juORE?f 

Creative Techf'l(J/Og/es 

Wolfdwlde 

March 1, 2016 

Via Courier 

Document Control Office (7407M) 

HECEl\/CO 

OPPT CB/C 

2016 w" nl11i -2 PM 3: 29 

Office of Pollution Prevention and Toxics (OPPT) 

U.S. Environmental Protection Agency 

1200 Pennsylvania Avenue, N.W. 

Washington, D.C. 20460-0001 

Sanitized Version 

CBIC Control Number 

368340-S 

Re: Supplemental Comments on Proposed Significant New Use Rule for 

Long-Chain Perfluoroakyl Carboxylate and Perfluoroalkyl Sulfonate 

Chemical Substances, Docket Number EP A-HO-OPPT-2013-0225 

To Whom It May Concern: 

As requested by the EPA, W.L. Gore & Associates, Inc. (Gore) is pleased to 

provide these comments to supplement the original comments we filed in a letter dated June 16, 

2015, which is attached for your convenience. 

Gore is pleased to confirm that the commercial uses numbered 1 through 5 in our 

original letter have ceased. 1 Commercial uses numbered 6-11 in our original letter are 

continuing. Supplemental info1mation regarding each of those uses is included below. 

6. The cables and cable assemblies returned to Gore for repair are articles, and may 

contain traces of APFO (CASRN 3825-26-1), because APFO would have been 

the surfactant used by our suppliers in the polymerization of the fluoropolymer 

raw materials. The fluoropolymers in the cable and cable assemblies returned for 

repair could include, but are not limited to: 

]. Gore expects to receive returns of these aiticles for repair from both 

domestic and international customers, until ]. As mentioned 

in the original comment, our repairs will not use LPCFAC based materials. 

In footnotes 7 and 8 of Gore's original letter, we noted several uses that are not subject to 

the SNUR. We are not undertaking to provide supplemental information for those uses. 

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. 
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March 1, 2016 

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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 of APFO (CASRN 3825-26-1), because APFO could have been the 

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 of the manufacture of these 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 of APFO (CASRN 3825-26-1), because APFO was the surfactant 

used in the polymerization process. We have approximately tml kilograms of the 

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 of APFO (CASRN 3825-26-1), because APFO 

was the surfactant used in the polymerization of the fluoropolymer raw material. 

We have approximately ~] kilograms of the fluoro olymer in inventory. 

Processing of the fluoropolymer is expected to cease by ], 

and sales are expected to be completed by 

10. We still lack sufficient information from our suppliers to provide EPA with a 

definitive list of LCPF AC 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 LCPF AC to be present in trace 

amounts is APFO (CASRN 3825-26-1). 
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11. As mentioned in our original comment, it will take some of om customers and 

distributors multiple years to clear their supply chains of LCPF AC based miicles. 

While we do not understand these downstream supply chains in detail, we expect 

that downstream sales will continue for at least five years. 

I trust that this additional infonnation is helpful. Please do not hesitate to contact 

me if you have further questions. 

Sincerely, 

~>~ ?/;/' ?/:?_tfr?Z_,,;;μ~Q::J ~a;·~ NL MaloneyB:S~' Counsel