Document RjXdE1Zdoxrm9xDww17QZmDmB

3M Dr. Charles Reich Group Vice President 8t,HQ -O L W - S I Z May 26, 1999 3M Specialty Material Markets Group RECEIVE! r o p v l.'iO 1SS9J'Jil - K FH : 56 CERTIFIED MAIL Document Processing Center (7407) ATTN: Section 8(e) Coordinator Office of Pollution Prevention and Toxics US Environmental Protection Agency 401 M Street, SW Washington, DC 20460 , ^ jt ^ J 3M Center. Building 220 St. Paul, MN 55144-10(X) ARttrOSMl651 733 0439 651 575 8001 Fax EPA-OTS 000811771P 00Dail?71P Re: TSCA 8(e) SUPPLEMENTAL NOTICE ON: Sulfonate-based Fluorochemicals Docket Nos. 8EHO-1180-373: 8EHO-1180-374: 8EHQ-0381-0394: 8EHO-0598-373 Dear Sir: fr. ro 3M Company is submitting this notice to supplement its previous submissions on sulfonyl- C*J based fluorochemicals (FCs). The purpose of this supplemental notice is to summarize recentri 3M studies conducted to determine whether perfluorooctanesulfonate (PFOS) ion can be -- detected in tissue samples from different animal species.1 Jl cc These studies were designed to obtain initial screening data on the distribution of PFOS in biota. Samples within each study were extracted and analyzed using high-performance liquid chromatography-tandem mass spectrometry (HPLC-ESMSMS). The analytical methods used in "Study 1" (eagle and albatross) and "Study 2" (eagle) were still being optimized at the time of data collection; the results are understood to be accurate to +1-50%. "Study 3" (wild bird livers study), below was conducted using more refined analytical methods that provide accuracy for PFOS determination to +/-30%. Although all of these studies involve a limited number of samples, we are providing the results so that EPA can place in context existing knowledge regarding the presence of PFOS in different biological receptors. Study 1: Screening o f PFOS Levels in Eazles and AIbatross. Five samples of plasma from eagles and albatross were analyzed. Three of the five eagles were less than 250 days old; the age of the remaining two birds are unknown. The eagles were obtained from Northern Minnesota and Michigan; the albatross were obtained from Midway Island in the Pacific. PFOS was detected in each of the five samples of eagle plasma at levels of 30, 34, 77, 31 and 34 ppb. Three out of the five albatross samples did not contain PFOS above the limit of detection (10 ppb). Detectable, but not quantifiable, levels of PFOS were detected in the remaining two samples, both collected from birds under 1 year old. As only a small amount (less than 1ML) of plasma was available for analysis, it was not possible to conduct matrix spike analyses. 1 These studies also include measurements o f other non-PFOS compounds, but these FCs have not been fully quantitated. US Environmental Protection Agency May 26, 1999 Page 2 Data collected in support of this study is of semi-quantitative screening quality with a margin of error estimated to be +/- 50%. Study 2: Analysis o fExtracts Reported in Eagles. Extracts from three samples of sea eagle plasma (collected from the Baltic Sea) and seven samples of bald eagle plasma (collected from North America) were analyzed quantitatively for PFOS. The target analyte was detected in all of the eagle plasma samples screened. Levels in sea eagle plasma samples were 125, 93, and 215 ppb; levels in bald eagle plasma were 165, 198, 494, 1047, 226, 371 and 375 ppb. All birds except for the one at 1047 ppb were less than 1 year old. Data collected in support of this study is of semi-quantitative screening quality with a margin of error estimated to be +/- 50%. Only 2 (250 ppb) PFOS matrix spike samples were extracted and analyzed. Study 3: Analysis o f Fluorochemicals in Wiid Bird Livers. Sixty liver samples collected from various species of birds were characterized with respect to PFOS. The birds were classified according to species and geographic location. Six species of birds were represented in this study, including Sandhill Cranes, Double-Crested Cormorants, White Pelicans, Brown Pelicans, Great Blue Herons, and Brandt's Cormorants. The birds were found at a variety of sites across the United States including Nebraska, New Mexico, Florida, Arizona, California, Louisiana, and Florida. In general, the cause of death to these birds is unknown. Although only minimal spike recovery studies were conducted, this data was collected using methods that have been fully validated on a related matrix. The data for PFOS is semi-quantitative screening data with a margin of error estimated to be +/-30%. The following table presents the study results: Semi-quantitative Results of Wild Bird Livers Sample number SPECIES LOCATION Liver [PFOS] ppb 1 sandhill crane Kearney, NE 41 2 sandhill crane Kearney, NE <LOQ 3 sandhill crane Kearney, NE <LOQ 4 sandhill crane Kearney, NE <LOQ 5 sandhill crane Kearney, NE <LOQ 6 sandhill crane Cochise Co., AZ <LOQ 7 sandhill crane Cochise Co., AZ <LOQ 8 sandhill crane Cochise Co., AZ <LOQ 9 sandhill crane Cochise Co., AZ <LOQ 10 sandhill crane Cochise Co., AZ <LOQ 11 white pelican Calipatria, CA 35 US Environmental Protection Agency May 26, 1999 Page 3 Sample number SPECIES LOCATION 12 white pelican Calipatria, CA 13 white pelican Calipatria, CA 14 white pelican Calipatria, CA 15 white pelican Calipatria, CA 16 brandt's cormorant San Diego, CA 17 brandt's cormorant San Diego, CA 18 brandt's cormorant San Diego, CA 19 brandt's cormorant San Diego, CA 20 brandt's cormorant San Diego, CA 21 double-crested cormorant St. Martinville, LA 22 double-crested cormorant St. Martinville, LA 23 double-crested cormorant St. Martinville, LA 24 double-crested cormorant St. Martinville, LA 25 double-crested cormorant St. Martinville, LA 26 brown pelican Miami, FL 27 brown pelican Miami, FL 28 brown pelican Miami, FL 29 brown pelican Miami, FL 30 brown pelican Miami, FL 31 sandhill crane Valenica Co., NM 32 sandhill crane Valenica Co., NM 33 sandhill crane Socorro Co., NM 34 sandhill crane Socorro Co., NM 35 sandhill crane Valenica Co., NM 36 double-crested cormorant Naples, FL 37 double-crested cormorant Naples, FL 38 double-crested cormorant Naples, FL 39 double-crested cormorant Naples, FL 40 double-crested cormorant Naples, FL 41 brown pelican Calipatria, CA 42 brown pelican Calipatria, CA 43 brown pelican Calipatria, CA 44 brown pelican Calipatria, CA 45 brown pelican Calipatria, CA 46 great blue heron St. Martinville, LA 47 great blue heron St. Martinville, LA 48 great blue heron St. Martinville, LA 49 great blue heron St. Martinville, LA 50 great blue heron St. Martinville, LA Liver [PFOS] PPb 1293 29 15 155 53 46 46 80 2055 59 145 333 76 170 106 134 125 159 48 <LOQ <LOQ <LOQ <LOQ <LOQ 212 10 52 100 152 16 36 <LOQ 6 32 188 59 1061 261 173 J? US Environmental Protection Agency May 26, 1999 Page 4 Sample number SPECIES LOCATION Liver [PFOS] ppb 51 white pelican Fallon, NV 141 52 white pelican Fallon, NV 362 53 white pelican Fallon, NV 927 54 white pelican Fallon, NV 133 55 white pelican Fallon, NV 291 56 brown pelican Ft. Lauderdale, FL 194 57 brown pelican Ft. Lauderdale, FL 75 58 brown pelican Ft. Lauderdale, FL 71 59 brown pelican Ft. Lauderdale, FL 31 60 brown pelican Ft. Lauderdale, FL 91 LOQ = Limit of Quantitation (approx. 6 ppb) 3M believes that the above three sets of data are insufficient to draw conclusions with any statistical merit. Therefore, 3M is in the process of implementing a more comprehensive program of sampling and analysis to quantify PFOS levels across a range of species, environmental media and geographic locations. These additional data will provide a fuller basis for characterizing the fate and distribution of PFOS and other FCs in biota and ecosystems. We will keep EPA informed of the progress of these efforts. If you have any questions in the meantime, please contact William Weppner at (651) 733-6374. Sincerely, Dr. Charles Reich Group Vice President Specialty Material Markets Group