Document pmMp7a3Nw809mDLZ3JjpbDm5B
Katherine E. Reed, Ph.D. Staff' Vice President
3M Environmental, Health and Safety Operations
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900 Bush Avenue, Building 42-2E-26 PO Box 33331 St. Paul. MN 55133-3331 651 778 4331
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August 15, 2006
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Document Processing Center EPA East - Room 6428 Attn: Section 8(e) Office of Pollution Prevention and Toxics U.S. Environmental Protection Agency 1200 Pennsylvania Avenue, NW. Washington, D.C. 20460-0001
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Re: TSCA Section 8(e) Supplemental Notice: Sulfonate-based and Carboxylic-based Fluorochemicals, Docket No. 8EHQ-0598-373
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Dear Sir/Madam:
3M is submitting this letter to supplement its previous submissions on sulfonyl and carboxylic-based fluorochemicals, and specifically its February 9, 2005 and June 14, 2005 submissions with analytical data for water samples.
3M has recently analyzed water samples taken from municipal wells in the community of Oakdale, Minnesota. The sampling and analysis of these wells occurred in cooperation with the Minnesota Department of Health (MDH). Water samples were split between 3M and MDH. Each sample was analyzed for PFBA, PFPeA, PFHxA, PFOA, PFBS, PFHxS and PFOS. 3M is providing a final report from its Environmental Laboratory as well as the data generated and set out in spreadsheets by MDH for the split samples (see attachments).
In addition to the foregoing data on Oakdale, 3M is providing three maps received from MDH which show water data for the Lake Elmo, Minnesota area. The maps show the cumulative results for PFOS and PFOA, and the results for PFBA. Inquiries on this data should be directed to the MDH since 3M was not involved in the testing and does not have copies of final analytical reports.
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3M does not believe that these data meet the TSCA Section 8(e) "substantial risk" reporting threshold. Nevertheless, 3M has decided to report this information, recognizing its importance to the ongoing work by U.S. EPA to assess fluorochemical exposure pathways and potential risks. If you have any questions, please do not hesitate to contact the TSCA 8(e) Coordinator, Dayna Blomquist at (651) 736-5413.
Katherine E. Reed Staff Vice President, Environmental Health and Safety Operations