Document 830R2J7mavrg3Xpkjab222Jm

p. 1 Katherine E . Reed, Ph .D . 3M Environmental, Health and 900 Bush Avenue, Building 42-2E-26 Staff Vice President Safety Operations PO Box 3333 1 St . Paul, MN 55133-3331 651 778 433 1 3111 Certified Mai l November 28, 2007 ---_--_. . _ ~,- -2;, Document Processing Cente r EPA East - Room 6428 A ttn : Section 8(e) Office of Pollution Prevention and Toxjes US EPA 1200 Pennsylvania Avenue NW Washington DC 20460-000 1 k r ~ai frap* NO CBI Re : TSCA 8(e) Substantial Risk Notice : Supplemental to Docket No . 8EHQ-0598-373 ; Sulfonate-based and Carboxylate-based Fluorochemical s Dear Sir or Madam, In October of 2006, 3M submi tted two analytical report s ( Exygen Study No . P0000760, E050209, Interim Report #22 - Analysis of Soil Samples and Interim Repo rt #24 - Analysis of Water, Sludge, and Sediment Samples) to U .S . EPA . These reports were provided to supplement previous submissions on sulfonate-based and carboxylate-based fluorochemicals . The reports included data on perfluorooctanoate (PFOA) in soil, ground water and surface water collected from sites adjacent to the 3M Decatur manufacturing facility . They also included data for leachate collected from a nearby l andfill, sanitary wastewater from the 3M facility and influent, effluent and sludge fr om the City of Decatur's Publicly Owned Treatment Works (POTW) . In November of 2006, 3M submi tted companion reports ( Exygen Study No . P000113 l, E050210, Interim Report #22 - Analysis of Soil Samples and Interim Repo rt #24 - Analysis of Water, Sludge, and Sediment Samples) to U .S . EPA containing data for perfluorobutane sulfonate (PFBS), perfluorohexane sulfonate (PFHS), and perfluorooctane sulfonate ( PFOS) for the identical sample locations . All of the aforementioned samples were collected as pa rt of an ongoing voluntary environmental monitoring initiative by 3M . 3M is now submi tt ing the enclosed eight analytical reports to supplement the October and November 2006 submissions . These are summarized as follows : Exygen Study No . P0000760, E05-0209 (PFOA) Interim Report #9 - Analysis of Ground Water Sample s Interim Report #I I - Analysis of Public Water, Wastewater, and Sludge Samples Interim Report #28 - Analysis of Groundwater Samples Interim Report #29 - Reanalysis of Groundwater, Soil, and Sediment Samples lIi lI li II I i! III! III 1111i l Ell 8 9 0 F O i~ 0 o U ~, 3U~,~7''7 p. 2 Exygen Study No . P0001131, E05-0210 (PFBS, PFHS, PFOS ) Interim Report #9 - Analysis of Ground Water Samples Interim Report #I I - Analysis of Public Water, Wastewater, and Sludge Samples Interim Report #28 - Analysis of Groundwater Sample s Interim Report #29 - Reanalysis of Soil and Sludge Sample s Much of this data is being submitted as supplemental either because it represents additional analytical results for previously reported locations or it reflects additional efforts to quantify results that previously did not meet data quality objectives (i .e ., data that was reported as Not Reported (NR)) . To further summarize the relevant data from the enclosed reports, and to provide a better description of the sample locations, a summary table has been prepared and attached to this correspondence . 3M does not believe that these reports contain substantial risk information, but is providing them with recognition of EPA's continuing interest in fluorochemicals . If you have any questions, please contact Deanna Luebker at (651) 737-1374 or diluebker(2mmm .com . Sincerely, Katherine E . Reed Staff Vice President, Environmental, Health and Safety Operations Enclosures (8)