Document omYw0gkRGDMowDM3Nmow9xYbg

3M General Offices 3M Center St. Paul, M N 55144-1000 651 733 1110 RECffVFD O'-i UG ! ? /!M 7 : 3 5 C/> rn < 3 "T l 'O n :i I 'O o ro August 9, 2004 VIA E-MAIL Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency EPA East, Room 6428 1201 Constitution Avenue, NW Washington DC 20460 Attention: Docket No. AR-226 and the FYI Docket FYI-00-001378 85040000004 8 jD ro UD 4 Subject: Second Submission o f Monitoring Data Pursuant to the 3M LOI dated March 13, 2003 and APFO Users LOI dated March 14,2003 Dear Sir or Madam: This report is submitted pursuant to the 3M Letter of Intent (LOI) dated March 13,2003 and the APFO Users LOI dated March 14,2003. The report is the second submission under the LOIs o f the results o f groundwater and wastewater monitoring at the 3M manufacturing sites at Cottage Grove, MN and Decatur, AL. As you know, perfluorooctanoic acid (PFOA) was previously produced at these sites. In addition, use o f PFOA is continuing at the Decatur site, as part o f the Dyneon fluoropolymer manufacturing operation. As noted in the 3M LOI and in the 3M submission pursuant to this LOI, monitoring o f wastewater treatment plant effluent and groundwater for the presence of PFOA has been underway at the Decatur and Cottage Grove sites for a number of years. This monitoring was initiated as a result o f 3M voluntary commitments and/or plans established through permits with local regulators. Under the 3M LOI, 3M agreed to continue this monitoring in order to assess the trends that are likely to occur as a result o f the 3M production phase-out of PFOA, completed at the end o f 2002. The Decatur monitoring program was continued for the additional purpose of assessing the impact of Dyneon's ongoing use of APFO in fluoropolymer manufacturing activities at the site and, in this manner, meeting Dyneon's monitoring commitments under the APFO Users LOI. Because the Dyneon and former 3M manufacturing operations are located at the same site, it was determined that monitoring would be conducted and reportedjointly by 3M and Dyneon. The description o f the monitoring program under the LOIs can be found in our May 7,2003 letter to Ward Penberthy o f EPA, and in our first Submission of Monitoring Data dated August 1, 2003. These two documents have been entered into the AR-226 Docket and the PFOA Electronic Docket 2003 - 0012. Please refer to those two Dockets for background information and a detailed description o f the test methodology, sampling plans and proposed test schedule for wastewaterand groundwater monitoring at the Cottage Grove and Decatur sites. 190 ON NIVIN^" / Page 2 Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency It should also be noted that under the APFO Users LOI, Dyneon conducted air dispersion modeling for its Decatur operations. Dyneon submitted this information to EPA in January 2004. COTTAGE GROVE, MN SITE MONITORING DATA Monitoring Results Groundwater Monitoring As explained in the previous submittals, 3M selected five ground water sampling locations for semi annual PFOA monitoring on a going-forward basis. The five monitoring points were chosen as representative o f the following site conditions (See attached site map): Monitoring Point MW-7 MW-4 PZ-14 MW-101 Water supply distribution system PZ, piezometer, a small monitoring well Site Condition Upgradient o f site industrial activities Central to site industrial activities Westem/downgradient of site industrial activities Eastem/downgradient o f site industrial activities Site-wide ground water from the production wells Sampling o f the water supply distribution system was substituted for sampling o f the individual highcapacity pumping wells because the water that supplies this system is a composite o f water drawn from these wells and therefore is representative of groundwater throughout the developed portion o f the site. PFOA data from the five monitoring points listed above was collected on September 30,2003 and on May 19, 2004. The results of these most recent monitoring events and previous sampling events for these points are presented in the table below. Page 3 Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency Sample Identification MW-7 MW-101 Water Supply Distribution System PZ-14 MW-4 Date Sampled 07/11/01 09/07/01 10/31/01 11/12/01 12/03/02 06/05/03 09/30/03 05/19/04 07/11/01 09/07/01 10/31/01 11/12/01 12/03/02 06/05/03 09/30/03 05/19/04 07/11/01 09/07/01 10/31/01 11/12/01 12/03/02 06/05/03 09/30/03 05/19/04 07/11/01 09/07/01 10/31/01 11/12/01 12/03/02 06/05/03 09/30/03 05/19/04 07/11/01 09/07/01 10/31/01 11/12/01 12/03/02 06/05/03 09/30/03 05/19/04 3M Cottage Grove P FO A Data Summary PFOA PFOA Lab DS PFOA Field DS (PPb) (PPb) (PPb) NA NA NA NA ' NA NA NA NA NA NA NA NA NA NA NA 0.309 0.307 0.326 0.329 0.334 0.327 0.367 NA 0.366 NA NA NA NA NA NA NA NA NA NA NA NA 170 180 135 149 172 125 158 155 154 236 NA 230 1.23 1.14 NA NA NA NA 40.6 38.5 11.4 10.8 41.1 17.1 NA NA NA 28.0 28.1 27.7 5.17 5.35 8.77 23.6 NA 23.3 NA NA NA 6.40 6.77 5.89 4.96 6.06 5.25 4.66 4.63 4.60 NA NA NA 4.80 4.67 4.96 4.10 3.98 4.09 4.68 NA 4.83 NA NA NA NA NA NA 5.67 5.93 7.39 5.30 5.11 5.45 NA NA NA 10.2 10.2 10.1 8.74 9.10 9.12 17.0 NA 16.4 PFOA Avg; (PPb) NA NA NA NA NA 0.314 0.328 .0.3665 NA NA NA NA ' 174 136 155.7 233 1.185 NA 40.1 13.1 NA 27.9 6.43 23.45 NA 6.41 5.37 4.63 NA 4.81 4.06 4.76 NA NA 6.33 5.29 NA 10.2 8.99 16.7 Std. Deviation NC NC NC NC NC 0.01 0.004 0.001 NC NC NC NC 5.29 12.06 2.08 4.24 0.06 NC 1.38 3.48 NC 0.21 2.03 0.212 NC 0.36 0.48 0.03 NC 0.15 0.067 0.106 NC NC 0.93 0.17 NC 0.06 0.214 0.424 Table N ot: ppb: Parts per billion NA: Data not available for sampling period NC: Not calculated Field DS: Field duplicate sample Lab DS: Laboratory duplicate sample Page 4 Document Control Office (DCO) Office o f Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency The results presented above indicate that groundwater levels of PFOA have remained relatively constant from 2001 to the present, notwithstanding the recent cessation o f PFOA production at the site. Please note that, during all groundwater monitoring at this site, 3M has collected a field duplicate sample to provide a measure of the precision associated with sample collection, preservation and storage as well as laboratory procedures. As noted in the Table, 3M did not conduct laboratory duplicate analyses for the samples collected on May 19,2004. Effluent Monitoring The site has a multi-phased wastewater treatment plant that is used to treat all process wastewaters generated at Cottage Grove. Two o f the systems treat inorganic wastewaters and the third is an organic, biological treatment system. At this time, all of the process effluent wastewater is treated with activated carbon. All o f the treated process wastewaters from these operations are combined at a single discharge point, and then are further combined with non-contact cooling and storm water before being discharged to the Mississippi River. Since January 2000, the 3M Cottage Grove plant has conducted PFOA analysis of its effluent. Sampling has been performed monthly beginning in January 2003 in accordance with the requirements o f 3M's NPDES permit. This information is reported to the Minnesota Pollution Control Agency in the monthly Discharge Monitoring Reports (DMR). Effluent wastewater samples are collected at the plant outfall on the Mississippi River. This is the common discharge point for all o f the plant's process wastewaters. All samples are collected as 24-hour composites and duplicate analysis is conducted for each sample. The following table presents the monitoring results of the Cottage Grove process wastewater effluent discharged under Minnesota NPDES Permit No. MN000149, Outfall SD 001. The data includes results of all monitoring events thru June 2004. Page 5 Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency Sample Date January 15,2003 February 12, 2003 March 12,2003 April 23,2003 May 15, 2003 June 11,2003 July 16, 2003 August 7,2003 September 10, 2003 October 8,2003 November 5, 2003 December 10, 2003 January 14,2004 February 4,2004 March 3,2004 April 7, 2004 May 5,2004 June 2,2004 3M Cottage Grove Effluent Monitoring Results PFOA Analysis from SD 001 PFOA PFOA (dup.) 80.1 77.9 80.0 78.8 74.3 74.7 112.0 109.0 95.0 101.0 18.9 16.4 77.4 79.7 79.7 85.2 53.3 55.5 73.9 102.0 60.1 67.8 66.5 66.5 1.60 1.74 127.0 102.0 73.3 75.9 8.9 9.5 36.8 34.3 2.5 2.0 PFOA Average 79.0 79.4 74.5 110.5 98.0 17.7 78.6 82.5 54.4 88.0 64.0 65.6 1.67 114.5 74.6 9.2 35.6 2.5 As shown above, PFOA levels varied throughout the most recent reporting period of July 2003 to June 2004. As mentioned above and in previous meetings and reports, 3M has installed an activated carbon treatment system to remove certain constituents from the wastewater treatment plant effluent. This system was in start-up during this reporting period and now is in full operation. While die system was installed for reasons unrelated to PFOA, this technology has been shown to be effective in removing this substance as well. J5 Page 6 Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency The expected in-stream concentration o f PFOA in the Mississippi River resulting from wastewater discharges would be extremely low. Assuming an average base flow for the Mississippi River o f 7500 MGD (million gallons a day) and an effluent flow of about 3 MGD, the expected in-stream PFOA concentration would be about 20 ppt (parts per trillion), very near the detection limit o f PFOA. DECATUR. AL SITE MONITORING DATA The 3M Decatur site is approximately 900 acres with the area of the manufacturing facilities being approximately 200 acres. The current Dyneon fluoropolymer production facilities are co-located with 3M's other manufacturing operations at the site where 3M previously produced PFOA and other fluorochemicals. The land surrounding the site is predominantly industrial and commercial. Chemical manufacturing operations began at the site in 1961. hi 1962 the facility was expanded to include a film manufacturing plant. Production of PFOA at the site occurred in 1999-2000. This site is the subject o f a Memorandum o f Understanding between 3M and EPA for additional monitoring on and around the site. Monitoring Results Groundwater Monitoring As stated in the previous submissions, 3M selected the following wells for groundwater sampling and PFOA analysis going forward: Monitoring Location Site Condition Wells 226R & L Wells 220R and L Well 320L Wells 327R Wells 310R & 317L Located east of inactive landfill and south o f wastewater treatment - monitors background conditions in residuum and shallow limestone groundwater Located northeast o f inactive landfill - monitors predominant flow path of plume in residuum and shallow limestone zones Located north o f inactive landfill - monitors secondary flow path of plume Located in the former incinerator area - monitors residuum groundwater near source area Located in the Chemical Plant - monitors dominant groundwater flow pathways in the Chemical Plant Page 7 Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency Groundwater samples from the eight monitoring points were collected on July 15-16, 2003, December 11-12,2003 and January 9,2004. The PFOA results are presented in the table below. As at Cottage Grove, 3M collected field duplicate samples dining the monitoring to provide a measure of the precision associated with sample collection, preservation and storage as well as laboratory procedures. As noted in the Table, 3M did not conduct laboratory duplicate analyses for the samples collected on June 9,2004. The groundwater data for recent and previous monitoring events are shown in the following Table. GROUNDWATER WELL MONITORING DATA FOR THE 3M DECATUR. AL MANUFACTURING SITE SAMPLE ID 310R 220R 220L 226R 226L 317L 310L 327R SAMPLE DATE 7/16/03 12/03 06/04 7/16/03 12/03 06/04 7/16/03 12/03 06/04 7/16/03 12/03 06/04 7/16/03 12/03 06/04 7/16/03 12/03 06/04 7/16/03 12/03 06/04 7/16/03 12/03 06/04 ND " Not detected. NQ = Not quantifiable. --= No sample. PFOA (ppb) 1570 2010 1580 68.2 102 92.3 89.2 135 110 10.6 ND ND NQ ND ND 0.94 0.521 0.776 ND NQ 0.483 2280 1780 1360 PFOA (ppb) LabDup 1560 2140 --- 68.6 89.0 -- 88.8 131 -- 11.0 ND -- ND ND -- 0.95 0.490 -- ND NQ -- 2600 1910 - PFOA (ppb) Field Dup 1590 2670 1940 65.8 106 97.9 90.2 142 121 10.6 ND ND ND ND ND 0.99 0.785 0.792 NQ NQ 0.506 2280 1910 1370 PFOA (ppb) Average 1573 2273 1760 67.5 99 95.1 89.4 136 115.5 10.7 ND ND ND ND ND 0.96 0.599 0.784 ND NQ 0.495 2386 1867 1365 Page 8 Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency As indicated by the data presented in the Table, there is a wide range of PFOA levels measured in the groundwater beneath the site. However, the data suggest a low likelihood of off-site groundwater contamination. For example, the levels in the well 31ORduring three sampling events show little change, which is predictable considering the slow movement of ground water explained above. In addition, wells 220L, 226L, and 310L show extremely low to non-detectable levels o f PFOA. These wells are drilled into the aphaltic limestone, which acts as the confining layer that prevents groundwater movement downward. Effluent Monitoring 3M's Decatur, Alabama manufacturing facilities obtain process water from the City o f Decatur Utilities, and directly from the Tennessee River. In addition, many o f the manufacturing operations utilize noncontact cooling water, which is obtained from the Tennessee River. All process wastewaters from the 3M and Dyneon manufacturing operations are treated in the site's wastewater treatment facility. The system contains both physical-chemical and biological treatment. Process wastewaters are mixed with non-contact cooling water prior to discharge to the Tennessee River. The discharge is permitted under Alabama NPDES Permit No. AL0000205. The process wastewater discharge and combined process wastewater/non-contact cooling water is designated as Outfall 001A and 001, respectively. As explained in our May 7 letter, wastewater sampling at the Decatur site for PFOA analysis is being conducted on a quarterly basis. Samples are collected at Outfall 001, which consists o f treated process wastewater and non-contact cooling water. The outfall discharges to Baker's Creek, which in turn empties into the Tennessee River. All samples are collected as 24-hour composites and duplicated analysis is conducted for each sample. The specific sampling and analytical protocols were described in 3M's May 7,2003 letter to EPA. The following table presents the PFOA monitoring results for the Decatur wastewater effluent discharged under Alabama NPDES Permit No. AL000205, Outfall 001. The data summary includes the historical data and the 2003 - 2004 monitoring events. 3M Decatur 2nd Q uarter, 2003 and Historical Events Outfall 001FC Sampling Results Sample Date 1998 1999 2000 2001 January, 2003 May 28,2003 July 21,2003 November 3,2003 January 27, 2004 June 16,2004 Results Duplicate Average (all values are listed as ug/1) N/A N/A 602 N/A N/A 766 N/A N/A 1028 N/A N/A 310 N/A N/A 58 89.0 87.5 88.3 10.1 N/A 27.1 N/A -- 411.5 N/A -- 2.5 N/A -- B Page 9 Document Control Office (DCO) Office of Pollution Prevention and Toxics (OPPT) US Environmental Protection Agency As indicated by these data, there has been some variation in the levels o f PFOA in the discharge to the Tennessee River. This is mainly a result o f the schedule o f actual production operations at the Dyneon plant. This was especially apparent with the results of January 2004 sampling, during which a particular washing step was occurring at the plant. The overall reduction throughout these 5 years is mainly a result o f the production phase-out of PFOA at this site, and the improvements in the fluoropolymer production process occurring at the Dyneon operation. Continued decreases in the effluent concentration are anticipated because of ongoing process improvement efforts. In addition, the results o f Tennessee River surface water monitoring previously submitted to the AR-226 Docket indicate that PFOA levels in the river remain at low levels. In summary, this letter reports results o f wastewater and groundwater monitoring at the Decatur and Cottage Grove sites. This submittal fulfills the continuing commitments o f 3M and Dyneon under the March 13,2003 3M LOI and the March 14,2003 APFO Users LOI. If there are any questions, please contact the writer at the address provided below. 1____ Director, Environmental, Health, Safety and Regulatory Affairs 3 M - Bldg. 236-IB -10 P.O. Box 33331 St. Paul, MN 55144 651 733-6374 (phone) 651 733-1958 (fax) E-mail: masantoro@mmm.com cc: Mary Dominiak - Room 4410 ?