Document RppoOX3r8KonVm71avQdzJQvE

Katherine E. Reed. Ph.D. Staff Vice President 3 \t Environmental. Health and Safety Operations P-1 400 Bush Avenue. Bunding 43-3E-36 PO Box 3333 ! ' St Paul. MX 55 133-333 I 65 I 778 433 I 3M CERTIFIED MAIL May 30, 2006 Document Processing Center EPA East - Room 6428 Attn: Section 8(e) Office of Pollution Prevention and Toxics U.S. EPA 1200 Pennsylvania Avenue NW Washington, DC 20460-0001 OoNr , ^ ^ - o - 3?3 Ahl Vo ,, Ho&f Re: TSCA 8(e) Substantial Risk Notice: Sulfonate-based and Carboxylic-based Fluoroehemicals, Docket Nos. 8EHQ-1180-374; 8EHQ-0381-0394; 8EHQ-0598-373 [check these numbers] - Results from Analysis of Groundwater, Sediments, Surface Water, Fish and Clams in the Decatur, Alabama Area To whom it may concern: 3M is submitting this notice to supplement its previous submissions on sulfonyl and carboxylicbased fluoroehemicals. More specifically, the data contained in this submittal have been generated as part of a site-related environmental assessment for fluoroehemicals that 3M is performing for its 3M Decatur, Alabama manufacturing facility. As part o f this effort, 3M has recently received the enclosed final analytical reports for various sampling activities conducted in the vicinity o f our Decatur manufacturing facility: Property Adjacent to 3M Decatur Facility 3M Environmental Laboratory Report No. E06-0199 - Analysis of PFOA, PFOS, PFHS, and PFBS in Aqueous Samples: 3M Decatur Offsite Sampling Event (BPP Sample Sites) Exygen Study No. P0000760, Interim Report #23, E05-0209, Analysis of Sediment Samples Exygen Study No. P0001131, Interim Report #23, E05-0210, Analysis of Sediment Samples Tennessee River Biota Sampling ` Exygen Study No. P0001131, Interim Report #10, E05-0210, Analysis o f Fish and Clam Samples The first three reports contain data for samples collected from property adjacent and immediately to the west of the 3M Decatur site. More specifically, three locations within an open water marsh area were sampled for surface water and sediments. The identification numbers for these locations are: 89060000338 9060000 3 U.S. EPA Document Processing Center May 30,2006 Page 2 P-2 Surface Water DAL-SWS-BPPO1-0-060413 DAL-SWS-BPP02-0-060413 DAL-S W S-BPP03-0-060413 Sediments DAL-SD-BPPO1-0-060421 DAL-SD-BPP02-0-060421 DAL-SD-BPP03-0-060421 In general, the BPP01 location represented the eastern end of the marsh, closest to inlet water being supplied by a nearby well. The BPP02 location was towards the northern edge o f the marsh and the BPP03 location towards the south and eastern portion of the marsh, near the outlet to adjacent wetlands. In addition to the samples referenced above, groundwater from a well located on the western adjacent property and used to supply the marsh with water was also sampled. This location is identified as DAL-GWS-BPWELL-0-060413 in the first report listed above. There are a two additional items pertaining to Report No. E06-0199 that merit discussion. First, the report represents a subreport for a series o f samples collected adjacent to, but off of, the 3M Decatur facility. Analytical results for additional off-site samples are pending but not final at this time. Second, there are several results that have been presented as estimated minimum values based on associated quality control samples that did not demonstrate adequate method performance. We are working to better quantify these results and may have revised values when the entire laboratory report is finalized. The fourth report listed above contains analytical data for fish and clams collected in late 2004 from the Tennessee River near the Decatur, AL area. Again, these laboratory results were just recently finalized. The enclosed figure provides sample locations corresponding to the results tabulated in the analytical report. While 3M does not believe that any of these data taken alone or cumulatively meet the substantial risk reporting threshold, we nevertheless recognize the ongoing work by U.S. EPA to assess fluorochemical exposure pathways. Therefore, we are placing these results in the 8(e) docket as a supplement to previous submissions. If you have any questions, please do not hesitate to contact Gary Hohenstein at (651)778-5150. Sincerely, Katherine E. Reed N Staff Vice President Environmental, Health and Safety Operations