Document QJBeno2MbDK4eVOjwLJz0Y8v8

Qrn-ioyooil-af^ 3M Specialty Materials 3M Center St. Paul, MN 55144-1000 if 651 733 1110 August 1, 2005 73 r\ te VIA UPS Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency EPA East, Room 6428 1201 Constitution Avenue, MW Washington DC 20460 p o <^n cr 'Z-O GO T J - m I CO CO Attention: Docket No. AR-226 and the PFOA Electronic Docket OPPT-2003-0012 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 and a detailed description of the test methodology, sa m p lin g plans and proposed test schedule for wastewater and groundwater monitoring at the Cottage Grove and Decatur sites. ! CONTAIN NO CBI J_ Page 2 Document Control Office (DCO) Office of Pollution 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 Upgradient of site industrial activities Central to site industrial activities Westem/downgradient of site 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. All of 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. 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 requirements of 3M's NPDES permit. This information is reported to the 2. Page 3 Document 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 results of all 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 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 Wells 226R & L Wells 220R and L Well 320L Wells 327R Wells 310R&317L Site Condition Located east of inactive landfill and south of wastewater treatment - monitors background conditions in residuum and shallow limestone groundwater Located northeast of inactive landfill - monitors predominant flow path of plume in residuum and shallow limestone zones Located north of inactive landfill - monitors secondary flow path of 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 3 Page 4 Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) 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 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 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 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 - 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 of 8 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 upstream of the facility at river mile 307.5 (LOC-3; designated as DL3 in the 2004 study), across the river from the facility at river mile 301 (LOC-2; designated as DL2 in the 2004 study), and downstream 4 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 DL1 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 LOI. If there are any questions, please contact the writer at the address provided below. Michael A. Santoro Director, Environmental, Health, Safety and Regulatory Affairs 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 cc: Mary Dominiak - Room 4410 Attachments TABLE 1 Sample Identification MW-7 MW-101 W ater Supply Distribution System PZ-14 3M Cottage Grove Groundwater Monitoring Results Date Sampled PFOA (ppb) PFOA Lab DS (PPb) PFOA Field DS (ppb) 07/11/01 NA NA NA 09/07/01 NA NA NA 10/31/01 NA NA NA 11/12/01 NA NA NA 12/03/02 NA NA NA 06/05/03 0.309 0.307 0.326 09/30/03 0.329 0.334 0.327 05/19/04 0.367 NA 0.366 09/29/04 0.36 NA 0.37 06/22/05 0.235 0.225 0.267 07/11/01 09/07/01 NA NA NA NA NA NA 10/31/01 NA NA NA 11/12/01 NA NA NA 12/03/02 170 180 172 06/05/03 135 149 125 09/30/03 158 155 154 05/19/04 236 NA 230 09/29/04 163 NA 165 06/22/05 125 129 183 07/11/01 1.23 1.14 NA 09/07/01 NA NA NA 10/31/01 40.6 38.5 41.1 11/12/01 11.4 10.8 17.1 12/03/02 NA NA NA 06/05/03 28.0 28.1 27.7 09/30/03 5.17 5.35 8.77 05/19/04 23.6 NA 23.3 09/29/04 12.9 NA 15.8 06/22/05 ND ND ND 07/11/01 NA NA NA 09/07/01 6.40 6.77 6.06 10/31/01 5.89 4.96 5.25 11/12/01 4.66 4.63 4.60 12/03/02 NA NA NA 06/05/03 4.80 4.67 4.96 09/30/03 4.10 3.98 4.09 05/19/04 4.68 NA 4.83 09/29/04 4.4 NA 4.4 06/22/05 1.60 1.73 1.78 PFOA Avg. (PPb) NA NA NA NA NA 0.314 0.328 0.3665 0.37 0.242 NA NA NA NA 174 136 155.7 233 164 146 1.185 NA 40.1 13.1 NA 27.9 6.43 23.45 14.4 ND NA 6.41 5.37 4.63 NA 4.81 4.06 4.76 4.4 1.70 Std. Deviation (+/-) NC NC NC NC NC 0.01 0.004 0.001 NC 0.022 NC NC NC NC 5.29 12.06 2.08 4.24 NC 32.4 0.06 NC 1.38 3.48 NC 0.21 2.03 0.212 NC NC NC 0.36 0.48 0.03 NC 0.15 0.067 0.106 NC 0.093 / i MW-4 (TABLE 1 continued! 07/11/01 09/07/01 10/31/01 11/12/01 12/03/02 06/05/03 09/30/03 05/19/04 09/29/04 06/22/05 NA NA 5.67 5.30 NA 10.2 8.74 17.0 12.2 10.4 NA NA 5.93 5.11 NA 10.2 9.10 NA NA 9.56 NA NA 7.39 5.45 NA 10.1 9.12 16.4 13.3 9.65 Table Notes: ppb: Parts per billion NA: Data not available for sampling period ND: Not detected at or above 25 ng/L NC: Not calculated Field DS: Field duplicate sample Lab DS: Laboratory duplicate sample NA NC NA NC 6.33 0.93 5.29 0.17 NA NC 10.2 0.06 8.99 0.214 16.7 0.424 12.8 NC 9.87 0.461 T TABLE 2 Effluent Monitoring Results 3M Cottage Grove, MN 3M Cottage Grove Effluent Monitoring Results PFOA Analysis from SD 001 January-March 2000 September-October 2000 December 2002 January 2003 January 2003 Sample Date Average o f 8 Data Points Average o f 3 Data Points 12/12/2002 1/15/2003 Januai> 2003 Average February 2003 February 2003 2/12/2003 1ebruaiv 2003 Average March 2003 March 2003 3/12/2003 March 2003 Average April 2003 April 2003 4/23/2003 April 2003 Average May 2003 May 2003 5/15/2003 Mav 2003 Average June 2003 June 2003 6/11/2003 lune 2003 Average _ JuK 200''' Jub, 200' - 1 6 2003 July 2003 Aveiage August 2003 August 2003 8/7/2003 August 2003 Average September 2003 September 2003 9/10/2003 September 2003 Average October 2003 October 2003 Oc1ober2(H)3 Average 10/8/2003 B iliB B -- -- November 2003 November 2003 Kovembci 2003 Average i 11/5/2003 PFOA (ppb) 1991 216 180 80.1 77.9 79.0 80.0 78.8 74.3 74.7 `: 112 109 110 5 95.0 101 98 0 18.9 16.4 7_7 - -7 1 79- i 78.6 79.7 85.2 s 1 53.3 55.5 54 4 73.9 102_ li 88 0 60.1 67.8 64.0 December 2003 December 2003 Decembei 2 0 0 ' A\ enure (TABLE 2 continued) 12/10/2003 2003 Average 2003 STD January 2004 January 2004 Januaiv 2004 Average rebru.ii> 2004 I'ebiiLin 2004 1'ebiuar> 2004 Average March 2004 March 2004 Match 2001 \veiage Apt ii :ou i April 2004 Apt 1 2004 Average May 2004 May 2004 Mu> 2004 Average June 2004 June 2004 Juno 2004 Aveiage July 2004 July 2004 Julv 2004 \veiagc August 2004 August 2004 August 2004 Average September 2004 September 2004 Septeinbei 2004 Average October 2004 October 2004 October 2004 Average November 200 1 November 200 1 Novembci 2004 Average December 2004 December 2004 Decembei 2004 Average 1/14/2004 2 4 2001 3/3/2004 1 7 2004 5/5/2004 6/2/2004 7/14/2004 8/4/2004 9/1/2004 10/13/2004 11 11 2001 12/1/2004 2004 Average 2004 STD 64.7 66.5 74.3 23.3 1.60 1.74 1.67 127 102 114 5 73.3 75.9 , 7 16 8 00 o 50 0.20 36.8 34.3 35.6 2.50 2.50 2.50 81.1 73.4 3.00 2.70 2.90 8.00 7.90 , mi 1.00 1.00 1.00 t2.8 ' 2.5 28.3 29.0 28.7 32.4 37.4 (TABLE 2 continued) January 2005 January 2005 J.muaiv 2005 /\ vet aye February 2005 February 2005 Febtuarv 2005 Average March 2005 March 2005 March 2005 Avetage \pi il 2005 \pril 200' April 2005 Avet aye May 2005 May 2005 Ma> 2005 Average 1/12/2005 2/3/2005 3/10/2005 1" 200*: 5/5/2005 19.2 20 19.6 22.2 23.8 ............^ 262 ____ 2 6 4 263 ' - - -h 1 24.~ 25.1 4.30 4.30 1.30 jo SAMPLE ID 210R 213R 216R 217R 306R 308R 315R 31 OR 310R 220R 220L 226R 226L 317L 310L 327R 220L 220R 226L 226R 31 OR 317L 320L 327R 220L 220R 226L 226R 310R 317L 320L 327R 220L 220R 226L 226R 310R 317L 320L 327R 220L 220R 226L 226R 310R 317L 320L 327R SAMPLE DATE 3/28/01 3/28/01 3/28/01 3/28/01 3/28/01 3/28/01 3/28/01 3/28/01 7/16/03 7/16/03 7/16/03 7/16/03 7/16/03 7/16/03 7/16/03 7/16/03 12/03 12/03 12/03 12/03 12/03 12/03 12/03 12/03 6/04 6/04 6/04 6/04 6/04 6/04 6/04 6/04 12/16/04 12/16/04 12/16/04 12/16/04 12/16/04 12/16/04 12/16/04 12/16/04 6/05 6/05 6/05 6/05 6/05 6/05 6/05 6/05 ND = Not detected. NQ = Not quantifiable. = No sample. TABLE 3 Groundwater Monitoring Results ______ 3M Decatur, AL______ PFOA (ppb) PFOA (ppb) Lab Dup 1060 996 223 231 75.7 81.8 0.091 0.088 3280 3690 107 131 637 635 1060 1110 1570 1560 68.2 68.6 89.2 88.8 10.6 11.0 NQ ND 0.94 0.95 ND ND 2280 2600 135 131 102 89.0 ND ND 11.7 10.6 2010 0.521 2140 0.490 NQ NQ 1780 1910 110 - 92.3 - ND - 9.54 -- 1580 - 0.776 - 0.483 1360 -- 139 ~ 68.5 -- ND 9.84 1870 ~ 0.860 0.0764 -- 1850 - 51.2 55.3 40.6 44.1 ND ND 4.94 5.08 1640 1430 0.41 0.763 0.134 0.158 1080 1030 PFOA (ppb) Field Dup 1000 220 79.9 0.082 3330 117 640 1190 1590 65.8 90.2 10.6 ND 0.99 NQ 2280 142 106 ND 13.2 2670 0.785 NQ 1910 121 97.9 ND 9.85 1940 0.792 0.506 1370 129 65.3 ND 11.2 1830 0.874 0.0802 1750 52.3 42.0 ND 7.92 1260 0.545 0.167 803 PFOA (ppb) Average 1018 224 79.1 0.087 3433 355 1912 1120 1573 67.5 89.4 10.7 ND 0.96 ND 2386 136 99 ND 11.8 2273 0.599 NQ 1867 115.5 95.1 ND 9.70 1760 0.784 0.495 1365 134 66.9 ND 10.5 1850 0.867 0.0783 1800 52.9 42.2 ND 5.98 1443 0.573 0.153 971 H TABLE 4 Effluent Monitoring Results 3M Decatur, AL 3M Decatur Outfall 001 FC Sampling Results Sample Date 1998 1999 2000 2001 January, 2003 May 28, 2003 July 21,2003 November 3, 2003 January 27, 2004 June 16, 2004 December 20,2004 February 15, 2005 May 24,2005 Results Duplicate Average (all values are listed as ug/1) N/A N/A 602 N/A N/A 766 N/A N/A 1028 N/A N/A 310 N/A N/A 58 89.0 87.5 88.3 10.1 N/A N/A 27.1 N/A N/A 411.5 N/A N/A 2.5 N/A N/A 21.5 21.8 21.7 12.9 11.7 12.3 8.33 8.38 8.36 12, Sample ID TABLE 5 Surface Water Monitoring Results _______ 3M Decatur, AL_______ 3M Decatur Surface Water PFOA Results River Mile Sample Date LOC-3 LOC-2 LOC-1 DL3-SW-LOCOO1-0041201 DL2-S W-LOCOO1-0041201 D L 1-S W-LOCOO 1-0041202 307.5 301 296 307.5 301 296 2002 2002 2002 12/1/2004 12/1/2004 12/2/2004 PFOA Concentration (ng/mL) <0.025 <0.025 0.20 <0.025 <0.025 0.190