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Creative Techf'l(J/Og/es Wolfdwlde March 1,2016 Via Courier

Document Control Office (7407M) 

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Office ofPollutionPrevention and Toxics (OPPT) U.S. Environmental Protection Agency 1200 PennsylvaniaAvenue, N.W. Washington, D.C. 20460-0001 SanitizedVersion

CBIC Control Number 

# 368340-S

Re: Supplemental Comments on Proposed Significant New Use Rule for Long-Chain Perfluoroakyl Carboxylate and Perfluoroalkyl Sulfonate Chemical Substances, DocketNumberEPA-HO-OPPT-2013-0225 To Whom ItMay Concern: As requested by the EPA, W.L. Gore & Associates, Inc. (Gore) is pleased to provide these comments to supplementthe original comments we filed in a letter dated June 16, 2015, which is attached for your convenience. Gore is pleased to confirmthatthe commercial uses numbered 1through 5 in our original letter have ceased. 1 Commercial uses numbered 6-11 in our original letter are continuing. Supplemental info1mation regarding each ofthose uses is includedbelow. 6. The cables and cable assemblies returned to Gore for repair are articles, and may contain traces ofAPFO (CASRN 3825-26-1), because APFO would have been the surfactant used by our suppliers in the polymerization ofthe fluoropolymer raw materials. The fluoropolymers inthe cable and cable assemblies returned for repair could include, but are not limited to: ]. Gore expects to receive returns ofthese aiticles for repair from both domestic and international customers, until ]. As mentioned inthe original comment, ourrepairs willnotuse LPCFAC basedmaterials.

In footnotes 7 and 8 ofGore's original letter, we noted several uses that are not subjectto the SNUR. We are notundertakingto provide supplemental information for thoseuses.

W. l, GORE &ASSOCIATES, INC. LEGAL OFFICES 551 PAPER MILL ROAD. P.O. Box 9206 NEWARK, OE 19714·9206 •US PHONE: 302.738.4880 •FAX: 302.292.4153 •FAX: 302.731.9098 gore.com Gore and design are trademarks ofW. l.Gore &Associates.Sanitized Version

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7. The aerospace products referenced in this continuing use are produced via a complex internal supply chain involving multiple Gore locations, both domestic and international. The products contain the following fluoropolymers:

8. We cannot rule out the possibility that the fluoropolymers in the current products contain traces ofAPFO (CASRN 3825-26-1), because APFO could have beenthe surfactant used by our suppliers in the polymerization of one or both of the fluoro olymer raw materials. The products also contain

Validation of new products made without LCPFAC materials is ongoing. United States portion ofthe manufacture ofthese products has ceased, and global production will cease by ] . Im ortation and sales of finished articles are expected to cease by ] . The venting products fluoropolymers, one ]. This fluoropolymer contains traces ofAPFO (CASRN 3825-26-1), because APFO was the surfactant used in the polymerizationprocess. We have approximately

# tml kilograms ofthe fluoropolymer remaining in inventory. Processing is expected to cease by**~],** and sales are expected to be completed by 

# ...------· 9. The venting products referenced in this comment are made from -] which contains traces ofAPFO (CASRN 3825-26-1), because APFO was the surfactant used in the polymerization ofthe fluoropolymer raw material. We have approximately**~]** kilograms ofthe fluoro olymer in inventory. Processing ofthe fluoropolymer is expected to cease by ], and sales are expectedto be completed by 10. We still lack sufficient information from our suppliers to provide EPA with a definitive list of LCPFAC based materials that may be in the various plastic articles that we purchase to make our cable and cable assemblies. Ty ical fluoropolymers used in these miicles would include but are not limited 

### to: ] . The most likely LCPFAC to be present in trace amounts is APFO (CASRN 3825-26-1).SanitizedVersion

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11. As mentioned in our original comment, it will take some of om customers and distributors multiple years to cleartheir supply chains ofLCPFAC based miicles. While we do not understand these downstream supply chains in detail, we expect that downstream sales will continue for at leastfive years. Itrust that this additional infonnation is helpful. Please do not hesitate to contact me ifyou have further questions. Sincerely,

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