Document kkeerm3yn1QDRJ248Z9vkK9E

3M Generai Offices 3M Center S t Paul, MM 55 144-1000 651 7 3 3 1 1 1 0 P-1 i\ QOlefP. ' 3M September 17,2008 RF'Ct-IVTD J ` I u IL 08 SEP I 9 AH I0-* f 0 Document Control Office EPA East Room 6428 AR- 226 Docket US Environmental Protection Agency 1201 Constitution Avenue, NW W ashington DC 20460 iOOC -.I $ : li 9 VIA Federal Express AZ2Cr38a% Attention: Docket No. AR-226 Subject: Environmental Assessment ofPerfluoroalkyl Sulfonates at the 3M D ecatur, Alabama M anufacturing Site Dear Sir or Madam, On October 24,2004, US EPA and the 3M Company and Dyneon LL entered into a Memorandum o f Understanding (MOU) to carry out a Screening Level Human Exposure Assessment (SLHEA) for Peffiuorooctane carboxylate. This program required that various environmental m edia on and o ff the 3M Decatur, A labam a m anufacturing site w ere to be sam pled and analyzed as defined by an extensive work plan. This w ork has culm inated in a Peer Ckmsutafion Process during w hich a panel o f experts provided comments a id recommendations on the SLHEA and w hether the Charge question posed in the MOU had been answered fiilly. This entire program has been documented in the Electronic Docket OPPT 2004 0112. Since the 3M Decatur site also was used for the m anufacture ofperfluoroalkyl sulfonates, 3M voluntarily conducted a separate environmental m onitoring program o f substances that had been or were being m anufactured at that site. The substances that were included in this environmental monitoring program were perfluorooctane sulfonate (PFOS), perfluorohexane sulfonate (PFHS), and peffiuorobutanesulfonato(PFB S). The analytical data and reports, and the environmental assessmem o fth is m onitoring effort are being subm itted to the AR-226 Docket to augm ent the inform ation relative to fluorochem icals at this location. Enclosed is the report in hard copy and a CD o f the electronic version. It should be noted that 3M has entered into an agreem ent w ith the Alabama Departm ent o f Environmental M anagement to cany-out a project o f capping the form er sludge incorporation fields on the plant rite. This project includes die installation o f a protective liner over the fields that w ill then be covered w ith tw o feet o f clean soils to support growth o f natural vegetation. A groundwater extraction and treatm ent system is to be installed to minimize the m igration o f groundw atertothe w est o fth e site boundary. The project is in progress and w ill require a num ber o f years to complete. CONTAINS NO CB Page 2 Document Control Office P-2 If you would Idee to discuss die content o f this report, w e w ould be pleased to have a conference call o r m eet in EPA offices in W ashington, h i the m eantim e, if you need any additional inform ation at this tim e, please contact m e on 651 733-6374. Sincerely, M ichael A. Director, Environm ental, Health, Safety and Regulatory A ffairs 3M - Bldg. 236-1B-10 S t Paul, M N 55144 651 733-6374 (phone) 651 733-1958 (fex) E-mail: masantoro@ mmm.com cc: T. Krasnic - M ail Code 4410 L (w ith enclosure) Enclosure