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3M Environmental, Health and Safety Operations 3M Center, Building 0224-05-W-03 St. Paul, MN 55144-1000 September 18,2014 Federal Express U.S. Environmental Protection Agency EPA Docket Center Docket AR-226, Mail Code 28221 T 1200 Pennsylvania Ave., N.W. Washington, DC 20460 Attention: OPPT Docket No. AR-226 RECEIVED OPPT CBIC 201~ SEP 30 A~lll: 50 CBIC Control Number 362022 Subject: Environmental Assessment of Perfluoroalkyl Sulfonates at the 3M Decatur, Alabama Manufacturing Site Dear Sir or Madam: On October 24, 2004, U.S. EPA and the 3M Company entered into a Memorandum of Understanding (MOU) to execute a Screening Level Human Exposure Assessment for perfluorooctanoic acid (PFOA). This program required that various environmental media on and off the 3M Decatur, Alabama manufacturing site be sampled and analyzed as defined by an extensive work plan. The last phase of this study was completed and summarized in a repott submitted last year to U.S. EPA entitled "Addendum to the Data Assessment Report". Accordingly, all commitments under this program have been fulfilled and the entire program is documented in the Electronic Docket OPPT 2004 0112. Since the 3M Decatur site also was used for the manufacture ofperfluoroalkyl sulfonates, 3M voluntarily conducted a separate enviromnental monitoring program of substances that had been or were being manufactured at the site. The substances that were included in this envirorunental monitoring program were perfluorooctane sulfonate (PFOS), perfluorohexane sulfonate (PFHS) and perfluorobutane sulfonate (PFBS). Enclosed is a report entitled "Addendum to the Perfluorinated Sulfonates Data Report" that presents the perfluorinated sulfonates results for samples collected under the aforementioned final phase of the MOU program. The analytical data and environmental assessment of this monitoring effort are being submitted to the AR-226 Docket to augment information pertaining to fluorochemicals at this location. The report is being submitted in hard copy and electronic (CD) formats. It should be noted that 3M has entered into an agreement with the Alabama Department of Environmental Management to execute a project of capping the former sludge incorporation fields on the plant site. This project includes the installation of a protective liner over the fields that is then covered with two feet of clean soils to U.S. EPA Docket Center September 18,2014 Page 2 support growth of natural vegetation. Significant progress has been made on this multiyear effort. Several additional mitigation measures have also either been completed or undertaken to reduce potential releases to the environment. If there are any questions or comments concerning this matter, please contact me at (651) 737-3570 or gahohenstein@mmm.com. Regards, X1l(1tt?; tf. l.I Gary Hohenstein Manager of Environmental and Regulatory Afiairs 3M Center, Building 224-5W-03 St. Paul, MN 55133 Enclosure cc: Toni Krasnic- Mail Code 7405M (with enclosures)