Document 2q98Z8GoqELD04N9RKgdydrp7

3M General Offices 3M Center P . Paul, MN 55144-1000 ~~~i . St 651 733 1110 ~c j'~ ~ 3M October 25, 2007 ` . _- - ~ , ' IJ VIA UPS Document Control Office (DCO ) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agenc y EPA East, Room 642 8 1201 Constitution Avenue, NW Washington DC 2046 0 Attention: Docket No . AR-226 and the PFOA Electronic Docket OPPT-2003-0012 Subject : Fifth and Final Submission of Monitoring Data Pursuant to the 3M LOT dated March 13, 2003 and PFOA Users LOI dated March 14, 200 3 Dear Sir or Madam : This report is submitted pursuant to the 3M Letter of Intent (LOT) dated March 13, 2003 and the PFOA Users LOT dated March 14, 2003 . The report is the fifth and final submission under the Letters of Intent of the results of groundwater and wastewater monitoring at the 3M manufacturing sites at Cottage Grove . MN and Decatur, AL . Perfluorooctanoic acid (PFOA) was previously produced at these sites . In addition to the data tabulated in this submittal, additional surface water, sediment and fish samples were collected from the Tennessee River in December 2006 . Final analytical reports for these samples are not yet available . When they are completed, the results will be submitted as an addendum to this annual report . As noted in the 3M LOT and in the 3M submission pursuant to this LOT, monitoring of wastewater treatment plant effluent and groundwater for the presence of PFOA has been underway at the Decatur and Cottage Grove sites for a number of years . This monitoring was initiated as a result of 3M voluntary commitments and/or plans established through permits with local regulators . Under the 3M LOT, 3M agreed to continue this monitoring in order to assess the trends that are likely to occur as a result of the 3M production phase-out of PFOA, completed at the end of 2002 and the discontinuation of the use of PFOA at the Dyneon fluoropolymer manufacturing facility . Because the Dyneon and former 3M manufacturing operations are located at the same site, it was determined that monitoring would be conducted and reported jointly by 3M and Dyneon . The description of the monitoring program under the LOIs can be found in our May 7, 2003 letter to Ward Penberthy of EPA, and in our first Submission of Monitoring Data dated August 1, 2003 . These two documents have been entered into the AR-226 Docket and the PFOA Electronic Docket 2003 - 0012 . Please refer to those two Dockets for background information and a detailed description of the test methodology, sampling plan s CONTAINS NO C61 2A7/1I A(, UV UN p. 2 Page 2 of 9 Document Control Office (DCO ) Office of Pollution Prevention and Toxics (OPPT) U .S . Environmental Protect ;-- A.o~a.,i;cv~ and proposed test schedule for wastewater and groundwater monitoring at the Cottage Grove and Decatur sites . COTTAGE GROVE, MN SITE MONITORING DATA Monitoring Result s Groundwater Monitoring As explained in the previous submittals, 3M selected five groundwater sampling locations for semi-annual PFOA monitoring . The five monitoring points were chosen as representative of the following site conditions . (Please consult the site map attached to the report dated August 1, 2004) : Monitoring Point Site Condition MW-7 Upgradient of site industrial activities MW-4 Central to site industrial activitie s PZ-14 Western/downgradient of site industrial activities MW-101 Eastern/downgradient of site industrial activities Water supply distribution system Site-wide ground water from the production well s Since submittal of the last annual LOI report, the only PFOA monitoring data that has been generated has been for the Water Supply Distribution System location . Additional 2006 sampling events occurred on July 31 and November 7 . The results of these monitoring events and previous sampling results for these points are presented in the attached Table 1 . Sampling of the water supply distribution system was substituted for sampling of the individual high-capacity pumping wells because the water that supplies this system is a composite of water drawn from these wells and therefore is representative of groundwater throughout the developed portion of the site . It should be noted that a granular activated carbon (GAC) treatment system was installed at this sample location in late 2004 . The results for samples collected on March 12 and June 22, 2005 represent post-treatment water. As expected, PFOA was not detected in these samples at a limit of quantitation of 0 .025 ug/L . For subsequent sampling events, inlet water was also collected in order to continue the trend analysis in the water supply distribution system . Results presented for samples collected after June 2005 represent water collected prior to GAC treatment . Effluent Monitorin g The site has a multi-phased wastewater treatment plant that is used to treat all process wastewaters generated at Cottage Grove . Two of the systems treat inorganic wastewaters and the third is an organic, biological treatment system . All of the process effluent wastewater is treated with activated carbon . The treated process wastewaters from these operations are combined at a single discharge point and then are further combined with non-contact cooling and storm water before being discharged to the Mississippi River . p. 3 Page 3 of 9 Document Control Office (DCO ) Office of Pollution Prevention and Toxics (OPPT) U .S . Env :ronme,ntal Protection Agenc y Since January 2001, the 3M Cottage Grove plant has conducted PFOA analysis of its effluent. Sampling has been performed monthly beginning in January 2003 in accordance with the requirements of 3M's NPDES permit . This information is reported to the Minnesota Pollution Control Agency in the monthly Discharge Monitoring Reports . Effluent wastewater samples are collected at the plant outfall to the Mississippi River . This is the common discharge point for all of the plant's process wastewaters . All samples are collected as 24-hour composites and duplicate analysis is conducted for each sample . The monitoring results of the Cottage Grove process wastewater effluent discharged under Minnesota NPDES Permit No . MN000149, Outfall SD 001 are shown in the attached Table 2. The data includes results of all monitoring events in 2006 and from previous years . As shown in Table 2, PFOA levels have clearly dropped since the original submittals under this LOI program . As mentioned above and in previous meetings and reports, several years ago, 3M installed an activated carbon treatment system to remove certain constituents from the wastewater treatment plant effluent . This system has been optimized and is in full operation . While the system was installed for reasons unrelated to PFOA, this technology has been shown to be effective in removing this substance as well . 3 p. 4 Page 4 of 9 Document Control Office (DCO ) Office of Pollution Prevention and Toxics (OPPT) U .S . Environmental Protection A penc v DECATUR, AL SITE MONITORING DATA Monitorin g Results Groundwater Monitoring As stated in the previous submissions, 3M selected the following wells for groundwater sampling and PFOA analysis going forward (see site map attached to the August 1, 2004 report) : Monitoring Location Site Conditio n Wells 226R & L Located east of inactive landfill and south of wastewater treatment - monitors background conditions in residuum and shallow limestone groundwate r Wells 220R and L Located northeast of inactive landfill - monitors predominant flow path of plume in residuum and shallow limestone zone s Well 320L Located north of inactive landfill - monitors secondary flow path of plum e Wells 327R Located in the former incinerator area - monitors residuum groundwater near source are a Wells 310R & 317L Located in the Chemical Plant - monitors dominant groundwater flow pathways in the Chemica l Plant Groundwater samples from the eight monitoring points were collected in November 2006 . The PFOA results are presented in the attached Table 3 . As indicated by the data presented in Table 3, there is a wide range of PFOA levels measured in the groundwater beneath the site . Effluent Monitorin g 3M's Decatur, Alabama manufacturing facilities obtain process water from the City of Decatur Utilities and directly from the Tennessee River . In addition, many of the manufacturing operations utilize non-contact cooling water, which is obtained from the Tennessee River . All process wastewaters from the 3M and Dyneon manufacturing operations are treated in the site's wastewater treatment facility . The system contains both physical-chemical and biological treatment . Process wastewaters are mixed with noncontact cooling water prior to discharge to the Tennessee River . The discharge is permitted under Alabama NPDES Permit No . AL0000205 . The process wastewater ly- p. 5 Page 5 of 9 Document Control Office (DCO ) Office of Pollution Prevention and Toxics (OPPT) U .S . Environmental Protection Agenc y discharge and combined process wastewater/non-contact cooling water is designated as Outfall OO1A and 001, respectively . As explained in our May 7, 2003 letter, wastewater sampling at the Decatur site for PFOA analysis has been conducted on a quarterly basis . Samples are collected at Outfall 001, which consists of treated process wastewater and cooling water . The outfall discharges to Baker's Creek, which in turn empties into the Tennessee River . All samples are collected as 24-hour composites and duplicated analysis is conducted for each sample . The specific sampling and analytical protocols were described in 3M's May 7, 2003 letter to EPA . The PFOA monitoring results for the Decatur wastewater effluent discharged under Alabama NPDES Permit No . AL000205, Outfall 001 are shown in the attached Table 4 . The data summary includes the historical data and the results from 2003 - 2006 monitoring events . As indicated by these data, effluent concentrations have shown a significant decrease since 2002 when PFOA production and use was phased out . Surface Water, Sediment and Fish Sampling As previously noted, surface water, sediment and fish samples were collected from the Tennessee River in December 2006 . As soon as final analytical reports are completed for these samples, an addendum to this annual report will be submitted . In summary, this letter reports results of wastewater and groundwater monitoring at both the Decatur and Cottage Grove sites . This submittal fulfills the commitments of 3M and Dyneon under the March 13, 2003 3M LOI and the March 14, 2003 APFO Users LOI, subject to the submittal of the aforementioned addendum when the December 2006 Tennessee River data is available . If there are any questions . please contact the writer at the address provided below . Sincerely, ~. . Michael A . Sdntor o Director, Environmental, Health, Safety and Regulatory Affairs 3M - Bldg . 236-113-1 0 St. Paul, MN 55144 651 733-6374 (phone) 651 733-1958 (fax ) E-mail: masantoro~(t'mmm .com cc : Toni Krasnic - Room 4410L Attachments ~~ Page 6 of 9 Document Control Office (DCO ) Office of Pollution Prevention and Toxics (OPPT) U .S . Environmental Protection Agenc y Table 1 . 3M Cottage Grove Groundwater Monitoring Results Sample Location Date Sampled PFOA ( ppb) PFOA Lab Replicate PFOA Field (ppb) Duplicate (ppb ) 07111/01 NA NA NA PFOA Avg (ppb) NA 09/07/01 NA NA NA NA 10/31/01 NA NA NA NA 11/12/01 NA NA NA NA 12/03/02 NA NA NA NA MW-7 06/05/03 0.309 0 .307 0 .326 0 .31 4 09/30/03 05/19/04 09/29/04 03/16/05 06/22/05 0.329 0 .334 0.367 NA 0 .36 NA 0.237 0 .294 0 .235 0 .225 0 .327 0 .366 0 .37 0 .314 0 .267 0 .328 0 .3665 0 .37 0.282 0.242 11/09/05 0 .238 0 .196 0 .251 0 228 06/29/06 0 .213 0.189 0 .237 0 .213 07111/01 NA NA NA NA 09/07/01 NA NA NA NA 10/31/01 NA NA NA NA 11/12/01 NA NA NA NA 12/03/02 170 180 172 174 06/05/03 135 149 125 13 6 MW-101 09/30/03 158 155 154 156 05/19/04 236 NA 230 233 09/29/04 163 NA 165 164 03/12/05 157 147 145 150 06/22/05 125 129 183 146 11/09105 120 120 121 120 06/29/06 127 124 126 126 07/11/01 1 .23 1 .14 NA 1 .18 09/07/01 NA NA NA NA 10/31/01 40 .6 11/12/01 11 .4 38 .5 10 .8 41 .1 17 .1 40 .1 13.1 12/03/02 NA NA NA NA 06/05/03 28 28 .1 Water Supply 09/30/03 5 .17 5 .35 277 2T 9 8 .77 6 .43 Distribution System 05/19/04 23 .6 NA 09/29/04 12 .9 NA 23 .3 158 23 .4 14 .4 03/12/05 ND ND ND ND 06/22/05 ND ND ND ND 11/09/05 06/29/06 07/31/06 10 .5 8 .34 10.5 9.72 9 .66 9 .27 7 .72 NA 7 .40 9.78 9 .55 7 .56 11/07106 13 .1 NA 13 .6 13 .40 07/11/01 NA NA NA NA 09/07/01 6 .40 6 .77 6 .06 6 .41 10/31/01 5 .89 4 .96 5 .25 5 .37 11/12/01 4 .66 4 .63 4 .60 4 .63 12/03/02 NA NA NA NA PZ-14 06/05/03 09/30/03 05/19/04 09/29/04 03/15/05 06/22/05 4 .80 4 .67 4 .10 3 .98 4 .68 4 .40 NA NA 2 .71 1 .60 2 .02 1 .73 4 .96 4 .09 4 .8 1 4 .06 4 .83 4 .40 4 .76 4 .40 2 .40 2 .38 1 78 1 70 11109/05 1 .67 06/29/06 1 .42 0 .96 1 .40 1 .69 1 37 1 .44 1 .40 07/11/01 NA NA NA NA MW-4 09/07/01 NA NA NA NA 10/31/01 5 .67 5.93 7 .39 6 .33 11/12/01 5 .30 5.11 5 .45 5 .29 12/03/02 NA NA NA NA 06/05/03 10.2 10 .2 10 .1 10 . 2 09/30/03 8 .74 9 .10 9 .12 8 .99 05/19/04 17 .0 NA 16 .4 16,7 09/29/04 12 .2 03/16/05 10 .7 NA 13 .3 12 .8 9 .47 9 .31 9 .83 06/22/05 10 .4 9 .56 11/09/05 12 .3 8 .90 06/29/06 6 .82 6 81 9 .65 9 .87 NR 10.6 6 89 6 .84 Table Notes : ppb: parts per billion (ug/L ) NA : data not available for sampling period ND : not detected at or above 0 .025 ug/L NR : not reportable due to quality control issues p. 6 (0 p. 7 Page 7 of 9 Document Control Office (DCO ) Office of Pollution Prevention and Toxics (OPPT) U .S . Environmental Protection Agenc y Table 2 . 3M Cott age Grove Effluent Monitoring Result s Sample Location Date Sampled I Jan-Mar 2001 Sep-Oct 2001 PFOA (ppb) PFOA Field PFOA I Duplicate (ppbI Avg (ppb) Average of 8 data points 1991 Average of 3 data points 216 12/12/02 180 01/15/03 80 .1 77 .9 02/12/03 80 .0 78 .8 03/12/03 74 .3 74 .7 04/23/03 112 109 05/15/03 95 .0 101 06/11/03 18 .9 16 .4 07/16/03 77 .4 79 .7 08/07/03 79 .7 85 .2 09/10/03 53 .3 55 .5 10/08/03 73.9 102 11/05/03 60 .1 67 .8 12/10/03 64 .7 66 .5 79.0 79.4 74.5 110 .5 98.0 17 .7 78 .6 82 .5 54 .4 88 .0 64 .0 65 . 6 2003 Average 74 .4 SD 001 01/14/04 1 .60 1 .74 1 .67 02/04/04 127 102 114 .5 03/03/04 73 .3 75 .9 74 .6 04/07/04 8 .90 9 .50 9 .20 05/05/04 36 .8 34 .3 35 .6 06/02/04 2 .50 2 .50 2 .50 07/14/04 81 .1 73 .4 77 .3 08/04/04 3 .00 2 .70 2 .90 09/01/04 8 .00 7 90 8 00 10/13/04 1 .00 1 .00 1 .00 11/11/04 328 32 .5 32. 7 12/01/04 28 .3 29 .0 28 .7 2004 Average 32.4 01/12/05 19 .2 20 .0 19 .6 02/03/05 22 .2 23 8 23 .0 03/10/05 262 264 263 04/07/05 26 .1 24 .7 25 .4 05/05/05 4 .30 4.30 4 .30 06/09/05 41 .9 48 .0 45 .0 07/06/05 46 .7 42 .4 44 .6 08/18/05 32 .0 28 .4 30 .2 09/15/05 1 .20 1 .20 1 .20 10/06/05 1 .90 1 .90 1 .90 11/02/05 66 .6 52 .5 59 .6 12/07/05 0 .90 0 .90 0 .9 0 2005 Average 43 .2 01/04/06 0 .83 0 .94 02101/06 1 .96 2 .10 03/01/06 0 .94 0 .96 04/05/06 4 .20 4 .40 05/03/06 0 .33 0 .34 06/08/06 0 .26 0 .25 07/05106 0 .34 0 .34 08/02/06 0 .50 0 .48 09/06/06 2 .31 2 .63 10/05/06 0 .54 0 .58 11/01/06 1 .51 1 .40 12/06/06 1 38 1 47 0 .88 2 .03 0 .95 4 .30 0 .33 0 .26 0 .34 0 .49 2 .47 0 .56 1 .46 1 .42 2006 Average 1 .29 Table Notes : ppb : parts per billion (ug/L) NA : data not available for sampling period ND : not detected at or above 0 .025 ug/L NR : not reportable due to quality control issues 17 p. 8 Page 8 of 9 Document Control Office (DCO ) Office of Pollution Prevention and Toxics (OPPT) U .S . Environmental Protection Agenc y Table 3. 3M Decatur Groundwater Monito ri ng Result s Sample Location Date Sampled PFOA (ppb) PFOA La b Replicate (ppb) g (pp ) DupliccaatteeField b PFOA Av b 07/16/03 89 .2 88 .8 90 .2 89 .4 12/xx/03 135 131 142 136 06/xx/04 110 NA 121 11 6 220L 12/16/04 139 NA 129 134 06/09/05 51 .2 55 .3 52 .3 52 .9 11/17/05 69.7 65 .8 67 .3 67 .6 06/23/06 90.1 89 .0 122 100 11/10/06 71 .8 67 .0 76 .7 71 .8 07/16/03 68.2 68 .6 12hoc/03 102 89.0 65 .8 67 .5 106 99 .0 06/W04 92.3 NA 97 .9 95 .1 220R 12/16/04 68.5 NA 65 .3 06/09/05 40.6 44 .1 42 .0 66 .9 42.2 11/17/05 51 .8 50.2 47 .7 49.9 06/23/06 64 .4 11/10/06 56 .6 67 .8 56 .4 61 .2 62 .3 64.5 58.4 07/16/03 NQ ND ND ND 12hoc/03 ND ND ND ND 06/xx/04 ND NA ND N D 226L 12/16/04 ND NA ND ND 06/09/05 ND ND ND ND 11/17/05 ND ND ND ND 06/23/06 ND ND ND ND 11/10/06 ND ND 0 .0296 0 .0296 07/16/03 10 .6 11 .0 10 .6 10 .7 226R 12/xx/03 11 .7 10 .6 13 .2 11 .8 06/xx/04 9 .54 NA 9 .85 9 .7 0 12/16/04 9 .84 NA 11 .2 10 .5 06/09/05 4 .94 5 .08 7 .92 5 98 11/17/05 9 .20 06/23/06 7 .57 11/10/06 6 .82 9 .05 7 .63 5 .98 8 .39 8 .51 7 .58 8 .88 7 .90 6 .79 03/28/01 1060 1110 1190 1120 07/16/03 1570 1560 1590 1573 12/xx/03 2010 2140 2670 2273 06/xx/04 1580 NA 1940 176 0 110R 12/16/04 1870 NA 1830 1850 06/09/05 1640 1430 1260 1443 11/17/05 1440 1280 1280 1333 06/23/06 1460 1740 1270 1490 11/10/06 NR NR NR NR 317L 07/16/03 12/W03 06 1 oc/04 12/16/04 0 .940 0 .950 0 .521 0 .490 0 .776 NA 0 .860 NA 0.990 0.785 0.792 0.874 0 .960 0 .599 0 .784 0 .867 06/09/05 11/17/05 06/23/O6 11/10/06 0 .410 0 .383 0 .514 0 .426 0 .763 0 .384 0 .369 0 .396 0.545 0 387 0.433 0 .453 0 .573 0 .385 0.439 0.425 07/16/03 ND ND NQ ND 12/xx/03 NQ NQ NQ NQ 320L Cuii-w"v4 "v .4o"3 i~A 0 .5V6 V,495 12/16/04 0.0764 NA 0 .0802 0 .0783 06/09/05 0 .134 0 .158 0 .167 0 .153 11/17/05 ND ND ND ND 06/23/06 0 .0406 0 .0397 0 0539 0 .0447 11/10/06 0 .0662 0 .0569 0 .0394 0 .0542 07/16/03 2280 2600 2280 2386 327R 12/xx/03 1780 1910 1910 1867 06/xx/04 1360 NA 1370 136 5 12/16/04 1850 NA 1750 1800 06/09/05 1080 1030 803 971 11/17/05 1260 1090 1150 1167 06/23/06 907 968 791 889 11/10/06 585 602 558 582 Table Notes : ppb: parts per billion (ug/L ) NA : data not available for sampling period NO, not detected at or above 0 .025 ug/ L NR : not reportable due to quality control issues NQ : not quantifiable ~ p. 9 Page 9 of 9 Document Control Office (DCO ) Office of Pollution Prevention and Toxics (OPPT) U .S . Environmental Protection Agenc y Table 4 . 3M Decatur Effluent Monitoring Results Sample Location Date Sampled PFOA (ppb) PFOA Field Duplicate (ppb ) PFOA Avg (ppb ) 1998 NA NA 602 1999 NA NA 766 Outfall 2000 NA NA 1028 2001 NA NA 31 0 01/xx/03 NA NA 58 05/28/03 89 .0 87 .5 88 .3 07/21/03 10 .1 NA NA 11/03/03 27 .1 NA NA 01/27/04 412 NA N A 001 06/16/04 2.5 NA NA 12/20/04 21 .5 21 .8 21 .7 02/15/05 12 .3 12 .0 12 .2 05/24/05 8 .36 8 .77 8 .56 08/23/05 8 .08 8 .14 8 .11 12/13/05 3 .58 3 .70 3 .64 02/14/06 2 .12 2 .12 2 .12 06/27/06 2 .52 2 .49 2 .50 08/29/06 1 .45 1 .51 1 .48 12/12/06 1 .02 1 .06 1 .04 Table Notes : ppb : parts per billion (ug/L ) NA : data not available for sampling period ~