemistry of thermal destruction of POSF based fluorochemcals, the destruction efficiencies of various technologies/ sitmtions such as municipal incineratorS, and the products that could result from incomplete combustion are elements of the study. The study invoives a review of 3M and external litt dure to compile infomation on tbr: formation and properties of thermal traosfonnation products of sulfiinated perfluomchemicals.

Modeling will be used to determhe to th@ ebnt practical, the releases to the environment from the amount of material sent to incineration, mewater treatment plants, and landfills.

The goals of the life cycle release studies are:

 to identify importaut fluor& mids based on volume of release, mode of  to provide d u e s for use in modeling the distribution of fluorochemicals in the  to determine sampkg sites and substantiate sampling results;  to predict which fluorochemical releases may result in exposure to humans and  to identify fluorochemicals that require M e r study as to their transport, f& e release and chemistry;

environment;

the enviromenf; and and exposure potentid.

7.0 Environmental Transport and Distribution The transport and fate of ckxnkals in the environment depends on many factors but principally on the interaction between environmental conditions ( e. g. water, temperature, winlight), and chemical p r o a e s ( e+ partitioning and reactivity). In the environmental area, eleven important fate and transport mechanisms for sulfonated perfluomchemicals have been identified for further sbdy. These are:

1. Partitioning between air and prodwt, i. e. volatilization from. product to air, 2. Indoor air deposition; .. 3. Accumulation on airbyme particulates; 4. Fate and transport to the stratosphere;

25 I . . . .. a,.,. L_. .. .. . . . . 5. Accumulation at the surface water microlayer; 6. Degradation ( includes hydrolysis, photolysis and biodegradation); 7. Dissociation in water; 8 Uptake in plantq; 9. Uptakeinfish; 10. Uptakeinbirds; 1 1. Effi& ncy of wastewatcr trcatmmt system. I

All of these fate and transport mechanisms have been linked to models. Modeling w s mathematical equations to simulate and predict rqil events and processes. Many types of modets will be considered for use in this effort to evaluate sulfonated perfluorochemicals. Simple models of ecosystems, indoor air, and treatment systems ( wastewater, IandiUs) .

are being used to screen fbr possible fate mechanisms, possible exposures, and possible sample detection limits. For example, one preliminffly screening model suggests that top trophic lwei species such as fish eating bids and sea mammals should be examined. This finding was incorporated into the design of the biosphere sampling plaa Chemicals differ greatly in their behavior. The major diffenenaes in behavior of organic chemicals in the enviroment are due to physicaf chemical properties, AILthoulfh laboratory studies are underway on physicaVchemical properties of PFOS, EtFOSE alcohol and MeFOSE alcohol, models are being developed to estimate the physicaVchemical properties of other sulfonated peffluorochemicals. This will reduce the time and testing required to gather these data for use in environmental fate models.

Fugacity is a concept that is used to describe % tendency of a compound to migrate in and between one environmental medium and another. Different media inclpde air, water, soil, sediment, and biota, all of which together compose a dynamic, interactive system an ecosystem. Predictions about movement of a chemical must incorporate both its physicaychemid properties and the environment the chemical is h. For example, a low vapor pressure does not mean a chemical is not present in air. It may evaporate appreciably from water despite a low vapor pressure if it has low sohbility in water. By. cntcring thc physicd chuid propaty & kt on LZ r; hemid into a fugacity model of a generic or specific environment, it is possible to estimate general features of a chemical's likely behavior and fate. The output of these calculations can be presented numerically and pictorially. ( 6)

Fugacity models Will be used to predict fate and transprt of sulfonated perfluorochemicds. Existing fugacity models typically are based on experience with chlorinated organics. An internationally recognized modeling expert is developingl adapting models to consider the d q u e properties of fluomchemicals. The goal of this modeling effort is to have a multimedia model or models to predict the fate of sullbnated perfluorochemical produrn and associated byproducts in a variety of ecosystems.

26 8.0 Environmental Sampling for Fluorochemicals 8.9 Envimnmental Levels 8.11 Historhl Data In the late f970sy 3M conducted a very limited number of studies to assess the distribution of fluorochernical constituentS in the environment. Several kshwater fish species were tested for a numb of fluomchemical compounds. In reviewing the data obtained from these studies in context of the current knowledge of the behavior of these & rials, 3M has coneluded that these historical data are highly qucstionabic and may be misleading. ThmTore, they are nQt included in this paper. The sections following present more reliable data a d i& omtion collected using validated sampling and analytical methodologies. . .

\

8.12 Recent Analyses of Wild Birds and Fish In analysis in 1999 of the plasma often fish eating birds, albatross nestlings at Midway Island in the Pacific Ocean and eagle nestlings in Minnesota and Michigan, PFOS was detected in each of the samples h m eagles. The samples were collected in 1989, ! 92, and 93 by Dr. John Giesy of Michigan State University as part of other surveys. Three of& e albatross adults show$ no detectable levels of PFOS (< 1 ppb detectian level). Detectable, but not quantifiable levels of PFOS were f o u l in the remaining albatross samples, bo& wlhttd b m birds less thau a year old. AU albamss samples were collected in 1992 93. See Table 7. These data am semiqwtihtivey screeninif quality. As only a small amount ( e 1 mL) ofplasma ' bas available to conduct the analyses, no matrix spikes were possible to estimate the method's recovery efficiency, but the methods used have been characterized in othery similar ktrices.

AAer the initial. screening results on wild bird plasma, the plasma fkom a second set of wild birds was examined for the presence of PFOS. ( See Table 7.) The some of the, plasma was three sea eagles collected from. the Baltic Sea and seven bald eagles caIIected from North America The samples were collected in 1992 93 and again by Dr. John Giesy. PFOS was detected in all of the eagle plasma screened. These data are semi quantitative, screeniug qualily. Twu matrix spikes ( 250 ppb) prepared from eagle plasma were extracted and analyzed. Both showed > 80% recovery. '

27 . . ' , ~ ...  ". ..... , .. ,, .. .. ti ..... , . . . . . .  ............. :: r .,., *. rmm'' . ' '  '. " . . a , , / , I *

Table 7. Levels of PFOS In the Plasma of Wild Birds BLQ= Below Limit of Qtmtk& on ( 10 ppb) B L P Below Limit of Detaction ( approximateIy 1 ppb)

Foilowing the bird plasma studies, sixty liver samples collected'by the US. Fish & Wildlife Servicti from various species of birds were d y k d . The dead birds were collected at a variety of sites across the United States. They were not part of a controlled research study, but were selected for their location and diet. AI1 but sandhill cranes are fish eating species. The sandhill cranes are an insect eating Species. The purpose of the analyses was to detennine if the presence of PFOS could be detected in these sample matrices. 3M believes that these sets of data twe insufficient to draw conclusions wi& any statistical merit. The PFOS data in Table 8 are semi quantitative, screening quality, with a margin of error estimated at If: 30%. The lirnit of quantitation for PFOS is 6 ppb.

28 I . I . _. , ~ ; ; r. . .. . . . . . . , ._ , .. . . . I a : , .... I........

, . . . c Table 8. Analysis of Wild Bird Livers.

BLQ Below limit of quantitation( 6 ppb) '

29 , * . ; . . . Sample No. Species Locatlon 46 Great Blue Heron St. Martiaville, LA 47 Great Blue Heron 5t. Martrtvlllville, LA 48 areat Blue Heron St. Martiavillc, LA 49 Great Blue Heron St. Martinville, LA 50 Great Blue Heron St. Marthville, LA 51 white Potieml ~ allcm, ? iv 52 w t e Pelican Fallon, NV 53 White Pelican FalIon, NV 54 White Pelican Fallon, NV 55 White Pelican FaIloI& NV 56 Brow Pelican FLLauderdaleiFL 58 Brown Pelican Ft L; iUderdale, FL

57 Brown Pelican Ft. Laudardalt. FL 59 Brown Pelican Ft. Lauded&, I% 60 Brown Pelican Ft LaUdadaIc, FL In addition to wild birds. some fish & om the wild were tested for the presence of PFOS. The fish were collected in 1997 98 fiom sites h Michigan as part of surveys conducted by Dr. John Giesy, They were stared frozen aud d y z e d in 1999. Six species were tested. Low levels of PFOS were detected in four of the twelve samples. Since no sample matrices were available for btrix spike studies, these data are of screening qualify only. No clear meaning can be drawn from the dah. They are being used to dcvclop sampling prugrams. Table 9 reports the findings. . PFOS ppb 188 59 1061 261 173 141 .   . 362 927 133 291 194 75 71 31 91 Table 9. PFOS Screening in Fish.

BLD Below Limit of Detection ( apprOXimat01y 7ppb) BLQ= Below Limit of Qumtitation { approXimately 70 ppb)

No. 1 2 3 4 5 Pine River, MI whole body BLD Lake Trout Siskiwit Lake, Isle RoyaIe, MI whole body BLD Lake Trout Siskiwit W e , Isle Rode, MI whole body BLD Lake Trout Pine River, MI wholebody BLQ Laice * mut Lake Superior wholebody BLD 30 6 Walleye , , . r.. ... :.. ..>. a 1 , 17r"":" Detroit River, MI wholebody BLD r . ....... ... . ,, . / I 7 ciscowet Lake Superior, FAarcp* MI 9 Brown Trout Rouge River, MI 10 Channel Catfish Lake St. CtaiFe, MI 8 Brown Trout Detroit River, MI  ei C a w 1 Lake S+ Clniip, W  I1 I . . muscle BLD muscle BLD IiVW BLQ muscle BLD I BLQ 12 Channel Caffish 1 Lake St. Claire, MI i I BLQ ,", ... 8.13 T d g o f Fishmeal Used in Rat Studies While performing human health toxicity studies ( see Perfluoroactane SuIfonate: Current SUmmary of IIumm Scra, Health and Toxiwlugy Data, Jan~ ary 1999), 3M found " endogenous" levels of PFOS in some of the d v e rats used in the studies. The levels found in the rat livers ranged fiom 29 ppb to 300 ppb. Livers of rats from one supplier showed no PFOS above the detection limit of 15 ppb. Further investigation revealed fishmeal to be an ingredient in the rat chow fed to the rats in which PFOS was detected. Fishmeal was not a dietary component of the mki that bad no detectable levels of, PFOS. 3M developed a complex analytical method to analyze fishmeal samples collected h m different fish stock. At a detection limit of 2 ppm, PFOS was detected in three samples of fishmeal and not detected in three samples. At this t h e , these data are not con~ lwive.

8.14 Plant Site Analyses In March of 1998,3M conducted screening level sampling for PFOS around the Decatw: plant. The outEd1 of the Decatur wastewater treatment plant is at a bay near the mouth of Baker's Creek. Baker's Creek flows into the Tennessee River, a large river that supports barge traffic. About 25 miles downstream is Wheeler Dam. The samples tested were of water surface hlm, subsurface water and sediment. A god of the sampling was to experiment with sampling techniques and analytical methods. Therefore, the anaiytical data are of screening quality only. Data on PFOS from the samplh 8re in Table 10.

Table I O . Sampling Near the Decatur Wastewater Discharge \

Sample Locations: UP1 & UP2: Tennessee River, upstream of discharge BC 1 : Baker's Creek below outfall Q 1 C 42: Baker's Creek, downstream of discharge, in quiet waters near Tennessee River WDl & WD2: Tennessee River beiow Wheeler Dam N/ C = not collected sur~ ace film samples were skimmexi fr~ m tht; top ofthe water, at the air/ water i n ~ c e . Sediment samples were collected from tho river bed Using M Ekman Ihdgc. Samph wcrc taktn at the water collection point or, if sediment was lacking there, 89 close as possible to it. '

31 , , I . ._ a_._ ., , . ._ _... C. L_..__.._.__. .. .. . . ,,.... . . .. . I , .. ,.,*.,., I..,. I ._ I_. Based on this initial sampling. a more extensive sampling was conducted. Sampling locations extended from about 10 dies trps` trean! of the facility to 25 mites below the facility. As a result of analytical. te~ hiques behg developed to lower detection limits, mdyses of these samples is pen% g.

8.15 Biosphere Sampling 3M is building on recent information with advances in technology to design a p r o m that could detect traces of sulfonaied perfluomchemicals across a range of species, envirornental habitats and geographic locations, including soil, water and organisms. 3M's approach is to use existing, scientifically recognjzed. sampling and data collection programs in order to minimize the t h e needed to obtain information. The goal is to set some bounds on the geographic regions where sulfonated perfluorochemicals are currently found, identi@ areas that shouId receive more investigation, and eliminate some general environments b m further samplii in the immediate future. Key ecosystem and species of concern swrounding rnanufiictming plants are being tested as well as ecosystems remote from rnmufhcturing and use locations.

Where possible, synoptic samples of soil, sediment, ah or water are also being taken, but the primary; focus of initial studies is tissue samples from biological reqeptors, especially those in upper trophic levels. The i& ormation obtained in the initial studies, will be used to determrne * appropriate studies for ascertainiqo critical pathways.

8.2 Human Eirposure Levels I Studies to investigate human exposures take several approwhes:

1.

2.

3. Environmentid exposure of the general U. S. population will be assessed in 1 phases through a " Multi Cities Study." This involves field investigation of . paired cities, one with significant manufWuring or commercial fluomchemical use, matched with a city without known significant use. The study will involve direct sampling for dietary and environmental presence.

Residential exposure will be assessed through a product's use and controlled measurements of the product's releases. This study will measure releases of fluomchemical residuals and total PFOS k m carpets.

The migation of sulfonated perfluomchemicals used in food packagii to the food is being quantified for several foods.

1.   . . a . I , . , . ,. /. ..... .. . . .. . . .. IF I 8.21 Muiti cities Sampling The mdti cities study pairs a city having significant manufactwing or coxmereid use of fluomohemid products baaed on customer d c s with a city h t docs uoi. IniWy six cities, ( three pairs) are being examined. This may be expanded, depending on initid results, The multi cities sampling will yield environmental disbiution data as well as data onpotendal sources of human exposure. The cities were selected to represent urba,~~ 1ocations with various levels of fluorochemical releases and various types of municipal water supplies. The samples to be obtained, where possible, are: urban air, surface water column and surfke microlayer, sedimm4 river fish, drinkhg water W e , treated drinking water, tap water, the influent and effluent to publicly owned waste tmatnient works, sludge. and municipal landfill leachate. Additionally a " market basket" of several food products will be sampled. These include: beef, pork, chicken, hot dogs, catfish, eggs, milk, bread, green beans, apples h m three grocery stores and, ifpossible, produce k r n local farmer' markets.

8.22 Carpet Use Studies The carpet study will estimate any loss of fluomhemid from normal use of carpets. Lf a pilot study of cargets finds significant releases, then the study will assess human exposure that. may occur via Mdatkn, dermal and ingestion mutes.

8.23 Paper and Packaging Studies Results of past studies on the migration of fluomchemicals from packaging into food have been submitted to the FDA, and FDA has cleared the use of paper and packaging proteclors fur h d as indirect food additives. Current work focuses on the development of new methodologies to extract various fluomchemicals & om paper and several foods, then perform quantitative, low level analyses (< 1 ppb).

834 Exposure Scenarios These scenarios will be developed wing data fiom release, fate and distribution studies. Their purpose is to priontke exposure PR& WE~ YS for fiather study by developing quantitative estimates of specific exposures under known conditions in a specific location.

33 , .. . .,.. ... ... ... . ._ ....... .. . ". . .. . a . .,., ".~ ~... .. . .. . . . . . ... I 8 , I _ i. . .. .... i r.,.. ".. 7":"" p:' I  ' .. , 0 , I .

. I .  9.0 Environmental TransformationlDerg~ datlon of Fluorochemlcals There are many physical, chemicsl and biol~ gical mechanisms that operate in the environment to tran& om or degrade molecules. They include abiotic mechanisms, e. g. hydrolysis an& photolysis, and biotic mechanisms, especially microbial metabofism. Because the carbon fluorine bond is one of the strongest in nature, witb high bond

energies, its cleavage t. equireS large amounts of energy. Most chemical and physical processes naturally occurring in the biosphere lack the required energy. In the laboratory, perfluoroaxkyl chains are not degded in the chemical oxygen demand ( COD) test, nor in total organic carbon ( TOC) analyzers that use very reactive chemical and ultraviolet degradation msc. Combustion docs dcstroy orgdc fluorochcmicals and degradation is fourid in high temperature TOC analyzers.

In perfluorhated molecules, the fluorines surround the carbon chain completely, shielding the carbon carbon bonds & om m k . The fluorine atoms confer a " rigidity" to the conformation of the molecule. This rigidity could make it difficult for the molecule to join with enzymes, thereby blocking biological attack of the carbon carbon bond. As a molecule becomes more fluorinated, carbon carbon bonds, carbon hydrogen and carbon fluorine bonds all typically increase in strength.

Early work with perfiuorochemical products using standardized screening tests for degradation found little susceptibility to degdati'on. ( See Table 1 1 .) Fluomchomcals lacking nonfluorinated organic portions produced esmtidy no biochemical oxygen d e h d ( BOD). Those with ionically bonded organics showed BODS near those cxptcttd & om thck non fluorinated portion alone. Fluorochemical swfktants with covalently bonded organic portions produced mixed results.

The early data on these degradabi ity studies has been given a reliability code that follows the test results.

I 34 ! . . ....,_ . , . \

sulfonic acid, NH4 salt K salt of carboxylic acid analogue of N Table I I . Historical Results of Standard Degradation Tesb on Fluotoc hemicSls ( 24) ( zA> ( 2A) ( 2A)

( 1) ( W 04 ( U) ( W . 462.000 09. SOq 172.000 179,000 2119, MQ Product PrincipIe COD BOD BOD BOD BOD FIuorochemical m m 5asy 10 2lMay 28 dsy N/ l3 N/ D nil .

( 4) merrcg m m z mg/ Kg mg/ Kg POSF 500 720 ( 4) d ( 4 ) nil( 4) nii( 4) N/ D nil( 1) NiD N MeFOSEalcohol 163,000 ( 1) N D N/ D N EtFOSE alcohol 260,000 ( 4) nil( 4) NID NID NiD Nrn

N D nodegradation in Warburg 3 hr stady or 2.5 montb shake flask study N EtF'OSA 1,800( 4) d ( 4 ) nil( 4) Nl( 4) N/ R N EtFOSEA 2 4 0 , ~ ( 1 ) 1& 000 19,000 23,000 N/ D N EtFOSEMA I 80,000 ( 1) 800 2,000 1 11,000 N/ D ( 2A) ( 2 4 ( 2A) I EtFOSE alcohol PFOS Lr" salt ( 4) PFOS K salt 54,000 N/ D N/ D Nn, N/ D 4,000 nil nil nil Nn,

I I I I I PFOS DEA salt I 78,000 j44, ooo 1 I 82,000 INK) t ( ZA) I@) I I o I N EtFOSEaIcohol I 1,070,000 I 0 1 N/ D I 107,000 I NiD Photo w/ D cm( l) nil ( 1)

1 3% of noq No deg m 6 month shRLe flask studies or 7 day activated sludge studies 40% removal BAS ( 3A)

1 I  b COD means Chemical Oxygen Danand. It is a measure of the oxygen e@ valent of the organic matter content of a sample that is susccptiilc to oxidation by a strong chemical oxidant such as potassium dichromate.

BOD means Biochemlcat oxygw Demand. It i s the amount of oxygen consuxned by microbial processes while breaking down a horn amount of a test substance.

35 ., . . . ... . . . . . . . . __  .. . .. . . . . . . . . ~ O D m nwretical OxYrJcn Demand. It iS the t h d d quantity of oxygen used when the test compound is fully rnineralhd. This value calculated usmg the structura of tho test chemical.

BiAS meam Bismuth Active Substances. These are materials, such as water soluble polyethoxylatw that prccipitatc with bariuru iewdudubismutbate.

N/ D means Not Determined.

Code meanings are: ( 2) Study used publiied test guidetines or well documented procedures.

( 2) Study meets all & e Criteria for quality tasting but has a deficiency ( 3) Study doeg NOT mea criteria far quality testing; data have one or more fiaws. Concentrations wera measured, and all quality control data were acceptable.

A. Concentnitions NOT measured. B. Analytical methodology questionable.

A. Demondated waakness in experimental procedures. B. Insufiicient description of method C. Unacceptable perfonnana of controls. ( 4) Data are available only as summaries; orighal reports not found.

9. I Hydrolysis Studies Hydrolysis is a major mechanism contributing to abiotic degradation of organic molecules, although it iarely is responsible for complete degradatioa The hydrolysis of sulfonated compounds is described below.

0 0 II I I R S X + H20 R S OH + HX 1: . 8.

X  halogen, OR, NR . .

3M is evduating the potential for hydrolysis of ffuorochemicals using EPA guidance pate, Transport and Transformation Test Guidelines, Hydi. 02ysi. s us a Function of pH and Temperature ]( 2), and is conducting pH dependent studies of PFOS and MeFOSE alcohol, as we11 as on fluorwhemical monomers, to estimate half lives. Selected fluorochemid products are being subjected to a single temperature ( SOOC), variable pH screening process. For those that demonstrate hydrolysis or a deviation form first order kinetics, multiple pH, multiple temjperanrte studies are planned. Hydrolysis test dara are being reviewed by an outside expert. ,

36 ,..*. ..  . , . . .. /*: , Like hydrolysis, photodegradation is a major abiotic mechanism contributing to the transformation of orgdc molecules, but rarely responsible fbr complete degradation. Photodegradation occurs primarily in air, in shallow water, on soil and vegetative surfaces. It is likely an important factor in the hte of soluble and volatile compounds, less so for insoluble and sorbed compounds. Products and intermediates most SuSceptibIe to photodegradation are those most likely to be used outdoors in sunlight.

Initially, the degradation that might occur in products dissolved or suspended in water is under investigation. The first studies are Using the PFOS precursors such as EtFOSE alcoMl, MdOSE " alcohol, MeFOSA, EtFOSA, andFOSh Later Studies will WG POSF based polymers. If simple methods can be found, gas phase photolysis of volatile and semi volatile fluodemicd degradation'htmnediates will IX investigated.

The preliminary results suggest that PFOS is unchanged as a result of light exposure. However, EtFOSE alcohol, MeFOSE alcohol, EtFOSA and MeFOSA as well as a surfhctmt and foamer product all appeared to undergo photolysis to FOSA, PFOA, a hydride, and olefins. PFOS was not detected. One product, an aromatic perfluorooctane sulfonate, did photodegrade to form PFOS.

9.3 Afmospherle Studies Although PFOS has a low volatility, several PFOS precursors me volatile. These include: EtFOSE alcohol, MeFOSE alcohol, MeFOSA, EtFOSA, and FOSA. When present as residuals in products, these precursors could evaporate into the atmosphere when the product is sprayed and then dried Once in the atmosphere, the compounds can remain in the gas phase, condense on particulates present in the atmosphere and be carried or settle out with them, or be washed out with rain. The measured vapor pressure of Et FOSE alcohol is sufliciently bigh that essentially all of it is likely to be in the gaF; phaF; e and not condensed on particulate matter. Gas chromatic data suggest that other precuxsors are even more volatile. The low water solubility of these compounds makes it unlikely they washout from the atmosphere in rainwater.

Thus the rate of removal of these precursbrs firom the atmosphere will lik~ ly depend on their photochemical, reactivity, e. g. their reaction with hydroxyl ions in the atmosphere. How widely distributed they are locally, regionally or globally depends on the rate of photochemical transf'omation to more soluble or less volatile products.

3M is examining atmospheric Metimes of these PFOS precursors. Initially EtFOSE alcohol and MeFOSE alcohol will be tested for reactivity with the OH mdicsl in the gas phase. Modeling wiI1 determine their atmospheric lifetimes and analytical work will '

determine their gas phase degradation products. Then those propetties of the degradation 37 products that affect removal rates & om the atmosphere, e. g. solubility and vapor p m , will be determined. This information will be used to predict distribution of these compounds r e s d ~ ~ f i o m atmospheric mechanisms.

9.4 Blodegmdation Studies Biodegradation is essential to the functioning of living systems. Natutal system rely on living organisms, especially microbes, to break down complex organic molecules to simple inorganic molecuIes that can be recycled back into the ecosystem. Some microbial communities have demo the ability to degrade some xenobiotic compounds. During biologically catalyzed degradation of these compouuds, the degradation intermediates produced are fkqumtlypf a molecular structure that nahually OCCZVS. Particularly importaut envir0ntnmt. s for biological breakdown are: sewage treatment systems, soils/ sediments, estuaries and wetlands. Both aerobic and anaerobic organisms play important roles in degradation. 3M is studying biodegradation uskg several approaches.

9.41 Microbial Studies an Perflnorochemicils Work at Michigan State Universiv by Blake Key ( 4,7) under the direction of Dr. Craig Cridde used a laboratory isolate of a bacterium, a Pseudomum species, to investigate I the potential for biodegradation of fluorhatted sulfonates. The researchers used model fluorinated sulfonate compounds: & fluoromethane sulfonate @ FMS), trifluoromethane suIfonate ( TFMS), 2,2,2 trifliiomethanesulfanate ( TES), PFOS and H PFOS . ( lH, 1 H, 2H, 2H pe~ uorooctme sulfonate).

Criddle et al. demonstratcd th& t thc microorganism degraded thosc fluomclianical compounds containing hydrogen and used them as sulfur sources for growth under sulfur limiting, aerobic conditions. They later found that such degradation occurred in soil even when sulfur was not limiting. The organism completely defluorinated DFMS. It used DFMS as the sole source of sulfur, but not as a source of carbon or energy. TES and H PFOS were partially defluohted. Six volatile products were detected for H PFOS, all containing oxygen and fluorine but not sulfur. Where the carbons were fully fluorinated, i. e. TFMS and PFOS, no degradation was found. Cridde et al; concluded that the transformation of fluorinated sulfonates required the presence of hydrogen at the alpha carbon on the fluorinated alkyl chain. They theorized that when hydrogen is present at the alpha carbon, a site for attack is provided and the carbon sulfur bond becomes more accessible. Perfluorinated compounds have a rigidity confetred by the fluorine substitution and no structures that are susceptible to electrophilic or nucleophiSic attack , ._ . ,  . . . . . .. , . 38 , . "*_ . , . . . . .... .. .. . . . . . .

9.42 Biological Transformation When perfluorinated organic molecules do biodegrade, it is not the fluorinated portion Lhdt is affected. Enzymes attack at non fluorinated side chains. Rather than compiete degradatioa Le. degradation to inorganic compounds, another fluorinated molecule results from biodegradation processes. ' Existing studies of metabolism appear to indicate that for POSF based compounds; the biological degradation halts when PFOS is formed.

POSF PFOS . POSF derivative PFOS Once formed, PFOS has not been shown to degrade any further under any ~ turoll conditions except combustioa Because PFOS is resistant to physical, chemical and biological degradation, it persists in the environment, but the mechanism of accumulation IS under study.

9.43 Optimizing Conditions for Biodegradation Past studies on flwrochemicals with hydrocarbon portions have demonstrated resistance to biodegradation under sim& ud test conditions, i. e. aerobic microbial degradation using a wastewater inoculum. These studies did not examine all combinations of conditions that could be opthized to favor the degradation of pa+ lIy fluorinated chemicals.

3M is conducting new screening studies for biodegradation. These will'determine if aerobic ador anaerobic degradation of key fluorochcmieals occurs using activated sludge, anaerobic sludge, aquatic sediments and soil. f degradation occurs, the studies will determine to what extent it ocqm and the nature of degradation products. It will also provide information on the degree of fluomchemical sorption onto microbial sludges and toxicity to microbes. New studies are being designed to promote degradation. They will use enriched environments that support biodegradation, e. g. sewage, soil, s6djmmts, and cultures of microbes selected for biodegradation capabilities.

' 39   . . . ,. . , . .. ,_ . . . .. . ._ .... . 7 0.0 Ecotoxiclty Testing of Fluorochemicab Ecotoxicology is the extension of tozdcology to the ecological effects of chemicals. Ecotoxicological studies measure the effircts of a chemical substance in the mviromea on indigenous populations of organisms. They provide amwhanism to estimate M. Ecotoxicologicd data are appropriately interpreted with knowledge of the ecosym where the organisms he. Tn aquatic ecntnx studies, what may be toxic under co& tiom created m the laboratory, may be more or less toxic in the aquatic environment due to h t o r s present in the aquatic ecosystem which affect bioavailability. Also the chemid itself may be transfonncd 89 o rcsult of physical and biological mechanisms, including metabolism. An gkarate evaluation of the toxicity of a chemical requires knowledge of these factors.

Sulfonated perfluorochemcals appear to produce a variety of responses in single species tests of aquatic org&. DBercnt species have varied significantly in their response to the same chemical even when using the same laboratory procedure. In ecotoxicology, environmental concentration often substitutes for knowing the actual amount or dose of a chemical entering an organism, but concentration and dose may not be directly related and their relationship varies fkom species to species.

Basic environmental todcity m a k g data IUD av& lablo for mnny sulfonated perflwrochemicals ( see Table 12), although their quali6 is variable. In considerjng the toxicity test results, it is important to note the year of the test. Test protocoIs typically were developed considering water soluble, stable and well dispersed compounds. Compounds such as sulfonated pe\ rfluorochemicals challenge test protocols due to their insolubility, polymeric, or s h e active nature. The older data may reflect these test limitations. Older test protocols are not comparable to recent and current bioassays that follow accepted, standardized test methods ( OECDKJSEPA).

Almost all previous testing used products which are complex mixtures and not purified perfluorochemicals. In old tests, the suIfonatd perfluorochernical product us8cz was liiely mom variablc, with mom i. mpuritks bccau~ t m* cturing proccsscs and product purity have significantly improved over time. Several tests were hampered by the insoIubility of the perfluomchemical and results are expressed as greater than the measured solubility.

Two sulfonated pduomchemicals have more toxicity test data than others because of their use as insecticides in ant and roach bait stations. These pduorochemicals are N EtFOSA and PFOS Li salt. Toxicity data on these compounds may be found in the disclosures filed by other regis ts under the Federal Insecticide, Fungicide and Rodenticide Control Act ( FIFRA).

40 . . . . . .. . .

Twt Orgaolsm ., . 1 . .

StudyType Year 3M has evaluated the reliability of its aquatic toxicity test data base. The numaid descriptor is model& after the reliability coding used by EPA's Office of Toxic Substances for the AQUIRE ( Aquatic Idormation Retrieval) toxicology data base.

Pirn& alts promelas Daphniamagna Table 12. Ecotoxicity Testing on Sulfonated Perfluorochemicai Products 30 day hatch, .020 78 W histopathol~ kY , 2D growth, SUNiVal 2D NUEC . mo 7s 2D LOEC >.( I20 48 hr EL50 14.5 98 2 w 48hrELIO 7.3 98 2A, c  . . . . . . . . .

Daphnia magna Pimephales pornelm Reliability Cdw. 1. Study USMI published ftsl @ eu3Hts or well doeurnenred procedures. C 01 pe ce ~ a 9 satisfactory. Toxicant i; onceOtration was meBsumd Test water temperature, pH and dissolved oxygen were measured. 2. Study meets all the criteria far quality testing but has one or more ofthe following dafichcieacies: A. Nominal test substance concentnation; actual conecntration n@

measut6d.

C. A water accommodated fkaction ( WAF) WBS used. D. An8lyticaI methodology WBS questionable.

A. Demonstrated weaknesses in expcrimentalprocedures. B, A statfc tesf with uome8suTed concentrations was conducted ia the pnsencc of precipitate or some undissolved chemical C. insufficient description of methods. D. Uns&& Wory oontrol mortality, B. Test water quality Mpiabtes not Feportctd or incomplete.

3. Study does not meet the u i t d for @ ity testing. Chmctedzed by one o f the following:

3 2 34 Product% Principal Fluorochelhical WSF N MeFOSE alcohol N EtFQSA I I Pinrephales promelm 96 hr LQO I > LO00 , / 84 2A 3B 48 k NOEL % hrWO % hrNOm, 48 hr EL50 48 kELl0 48 hrNOEL MhrLLia 5.8 206 115 130 328 184 216 98 '

98 98 98 98 98 98 84 84 41 ..,_ . . . . . . . . ~  . ~ ............. . . . . . . . . . . . . . ~

. . . . , ... ,.,.. ,.& .... ,. ............  . . . . . . . . _ * ..,__ . ..,  ~.~

.,:

I . . . . . . ' . . . .. r..,. ,

82 2A I 78 2D 7s 2D 77 2A 78 2A 79 2A 74 2A 73 2A 179. 2A 1 92 2A I 78 2A 179 ' 2A hurdUCt' 8 hindpal Flnorochcmical Pim& altspromeh  macrochina Dophnfa magna Pimephula prom& h! limm PimevMa llromelm PFOS Li salt 96 hr LCSO 96 hr LCSO 96 hr NOEL 48 hr ECSO 96 hr LCSO 30 min ECSO 96 br LCSO PFOS K salt:

97 97 $ 7 97 97 97 PFOS DEA , Salt peffluoroCl0 sulfonic skid, N) 4+ salt K salt of csrbo~ fic acid analogue of N Et FOSE alcohol 24 2A 2A . 2A 2A 2A N EtFOSE && Ol ethylene oxide adduct I Code P ~ w a ~ n t e & s 96 br LCSO ~ 1OOO 84 3B \ Pim& huItwpromeim 96 hr LCSD =+ 1000 ~

84 3B Pimephalarprmercls 96 hr LCSO 85 74 3 A P h ~ ~ p r o ~ 96 hr E50 Micrptox P. phatporeum 30 min EC50 Lkaphniamagnil 48 hr EC50 48 hr NOEC Ptmephulespomelus I 96 hr LCSO Microtox I 30 min EClO 30 min EC50 48hrEC50 28 day NOEC 4 day ECSO cellcount ' 14 day EC50 cell count 30 day NOEC 30 day LOEC 96 hr LC50 96 hr LCSO 96 hr LC50 48 hr ECSO 96 hr LC50 Lepomis macrochkur "

Daphnia mrgna 96 br NOEC 96 hr Ed50 96 hr NOEC 48 hrEC50 48 hrNOEC 30 min IC50 96 hr Le0 100 > lo00 ' 210 100 19 ~

45 > 280 27 7 82.

95 1 1.9 38 68 11 50 29 32 31 18 44 4.8 330 97 54 600 216

9. L 3 9 270 518 15 285 1.5 78 2A Table Key EC5o. L Median Effective Concentration. It is the mucentration of a test substance that causes a 50% ef% tct on a specific charactars tic of the test ocganim ( e. g. immobilization of SO? k afthe Daphnia, redudion in algat ceu gwwE by 50% xs compared lo endpoint in a toxicity test with DapW and other small ogatlhs where death is hard tu determb or in tests where growth is measured. Contds) after a specified exposure period. It is the usual 42 , , . . I , . . _ . ..: . . . . . . . . .  .. . , . , . . .? ._. . . . . . . ~ , ~ ~ ..., . I . . . . ~.

I _._ . _ I. L a p Median Mal C o n c ~ t i o n . It b the caneentretion of a substance that kilk SO?! of the test organisms exposed to it in a specified time. It is the usu81 dndjpomt in an acute vlxicity test with fish.

1 ~ 5 0  ~ f i ; ~ i a o Inhibitory Couaocratiua It is the concentnitton or a tesf substance maf intaibfts a biological process of a test organism by 50% ( e. g. I i i t production, respiration) after a qmified exposure period NOEL= Nn Chewed Effect Level NOEC No Observed Effect CrmcentratiOn . _ _  . .

ELPiEffectve M g , WL LedLal loading. Thac are used whera the test substance is not completely water soluble. A water accomodated fradon ( WAF) is prepan? d The test substance is loaded into water at different loadings to prepare each test concentmion. The solution^ are mixed and the liquid W o n is decanw to usc as the . fcst Wata.

Additid studies are unde~ way on ecotoxicity Using established OECDIEPA methods. Initially purified PFOS and EtFOSE alcohol B T ~ being tested to determine acute and chronic toxicity to a wide range of species. The results to date ah found in Table 13.

43 Y r a . . a,. . , . ' I '?.' . '' Table 13. New Ecotox Studies on PFOS, potassium salt . I e .

Parameter Wastewatef Bacteria ( OECD 209)

Senenasmun capicconnrhc ( green algae)

DapWmagna ( freshwater flea)

~ s & p s f s bahta ( marine shrimp)

Freshwater mussel I PimnepMespromelmr ( ffiaad Illiuuow)

water Shell Depositian Aviad Dietary ToXicW Testing . . Study Type Results,

36rNOEc 1.0 mg/ L 3 hr. EC50 .1080mgn mgn) 3956   Inhibition ( r3 highest con~ ( 1000 96 hr NOEC ( growth rate) 96 hr ErClO 96 hr. ErC50 Acute 48 hr NOEC . Acute 48 hr EClO Acute 48 hr K50 Acute 48 hr EC90 21 day stmi statiC life cycie NOEC 21 day Semi static lifecycleNOEC Acuta96hrNOEC 1.2 m a Acuas 96 hr EC50 4.00.3 5.0) mgfL 35 day flow thru life cycle NOEC 0.28 mg/ L 35 day flow thm life cycle NOEC 0.6 mrJr. Acute 96 ht NOEC Acute 96 hr LC50 65m&  48 m a 65 69 69] mgA.

36 mg/ L 57 ( 42> 99) mg/ L 69 ( 42399) m@ L 13 m& 26 m@ L 138 ( 125 149) mg/ L 66 ( 36 99) mgn,

22 m&

Acute 96 hr. NOEC AGUW 96 IIr LCSO 47 day eaciy lifP. stage toxicii NOEC 47 day early lifissrage toxicity LOEC Acute 96 hr NOEC Acute 96 hr ECM ( Solubility l i i t s precluded ECSO) Inhibition @ highest conc ( 3.3 m@) 3.6 m a 0.33 mgiL 0.65 mglL 2.1 mgL ~ 3 . 3 m'fl IO ( 8.812) m&

28% Acute Maliant Duck LCSO 730 ( 532 IUS9J mg'kg AcuteNalIardDuck, IWmortality 160 m&

All of the results shown in Tabie 12 suffer from limitations in the reliability of the data, and thoro is n olwr ncod for high q d t y Ccoto~ city dab using Cstablishca OECDlEPA methods. Testing on purified PFOS and EtFOSE alcohol is in propss. However, the available new & a ( Table 13) and the historic data are conSistent h that almost all toxicity values for PFOS and related suIfomted gerfIuorochemicals are greater than 1 mg/ L and most are greater tltEm 10 m&. An excqtion is the fatliead minnow msults reported on Table 12 for N EtFOSE alcohol where apparently there is no acute toxicity at 44 (,

Acute MaIlard Duck NOEC A~ UaBabwhit~ QUailLC50

AcutG Dobnhibc Quail, no mortality Acute Bobwhite Quail NOEC . . . 40 m e 214 ( 163 260) m& BO fk&

80 m& 4 l or above the water solubility level. The available nwdata on PFOS itself suggest that it has SMEW aquatic toxicity to that of other anionic surfactants ( 9). Few other concIusiox1s can be reliably drawn at this tiale. Fbr instan=, ecological risk assessment typically concIusioDs. .  dies on chronic toxicity V ~ W S , but th too few data on this to draw any . . . 1 I . O Comprehenshr Plan to Assess Environmental Exposure The ongoiug activities described in the previous sections of this paper are being carried out 8s part of a 3M developed comprehensive plan using B combination of 3M resoyrces ami outside experts. This plan, summwwd in Figure 1, is designed to assess the potential pathwaysof envhnmerttal qosure associated with the man, use and disposal of its sulfonated perfluorochemical products.

The plan structure consists of four components:

1. Characterize the properties critical to understrurding the fit6 and transport of sulfonated perfluorochemicals.

2. Estimate the releases of suifonatedperfluorochernieais.

3. Characterize the distiiiution of sulfonated perfluorochemicals in the environment.

4. Estimate human and ecological expos& to sulfonated perfluorochemicals.

Several individual research projects feed information into each cumponent. The mIy . components provide information needed to mmpleb the later ones. Thus the Wormation base expands when one goes hrnwmpomt I to cornponmt 4.

This section provides 80. overview of the plan and its research projects. Specific descriptions of how and why the research projects are being conducted can be found in the preceding sections of this document. The results generated by this plan wilI be combined with the ecotoxicological studies to develop an assessment of risk. A tentative , initiation c4xte for each of the research projects is found in Figure 2. It is ewcted that the studies will continue over several years.

45 E Figure I Diagram of Fluorochemicaf Assessment Plan.

. ."

46 . / Figure 2 Schedule for FC Exposure Plan Components.

lQ First Quarter, 2Q= Second Quartet, 3QcThird Quarter, 4Q= Fourtb. Quarter Characterke Fate & Tmnspart Pmpertl* PFOS PhyolChem Pppertiqct EtFOSE alcohol PhyaFChern Pkpertl&  MeFOSE alcohol PhydChem Properties Hydrolysis Photodegradation and AtmospheiicTransport Biodegradation ( aerobic and anaerobic) Sorption. Processes EtFOSE alcohol Bimcentradlon J c . PFQS Bioconcentration Initlation Dates Complete lQ2000 ? Q 2000 ? Q 1999 IQ 1999 IQ 1999 2Q 1999 2Q 2000 4Q 2000 Estimate Release8 3M Plant Effluent 81 Process Waste Analyses I Q 1999 Estimate Mfg, Supply Chain, & Use Waste Streams Estimate' Waste Releases IQ 1999 FC Thermal Destructability 2Q 1999 Complete Characterize Dlstrlbution ln Envimnment Bird 8, Fish Analyses U. S. Bird Livers Analyses Biosphere Sampling Pan Multimedia Modeling Muiti cities study. Complete Complete iQ 4999 la 2000 i Q 1999 Estimate Exposure Carpetstudy Paper and P@ caging Studios Ekposure Scenarios 2Q 1999 IC? 1099 24 1999 Ecotoxicity Daterminations PFOS Acute Eootoxicity PFOS Chronic Ecobxicity EtFOSE alcohol Acute Emtoxicity EifOSE alcohol Chroniq Ecotoxicity FOSA Acute Ecotoxicity FOSA Chronic Ecotoxicity 1Q 1999 2Q 1999 29 2000 .3Q 2000 1Q2000 2Q 2000 ' 47 1' . . ' ' ' " . .. .( . . . . , ' T n" pT'.,".""* ...... .. ..... ... . . . , : . I . , . . . . _ _ _ . ,., .. , WY. > am . 1. 1 .. , 11.2 Component I: Chamcterize Feb and T'nbparL Pmperi; fes This component was developed in three steps. First, the important fate and'transpo; m c c W m wcm identifid. Next, priorides were set for tesdng, with the likely degradation products having the highest priority for tesfipg. Finally, methods and laboratories were selected to do the testing. For sulfonated perfluorochedds not tested, models are being developed that wiU predict physical and chemical properties. The specific research projects underway are: . _

1. Physical and chemical properties testing. 2. Hydrolysis testing. 3. Photodegradation and atmospheric transport teding. 4. Anaerobic and aerobic biodegradation testing. 5. Soil and sediment sorption testing. 6. Bioconcmtxatioon testing.

77.3 Component 2: Estimate Releases This component was also developed in s e v d stages. First product sales data h r n 1997 were used to identify a study set of products. The study set was based on volume of use and wqste streams, mqde of release and product chemistry. Next, evaluation efforts of the waste streams generated focused OB those study set products sold by 3M in the gremst quantities in the United States. Commercial and residential uses of these prcdu~, including transportation, handling and appiication during the supply chains that lead to product use, were examined. Additionally, the releases likely to result h m disposal during these portions of the products' life cycles weze also estixnated. The estimates included disposal via incineration, landfilling and wastewater treatmest.

Waste streams genqtexi at the start of the products' life cycles, i. e. the manufiicmhg process, were also examined. Better estimates are contintiiug to be developed of waste streams occurring during the Illan process.

f7A Component 3: Characfenize Didbution in the Environment This component is distinguished by iterative interaction between modeling and field sampling. Models are being used to suggest sampling locations and detection limits. Field sampiing is planned to obtain empirical data to validate mode1 output and hprove predictions. As new data become available, research projects become more refined and focused. The research projects completed or planned to characterize environmental distribution include: , r 48 .__ c_ . . . . .. .. .. . . . . . ... ._.&.. I .. ...... I. 1. Field samphg of environmental media near the Decatur manufacaning plant. 2. Screening of eagle and albatross plasma and fish tissue from archived samples. 3. Analysis of wild bird livers. 4. Biosphcrc sampling plan to dctaminc lcvclj in biota of diff'nt geographic locations. 5. Development of a mdtimda model for predicting distribution. 6. Multi cities studies in which cities of a similar SiZR are paired, one demonsbating sigdficant manufhctmhg or commercial uses of sulfonated perfluorochdcals, the other having no identifed use of sulfonated perfluorochemicals. _ .

f1.5 Cqmponent 4: Estimate  ? rposunr When data from the release and Wbution cpmponents are avrtilabb, hypotheses will be developed about important exposure pathways. Iterqtive sclmpling and modeling will be used to test these hypotheges and to detenrrine the important exposure pathways to be used in risk assessment. The research projects planned to estimate exposures are:

1. carpet releases and links to ingestion, inhalation and dennal exposure. 2. Paper and packaging studies and ingestion exposure. 3. Exposure scenarios m c h combine information from the release, f& te, and sampling studies.

12.0 Ecotoxicity. Determinations In conjunction with the studies described in the four component plan described above, 3M is conducting ecotoxicological studies. Ecotoxicological studies arellsed to estimate hazard. Initial ecotox testing is focusing on PFOS, EtFOSE alcohol. and FOSA. The results of the release, distribution and expome assessments may provide reasons to test more substances.

The following research projects on ecotoxicity m planned or underway:

1. Aquatic acute UIXIclty studies: sewage microorganisms, freshwater and marine algae, duckweed, daphnia, mysid shrimp, kshwater mussels, fathead minnows. _ _ 2. Terrestrial acute toxicity studies: mallard duck and bobwhite quail dietary exposure studies, earthworm toxicity studies, and green plant growth and uptake studies. 3. Aquatic chronic toxicity studies: oyster shell deposition, daphnia, mysid shrimp, frog embryo development and fish early life stage studies.

49 I .

4. Terrestrial chronic toxicity studies: mallard duck and bobwhite quail reproduction.

13.0 Ecological Risk Evaluation Evaluating ecologkd risk is mom complex anclrnore u n d than assessment of human heal* risks whme a clearer connection can be dram between dose and response.

L As this comprehensive science and exposure assessment pmgram progresses, a framework in which ecological d9k catl be evaluated wiU be developed. The evaluation of ecological risks and human risks will both use information about distribution in the envjronmenf and exposure^ gemrated by this comprehensive exposure plan, Because of . the scope and magnitude of the overall program, aspects of the knowledge gained will be compartmentalized into discneet elements to create this Wework. For example, as data on ecotoxicologid prope'rties, fate and ttmsport mechanisms, and environmental clisuibution art: devdoped, they will be used to evaluate ecolo@ cd risk within a certain geographic area or localiry. The science data and environmental sampling results will be applied to a very speciiic area and set of species to evaluate relative risks in that area. Building a number of these compartmental evaluations will fesult in a much more complete picture of ecological risk. This evaluation will identi@ additional actions 3M could talc@ to minimiZe themleases of sulfonatedperfluorachemicats.

50 14.0 References i 1. Coben, J. J. and Covello, V. T. Risk M y s i 8 : A Guide to Principfes and Metho& for Analyzm * g Health and EavimnmentalRisks, U. S. Council on Environmental Quality, ExecutEve Office of the President, 1989 ..  .

2. Fate, Transport and Tdormation Test Guidelines. Office of Preventiow Pesticides and Toxic Substances ( OPPTS) 835.21 10, Hydrolysis as a Function of pH and Temperature, EPA 7124 98 057, Jauuary 1998.

3. Flynr~ RL. in `` Mustrial Applications of Organochlorine Compounds," P r o c ~ s of the Symposium on Electrochemistry in the Preparation of FIuorine a d Its Compounds, Childs and F~ Bgami, EMS, The Electrochemical Society, Inc.: Pennington, NJ, 1997; 97 IS 51.

4. Guidelines for the Testing of Chemicals, vol. 1, Section 1, " Physical Chemical Properties," Organisation for Economic Co operation and Development ( OECD), Paris, France.

5. Guidelines for the Testing of Chemicalsz vol. 1, Section 2, ` Zffects on Biotic syitems," Organisation for Econorm ` c Cwperation and Development ( OECD), Paris,

6. Key, B. L.; Howell, RD.; Criddle, C. S. " FluoFinated Organics in the Biosphere,)' Emiron. Sei. Tecbol, 1997,31: 244 2454"

7. Key, B. L.; Howell, Rb.; Griddle, C. S. " Defluorination of Organofluorine Sulfur Compounds by Pseudomonas Sp. Strain D2,"' Emiron Sci. Techno!, 1998,32: 2283 2287.

8, Mackay, D. SKU, W. Y., and Ma, K. C., lllustrarted Handbook of Physical Chemical Properties and Envitonmental , Fate for Or~ anic Chemicals. Volume I: Monoaromafic Hydrocarbons, Chlorobenzcnes and PCBs. Lewis Publishers, Chelsea, MI. 1992.

9. Scholz, N., " Ecotoxiwlogy of surf8ctants," Tenside Swfactmts and Detergents, 1997, 34~ 229 32. . . .

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