Document njJjmz74pg927j93a6EmRZ6G

p. 1 Katherine E . Reed, Ph .D. 3M Environmental, Health and 900 Bush Avenue, Building 42-2E-26 Staff Vice Prsident Safety Operations PO Box 3333 1 ~~ 373 ~~ t . Paul, MN 55133-3331 51 778 433 1 3M Certified Mai l 7 November 28, 2007 Document Processing Cente r NO CBI EPA East - Room 6428 Attn : Section 8(e) OffiEcePAofPollution Prevention and Toxic s US IIIIII III I II II IIIII IIIII ~Ii~ I~~ 1200 Pennsylvania Avenue NW s 9 lo s o n:'i III0 I II!li II5 ~I~ II~~I2II i ~ I Washington DC 20460-000 1 Re : TSCA 8(e) Docket No . 8EHQ-0598-373 ; Sulfonate-based and Carboxylate-based Fluorochemical s Dear Sir or Madam : 3M is supplementing its previous submissions to the above-referenced docket with the enclosed analytical repo rt s ( Exygen Study No . P0001131, E05-02 10 Interim Repo rt Nos . 2, 5, 13, 15, 17, 18, and 20) . These reports present laborato ry analysis results for off-site water samples collected during 2005 and 2006 fr om the Tennessee River and potable water sources in the vicini ty of 3M's manufacturing facili ty in Decatur, Alabama . These samples were collected as pa rt of a volunta ry environmental monitori ng initiative by 3M and analyzed for several sulfonate-base d fluorochemicals, including for perfluorooctanesulfonate (PFOS) . 3M does not believe that these reports contain substantial risk information . Moreover, analytical results for PFOS in many o f the same or similar Tennessee River sampling locations have been previously provided by 3M to the Agency an d/or presented in the published literature . In part icular, a 2002 publication by Hansen et al. (2002) 1 presented data for PFOS collected in the same vicinity . Hansen, et al. reported PFOS levels in the Tennessee River averaging 32 +/- 11 ng/L directly upstream and 114 +/- 19 ng/L directly downstream of the Decatur facility . As reflected in the enclosed repo rts, the data for the 2005 and 2006 samples indicate significantly lower PFOS levels than repo rt ed in Hansen, et al ., with many levels repo rt ed as non-detectable or below the limit of quantitation (LOQ) (typically 0 .025 ng/ml) . 3M appreciates the oppo rt uni ty to provide the Agency with this information . If you have any questions, please contact Deanna Luebker at (651) 737-1374 or djluebker(~a,mmm .com . Sincerely , Katherine E . Reed Staff Vice President, Environmental, Health and Safety Operations Enclosures (7 ) Hansen et al., Quantitative characterization of trace levels of PFOS and PFOA in the Tennessee River ., Environ Sci Technol ., 2002, 36(8) :1681-5 . 3 5