Document NeNxkYvGG65y1vaYgzxG3G3Rw

Katherine E. Reed, Ph.D. Staff Vice President 3M Environmental, Health and Safety Operations %erfQ>o7-/gsy p. 1 900 Bush Avenue, Building 42-2E-26 PO Box 33331 " St. Paul, MN 55133-3331 651 778 4331 __ _ 2031C i 2 Certified Mail rL V.-> L' t May 29, 2007 Document Processing Center EPA East - Room 6428 Attn: Section 8(e) Office of Pollution Prevention and Toxics US EPA 1200 Pennsylvania Avenue NW Washington DC 20460-0001 Cont* in no CBI NO CBI 88070000272 05 03 Re: TSCA 8(e) Substantial Risk Notice on: Guin, Alabama FC-203CF Light WaterTM Aqueous Film Forming Foam (AFFF) 3% release To whom it may concern: On Saturday, April 28, 2007, a sprinkler system at the 3M production facility in Guin, Alabama was accidentally damaged, resulting in a discharge from the sprinkler system. This particular system contained the fire control agent FC-203CF Light WaterTM Aqueous Film Forming Foam (AFFF) 3%, a mixture containing approximately 70% water, 20% diethylene glycol butyl ether, 3% active fluorochemicals (including approximately 1% perfluorooctane sulfonate (PFOS)), 1% triethanolamine, and low levels of surfactants. A portion of the sprinkler system discharge ultimately flowed into a nearby creek which, in turn, led to low levels of AFFF being introduced into the local water supply. 3M informed state and local officials of this discharge. In coordination with these officials, 3M has been, and continues to be, engaged in monitoring efforts to characterize the impact of this discharge. As described below, these monitoring efforts have focused on PFOS, but also have included diethylene glycol butyl ether. The monitoring has taken place at four sampling locations briefly described as follows: Water Treatment Plant (WTP) Inlet Water - inlet water from Purgatory Creek, samples collected from continuously flowing sample line in WTP laboratory. Water Treatment Plant Finished Water - finished or product water from the WTP, samples collected from continuously flowing sample line in WTP laboratory. Water Distribution System, 3M Guin Facility - water sampled as it enters 3M's manufacturing facility at 6675 U.S. Highway 43. Water Distribution System, 3M Guin Guest House - water sampled from faucet within 3M's Guest House at 451 Dupuy Drive. A summary of PFOS results for the four locations listed above, for samples collected through May 21, 2007, is enclosed as Table 1. These numbers show a rapid decline in PFOS levels following the release. In addition to this data, there were two additional sample locations included in the first round of samples collected on April 30, 2007: / 30SD3 P-2 The PFOS result for water collected from Purgatory Creek upstream from the 3M facility, at the Highway 21 bridge, was <0.050 ng/mL (ppb, average of sample and sample duplicate). The PFOS result for water collected from Purgatory Creek, immediately before it entered the City Water Treatment Plant, was 28.8 ng/mL (ppb, average of sample and sample duplicate). All PFOS results have been generated by the 3M Environmental Laboratory in Maplewood, MN. A copy of the interim laboratory report for this work will be provided once it becomes available. In addition to monitoring for PFOS, at the request of the Alabama Department of Environmental Management (ADEM), a water sample from the distribution system was collected and analyzed for diethylene glycol butyl ether. The result for a sample collected on the afternoon of May 2, 2007 from the 3M Guin Guest House was 524 ng/mL (ppb, average of sample and sample duplicate). The analysis for this parameter was performed by Pace Analytical Services, Inc. in Minneapolis, MN. The final laboratory report is enclosed with this correspondence. Based on the AFFF formulation, this level of diethylene glycol butyl ether was to be expected based on the PFOS concentrations observed at the time the sample was taken. Levels of this constituent are expected to diminish in a similar manner to levels of PFOS. No further monitoring for diethylene glycol butyl ether is planned. If you have any questions or need additional information, please contact Deanna Luebker at (651)737-1374. Sincerely, Katherine E. Reed Staff Vice President, Environmental, Health and Safety Operations Enclosures Table 1 p.3 City of Guin Water System - Analytical Results for Perfluorooctane Sulfonate (PFOS) Date 4/30/07 5/1/07 5/1/07 5/2/07 5/3/07 5/3/07 5/4/07 5/4/07 5/5/07 5/6/07 5/7/07 5/8/07 5/9/07 5/10/07 5/11/07 5/12/07 5/13/07 5/14/07 5/15/07 5/16/07 5/21/07 Time pm am pm pm am pm am pm pm pm pm pm pm pm pm pm pm pm pm pm pm Water Treatment Plant Inlet 29.6 16.6 13.6 5.65 2.15 2.07 2.41 1.94 1.14 0.767 0.744 0.547 0.434 0.420 0.491 0.468a 0.452 0.294 0.312 0.358 0.239 PFOS Average, ng/mL (ppb) Water T reatment Distribution System - Distribution System Plant Finished Water 3M Guin Facility 3M Guin Guest House 11.8 22.4 17.3 6.06 2.78 1.94 2.15 1.78 1.05 0.592 0.449 0.433 0.394b 0.546 0.285 0.340 0.382 0.159 0.314 0.402 0.210 39.8 23.4 18.7 6.82 3.19 2.23 1.98 1.81 1.00 0.612 0.517 0.339 0.388 0.376 0.373 0.309 0.382 0.120 0.382 0.468 0.180 not collected not collected 33.5 47.3 48.3 3.98 1.90 17.4 8.19 9.48 8.35 0.333 0.330 0.429 0.296 0.464 0.828 0.193 0.795 0.339 0.243 All results represent average of sample and sample duplicate results. a - Value reported with an analytical uncertainty of 10044%. b - Value reported with an analytical uncertainty of 10035%. c - Value reported with high Relative Percent Difference (RPD) value.