Document evezx7pbJnddNGpZq6p4wNaYm

~~ 3M p. 1 Katherine E . Reed, Ph .D. 3M Environmental, Health and 900 Bush Avenue, Building 42-2E-26 Staff Vice President Safety Operations PO Box 3333 1 St . Paul, MN 55133-3331 4-7 1/ -<< < 65 1 7784331 _3,7 ~U, ~r~ Certified Mail ~~~ ~~~li~ ~~ I I ~2 - ~ ~ I ' i i ,11 1 11 [111 I> . S~ F E H O - ti h t May 29, 2007 Document Processing Center EPA East - Room 6428 Attn : Section 8(e) Office of Pollution Prevention and Toxics US EP A 1200 Pennsylvania Avenue NW Washington DC 20460-000 1 CON-r,4f~ No NO CBI m -- 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, Alabam a 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 : . -- ~ 30SV,36 p. 2 The PFOS result for water collected from Purgato ry Creek upstream from the 3M facility, at the Highway 21 b ri dge, was <0 .050 ng/mL ( ppb, average of sample and sample duplicate) . The PFOS result for water collected from Purgato ry 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 Laborato ry in Maplewood, MN . A copy of the interim laboratory repo rt for this work will be provided once it becomes available . In addition to monitoring for PFOS, at the request of the Alabama Depa rt ment 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 afte rn oon of May 2, 2007 fr om 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 Se rv ices, 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 obse rved 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 monitori ng for diethylene glycol butyl ether is pl anned . If you have any questions or need additional information, please contact Deanna Luebker at (651) 737-1374 . Sincerely, Katherine E . Ree d Staff Vice President, Environmental, Health and Safety Operations Enclosures ~ p. 3 Table 1 City of Guin Water System - Analytical Results for Perfluorooctane Sulfonate (PFOS) PFOS Average, ng/mL (ppb ) Date Time Water Treatment Water Treatment Distribution System - Distribution System Plant Inlet Plant Finished Water 3M Guin Facility 3M Guin Guest House 4/30/07 pm 29 .6 11 .8 39 .8 not collected 5/1/07 am 16 .6 22 .4 23 .4 not collected 5/1/07 pm 13 .6 17 .3 18 .7 33 .5 5/2/07 pm 5 .65 6 .06 6 .82 47 .3 5/3/07 am 2 .15 2 .78 3 .19 48 .3 5/3/07 pm 2 .07 1 .94 2 .23 3 .98 5/4/07 am 2 .41 2 .15 1 .98 1 .90 5/4/07 pm 1 .94 1 .78 1 .81 17 .4 5/5/07 pm 1 .14 1 .05 1 .00 8 .19 5/6/07 pm 0 .767 0 .592 0 .612 9 .48 5/7/07 pm 0 .744 0 .449 0 .517 8 .35 5/8/07 pm 0 .547 0 .433 0 .339 0 .333 5/9/07 pm 0 .434 0 .394b 0 .388 0 .330 5/10/07 pm 0 .420 0 .546c 0 .376 0 .429c 5/11/07 pm 0 .491 0 .285 0 .373 0 .296 5/12/07 pm 0 .468a 0 .340 0 .309 0 .464 5/13/07 pm 0 .452 0 .382 0 .382 0 .828 5/14/07 pm 0 .294 0 .159 0 .120 0 .193 5/15/07 pm 0 .312 0 .314 0 .382 0 .795 5/16/07 pm 0 .358 0 .402 0 .468 0 .339 5/21/07 pm 0 .239 0 .210 0 .180 0 .24 3 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 .