Document n9bpgwmz2L3Vvnz4XBoBZdnMX

~s p. 1 Katherine E . Reed . Ph .D . 3N1 Emironmentai . Health and 900 Bu~,h A~enue . Bu .jir._ 4=-2E-26 Staff Vice President Safety Operations PO Box 33=~ 1 St Paul . M N 55 133-3331 .~~ R2 ro 3 6F4 651'7R-133 1 G,~~_r~. ~ it : ~dr~ -~ ~ ~ ~'+ ~ ~ PP T ' 7 v l .J CER11FIED MAIL 06 JUN -7 AM 6: 21 am ~,373 96410 _ 0 6 0 6_ o May 30, 2006 CO ~--ff Q - ~0_ 3?~ Document Processing Center EPA East - Room 6428 Attn : Section 8(e) Office of Pollution Prevention and Toxic s U .S . EPA 1200 Pennsylvania Avenue N W Washington, DC 20460-000 1 NT~il;`~ ~ Re : TSCA 8(e) Substantial Risk Notice : Sulfonate-based and Carboxylic-based Fluorochemicals, Docket Nos . 8EHQ-1180-374 ; 8EHQ-03 81-0394 ; 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 fluorochemicals . More specifically, the data contained in this submittal have been generated as part of a site-related environmental assessment for 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 conducted in the vicinity of our Decatur manufacturing facility : Property Adjacent to 3M Decatur Facilit y 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 Samplin g Exygen Study No . P0001131, Interim Report #10, E05-0210, Analysis of 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 thes e locations are : I8 ~I9~IliI~I~{1i1 1Ii$ lhll 11$ 1111131i1I1I It ~ y 6~~~ p. 2 U .S . EPA Document Processing Cente r May 30, 2006 Page 2 Surface Wate r DAL-SWS-BPPO 1-0-0604 1 3 DAL-S W S-B PP02-0-060413 DAL- S W S-B PP03 -0-060413 Sediments DAL-SD-BPP01-0 -0 60421 DAL-SD-BPP02-0-06042 I DAL-SD-BPP03-0-060421 In general, the BPP O 1 location re pre sented th e eastern end of th e marsh, closest to inlet water being supplied by a nearby well . The BPPO2 location was towards th e northern edge of the marsh and the BPPO3 location towards the south an d eastern portion of the marsh, near th e outlet to adjacent wetlands . In addition to the samples referenced above, groundwater from a well located on th e western adjacent property and used to supply the marsh with water was also sampled . This location is identi fied as DAL-GWS-BPWELL-0-060413 in the first repo rt listed above . There are a two additional items pertaining to Repo rt No. E06-0199 th at meri t discussion . First, the report represents a subreport for a se ri es of samples collected adjacent to, but off of, th e 3M Decatur facility . Analytical re sults for additional off-site samples are pending but not fi nal 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 me thod performance. We are working to better quantify these results and may have revised values when the entire laboratory repo rt is finalized . The fourth report listed above contains analytical data for fish and clams collected in late 2004 from th e Tennessee River near the Decatur, AL area. Again, these laborato ry results we re just recently finalized . The enclosed fi gure provides sample locations corresponding to the re sults tabulated in the analytical report. While 3M does not believe that any of these data taken alone or cumulatively meet the "substantial risk" re port ing 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, 'c'~i Kathe ne E . Reed Staff Vice Pre sident Environmental, Health and Safety Operations