Document mmG9GMakrXJdBqq8g3QgNmM4J

J e s i B. Sweeney J Staff Vice President Certified Mail 3M Environmental, Health and Safety Operations p. 1 900 Bush Avenue, Building 42-2E-26 P0 Box 33331 St. Paul, MN 55133-3331 651 778 5488 3 & / 3 f^ ZjW -0330- 00373-', March 13, 2008 Document Processing Center EPA East - Room 6428 Attn: Section 8(e) Office of Pollution Prevention and Toxic US EPA 1200 Pennsylvania Avenue NW Washington DC 20460-0001 89080000148 CB! ttOCBI ;;n Re: TSCA 8(e) Substantial Risk Notice: Supplemental to Docket No. 8EHQ-0598-373; Sulfonate-based and Carboxylate-based Fluorochemicals To whom it may concern, 3M is submitting this notice to supplement its previous submissions on sulfonyl-based and carboxylate-based fluorochemicals. More specifically, the data contained in this submission have been generated as part of a site-related environmental assessment of fluorochemicals that 3M is performing for its 3M Decatur, Alabama manufacturing facility. As part of this effort, 3M has recently received the enclosed final analytical reports for various sampling activities in the vicinity of that site. These reports included data on perfluorooctanoate (PFOA), perfluorobutane sulfonate (PFBS), perfluorohexane sulfonate (PFHS), and perfluorooctane sulfonate (PFOS) and are summarized as follows: 3M Environmental Laboratoiy Report No. GLP07-01-02 - Analysis of PFOA from 3M Decatur Offsite 600 Series Monitoring wells 3M Environmental Laboratory Report No, GLP07-02-02 - Analysis of PFBS, PFHS and PFOS from 3M Decatur Offsite 600 Series Monitoring wells 3M Environmental Laboratory Report No. GLP07-01-01 - Analysis of PFOA from 3M Decatur Offsite Sediments 3M Environmental Laboratory Report No. GLP07-02-01 - Analysis of PFBS, PFHS and PFOS from 3M Decatur Offsite Sediments The first two of these reports presents off-site data from sampling of groundwater monitoring wells to the west, south, and east of the 3M Decatur property, and represents a re-sampling of these monitoring wells. The initial data had been provided to this TSCA 8(e) docket previously (October 24, 2006). In this submission we are providing the data from a re-sampling and highlighting data for one specific groundwater well, namely 605L, which now shows the presence of the 4 analytes. (The original sample data were non-detect for these analytes.) A summary of this data is as follows: P-2 Sample Location Analyte April 12. 2006 Sept. 8. 2007 605 L PFOA ND 31.6 ppb 605L PFBS ND 18.1 ppb 605L 605L PFHS PFOS ND 27.7 ppb ND 28.6 ppb All data from the sampling of the remaining monitoring wells were comparable to the original dataset. The third and fourth reports provide analytical data for samples of sediment collected from an off-site marsh area to the west of the 3M Decatur site. In the immediate vicinity of this marsh area, the results ranged from 8.47 to 147 ppb for PFOA, from non-detect to 5.39 ppb for PFBS, from 0.35 - 26.2 ppb for PFHS, and from 75.3 - 1480 ppb for PFOS. This marsh area is located on private property, which is not open to the public. In addition, no activities presently occur on the property which would result in human contact with the marsh area. At a distance of about 2200 feet to the southwest, the results for all substances were below detectable limits. While 3M does not believe that any of these data taken alone or cumulatively meet the "substantial risk" reporting threshold as defined by the EPA, we nevertheless recognize the on going work of the 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 or would like any additional information, please contact Deanna Luebker at (651) 737-1374 or diluebker@mmm.com. Sincerely, Jean B. Sweeney Staff Vice President, 3M Environmental, Health and Safety Operations Enclosure