Document DK3p7GxXwxbnzn585bzDLKo4

. . . , 301 Spestaley Matern ff SKgerFeronneA20S0s314-401000\0L-072% ARRR6 _35<57 mE VIA UPS Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency [1E2P0A1 ECaosnts,tiRtoutoimon6A4v2e8nue, MW Washington DC 20460 Attention: Docket No. AR-226 and the PFOA Electronic Docket OPPT-2003-0012 E ox <2 38 @ = on = 52 z= Subject: Third Submission of Monitoring Data Pursuant to the 3M LOI dated March 13, 2003 and PFOA Users LOI dated March 14, 2003 Dear Sir or Madam: `This report is submitted pursuant to the 3M Letter of Intent (LOI) dated March 13, 2003 and the PFOA Users LOI dated March 14, 2003. The report is the third submission under the LOIs 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. As noted in the 3M LOI and in the 3M submission pursuant to this LOI, 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 LOI, 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 anda detailed descriptionofthe test methodology, sampling plans and proposed test schedule for wastewater and groundwater monitoring at the Cottage Grove and Decatur sites. L3 Page Document Control Office (DCO) OfficeofPollution Prevention and Toxics (OPPT) US Environmental Protection Agency COTTAGE GROVE. MN SITE MONITORING DATA Monitoring Results 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 MW-7 MW-4 PZ-14 MW-101 Water supply distribution system Site Condition Upgradientofsite industrial activities Central to site industrial activities Wester/downgradientofsite industrial activities Eastern/downgradient of site industrial activities Site-wide ground water from the production wells 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. PFOA data from the five monitoring points listed above was collected on June 21, 2005 and on June 22, 2005. The results of these most recent monitoring events and previous sampling events for these points are presented in the attached Table 1 Effluent Monitoring 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. At this time, all of the process effluent wastewater is treated with activated carbon. Allofthe 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. Since January 2000, 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 requirementsof 3M's NPDES permit. This information is reported t0 the - PDaogceu3ment Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency Minnesota Pollution Control Agency in the monthly Discharge Monitoring Reports (DMR). Effluent wastewater samples are collected at the plant outfall on 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 resultsofall monitoring events in 2005 and in previous years. `As shown in Table 2, PFOA levels varied throughout the most recent reporting period of July 2004 to May 2005. As mentioned above and in previous meetings and reports, 3M has installed an activated carbon treatment system to remove certain constituents from the `wastewater treatment plant effluent. This system is in 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. DECATUR, AL SITE MONITORING DATA Monitoring Results Groundwater Monitor As stated in the previous submissions, 3M selected the following wells for groundwater sampling and PFOA analysis going forward (sce site map attached to the August 1, 2004 report): Monitoring Location Site Condition Wells 226R & L Wells 220R and L Well 320L Wells 327R, Wells 310R & 317L Located east of inactive landfill and southofwastewater treatment -- monitors background conditions in residuum and shallow limestone groundwater Located northeastof inactive landfill ~ monitors predominant flow pathof plume in residuum and shallow limestone zones Located north of inactive landfill ~ monitors secondary flow pathof plume. Located in the former incinerator area -- monitors residuum groundwater near source area Located in the Chemical Plant -- monitors dominant groundwater flow pathways in the Chemical Plant Paged Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPT) US Environmental Protection Agency Groundwater samples from the eight monitoring points were collected on June 15, 2005. `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 Monitoring 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 sites 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 discharge and combined process wastewater/non-contact cooling water is designated as Outfall 001A and 001, respectively. As explained in our May 7, 2003 letter, wastewater sampling at the Decatur site for PFOA analysis is being conducted on a quarterly basis. Samples are collected at Outfall 001, which consists of treated process wastewater and non-contact cooling water. The outfall discharges to Baker's Creek, which in tum 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 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 ~ 2005 monitoring events. As indicated by these data, there has been some variation in the levels of PFOA in the discharge to the Tennessee River. Effluent concentrations have shown a significant decrease since 2002 as PFOA production was phased out. Surface Water Sampling Surface water sampling in the Tennessee River/Bakers Creek was performed at a total of8 locations, including the 3 LOI locations sampled in 2002. The LOI surface water samples were co-located with sediment sample locations and fish and clam sampling locations. `The three LOI surface water sampling locations were located upstreamof the facility at river mile 307.5 (LOC-3; designated as DLS in the 2004 study), across the river from the facility at river mile 301 (LOC-2; designated as DL in the 2004 study), and downstream Page 5 . Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency of the facility at the mouth of Fox Creek (river mile approximately 296; LOC-1; designated as DL! in the 2004 study). Additional information on the sampling rationale, procedures, and locations is contained in the Phase 2 Work Plan for Sampling Environmental Media (WESTON, 2004). Analytical data from the 2002 and 2004 sampling periods are shown in the attached Table 5. Sediment and Fish Sampling Analyses of sediment, fish whole body, fish filet and whole body clam tissue samples for PFOA concentrations are currently being performed at the Exygen laboratory. Results of these analyses will be provided in subsequent Phase 2 PFOA Quarterly Progress Reports upon completion of analyses and the quality assurance and quality control (QA/QC) review of the data packages. In summary, this letter reports results of wastewater, groundwater, and surface water monitoring at the Decatur site and wastewater and groundwater sampling at the Cottage Grove site. This submittal fulfills the continuing commitments of 3M and Dyneon under the March 13, 2003 3M LOI and the March 14, 2003 APFO Users LOLIfthere are any questions, please contact the writeratthe address provided below. Sincerely, Hues J Michael A. Santoro DSiarfeecttyora,ndEnRveigruolnamteonrtyalA,ffaHierasl.th, 3M - Bldg. 236-1B-10 P.O. Box 33331 St. Paul, MN 55144 651 733-6374 (phone) 651 733-1958 (fax) E-mail: masantoro@mmm.com ce: Mary Dominiak -- Room 4410 Attachments * "TABL|E IT or Counts ong resus ilCT)Rdvl ll vill [oome e [ e ww ae e ae w oer |W wa Wve| [oI sm |e| ww| ome | en | om--| [[oCmoemno[wwamr|| oww[ooww[|oowws[|oom || [[Coommeer[|womw |w wm [ww o ooww | Ie o | [Fomeermawa] ww w ww| nn i E EE a ---- "CoCm |iCO| |e[ | s |= ar w | wiv |n |ow w |ow| a e| [ n o|mw ee rw Tow| e wer e |i|e es | wo i nr |sa|| War SosyDisbuion yenI[Cous|| =aviJ | wy| o7ar I [3 ma |oxem| F [omm t[ ot w o w | o | [ w e|| LLL a [s |I or w | [mm mm[weo we r ew aee ||oes| [FCoommomr[w--two[ t--sa--w ioa ase--||s oowor|] [fCoCEmw[TLwE [ NLJ Lw N|BweC w |IC | ` (TA1cBontLinuEed) [[oommer e aTwT w w w ww w)| L (ns c e fes es e[oe asn ha [[Coosmesr e wr w [mew w[ [m owr| wwe ow | (Fromme m ww e| oiad [m | os| wr | os |se[ow |ow | DTBR eRosiE crmpegpns uL[SDS -- bee asmee Lo TABL2E Effluent Monitoring Results 3M Cottage Grove, MN EffluIeMntCMootniatgoeriGnrgovReesuls PFOA Anabsis from5D001 SepareymMbaerrc-hO2c0i0o0b10e0r0 ||D AAvvereagreageou offDaab Pons | o |2__1_s 6159]1] P December2002 [ o os m se p s [[1iw]] dagns [mT |iaFerbriuaumryary a220003 03Average 0 0 HET y me fa[l 00]90 | appirt20200037 ApMMraayiyl222000000335 AVerige Jr une 2000033 Average Thine 203Aver 28) RR T oon e Coilo ssa=_-- sEsneo] a] SEE iso]80] 2 es| 2003 9102003 ss OOccoibsebre2r0a0030s 032003 of Er1 . (TA2 cBontLinueEd) December2003 ---- a r Pom r _ am e e 18] H[ormoinan| Februay 2004Avera; 1 March 2004 o2o00n8 [i] R Es] I ake 2004Avetige 71H pil 2004 EIAFEpTr0i0a-- EE -- min%s [o-- s]as] EET S008 -- -- -- Jly u20n04 -- sui] S004 sol Sa -- sober2004 Octoter 2004. | Fciober 2004 Average LL Nr Noovveemnbba eerr22000048 N December 2004 ona srs re |1[0--] TER -- Tas) [290] GC| ooviwasveonge | ] . (TA2 BcontLinuEes) mT eViwa me |wei [JFraebnruuaarroyy 202m00505Aeverage + 2 eea ET-- I | February 20; ! a i ET 196 | a ede | ees ib) TABLE 3 . Groundwater Monitoring Results 3M Decatur, AL [em[saDAeTE [Toren nLae b Dup [TeFieeld Dnup |TeAveersa "| [z[Coomrm seawseer w mse|es a| wa low a tow | [[CCaome aawwee[[o5e7r || ommse[ | 9 oom | ooorr]| [oe os saawweer wswr0[ | sei o[amp o s sm] [[CCoSsR aaswoe Ter wow ewso T[teewe dnoane] S To S w Te1 wSS wzTe NO sJ | esSO A esS|| [CCm e nneewm swoae | nmso wwea | wosa]| [me new No Ww [ww| [ [Sm o T nneewss oNopd [TW70w05[TN oe o10 |96 Nn]| C SO IS o SO I BsSOT Ip m NS w|ee S he | CCe2m boww T Tw wTw woT [ww eT | w || i -- ---- ---- ---- 1------ 1 -- [CCoSmR woows owise | aamwo[|om osm] [Cos hw No | No[No | No | m Ca e heoee 1.enm e w s ieles Tas ser]| m 1e 3Tena eTes [[ aTea w 1 eNm speoo o m ND r oNmD | [[CCoomw wsooi[soo me[ T= om [e om me]| Co ew osm |= ose |oa | Cm ao Tmeeonss meeoTo myTT T em s] [2om e TorweinsT [ esTw oTey 8p = Tex es]| [s Caosnk eeone[ [e ee s T[ oTh we a dwees | IoP m 1 onesSS ose S [ So 1S e | RO m ose | orm em [ wm bs [wo CoZeR wewoss wweo[ Twwao w w0 | w pa] [Comosees ms[eaww |swme[ [h ge m | | lsem]| C[ omTe C s o oomme[o m ome |e ooses | |s ooiss m|] " ND = Not detected. m ws jww W w '=NQ =NoNostamqpulaen.ifiable. : - TABLE 4 Effluent Monitoring Results 3M Decatur, AL 3M Decatur Outfall 001 FC Sampling Results EN---- [wes TwaTWA Te 1 [wo Twa Twa T 76 1 [200 Twa T wa T os [2m TwaTwa T 30 [Jan Tw waa Twn ay T 2s0 s s1 [_ma1y soo2 [ s52 T 0e0 835 s1 [_wv1 a doiTr waa To we a s1 [mesa |3s| wa | wa | [Decem1b21esTr 272 180 T7 ,52107041 [va [8y 35Ta s36s [ o 836s1 TABLE 5 + Surface Water Monitoring Results 3M Decatur, AL amn all [oes IswsTee coms | [[ f-- oc moi c Tae sei[TTom a0 [ TT oeox s |