ORIGINAL
TSCA NON-CONFIDENTIAL BUSINESS INFORMATION
DOCUMENT DESCRIPTION

8EHQ-o0598 -33

DOCUMENT CONTROL NUMBER

DATE RECEIVED

1191200(000116

i

COMMENTS:

DOES NOT CONTAIN CBI

 3M Environmental, Health and
Safety Operations

3M Center, Building 0224-05-W-03
S.Paul, MN 55144-1000

2,aL
RECEIVED
OPPT CBIC
2011INOV -3 AM10: 50

IA M

Certified Mail

October 27, 2011

11111 11111 1E 1E II 111111
HiI1
NO CBI

Document Processing Center
EPA East - Room 6428 Attn: Section 8(e)
Office of Pollution Prevention and Toxics, US EPA
1200 Pennsylvania Avenue NW
Washington DC 20460-0001
Re:

TSCA 8(e) Substantial Risk Notice: Supplemental to Docket No. 8EHQ-0598-3 73;
Sulfonate-based and Carboxylate-based Fluorochemicals - Cordova, IL well water
sampling

To whom it may concern,
3M is submitting this notice to supplement its previous submissions on sulfonyl-based and
carboxylate-based fluorochemicals and more specifically, our September 5, 2006 submission
on water samples taken from groundwater wells and from the water distribution system at the
3M plant site in Cordova, Illinois and our March 10, 2010 submission on water samples taken
from commercial wells adjacent to the 3M Cordova facility.
The data contained in previous submissions and in this correspondence have been generated as
part of an on-going site-related environmental assessment of fluorochemicals that 3M is
performing for its 3M Cordova, Illinois manufacturing facility. As part of this effort, which is
being done with the involvement and approval of the Illinois Environmental Protection Agency,
3M has recently received the enclosed well water data taken from various private residential
properties in the vicinity of the 3M plant. Off-site data are limited to seven private wells,
referred to by five-digit identification numbers as listed in the enclosures to this submittal.
Enclosed please find a map depicting the sampling locations, a data summary table, and a final
analytical report (Interim Report #3-Analysis of 3M Cordova Groundwater Samples: July 2011;
Analysis of Perfluorobutanoic Acid (PFBA), Perfluorooctanoic Acid (PFOA),
Perfluorobutanesulfonate (PFBS), Perfluorohexanesulf'bnate (PFHS), and
Perfluorooctanesulfonate (PFOS) in Groundwater Using LC/MS/MS for the "3M
Fluorochemical (FC) Assessment Work Plan for the 3M Cordova, IL Facility).
With the exception of one low measurement of PF13S in one well and a similar low reading for
PFOS in another well, the results for PFOA, PFOS, PFHS and PFBS were all less than the limit
of quantitation (<0.025 ng/ml). PFBA results ranged from 0.0673 to 3.41 nglmL.
For context, it should be noted that U.S. EPA has established Provisional Health Advisories
(i.e. guidance levels pertaining to drinking water) of 0.4 and 0.2 nglmL for PFOA and PEOS,
respectively. We are not aware of any EPA plans to establish a PHA for PFBA. Further
perspective is provided by recently issued site specific cleanup objectives as derived by the

CONTANS NOCBI

 Document Processing Center
October 27, 2011
Page 2

Illinois EPA. As established for the 3M Cordova site, these groundwater objectives are 0.4, 0.2
and 20 ng/mL for PFOA, PFOS and PFBA, respectively. Another comparator for PFBA comes
from Minnesota where the Department of Health has set a Health Risk Limit (HRL) value for
drinking water of 7 nglmL for PFBA. In conclusion, all results for all the wells sampled are
well below known drinking water guidance values or standards. Inherent in these criteria are
assumptions and safety factors to ensure safe levels in drinking water for a lifetime of
consumption.
While 3M does not believe that any of these data taken alone or cumulatively meet the
"substantial risk" reporting threshold as defined by the EPA, we nevertheless recognize the ongoing work of the 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 or would like any additional information, please contact Deanna
Luebker at (651) 737-1374 or diluebkerkinm.com.

Sincerely,

Jean B. Sweeney
Staff Vice President, 3M Environmental, Health and Safety Operations
Enclosure

 

 

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3M Cordova Facility
Cordova, IL
Perfluorochemical Results for Residential Wells Sampled on July 18, 2011
Sampling Location
23321
22610
22704
22703
22414
22009
21421

PFBA
0.224
0.182
0.452
0.0783
0.0673
3.41
1.73

All results in nglmL (ppb).

PFOA
<0.025
<0.025
<0.025
<0.025
<0.025
<0.025
<0.025

PFBS
<0.025
<0.025
<0.025
<0.025
<0.025
<0.025
0.0583

PFHS
<0.025
<0.025
<0.025
<0.025
<0.025
<0.025
<0.025

PFOS
<0.025
<0.025
0.0412
<0.025
<0.025
<0.025
<0.025

 7010J 1670 0000 0222 2178
Deanna Luebker, PhD
CTRS 220 6E 03
651
1374St.
73

3M

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3M Center

Paul, MN 55i44-1001