Document vyjKx0ZoOdKLz4Gnd9qdNVG4w

~James Kelley - RE: 3M Cotta.ge Grove/Call from Bob Paschke Lg From: bo fini To: Be am Date: ee cottonBobPasate Subject: "Douglas, David" <David.Douglas@state.mn.us> "Kriens, Don" <Don.Kriens@state.mn.us> 7/23/04 11:23AM RE: 3M Cottage Grove/Call from Bob Paschke on, arkfor urvay clo eatin hess. Wa my Don, thanks for your very clear explanation of the situation. It is my So recollection that you estimated that about 1,500 pounds of PFCs were i ram et So en i being discharged into the river from the 3M Cottage Grove WWTF at the nn orn co So time that the MPCA required the construction of the GAC system. There om a pe arecien f n QAC rte,Ts is a 3M Woodbury site report that indicates that about 45 tons of PFC a oaseores waste was buried at the 3M Woodbury site. If 50 pounds of PFOS and EE ess oryr ey PFOA are being discharged into the river per year from the 3M Woodbury a rrJe mo Ho site (please note that Bob Paschke told me that he believes that the EE Thawte flow is 5 million gpd), can you estimate the discharge of all PFCs per Redd year from the 3M Woodbury site? Dave -- .....Original Message..... Igae---- From: Kriens, Don SR os 1034 Sent: Friday, July 23, 2004 10:34 AM IE gn To: Douglas, David FS ---- Cc: 'Jim Kelly (E-mail)'; Brott, Bruce; Ferrey, Mark; White, Dann; LE BBFr Me Stahnke, Gerald; Connolly, Mike; Oliaei, Fardin; Solem, Laura; a. a Everstine, Karen; Day, Douglas; Williams, Alan ; Silis, Ainars SET By Syi mS Ar Subject: RE: 3M Cottage Grove/Call from Bob Paschke Ep ---------- Dave, just a few brief comments. The Woodbury pumpout flow is eo eyfue probably less than 5 MGD; I believe it is more on the order of 2-3 MGD vss (unless there are considerable consumptive water losses in the Cottage Tom Grove plant). We can get the accurate flow numbers. The total BE a cooling water flow from the 3M Cottage Grove plant is about 4 MGD on Ssa Ea Tu average. The Woodbury pumpout is directed to the plant for cooling Foog hr water use/makeup. A portion of the cooling water flow used at the a ma plant, however, is obtained from the plant site wells and is thus Ban boreranagboepinmt combined with the Woodbury pumpout flow. ES -- The granular activated carbon (GAC) system recently installed at the a Sel cosles plant is designed solely for carbon treatment of the treated process a a an ara1s OM wastewater effluents, which also averages about 4 MGD. The new GAC Ss system was not designed to treat any additional cooling water flow a although during emergencies, such as spills into the cooling water a bbe system, the cooling water can be diverted for temporary treatment att through the GAC system. At the time we negotiated the installation of TE Spgs ares beboar the GAC system, required by the NPDES permit, we were unaware that FCs rm) were contaminants of the site groundwater as well as the Woodbury EE groundwaters (pumpout). The GAC system was installed to remove the i miscellaneous organics discharged from the facility, in part initially a a on Sai driven by a need to remove acute effluent toxicity due to APE SmSOS ones compounds. The GAC system in our view would also represent the best moa L i miSres available technology to remove the FCs. Given the relatively high EE moe te A molecular weight of these compounds we would expect removal to very i low concentrations. 3 too itn tyatoYa stolen At some point it would be relatively easy, via additional sampling of Se, the combined cooling and process effluent (post GAC treatment), to BEL LA a Sapo determine the FC mass loading discharged to the river. If we are planning a fish or "stream" study of the Mississippi River with 11995577..00000011 , ........... - Page1~ on Exhibit 11995577 State of Minnesota v. 3M Co., Court File No. 27-CV-10-28862 Tee STATE_02803858 [J.ame_s .Kelly - RE: 3M Cttage Grove/Call from Bob Paschke ......... " ropa 10 Fath nam sprpritst cot rrssSeo FG respect to FCs then it seems appropriate to conduct a mass balance (FC tomass discharged in the combined effluents) for the FCs. oemDon er > .....Original Message..... Dee 5 Toi JimKell(E-mal); Brot, Bruce; Ferrey,Mark; Kriens, > From: Douglas, David >> SSeennt:t: T Thuh rsdau y,JJur ullyy22s 22,,2d 2000044a1111:y :1144, AAMM > To: Jim Kelly (E-mail); Brott, Bruce; Ferrey, Mark; Kriens, por: he Sof lS, Bc cy Ma Kr > Don; White, Dann; Stahnke, Gerald; Connolly, Mike; Oliaei, Fardin; k To hRBrn Sg > Solem, Laura; Everstine, Karen; Day, Douglas; Williams, Alan > Subject: 3M Cottage Grove/Call from Bob Paschke 2 aan Parks cat ma cytoaksouth ra Coa Bob Paschke called me today to talk about the draft 3M Cottage cr a Grove Health Consultation report and expressed concerns about MDH's os tro first recommendation about considering conducting a 3M Cottage Grove a remedial investigation under the consent order addendum similar to the eS arr Su 59 3M Decatur, Alabama facility investigation being conducted under EPA ae authority. I stated that nothing has changed here regarding what ot ad accede Goa rina Bruce Brott told 3M regarding proceeding at 3M Cottage Grove with a rg canara tate Cre phased approach starting with ground water under the facility. Bob ao on expressed concerns about doing a mammalian s|udy and a vegetation co hm one sporm study. I stated that we had not talked about these types of studies nena nd > but had talked about a stream and Mississippi River sediment study and a asomos > a Mississippi River fish study. Also I stated that we had concerns edPe a a ci > about second generation human effects from PFCs. He said that he did Ee Foc Bes > not know much about second generation human effects from PFCs, but eon sha tr, said that John Butenhoff at 3M was the toxicologist who knows most et rvs about the toxicology of PFCs. I emphasized several times that 3M pbA et eosho hr cer Cr > needs to respond directly the MDH about their concerns about MDH's first recommendation and anything else in the document. > ITI I asked Bob if 3M had test results back for the ground water re pump out well effluent from the 3M Woodbury site (where PFC wastes So aur were buried) and he said that the results indicated that there was 1 SE PERI] > ppb PFOS and 2 ppb PFOA in the effluent. (The HBV for PFOS is 1 ppb Ee nerwaco and the HBV for PFOA is 7 ppb.) He said that the volume of Woodbury ET a en site effluent (discharged directly to the Mississippi River) is 01 approximately 5 million gpd. I estimate that this is equivalent to a esd EOS ur sor discharge of 33 pounds of PFOA per year and 16 pounds of PFOS per year Aa CL or about 50 pounds per year of the two PFCs. Because these are just En nh two of many PFCs in the effluent, it is difficult to say how many a LS pounds of PFCs are discharged into the Mississippi River per year. a This effluent is not treated by the 3M Cottage Grove WWTF and there a are no plans for this effluent to be routed through the new carbon a Ee ae filtration system. I asked for a copy of the lab data and Bob said SIR Fe caer arte that he would fax a copy to me. If you are interested in copy of the data, please let me know. ymin David N. Douglas Diascary > Minnesota Pollution Control Agency TE mm Superfund Unit 2/Superfund Section IEMajors and Remediation Division I Ger Office: (651) 296-7818 IRR Fax: (651) 296-9707 DE cms mis Email: david.douglas @ pca.state.mn.us 11995577..00000022 Pae 2~ JE-- STATE_02803859 eX| ~J~ames.Kelly - RE: 3M ~Co_tt_a~g~ Gr_ove/Cal! ,fro_m Bob Paschke - Pa~ Cc<BcCr::uce Brott@stat""oJj.iimmmn.KKouelslll>yy,E(E`-F-memraraieilly)"," <M<aJJraakmm"ee<ssMK.KaoerlikllyF@@esrstrtaeatytee@..mmsntn.a.ulusos>.>,m,n`".BBurrsoo>tt,,t, "BBWrrhuuiccteee"", Dann" <<<MDBiDakraunencn.neWC..WoBhnirhnotiotteetl@@l@ysss@tttasaatttteaeo.t..mmemn.nn.m..unuus.ss>u>>,s,,>""*F,SSet"traarOehhlnynak,ke,eM,,aFGGraekerr"draia<lnldMd""a<<<rFGkGa.erFerceraiarlnrldde,.SyOS@ tftaiashehtnian@ktkesoe.t@msattnsea.tua.tsmtee>n.,.mmu"nnWs..>uuhss"it>>Se,o,,l"De'CCmoao,nnnnnLan"alolullyry,a,"MMiikkee"" <<"<DLLMoaaiuukugrerlaa.Ca.SSsooo.nlDlneoaommyl@ly@@s@sastlstaaottat.eotme..rn.mam.nnun.uus.uss>s>s,,>, ,"`"EEW"vOivolerli~rssatetmiiin,nsee,F,,AaKKlrdaaarinnree"nn<"<"FA<<aaKKrandarirWnoei.nnOl.EElliavaveemerisr@ss@tiissnntteaoa@ t@teso.smi.tamantnt.eo.u.u.smsm>>nn,,."uuSsSso>i,l,sem,`"DD,AaaylLy,aa, ruDDsroao"uu"ggllaass"" <AnarsSis @stato.mn.us> <Douglas.Day@state.mn.us>, <Ainars.Silis @state.mn.us> "Williams, Alan "<Alan.Williams@state.mn.us>, "Sills, Ainars" 11995577..00000033 STATE_02803860 STATE_0280 3860