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2010-04-07 PACKET 12.A.
REQUEST OF CITY COUNCIL ACTION COUNCIL AGENDA MEETING ITEM DATE 04/07/201 PREPARED BY Engineering Jennifer Levitt ORIGINATING DEPARTMENT STAFF AUTHOR COUNCIL ACTION REQUEST Workshop: PFC Remediation Work Plan. STAFF RECOMMENDATION Workshop: PFC Remediation Work Plan. ADVISORY COMMISSION ACTION DATE REVIEWED APPROVED DENIED ❑ PLANNING ❑ ❑ ❑ ❑ PUBLIC SAFETY ❑ ❑ ❑ ❑ PUBLIC WORKS ❑ ❑ ❑ ❑ PARKS AND RECREATION ❑ ❑ ❑ ❑ HUMAN SERVICES /RIGHTS ❑ ❑ ❑ ❑ ECONOMIC DEV. AUTHORITY ❑ ❑ ❑ ❑ ❑ ❑ ❑ SUPPORTING DOCUMENTS ❑ MEMO /LETTER: Jennifer Levitt, March 19, 2010. ❑ RESOLUTION: ❑ ORDINANCE: ❑ ENGINEERING RECOMMENDATION: ❑ LEGAL RECOMMENDATION: ® OTHER: Groundwater Flowpaths and PFBA Plume in Jordan Aquifer, MN Decision Documents, PFC in Minnesota's Ambient Environment: 2008 Progress Report, Rural Residential PFC Concentrations, and MPCA Settlement Agreement and Consent Order. ADMINISTRATORS COMMENTS f f ity Administrator Date COUNCIL ACTION TAKEN: ❑ APPROVED ❑ DENIED OTHER CITY OF COTTAGE GROVE MINNESOTA To: Honorable Mayor and City Council Ryan Schroeder, City Administrator From: Jennifer M. Levitt, P.E., City Engineer Date: March 19, 2010 Re: Workshop: PFC Remediation Work Plan The Settlement Agreement and Consent Order for the PFC remediation for the 3M Cottage Grove site, the 3M Oakdale Disposal site and the 3M Woodbury Disposal site was signed on May 22, 2007. The agreement is included for reference. The consent agreement provides for the excavation of the contaminated materials at all three locations. The contaminated material is removed for the sites and transported to SKB for disposal in a lined vault that meets all hazardous waste disposal standards. Following the excavation, the areas are capped, and a pump- and -treat system is installed to address any residual release that may occur. As part of the agreement, 3M commits to providing alternative drinking water if and when a Health Based Value (HBV) or Health Risk Limit (HRL) is exceeded as a result of contamination from the sites. The City's drinking water comes from groundwater via eleven municipal wells. The wells are located in the Jordan and Prairie Du Chien aquifers. The City's wells have all tested below the MDH standards of 0.3 ug /L or ppb for perfluorobutanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) and 7 ug /L or ppb for perfluorobutanoic acid (PFBA). Currently none of the City's municipal wells have PFOA or PFOS in them The City has four wells with trace amounts of PFPeA, three wells with PFBS (0.16 ppb) and three wells with PFHxS at trace levels. All wells have PFBA present averaging 0.91 ppb, which is considerably below the HBV of 7 ppb. A list of the private wells receiving treatment are enclosed, along with the corresponding concentrations. The Consent Order also requires 3M to pay up to $5 million to the Pollution Control Agency (PCA) for research costs on the presence and effects of PFCs found in the environment. The Environmental Commission received an update on the research efforts in relation to PFCs by Paul Hoff from the Environmental Reporting and Special Studies area of the PCA. Enclosed for reference is the PFCs in Minnesota's Ambient Environment: 2008 Progress Report from the PCA, along with the Power Point slides from Mr. Hoff's presentation. The Consent Order requires 3M to fully cooperate with the Minnesota Department of Health (MDH) and the PCA on research. The Order also provides PCA with full access to all non - privileged 3M documents on PFCs and includes provisions of any such documents of interest upon request. Discussion Environmental Commission The Environmental Commission approved a work plan regarding the PFC remediation efforts that proposed development of a work group to work with representation from the following organizations: • MDH • MnDNR • MnPCA • Washington County • Metropolitan Council • South Washington Watershed District • Other local units of government • 3M A letter has been drafted to the Commissioners of the PCA, DNR, and MDH to request participation in the work group. The goal of the work group is to seek a plan to address the valuable resource of groundwater that is proposed to be pumped from the remediation sites and discharged into the Mississippi River following a treatment process. The work group would also address the discharge concentration of the PFCs into the Mississippi River from the proposed treatment plant; currently the Consent Order is silent on the specified concentration. According to the PCA, the discharge concentration would be governed by the Industrial NPDES permit for the site. The NPDES permit would be available for public comment. The goal is to find re -use options for the pump out water from the remediation sites, such as wetland or other water feature creation, aquifer storage, aquifer recharge or industrial processing water. The proposed pump out system for the two sites will pump 7.4 -9.2 million gallons per day; this compares to Cottage Grove's pumping to provide municipal water to the entire City's population at 3.6 million gallons per day. Groundwater is a resource that needs to be protected from contamination, but it also needs be conserved for future generations. The Cities of Cottage Grove and Woodbury are working to set up a meeting with local legislators to discuss this work plan and the concerns both communities have on the impact to groundwater and the fact that the current plans do not address this valuable resource. 1 4 P a= -W . ex /. al'J /Wr ♦ �l B A nw r y � a 3 JS t'repared by DH - 730/07 v. Y k 'u Ca. 3 rk x3 b O , A A- Z'PFW r a K - 100th . Vim 1 AFTOW 30th St. C � . -I . -0- _ 11 I 91 o 70th -7124107 PFBA in Prairie du Chien - July 20 07 Not detected I..o - 1.5 ppb 0.2 - 0.5 ppb 1.6 - 1.9 ppb 0.6-0.9 ppb > 2.0 ppb : \� [� d � / � \� � \ � } _'I e 0 0 �.: o �. o 0 0 IiIM�p 9r� j .. r `- o \. '�`__- , i i 4 �� 1 `i ` _y�� a 4 \ \ � � t� � ��. 0 �� e w vS A � � .� + 'r i q' i 4 rXa,�. i \ � v � .,� , � � ,. . � `. ,, ����,, � �� �. .; °a ., � �� er a �E7 .�� l' �� � ..p c ,��yprrt�"� o ��� 3M Cottage Grove Disposal Site City of Cottage Grove, Washington County, Minnesota SITE DESCRIPTION Background The 3M Cottage Grove Site (Site) encompasses a large industrial complex located along U.S. Highway 61 in Cottage Grove, Minnesota. The property covers about 1,700 acres but only about 200 acres on the southern portion are industrialized. High bluffs above the Mississippi River are on the southwest side of the property. Formerly known as the 3M Chemolite plant, the facility has been in operation since 1947.3M currently manufactures a range of products there, including adhesive products, specialty paper, industrial polymers, abrasives, and reflective road - sign materials. The company also does proprietary research and development there. As was common in past manufacturing before the advent of environmental regulations, 3M disposed of various industrial wastes, including those from Perfluorochemicals (PFCs) manufacture, on the property as well as at three other Disposal Sites in Washington County. Disposal methods on the Site included burial and disposal pits. The Site was placed on the State Superfund list in 1984 due to soil and groundwater contamination from Volatile Organic Compounds (VOCs), typically solvents. 3M completed site investigations and cleanup actions to address VOCs at the Site in both soil and groundwater. A groundwater pump -out system was installed to prevent VOCs in groundwater at the Site from reaching the Mississippi River. The pump -out system is still in operation today. STATEMENT OF PURPOSE This Minnesota Decision Document (MDD) presents the selected response actions for PFC contamination at the 3M Cottage Grove Disposal Site and summarizes the facts and determinations made by the Minnesota Pollution Control Agency (MPCA) staff in approving the recommended response action alternatives. Soil and groundwater at the Site are impacted with PFCs and VOCs. Previous response actions have been taken by 3M to address VOC releases. The selected response actions in this MDD are intended to prevent human receptors and the surrounding environment from being exposed to contaminated environmental media that are currently on -site. The Commissioner or his delegate has determined that the response actions set forth in this MDD are reasonable and necessary to protect the public health and welfare and the environment from the release and threatened release of PFCs from the Site. o-pfc3 -05 PFCs at the 3M Cottage Grove Site PFCs are a family of synthetic chemicals that were initially produced in the 1950s and manufactured by 3M at the Cottage Grove facility. PFCs are used in a wide variety of products made around the world because of their unique abilities to resist heat, oil, stains, grease, and water. 3M phased out manufacture of some PFCs by 2002, most notably Perfluorooctanoic Acid (PFOA) and Perfluorooctane Sulfonate (PFOS). As a result of the discoveries starting in 2004 that drinking water in parts of Washington County had become contaminated with PFCs, the MPCA directed 3M to look for PFC contamination remaining in soil or groundwater from past disposal practices on the Cottage Grove property. Investigation began in 2005 and continued into 2009 under MPCA oversight. Site Investigations The MPCA and 3M signed a Settlement Agreement and Consent Order (CO) in May 2007 governing investigation and cleanup of three 3M PFC Disposal Sites (i.e., Oakdale, Cottage Grove, and Woodbury). As part of the agreement, 3M completed a Remedial Investigation (RI) and Feasibility Study (FS) for the Cottage Grove Site, the focus of which was to identify any remaining threats to public health or the environment from releases of PFCs at the Site. The CO also required that in developing cleanup alternatives, primary consideration should go to those that excavate and destroy remaining PFC wastes, or that excavate and dispose of PFC wastes in a permitted, isolated, engineered containment facility. The RI for the Cottage Grove Site showed that previous cleanup actions for VOCs had not removed all residual PFCs on the property. A number of areas were found to contain elevated levels of PFCs in soil and in groundwater beneath the property. These areas had been used in the past for a range of purposes including storage, disposal, or treatment of various types of solid or liquid wastes. Groundwater under the property flows toward the Mississippi River. PFCs are also found in treated wastewater discharged from the Site to the Mississippi River, and in sediments in a cove at the foot of the bluff and near the river's shore. Feasibility Study The objective of the FS is to evaluate various response- action alternatives which address PFCs in soil, sediments and groundwater at the Site, and to provide a recommendation for implementation. The MPCA has reviewed the alternatives and is now ready to present the selected remedy for the Site. The FS for the Site was developed with U.S. Environmental Protection Agency (U.S. EPA) guidance and screening criteria which are used in the federal and Minnesota Superfund programs. The FS evaluates, compares, and contrasts each alternative for: • short and long -term effectiveness • reduction of toxicity, mobility, or volume through treatment • implementability • cost effectiveness • overall protection of human health and the environment. 19 In addition, the Settlement Agreement and CO between 3M and the MPCA specified that when evaluating the response action alternatives, primary consideration should be given to the excavation and destruction of PFCs, or excavation, engineered isolation and containment of PFCs. Summary of Alternatives To comply with terms of the CO, 3M developed alternatives for three aspects or components of the Site: Site -Wide (SW), Groundwater, and Soils and Sediments (S /S). Specifically the following alternatives were developed for the FS: Alternative SW -1 —No Further Action. Standard baseline option evaluated at all Superfund sites. No additional work to address soil and sediment contamination. No changes in current groundwater monitoring. Alternative SW -2 — Institutional controls, access restriction, and groundwater monitoring. Would include deed restrictions to ensure the area remains zoned industrial /commercial. The Site is already fenced securely and new drinking -water wells near the property would be prohibited. Existing groundwater monitoring would continue and development of an updated groundwater monitoring plan. Alternative GW -1 — Enhanced groundwater recovery with treatment prior to discharge. Would expand and improve the existing groundwater extraction system to prevent off -site migration of groundwater beneath the Eastern Disposal Area and the East Cove, as well as the main plant area. Discharge from the system would be treated in the facility's existing wastewater treatment plant, which has a large Granulated Activated Carbon finishing system that removes PFCs. Treated wastewater from the facility is currently discharged via a flow channel to the Mississippi River at the East Cove. Discharge to the river must meet MPCA- imposed limits for PFCs. (GW -1 was the only groundwater alternative developed in the FS because this type of system has proven effective at permanently destroying PFCs when carbon filters are thermally regenerated). Alternative S /S -1 — Stabilize flow channel to East Cove and remove PFC- containing sediments in portions of the cove; remove portions of sandbar at cove outlet; transport excavated sediments to containment facility; the flow channel would be stabilized to prevent scouring; the removed sediments would be dewatered and placed in a newly constructed long -term containment cell at the SKB Industrial Landfill in Rosemount. Excavated land areas would be backfilled with clean soil. Cover (cap with clayey soils) Disposal Areas D1, D2, and D9, shape cover for positive drainage and re- vegetate. Alternative S/S 2 — Includes all elements of S /S -1 plus removal of PFC - containing soils above Industrial Soil Reference Values (SRVs) for PFOA and/or PFOS in selected portions of Disposal Areas Dl, D2 and D9. This is consistent with soil cleanup conducted at other Minnesota Superfund or Brownfield Sites with planned industrial use. Alternative S /S -3 (refined) — Same as S /S -2 plus removal of concrete basin previously used for Disposal in Area D 1 and overlying soils. Under this refined alternative, 3M conducted MPCA- required supplemental investigations, and identified additional soils in Disposal Areas Dl, D2, and D9 that will be removed. In addition, PFC contaminated sediments from the entire East Cove will be removed, not just selected areas. Long -term containment of excavated PFC- containing material Any soil, sediment, or other material excavated during cleanup that contains PFCs above the Industrial SRVs will be removed and stored in a permitted, engineered, long -term containment facility that is being built for these 3M materials at the SKB Industrial Landfill in Rosemount, Minnesota. This disposal facility will also be used for materials excavated and removed from the 3M Woodbury and 3M Oakdale Disposal Sites. All leachate from these PFC - containing materials will be collected at SKB and taken to the 3M Cottage Grove facility for treatment. MPCA's Recommended Alternatives To meet terms and conditions set forth in the CO, the MPCA recommends the following remedies at the 3M Cottage Grove Site: • Institutional controls /deed restrictions, site access controls and long term groundwater monitoring • Enhanced groundwater recovery with carbon treatment to remove PFCs prior to discharge • Stabilize flow channel to East Cove and remove PFC - containing sediments throughout the cove • Remove portions of sandbar at cove outlet • Remove concrete basin previously used for sludge neutralization/disposal in Disposal Area D 1 and remove additional overlying soils in that area • Remove PFC contaminated soils in Disposal Areas D1, D2 and D9 which exceed Industrial Soil Reference Values for PFOA and/or PFOS • Transport excavated soil, sediments and material to engineered long -term containment cell at SKB Industrial Landfill, Rosemount, Minn. All excavated material will be disposed off -site. DOCUMENTS REVIEWED MPCA's decision to select the remedy set forth in this MDD is based primarily on the following documents describing the Site as well as the effectiveness and cost analysis of response action alternatives for the Site. • Facility Wide FC Assessment — 3M Company, July 2005 • Facility Wide FC Data Assessment Report — Cottage Grove Site — 3M Company, April 2006 • RI Report — Cottage Grove Disposal Site — 3M Company, July 2007 • FS — Cottage Grove Disposal Site — 3M Company, March 2008 • Addendum to the FS for the Oakdale, Woodbury and Cottage Grove Sites — 3M Company, April 2008 • ITS Addendum #2 — Cottage Grove Disposal Site — 3M Company, February 2009 ESTABLISHMENT OF RESPONSE ACTION OBJECTIVES AND SOURCE AREA CLEAN -UP CONCENTRATIONS The MPCA developed response action objectives to minimize human exposure risk. Removal of PFC contaminated soil, as well as backfrlling with clean soil, will address potential human soil exposure risks. Contaminated groundwater will be controlled from migrating off -site to avoid impact to adjacent surface water bodies. Groundwater that is pumped -out will be treated with carbon as part of the 3M Cottage Grove facility waste water treatment system prior to discharge to the Mississippi River. 3M will be required to meet appropriate discharge limits for PFCs through a MPCA - issued NPDES permit. Sediments in the East Cove, which have been impacted by PFCs, will also be removed to reduce or eliminate continued migration of PFCs to the Mississippi River. The 2007 CO requires primary consideration be given to the excavation and destruction or excavation and engineered isolation and containment of PFCs. Response action objectives have been developed using Applicable or Relevant and Appropriate Requirements (ARARs) and are based on soil and groundwater contamination data present in the MPCA site files. The ARAR and other criteria considered by MPCA in selecting a remedy for the Site are listed below: 1. 29 CFR 1926. OSHA regulations for persons engaged in site - related activities 2. 40 CFR 264. Standards for Owners and Operators of Hazardous Waste Treatment, Storage and Disposal Facilities 3. 40 CFR 265. Interim Status Standards for Owners of Hazardous Waste Treatment, Storage and Disposal Facilities 4. 40 CFR 268. Land Disposal Restrictions 5. Minn. Stat. ch. 103A. Provides State jurisdiction over surface water features, including wetlands such as lakes and ponds, and other wetland types 6. MPCA SRVs 7. Minnesota Department of Health (MDH) Health Risk Limits and /or Health Based Values A. Response Action Objectives The objectives for response actions at the Site are: 1. To eliminate unacceptable human risk exposure to PFCs in soil. 2. To reduce unacceptable human or environmental risk exposure to PFCs in groundwater. 3. To control migration of PFC contaminated groundwater to adjacent surface water 4. To reduce unacceptable human or environmental risk exposure to PFCs in surface water. 5. To reduce PFC concentrations in sediments Pursuant to Minn. Star. § 115B.17, subd. 2b(2008), the MPCA issued a public notice describing the MPCA recommended response actions. The public notice was published on May 20, 2009 in the South Washington County Bulletin for the purpose of soliciting comments from the community. MPCA staff also held a public meeting on May 27, 2009 at Cottage Grove City Hall to discuss alternatives and provide the public the opportunity to ask questions and provide comments on the proposed remedy. Comments made at the public meeting focused primarily on amount of material to be excavated, control of contaminated groundwater, truck traffic during excavation/construction activities and keeping the public informed of planned activities. No written comments were received during the public meeting. Three comment letters were received during the public comment period. One comment received from an environmental advocate group, while supporting the MPCA's recommended remedies for a majority of the project, asked that the MPCA require 3M to excavate all PFC contaminated soil for the DI, D2 and D9 areas. The MPCA makes decisions regarding the amount and concentrations of soil to be excavated based on SRVs for PFCs developed by MPCA staff. SRVs were developed to assist MPCA staff in determining risks and making cleanup decisions related to potential human exposure to contaminated soil under certain land use conditions. In this case, all soil in the affected Disposal Areas (D1, D2 and D9) that exhibits PFC contamination above Industrial SRVs will be excavated and disposed off -site. This includes even remotely accessible soil (> 12 feet) in some of the Disposal Areas. This is consistent, and even goes beyond, what would be done at other State Superfund or Brownfield cleanup projects for industrial settings, and is consistent with cleanup remedies already approved for the 3M Oakdale and Woodbury Sites. In addition, sediments throughout the East Cove which have exhibited PFC contamination will be excavated and removed for disposal off -site. Over 5,400 truck loads (or approximately 51,000 cubic yards) of soil/sediment will be excavated and removed from the Site. This amount of excavation will remove approximately 2,875 pounds of PFOS and PFOA or just over one cubic yard. A minimal amount of PFOS and PFOA will remain in the soil but any migration of PFCs in groundwater will be contained by the enhanced groundwater control system. In addition, PFCs will be destroyed when carbon used to filter PFCs out of the water is regenerated by thermal treatment. 3M will be required to record and comply with environmental covenants which impose land use restrictions to ensure that this area will be maintained for industrial land use only. A second comment letter was received from the Washington County Board and the Washington County Department of Public Health, and commended the MPCA on the cleanup being proposed at the Site. One issue that the County would like to see evaluated further is the potential for beneficial re -use of the pump -out water from the groundwater control system. The current plan is to treat the pump -out water with carbon through the 3M Cottage Grove waste water treatment plant prior to discharge to the Mississippi River. While the MPCA cannot dictate the use of the pump -out water for beneficial purposes, the MPCA can relay this recommendation to 3M for further consideration. The primary concern for the MPCA is that contaminated groundwater is appropriately treated prior to discharge to ensure that receiving waters are adequately protected. This expanded groundwater recovery system will remain in place during the entire cleanup process and until the MPCA has determined the groundwater recovery system is no longer necessary. A second concern expressed by the County was the potential impact of the region's hydrogeology, specifically bedrock faults in the area, on the expanded groundwater system. MPCA staff has reviewed information from the Minnesota Geological Survey and information concerning site specific geology submitted by 3M. Based on that review, the proposed new extraction wells will be screened in the surflicial aquifer, at or just above the upper bedrock aquifer. Thus the bedrock faults will have a minor potential impact on the expanded groundwater extraction well system. The third comment letter received was from State Senator Katie Sieben. Senator Sieben expressed concern about the amount of PFCs planned for excavation and disposal, and stated that all remaining traces of PFCs should be removed from soils /sediments and water at the 3M Cottage Grove facility. Senator Sieben also commented on the potential risks for surface water and drinking water supplies. As previously indicated, over 50,000 cubic yards of PFC contaminated soil /sediments will be excavated and removed from the Site, resulting in the removal of approximately 2,875 pounds of PFOS and PFOA. All soils exhibiting concentrations above Industrial SRVs will be removed, which is consistent with approved response actions at the 3M Oakdale and Woodbury Sites. In making this decision, the MPCA has followed requirements specified in Minnesota Environmental Response and Liability Act (MERLA) and appropriate guidelines established for the cleanup of State and/or Federal Superfund Sites. As noted previously, the CO also specifies that primary consideration be given to excavation and destruction or engineered isolation of PFC contaminated material. While a minimal amount of PFC contaminated soils will remain on site in soils greater than 12 feet below the surface, any migration of PFCs to groundwater will be contained, and the PFCs will be removed and thermally destroyed through operation of the expanded groundwater control system. Thus the expanded extraction well system will prevent any future migration of PFCs to adjacent surface waters. Another important component of the CO addresses the concern regarding PFC contamination in drinking water supplies. The CO specifies that any drinking water supply, public or private, that exhibits PFC contamination above MDH drinking water standards as a result of a release from a 3M Disposal Site, must be either replaced or treated by 3M to ensure levels of PFCs below MDH requirements. This is not only for current standards, but any changes in standards in the future. At this time, the city of Cottage Grove's municipal wells have shown trace levels of PFC contamination below MDH standards. In addition, those private wells in Cottage Grove that have been issued Drinking Water Advisories by the MDH, have been supplied with an alternative drinking water supply, either bottled water or a whole house Granular Activated Carbon (GAC) system, at 3M's cost. VA Once the MDD is finalized, 3M will be required to submit a Remedial Design/Remedial Action Plan for review /approval by the MPCA, which will specify more detailed construction activities such as hours of operation, truck traffic and controls, worker safety and noise /dust controls. The MPCA also plans to conduct air monitoring during construction activities to measure any PFC emissions. MPCA staff or a MPCA contractor will be on -site for oversight during construction activities. MPCA's Selected Remedial Actions for the 3M Cottage Grove Disposal Site To meet cleanup objectives for PFC releases at and from the Site, the MPCA has selected a remedy that is a combination of the following alternatives outlined in 3M's March 2008 FS and February 2009 FS Addendum: SW -2: Institutional controls, access restriction, and groundwater monitoring. Institutional controls must be executed pursuant to the Minnesota Uniform Environmental Covenants Act, Minn. Star. ch. 114E. A long -term groundwater monitoring plan must be submitted by 3M and approved by the MPCA. GW -1: Enhanced groundwater recovery with treatment prior to discharge. Will expand and improve the existing groundwater extraction system to prevent off -site migration of groundwater beneath the Eastern Disposal Area and the East Cove, as well as the main plant area. Discharge from the system will be treated in the facility's existing wastewater treatment plant, which has a large GAC finishing system that removes PFCs. During regeneration of the carbon, PFCs will be destroyed. Discharge of treated water to the river must meet MPCA- imposed limits for PFCs. S /S -3 (refined): Stabilize flow channel to East Cove and remove PFC- containing sediments throughout the cove; remove portions of sandbar at cove outlet; remove concrete basin previously used for sludge neutralization in Area D1 and overlying soils; Remove PFC - containing soils in Disposal Areas D1, D2, and D9 that exceed Industrial SRVs for PFOA and/or PFOS in accordance with the MPCA approved Remedial Design/Remedial Action Plan; transport excavated materials to newly constructed containment facility at the SKB Industrial Landfill in Rosemount, thus isolating the PFCs; backfill excavated Disposal Areas with clean soil; shape cover for positive drainage and re- vegetate to reduce infiltration; collect leachate at SKB containment facility and take to 3M Cottage Grove facility for treatment. These selected remedies will meet requirements specified in the CO for the excavation and destruction of PFCs, or excavation and engineered isolation and containment of PFCs. The Commissioner or his delegate has determined that the response actions set forth in this MDD are reasonable and necessary to protect the public health and welfare and the environment from the release and threatened release of PFCs from the Site. A copy of the Final MDD will be sent to 3M, the MDH, the city of Cottage Grove, the U.S. EPA and those who submitted written comments regarding the proposed remedy. STATUTORY DETERMINATIONS The selected response actions are consistent with the MERLA, Minn. Stat. §§ 115B.01 -.20, and are not inconsistent with the Federal Comprehensive Environmental Response, Compensation' and Liability Act, 42 U.S.C. § 9601 et seq., and the National Contingency Plan, 40 CFR pt. 300. The selected response actions are protective of public health and welfare and the environment. Paul Eger Date Commissioner Minnesota Pollution Control Agency E E k ti ♦h f r ws a e � � 1 t ♦� x k� E 6 1 1. • � �--- .,..,,., ��•: tom,:: -^ r; � 3M Company St. Paul, Minnesota Feasibility Study Work Plan Cottage Grove Site Cottage Grove, Minnesota June 2007 07P -0446 -2 COTTAGE GROVE SITE JUNE 2007 Prepared for 3M Company Prepared by WESTON SOLUTIONS, INC. 1400 Weston Way West Chester, Pennsylvania 19380 TABLE OF CONTENTS I Section Page 1 . INTRODUCTION .............................................................................. ............................ - 1.1 BACKGROUND AND SITE ASSESSMENT HISTORY ..... ............................1 -1 1.2 PURPOSE OF THE FS WORK PLAN ................................... ............................1 -4 1.3 PROJECT MANAGEMENT ................................................... ............................1 -4 1.3.1 3M Company Personnel ............................................ ............................... 1-6 1.3.2 Weston Personnel ...................................................... ............................... 1 -7 2. LIST OF POSSIBLE TECHNOLOGY TYPES AND PROPOSED TREATABILITYSTUDIES .......................................................... ............................... 2 -1 2.1 RESPONSE ACTION OBJECTIVES .................................. ............................... 2 -3 3. DEVELOPMENT AND SCREENING OF RESPONSE ACTION ALTERNATIVES ........................................................................... ............................... 3 -1 3.1 DEVELOPMENT OF RESPONSE ACTION ALTERNATIVES ...................... 3 -1 3.2 SCREENING OF RESPONSE ACTION ALTERNATIVES . ............................3 -1 4. DETAILED ANALYSIS REPORT ............................................... ............................... 4 -1 4.1 DETAILED DESCRIPTION AND ASSESSMENT OF RESPONSE ACTION ALTERNATIVES ............................. ............................4 -1 4.2 COMPARATIVE ANALYSIS OF RESPONSE ACTION ALTERNATIVES................................................................. ............................... 4 -2 4.3 RECOMMENDATION OF RESPONSE ACTION ALTERNATIVE AND CONCEPTUAL DESIGN ................ ............................4 -3 5. COMMUNITY RELATIONS AND PUBLIC INVOLVEMENT . ............................5 -1 6. FEASIBILITY STUDY REPORT AND SCHEDULE ................... ............................6 -1 7. REFERENCES ................................................................................... ............................7 -1 M ;T; "30MLDERSD- W. —.,F —v WmkPIe.TMW W. ii LIST OF FIGURES Title Page Figure 1 -1 Project Organization Chart .......................................... ............................1 -5 MN,(.'ON 33%F DEM.0 -9Um Mgag wTS WoekPlanTy l W . &O iii 1.1 BACKGROUND AND SITE ASSESSMENT HISTORY The 3M Company (3M) Cottage Grove, Minnesota plant (Cottage Grove Site), formerly the 3M Chemolite plant, has been in operation since 1947. The facility currently manufactures a range of products which includes adhesive products, specialty paper, industrial polymers, abrasives, and reflective road sign materials. The facility also engages in research and development of a proprietary nature. In December 2004, 3M submitted to the Minnesota Pollution Control Agency (MPCA) the Facility -wide Fluorochemical (FC) Investigation Work Plan (FC Work Plan) which was prepared by Weston Solutions, Inc. (WESTON ®) to voluntarily assess FCs at the Cottage Grove Site. The Work Plan presented a systematic approach to collect data in various environmental media related to FC manufacturing operations. In a letter to 3M dated January 31, 2005, MPCA approved the Work Plan with modifications. During 2005, 3M implemented the FC site- related assessment program (Phase 1 program) at the Cottage Grove Site in accordance with the MPCA- approved FC Work Plan. During the course of the FC assessment program, data from the samples collected during Phase 1 were submitted to the MPCA in interim progress reports and addenda. 3M and WESTON presented the results of the assessment activities, data gaps, and recommendations for closing these data gaps to the MPCA and the Minnesota Department of Health (MDH) on March 22, 2006. Subsequently, on April 7, 2006, 3M submitted the Fluorochemical (FC) Data Assessment Report (FC Data Assessment Report) to the MPCA. This document contained a summary of the assessment activities, the results of these activities, identification of data needs and recommendations for the future course of action. Based upon the agreements reached between 3M and MPCA during the March 22, 2006 meeting, 3M proceeded on a voluntary basis to initiate additional fieldwork as part of the Phase 2 FC Assessment Program. Specifically, 3M had proposed installation of MAECON_530\FOLDERS.Mk3mcottage grove \FS Work Plan\Flnal VJP.tlae 1 -1 additional borings and groundwater monitoring wells around the D1/D2, D5, and D9 Areas. The MPCA gave preliminary approval for these borings and wells on May 17, 2006 and discussed the sampling approach with 3M and WESTON on May 22, 2006. Subsequently, 3M provided MPCA with a map on May 26, 2006 depicting the proposed soil boring and groundwater monitoring well locations, which was approved by the MPCA. In accordance with these communications, WESTON performed the additional soil boring and groundwater monitoring well installation in early June 2006. Also, in May 2006, WESTON collected water level and drawdown data from existing monitoring wells during a planned shutdown of production well PW -6. The data recorded during this activity were used to evaluate the area of groundwater capture resulting from the routine and ongoing pumping of production wells PW -5 and PW -6. The 3M Cottage Grove MN Fluorochemical (FC) Assessment: Hydraulic Capture Zone Evaluation was submitted to the MPCA in November 2006 and is included in Appendix A of this report. In a letter to 3M dated June 13, 2006, the MPCA indicated that the primary objective of the assessment (identifying the presence of FCs in various media) was met. With respect to follow -on activities (Phase 2 assessment activities), the MPCA requested that 3M submit an addendum to the FC Data Assessment Report containing a work plan to further define the extent of FCs in soils, evaluate the groundwater to surface water pathway, and conduct additional assessment of the East and West Cove and of the Mississippi River, both near the facility and downstream. The MPCA also requested that the FC analytical parameter list be expanded. Accordingly, 3M retained WESTON to prepare the Phase 2 Work Plan, perform the assessment work, and present the findings in a Phase 2 FC Data Assessment Report. The Work Plan incorporated the recommendations for additional assessment activities presented in the FC Data Assessment Report and requests made by MPCA in its June 13, 2006 letter to 3M. MPCA also requested a visit to the Cottage Grove Site that was conducted on June 21, 2006. During the visit, MPCA observed the on -site disposal areas, East and West Coves, Mississippi River, and soil boring activities at the D9 Area. M1ECON 530VOLDERS.O5Mm- Rage gro V$ Work Plan\FInal WP.doc 1 -2 � 1T�CI� 1. On July 14, 2006, 3M submitted the Phase 2 FC Assessment Work Plan (Phase 2 Work Plan) and met with MPCA on July 25, 2006 to discuss comments on the Work Plan. A revised Work Plan, incorporating changes made in response to the agreements reached during the July 25, 2006 meeting was submitted to the MPCA on August 7, 2006. The Phase 2 field work was completed in the fall of 2006. In addition to overall site conditions and potential pathways, the Phase 1 and 2 FC assessment activities addressed historical waste management areas and areas of past FC manufacturing. Three of the historic waste management areas are referred to as the D1 Area (Former HF Tar Neutralization Basin), D2 Area (Former Sludge Disposal Area), and D9 Area (Former Sludge Disposal Pit). In December 2006, at the request of the MPCA, 3M submitted a document entitled "Interim Remedial Measures Evaluation ". The purpose of the report was to evaluate possible options for interim remedial measures (IRMs) in the aforementioned three areas based on the results of the Phase 1 and 2 FC assessment activities and provide the rationale for the initiation of the IRM. In a letter to 3M dated February 1, 2007, the MPCA approved the Interim Remedial Measures Evaluation report for the Dl, D2, and D9 Areas and requested a meeting to clarify the factors and assumptions for the proposed multilayer cap and then have the "final design" for the IRM submitted to the MPCA. At a meeting on February 7, 2007, 3M, WESTON, and the MPCA discussed all of the issues raised in MPCA's February 1, 2007 letter. 3M summarized the discussions and results of the meeting in a letter to MPCA dated February 21, 2007. Subsequently, on March 15, 2007, 3M submitted to the MPCA the Fluorochemical (FQ Interim Remedial Measures Work Plan for the D1, D2, and D9 Areas, which addressed and incorporated the items discussed at the February 7, 2007 meeting, including the IRM design. In April 2007, 3M commenced discussions with the MPCA to formalize, under a Settlement Agreement and Consent Order (Consent Order), the process of conducting remedial investigations and response actions to address FCs at the site. The Consent Order became effective on May 22, 2007. It requires that 3M conduct a Remedial Investigation/Feasibility Study (RI/FS) with respect to release or threatened release of M9ECON 5WNFOLDERS.O -913m- cottage grove \FS Work PlanTinal WP.d= N] u 3'T 14 FCs at and from the site. In the Consent Order, MPCA states "An RI Report addressing all of the investigative work required under the MPCA approved Phase 2 FC Assessment Work Plan shall be submitted to MPCA by June 30, 2007. Upon MPCA approval of the RI Report, the approved RI Report and the April 2006 Fluorochemical (FQ Data Assessment Report shall be deemed to meet RI Report requirements ... ". The RI Report is being submitted concurrently with this document, the FS Work Plan. It is further stated in the Consent Order that by June 30, 2007, 3M shall submit an FS Work Plan to address possible response actions for the Cottage Grove Site. This FS Work Plan addresses possible response actions in compliance with the Consent Order. 1.2 PURPOSE OF THE FS WORK PLAN The purpose of the FS Work Plan is to describe the procedures that will be followed to conduct a Feasibility Study (FS) and prepare a FS Report for the Cottage Grove Site. The objective of the FS is to provide an evaluation of various response action alternatives which address FCs in soil, groundwater, and sediment at the Cottage Grove Site, and to provide a recommendation for implementation in accordance with the Consent Order provisions, which include MPCA guidance contained in Guidelines: Remedy Selection (MPCA, 1988), and United States Environmental Protection Agency (USEPA) guidance contained in Guidance for Conducting Remedial Investigations and Feasibility Studies under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA) (USEPA, 1988). The performance of RI activities at the Cottage Grove Site is essentially complete and has been conducted under work plans approved by MPCA. The RI Report is being submitted concurrently with this FS Work Plan and will be reviewed shortly by MPCA staff. Thus, the following sections provide a generalized description of the organization and responsibilities of key individuals in the performance of the FS. The organization of the project responsibilities described in this section is depicted in Figure 1 -l. MAEOON_530XFOLDERS.0513m co0ege groveTS Work PlanTinai WP.Eoc I0 WFtiSiT��N 3M Project Manager R. Paschke, P.E., DEE (Alternate - M. Gaetz) WE WEST Technical al Advisor Project Manager M.N. Corbin, P.E. J. Kesari, P.E., DEE WESTON Project Engineer J. Savage, P.E. 07P -04463 PR OJECT ORGANIZATIO STU FEASIBILITY COTTAGE GRO 1 -5 1.3.1 3M Company Personnel Mr. Robert Paschke, P.E. will serve as the 3M Project Manager. The Alternate is Mr. Mark Gaetz. To the maximum extent possible, communications between 3M and the MPCA concerning the terms and conditions of the Consent Order as they apply to response actions for the Cottage Grove Site will be directed through the 3M and MPCA- designated Project Managers. The 3M Project Manager will be responsible for assuring that all communications from the MPCA Project Manager are appropriately disseminated and processed. The 3M Project Manager, as well as the MPCA Project Manager, has the authority to (1) take samples or direct that samples be taken; (2) direct that work at a Site stop for a period not to exceed seventy -two (72) hours if the Project Manager determines that activities at the Site may create a danger to public health or welfare or the environment; (3) observe, take photographs and make such other reports on the progress of the work as the Project Manager deems appropriate; (4) review records, files and documents relevant to the Consent Order and (5) make or authorize minor field modifications in the RI, FS, Response Action Plan (RAP) or RAs or in techniques, procedures or design utilized in carrying out the Consent Order which are necessary to the completion of those activities. Any field modifications will be approved orally by both the 3M and MPCA Project Managers. If the 3M Project Manager requests a field modification, he will within seventy -two (72) hours following the modification, prepare a memorandum detailing the modification and the reasons therefore and will provide or mail a copy of the memorandum to the MPCA Project Manager. The 3M Project Manager will either be on the Site or available on call by telephone during all hours of work at the Site. Communications from the MPCA Project Manager are appropriately disseminated and processed. M1EOON_530WOLDERS. AWmco ge gmveTS Work PlamFlnal WP.dm 1 -6 The 3M Project Manager, as well as the MPCA Project Manager, has the authority to (1) take samples or direct that samples be taken; (2) direct that work at a Site stop for a period not to exceed seventy -two (72) hours if the Project Manager determines that activities at the Site may create a danger to public health or welfare or the environment; (3) observe, take photographs and make such other reports on the progress of the work as the Project Manager deems appropriate; (4) review records, files and documents relevant to the Consent Order and (5) make or authorize minor field modifications in the RI, FS, Response Action Plan (RAP) or RAs or in techniques, procedures or design utilized in carrying out the Consent Order which are necessary to the completion of those activities. Any field modifications will be approved orally by both the 3M and MPCA Project Managers. If the 3M Project Manager requests a field modification, he will within seventy -two (72) hours following the modification, prepare a memorandum detailing the modification and the reasons therefore and will provide or mail a copy of the memorandum to the MPCA Project Manager. The 3M Project Manager will either be on the Site or available on call by telephone during all hours of work at the Site. 1.3.2 Weston Personnel Mr. Jaisimha Kesari, P.E., will serve as the WESTON Project Manager. He will be responsible for day -to -day activities on the project and planning, coordinating, integrating, and managing all project activities. These will include the activities of any subcontractors to WESTON. Mr. Kesari will also provide technical oversight and review for performance of the Feasibility Study. Mr. Michael Corbin, P.E., will serve as the WESTON Technical Advisor. He will be responsible for guiding and providing technical oversight in the performance of the FS and ensuring that it meets Consent Order requirements and follows USEPA guidance ( USEPA, 1988). Ms. Janet Savage, P.E., will serve as the WESTON Project Engineer. She will be responsible for conducting the FS and preparing the report in accordance with the Consent Order and USEPA guidance. M:%ECON MFOLDERS.O -gl Rage 9MWTS Work PlaMFnal WP.d 1 -7 WF �iN 2. LIST OF • SSIBLE TECHNOLOGY TYPES AND PROPOSED TREATABILITY STUDIES Possible general response actions have been identified for the Cottage Grove Site based on the information and data provided in the RI report. In accordance with USEPA guidance on conducting feasibility studies, the general response actions, response technology type, and associated process options have been subjected to an initial screening process on the basis of technical implementability ( USEPA, 1988). The general response action/technology types and process options that have been retained as the List of Possible Technology Types are as follows: LIST OF POSSIBLE TECHNOLOGY TYPES Soil ■ Removal — Excavation ■ Treatment - Thermal - Incineration ■ Disposal - Landfill - New landfill - Existing landfill ■ Containment - Cap - Soil /clay cap - Engineered multilayer cap ■ Institutional and Site Controls - Access restrictions - Deed restrictions - Fencing ■ No action Groundwater ■ Collection - Groundwater recovery - Recovery wells ■ Discharge — On -site MIECON MOTOLDERS.O -Wm.o ge gmv T-S Wwk PlaMFinal WP.Goc 2-1 • Containment — Cap - Soil/clay cap - Engineered multilayer cap ■ Treatment - Physical - Activated carbon - Ion exchange resin - Reverse osmosis - Air stripping • Institutional and Site Controls - Deed restrictions - Fencing - Monitoring • No action Sediment Removal — Excavation/Dredging • Treatment - Physical - Dewatering - Surface water diversion • Treatment - Thermal - Incineration ■ Disposal - Landfill - New landfill - Existing landfill ■ Containment —In Situ Cap - Clean sediment, sand, gravel, geotextile, or liner ■ Institutional and Site Controls - Access restrictions - Deed restrictions - Fencing • No action Following the MPCA approval of the RI Report and FS Work Plan, these technologies will be assembled into response action alternatives and evaluated further for M: \ECON 530\FOLDERS.O -9G3m- cottage gMve \FS Work Ptan\Final WP.d c 2 -2 implementation at the Cottage Grove Site as described in Section 3 of this FS Work Plan. Treatability testing may be conducted in an effort to collect additional information for technology evaluation and implementation. For instance, a pump test may be conducted to evaluate groundwater recovery rates, or depending upon the water quality criteria established by the MPCA, a bench- or pilot -scale test may be conducted to determine effectiveness and usage rate in the treatment of groundwater containing FCs by carbon adsorption and/or ion exchange resin. Although chemical and solidification treatment technologies have been screened out due to the lack of data regarding the use of these technologies to effectively treat FCs, 3M may choose to conduct bench -scale and /or pilot -scale testing to determine if these technologies should be considered for possible innovative application at the Cottage Grove Site. 3M will notify MPCA if a treatability study is to be conducted. 3M will prepare a work plan for submission to MPCA that will provide details on the performance of the study and reporting of results. The results of any treatability studies will be included in the FS Report and considered in the evaluation of response action alternatives. 2.1 RESPONSE ACTION OBJECTIVES During the initial stages of response alternative development, response action objectives will be established for the Cottage Grove Site. Response action objectives consist of medium - specific or operable unit- specific goals for protecting human health and the environment. Based on the response action objectives, an estimate can be prepared regarding the volume of media and area to which containment, treatment, or removal actions may be applied. 3M will work with MPCA to determine the site - specific response action objectives and cleanup levels that will be protective of human health and the environment. MrECON53MFOLDERS.O.MM Uge grOv T$ Work MmkFlnai WPdoc 2 -3 3. DEVELOPMENT AND SCREENING OF RESPONSE ACTION ALTERNATIVES 3.1 DEVELOPMENT OF RESPONSE ACTION ALTERNATIVES The List of Possible Technology Types will be assembled into a range of response action alternatives. The range of alternatives developed for soil may include, but will not be limited to: an excavation and treatment alternative, an excavation and disposal alternative, a containment alternative, and a no action or limited action alternative. The range of alternatives developed for groundwater may include, but will not be limited to: an extraction and treatment alternative, an extraction alternative, and a no action or limited action alternative. The range of alternatives developed for sediment may include, but will not be limited to: an excavation/dredging and treatment alternative, an excavation/dredging and disposal alternative, a containment alternative, and a no action or limited action alternative. 3.2 SCREENING OF RESPONSE ACTION ALTERNATIVES According to MPCA guidance, each response action alternative or evaluated alternative must meet the threshold criterion of providing overall protection of public health and welfare, and the environment (MPCA, 1998). This criterion is met if the response action alternative or evaluated alternative will achieve response action objectives and cleanup levels or provides for a permanent remedy. As stated in the Consent Order Exhibit A, Section III.E.3.a, once the response action alternatives have been developed, they will be evaluated and screened using the site - specific response action objectives and cleanup levels discussed in Section 2.1. Those response action alternatives that do not meet the response action objectives and cleanup levels will be eliminated from further consideration. Response action alternatives that pass this screening will be designated as "evaluated alternatives" and will be further evaluated in the Detailed Analysis Report (DAR). MAECON 53WOLDERS.Oa3m- ottage gmv TS Wof PlanlFftl WP.tloc 3 -1 Once a set of response action alternatives meeting the threshold criterion of providing overall protection of public health and welfare, and the environment has been developed, a detailed evaluation of each alternative and a comparison of the alternatives will be performed so that a recommendation for response action alternative implementation at the Cottage Grove Site can be made. The DAR section of the FS Report will contain an assessment of each alternative with respect to balancing criteria and a comparative analysis of the alternatives as described in Sections 4.1 and 4.2, respectively. 4.1 DETAILED DESCRIPTION AND ASSESSMENT OF RESPONSE ACTION ALTERNATIVES In the DAR, each evaluated response action alternative will be described and individually assessed with respect to balancing criteria including long -tern effectiveness, implementability, short-term risks, and total cost. At a minimum, the detailed description of each response action alternative will include the following information: the operable unit to which the evaluated alternative would be applied, a description of the technology type and process option, engineering considerations required for implementation (e.g., for a pilot treatment facility, identification of any additional studies that may be needed to proceed with final response action design), operation, maintenance, and monitoring requirements, off -site disposal needs and transportation plans, temporary storage requirements, safety requirements associated with implementation, a description of how other alternatives could be combined with this alternative to optimize the system or better achieve response action objectives and cleanup levels, a review of on -site or off -site treatment or disposal facilities which could be utilized to ensure compliance with applicable or relevant and appropriate requirements (ARARs), and decommissioning activities that would be conducted upon completion of the response action. Each of the response action alternatives will be assessed in the DAR using balancing criteria. The following is a description of the balancing criteria in order of importance: WNECON 330TOLOERS."S 3m- cottage groveTS Work PlenVinal PAoc 4 -1 W T;N s Long -term effectiveness — Long -term effectiveness is the ability of an evaluated alternative to maintain the desired level of protection of public health and welfare, and the environment over time. Permanent remedies provide absolute long -term effectiveness. In the event a permanent remedy is not feasible, evaluated alternatives that significantly alter the FCs to produce significant reductions in toxicity, mobility, or volume will be preferred. In addition, the ability of the alternative to obtain and/or manage treatment residuals, minimize transfer of contaminants to another environmental media, and maintain established response action objectives and cleanup levels over time will be a major consideration. • Implementability — For this criterion, technical and administrative factors and the availability of services and materials are considered with respect to their affect on the ability to implement each alternative. • Short -term risks — For this criterion, the short-term risks that may be posed as a result of implementing an evaluated alternative will be considered and weighted against the ultimate long -term benefits of implementing the alternative. • Total costs — For this criterion, a conceptual cost estimate for implementation of the response action alternative will be provided including long -term monitoring, operation and maintenance, and decommissioning activities. 4.2 COMPARATIVE ANALYSIS OF RESPONSE ACTION ALTERNATIVES Once the response action alternatives have been described and individually assessed using the balancing criteria, a comparative analysis of the alternatives will be conducted and presented in the DAR. The purpose of the comparative analysis is to identify the advantages and disadvantages of each response action alternative relative to one another with respect to each of the balancing criteria. The comparative analysis will include both a narrative discussion and a tabular summary of the strengths and weaknesses of each alternative relative to one another considering specific components of each criterion. A narrative will be provided for each criterion with a discussion of each alternative's expected performance. Differences among the alternatives will be described and presented both quantitatively and qualitatively, as appropriate. M.IECON 53MFOLDERS.0 -9l4m. cottage gro"TS Work PlanXRnal WP.aoc EN 4.3 RECOMMENDATION OF RESPONSE ACTION ALTERNATIVE AND CONCEPTUAL DESIGN Based on the detailed analysis and comparison of response action alternatives, 3M will provide a recommendation for implementation to address FCs in soil, groundwater, and sediment at the Cottage Grove Site. A conceptual design for implementation of the recommended alternative will be presented in the DAR and may include the following: conceptual plan drawings, layouts, and cross sections to depict the various components of the response action alternative, descriptions of the equipment and process used, as well as expected quantities and volumes of materials required, identification of additional data needs for the final design, discussion of operation and maintenance requirements, institutional issues, costs, and estimated schedule for implementation. MAECON_MTOLDERS.O- Mm-col ge groveTS Work Plan \Final WP.doc M, • • , 3M is committed to keeping local residents and public officials informed of activities at the Cottage Grove Site and responding to inquiries they may have. This section outlines some of the approaches that will be used to conduct the community relations and public involvement components of the project. Throughout the implementation of the Consent Order requirements, 3M will be coordinating with the MPCA on the community relations activities described herein, along with many other aspects of the investigation and remediation of the Cottage Grove Site. The communication tools below are intended to serve as an initial plan for communicating to local residents and public officials. 3M will seek the advice from the MPCA, city officials and others regarding these public communications tools. 3M offers the following for use in communicating project activities: 0 3M Fluorochemical Website: 3M has established and maintains a website for disseminating important information on fluorochemicals. The URL for this site is: www.3M.com /pfos -pfoa The website will include a link to the Cottage Grove Site on which information will exist to direct local residents and public officials to the availability of relevant documents and meeting dates. Additionally, the website will indicate that people can contact 3M via a telephone helpline, "I- 800 -3M HELPS ", to make inquiries about the status of the remediation efforts. Public Repository at Local Library: Key documents about the project will be maintained and available for the public to review at the Park Grove Branch of the Washington County Library located at Cottage Grove, Minnesota. Examples of the types of documents to be available at this location would include the Settlement Agreement and Consent Order and key submittals to the MPCA such as the Remedial Investigation, Feasibility Study Work Plan and Feasibility Study Report. Informational and Public Meetings: 3M recognizes the importance of input from the public, including public officials and staff at the municipal level. Information meetings will be conducted to update interested local residents and public officials and to provide opportunities for their input. The following briefly describe some of the forums that will be used: MAMON 53DIFOLDERS.D -Wmc nge gmv TS Work Man\Flnal WP.doc 5-1 Elected Officials and Staff: 3M will continue to provide periodic updates to Cottage Grove public officials and staff. These updates may be formal or informal. At these meetings, public officials can provide input relative to opportunities for public participation. - MPCA Citizens Board: Quarterly updates to the MPCA Citizens Board will occur on the progress being made on investigations and remediation efforts at the Site. This will provide opportunities to inform the Board on developments at the Site and to address questions. - Public Meetings: It is envisioned that at least two public meetings will occur prior to the implementation of any response actions at the Site. An initial meeting will be conducted by 3M during development of the Feasibility Study Report. The purpose of this meeting is to provide the community information about the investigation and remedial alternatives so that public comments can be taken into account. 3M will work with city officials on how best to publicize the meeting to ensure timely notice to the community. Following this meeting, and with the benefit of the public's questions and comments, the comparative analysis and recominended evaluated alternatives and conceptual design steps will be completed. A second public meeting will be convened by the MPCA after reviewing the FS Report and before selecting a remedy for the Site. MIECON 530XFOLOERS.CAWmc ftge gmveXFS Work PlanTinal WP.Doc 5 -2 3M will work with MPCA to determine site - specific response action objectives and cleanup levels. Based on the response action objectives and cleanup levels, 3M will prepare an FS Report as described in this FS Work Plan. In accordance with the Consent Order, the FS Report is due to the MPCA within 90 days of MPCA's approval of this FS Work Plan and the RI Report, which are being submitted concurrently. MaECON 530%FOLDERS.O -9�m-Oottage groveTS Work Plan\Flnal WPAOO 6 -1 7. REFERENCES MPCA, 1998. Draft Guidelines: Remedy Selection. Working Draft, September 1998. USEPA, 1988. Guidance for Conducting Remedial Investigations and Feasibility Studies under CERCLA. Interim Final, October 1988. MAECON_530TOLOERS.99�3 Rage groveTS Wak Plaffinal WP.d. 7 -1 APPENDIX A.1 STRATIGRAPHIC BORING LOGS S -1 THROUGH S -5 A 1 o V E E 3 �N 3 a C5 CN �N E A y �qN ®� � E � m �� o 3� 8 ;•` E : n' ��,. E� Vi i; c; a:. o •�' �I ;r: 0 � m r qr �• r Q r Cr :ya d d f F; q. (s] n Y: ^• C: ni 9:Fi C; vii c• �' au 'y; �: N �"'r E' E, ' '` E. »: '; ..r S: �; : y• Nr c: ; �r ; E; 3 3 3 3 3 ia� S m T.S l (�; mr m•m•3. 0.• A;- 1�6•Y• Or x•�r n• a•J. v...�•.J�..1• °•J mr w• v _] iY Nr Nr ... 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Q L IY00J NO {8 y N^ d �! r h rl' n TN`✓ -' qq C o Yj C • G S N S O U L S$ O r C N P ` C T T^ N ni N 11 N< O C C E x rr LLmp'iOq W - n U' fl N� N G "A N N N N NH O N HI ry T N N m C C Yi p k G C C C C BiJN3N.L5710S N O V U N N N E A N j VI N N C Y O y L Q f' P 8 Yf C Nm 3an3s1Ow [� o r33 (A Vl N VI N !1 V! Vl G N N C - d 9 E E9 S a q • T ` 8 F% P 1 V V u a N N N • C A33A ®.13YI P m M^ P � P N N N nn N h b Q C y- L S3 C R J Z it 'Gj Z Z y r (� ' u 'IV.1FE31RE 3Y103 1 f1 N M „ I G I M1 Vi I P J! 2A N .Y. Y 0 '✓. T ry' m V N 0 r fTi T P nl f1 '$ „ '[ ' J n 6 C d O n • • �1 J ',di • L te r: a p _ y_ e o n n f F G 4 E N 3 tiq = �_ y �� g� w £ a S eb a c w om EE�4 E m'�s 333 8 q kg�` �� �mnaamo�aaaaa�saaaxa�aa�a ����� x; pP S' vi m m e ('l v t7 p v e N tfJ 1p M N N N IU O H NI YI C IA 3 2 (ism 7aa }) No1IVA3'13 c N ? £ a # U D � 6 4M q V'<n �M1�ONN1 nl�NCM1"S � �j b S tl U Z O IN NU� NOIB S i .. F' € C C €'r C C W G C G G m E€ 5 H19smuls't1®S . n a LL ;� r ic r ,€ 3millsIOW y $ O p y O u o qqgg pv V4m C G 0 2' �L t (� O, Q� H 0 N ,/1 .O N i _ _ N N I T T V. N V1 3 J M1 r 1 M1 W 'SC ? 1 Q r J d $ o w G v o - o .RY13,AO.>3 d o° z e x e v a e e v e l e, oo e e a en e j e tt '� 'IV.U131MC 3NO3 .4 a N `; n .A a A ',di • L • i s �i H N p p • q � q F i i •O ° M i � tl O � O W p C i 4 • •• C6 6 a T•� V 9 m i � � � C .� i � O .4 T C. 3 A s _ yyy N • �+. 5+ .�+. Z r � u cu � n n "n n r c7 c7 V c UGW I-J) Nouvxym r °o ° Juno, mo1H — W U N N VI C_ O_ C O p O_ yy��•• A pp CC 6S G P P E HION31f1$•IIOS p 3aiI.{.$lo N V f emu. V o 57 GC ANIAOD Hill Iv.ou31Ne 3ao3 • i s �i APPENDIX A.2 PIEZOMETER BORING LOGS ECPZ -1 THROUGH ECPZ -3 0 0 V I 0 �i F N N F e y s A Y a 4 e f u 1 q u V 5 N 3 y 6 m g� « i P� ai �NI n5 P I I I I I I I cl a. cl n ; it ,�� r Q N�6; qP'O O ;�� C• °1 & �{ 1 Ei0;� ° e 8 T'Tgr ; s.9; SE °' g ; o y : Z" dl 1. o 4' _y� Ur zr 9 ° P �I v� f •;. 2, y� �r c� g E y _ . � n J` v.y 'cu4'- 'eyu'mc' } ; -y'�6; _gi p 4E�P'P; G� .i 4 v e j g am _ -�`' � Z' Z; Z; 5' �. Cr , •_�' Or PI, M. S 9 _� @p p%. '" E'y'' -'. a • ••fit y eSg ACC II, J Y. ;_ ;; 9. ZI Z Zr ' Z • Z' Z, Z, Z, P: P. P• . P. etl i' e• 3• Cr � 4 4 U p i C g S R �T V u 1 . � 4 9 q �'� �r y N Pi y. Ni Ni Nr Vir; N; Nr �. E; S� �'� 6i 61 E� M 1 � ✓r D os°S 5 P�Pr P�P�P; Pr l+z. :w c ra S -� �•- Z• Z z' C G� r c' $i.i U�V; c Y gE r u E :. t ' y� g� o � g� yr - p Z� �� P� �i J� v u� 6 r y� m y' o. g o o v _ - _i 1. - � X� �.-J", - _ b Z n; r Y� s� 5; � - _ - g z� - �a m;. ;ry ° �rTn_ g � y 'rjCS C-5 ; _ t i t t 3�_s; 5; 3�s's' S!> ' E�E'r •ti iia x z �. F. n'$1n A� F�- Ei >`.,..' i.'i °+•; +v �',' X; i„ `a,' Tl.' +:„ >`: +: 3'.' - °� EI g� a °' g � s� z� y -Y � �r r �' 6 � n• ^ E E°� is r ` 1; It s . i. ° B� d s� a ° g �'`� -� $ x�� ar } p V 1: Ei �i g� �v. g 6 O i o c ° • U 1 R 6 g Y, y Y, � $i P� 11 �• }� G1' GJ' C' C' C' C' C' C 2' C' C' C' C' C' C 1" C C' C' C ' L' ir.' P' P' .�]' �• C' �' �' }' Y Y r r C(Jr t uwmoc OOF� }Pt �•.ri; F M1 y L C C t � 4 4 O 3 �,� Iewetui � z ' S; � ^ r Fi n• ,a �r a� w' �' v Ui Ur yi 4n• m. vi v yr '2 i v c, ni v. Nr %i wi •ii vii �� "' v ni . F °;3°1 -u'r Lr Jr J: Q. ��J. J•J J....t•Jr _I. J. Ji S•J•J... J�Jr.a ..•J:.i, Jr J.J ° •N, C,M p 4 - N N•Oi 'N' iNi NiM N N. O.O•P•Rr Ri P. OriP N N•Q••Pi R'Q•' O• ; P. T•P P•p•. P• P. Rr , P. PAP r P•P. OrO R•P'P R'Pr P•N•N „r N•N•P•O�Nr Pr P•P•P •Pr R•P. vf. h•P. R•P•P P•P• rO P. R• •M Vi " ° t9 '� •O 'O'O ,Y,N yi ;0i 'O'v'i ,'Aj N. hli U' xC Ci r rhi ihi r •M _ I•v JOIOQ a g § g € r = wmsl°w u• v u• _• i Yi. i; �, �. • �r • 'i '�i tAt V: U. Ur 9 ` Y.1. . �; ; 3; 3.3' J' 9 Y. N. - 6: zt Z: 9• Sr V � r; - 6: Gtr Nr ` y W q1 r• 'Ni O N VS N Ni 'N rn N �Ni O p Ntgi Oi Or B_'8O_ p p O •'Jr 'il ii�; O ^ C O �$`�� G s C R19A000 M Nr ,h blihi hrhrl�ih�h r • . . hi h�lwi t�;hii�r n. •NiV • r r r . r r r • �O,:e. .r h; rNi r ; It _ b :pF•b•� - •r •et•Q 1 Nr�.rM�Mr O••Or N•PrQ•p3.30•NrN NrN• rN'Ni rP. Mr @r[�r*✓. M NOrb re'r Nr �'�; hi N;^j +M• 00. � i � ;(y �''�i hi i'JOi Ned'. Pi Vi Wr��� h�Nr N�n_�W_'V�O, N,�O; •G N�Oi Mr '� M'M'T'� • . .y���N�M�M� m y • r ; Sr iEe i r L 0] + '�!i N �•Dr N� ;N�N�d'�d'�V�WiMiM .y � �r ?� PrN M N ib� N��r �i ^Jr� O••Or•O•T. 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Vl:.'/ N: ; 8, zi ' 4€ � Nr O Nr Nr rO'N:O: Or O: O'Or O: :�: :Wr �: ' N •' �r it 7J: rP' •' Wr :P: Pr Tr rW; TraD, •Or Y., Wi Tr Pr r�r O>, :V': Tr rT: Vr rP: ry"N:(1^, :4 rNr (S, MI Mr M Mr rpr rN VY Vt rMr ; mloo o; , rrr 'r; :' 'r; 'r; r; 'r; :r: :rr :5 gt wnlspw W: + c.Sle }9nV •v: y r � :,y: ;a?: :1�: ooh : ' :a: _ '^!; : ?; "°; Ainooia • • �; , Nr ;p; ri..r OO,Wr ^rlM1r rhr rTr 'nr rSr In. r.1r rN}r :Nrni: _ rNr rNr Nr r r 1qr ry.r O • y ^ r rVfr r rr/yrPr rY1a 1q, rNr O ¢ G P r r r r r W Z U• n.. .� r r r ;M; h N: Hr r�r ;rn; 'r 6 U Z�ZY Q F� L z M C W e 0. y � 9 H G L � COL ' �Qy 4 C A At r �; > A� r n; ; >q; 9 ; n n S ° � � s s r E E' F o - ea r r r, � � i: 3; S � ° oI: g g wg - it :a, a a: � �I;' =: ° N; $: _9: � � ! �S� Q F� L z M C W e 0. y � 9 H G 0 M W 0 I � V W � W L F m 1, .€ Y �r r i r Lr 'S5 u i Y; 'S•; ; y p r'; •v'; � • e' >:�; a ,5; u 's; 0 ; °r' ;; o Yi C: .Yr E y: .QI p z; a� z� z. z: S S p ; z; d; '.� -'gyp '•.!1 d ^ � •� .a '�� ci of ? .E; 5; ii v`a : u ' S; Q; a a b; ; i °; =r �i ;1.1; V !. ..r i gi ;' ; $; 4 � n: 3 ' q; � Yi S r Z1 u h; n Z $.; �; '•�; �; �' C; W t�; Ei i+; ri K; . ;.� mr rz' ;mr ro. pl p ° °; � >• •> > >r> pr❑ m '�; $;$ S a m r uwnloo :UUV • E <�^ )0-� iS ;E /r•Yi75t•UUo; W ;NI p I �3; rs •, �p N; '�� ;H� —; N; - - ; M; N; M; rW: ; ; rN r �,° • Or �O�Oi Or O: N; •'+ry N; „i00r ;O po� i0� M U' • O•r iooi Pr Pr nr Pr Pr ;Pr iMi d'i ib ;P; iPi ;(T; 'E e U ; M; N; i C; N; i M; e r'If• � Z ;E r r r r r r r x' L C;, { ar rVir : <; r�r Mi 'Mr ;e1: Mr a; Mr VrC rayr rVr rV; 10•`7 , }� r J-r : Nr : y Yr r }f r }r }r jj }: }�} r }' r }r In �_�O ;�� ;�; pp YI E E WnjS�OVj :14t V.'; I N . —r goo: ry r — �'n: �ry roar ;N. e C b G 6 e G ti'C /J•G0D9}j e U U e 41 G^ F tq Ll;m :W • • • • ° • � — — — ryr O���y. — rNrNr rMiFrrnrN r�r N r <r�rNr rN • NE;C C' 'Ni 'd'r rr0•�M'P ��; �; ^;�';�;P;N; N' ;NrN;M; gy m; ; EF E ;_O; Z Z1 6lWRG `1C. O; ;N_ V �n�<00 �E rMr $ C f A c r I I I i I .p Z' �' 1 ; • •; ; ;1 0; � 1 u� ; ; Q; -r U U w yr 3 3� z le, RI Zi 2 2 ' J; r , ,; 3: a : r y r Lr~ B T yy 5 5; 8; p pr y; o; B E T $ C f WFS�T�'N APPENDIX A.3 A REA - -.: BOR ING r 04 THROUGH D209 . • Ig • a LL ti sv O i mo w j; bKoks — i - % d �i Y � C! Ise � t i ! Zj `2.� �Q: � z i.°_? 0.1 in ct! zi MP U! 0 I E a Ob bp ob >t i U. > .0 Gi FF OM o f ,G uwnloo w ...... ..... ..... -1 0 Old N 446ug4s 01 0 04 t o Joloo cd m: C-i eirqslow fJGAOPSH C M! ni i 3 1.n i c Cq WWO ;4 i cc U a LL ti sv O • • LL Z� E V 0 O tn cz C4 Ic I ul in c a l l -W , I ' .. .. ..... .. ------------- ...... ....... ...... . . . . . . . . . . . . . . ....... ... . . . .... . . .. ..... lz o z -a v Clid 0 0 l taftens N io Joloo P4 o4 94' airnslow .12 fJOA008H v j a • • LL Z� E V 0 O • • • • LL LL s9 i9 o N X J Q-: V U c o LL g !"I t $ ..i '•'''i lul ( ��_ t�� �F 1 I n� I € i�, � i i : I .�) Zj9i =i Ea� �'✓i 17t «�� I I� ^i..1ly C € l y. � "• at+ IL' t• 'w � I `� }� 0 e�gl.. � OE I „� 1 �r_ !z2.•.} dI >.a.�' T ! i ! �N F Y ^ q I.�(E! p�Stl i3' w� j !f8E F I { l F } Hof .i ..}UfC3E a {.`°� h ti � � u� � �j� E ��,� i •p; i � I °io�l a i �n� E64 �l o I � i >��s�j ' 'r!�I���i ° ' ��� i9� I , F I � 1�1�fil I Ci I �� 11 e N ��� ; C Ni m'v!: i�Y. YU !�I I�� V IYji i ij17�V c uwnloo F IMMI m 7 t i r : mt mrc a I_ 1 9 i l i i ! 17 o r Old I�I..i fC.i. �C �G' i1II C I CCC , 1 ! i. LROMIS I t t I ° (tl i li l�tl 1 N Ems{ N i C� rn C w I(�! i IMI !MI �✓� i � '(�€ i f�l (.�`! N �I i 1OjOU P4 S °J " ;S ° ® 4 C I t P I ^ i N f I Uwau600 ®d' tt i E i ? I I • • • • LL LL s9 i9 o N X J Q-: V U c o LL g • • • LL 7 E � N z Fb N o N IK !J S 3 ° A 2 0 N r ` J �z i w � t 4I 4's�i � �p c - `• cfF�O� 9 C E�[_ E J 1 IP 11 1- k i 1- y 2 2 � i��sr � , iool.a C F F: r• n ro e FI � y: GI { w E € �t q � LI O� X61 0; ' I ! ' �� ' N E � wrlfp ( " € �.i U NEO ` O U E N E i j 1ni`Sr•t `N Ei j W m t�Ibl aim 1 t f d ` a �n �o,.... I I aid !- m II 4aBueiaS o, 0 0 o ltll' ( I 4 in Vl I O i i r, I l i C i7 ! . yy j;I !M1 VJ1 �t M� I O W y N C emas(°yg E2 12.�x • :z I 3 3 i3 f 3 O C .• d 4 ': N .q a: IGBA008tf C.%V ecm <4 "FO i f i I { !i 1vi tt O.�O' a! Y1I�OV°•�C°i 4 �. tyifl i y y C�� Sy 600 ° ® z O IT �.� ' N O °ey �F C i f b ri) ®Ccr�C 1 • • • LL 7 E � N z Fb N o N IK !J S 3 ° A 2 0 N r • • • It U to 0. 25 0 0 0 1: L: 1: 0 �ui�tV � � I , - . ,] I e'� s ' 0 Ed �T� 1 'li" �LE 1 I. {L I ��i � I'G� i �, o I �l�I cszz 2iO 3��"� • 3: I ,�� l ENI I el G' 0 ^� € e`�.j A >m 0 Nj c - a R ac 10 aw 1 0 t� � �>• ' i ^e .c�`°�`'I— �— `�— I E —, -- o f � I € I W 7 r o `° . i 1jwnlo3 i , 't 0i e- Old # i 1 I � p 1 �� i k t " l i � 1 . I ` I I# I � k j a i {� I ! 1416UOJZS ; a jo a 00 Z4 12 I In 01 100 Io N "I I i # h Nf : ce re g C41 od ed Joloo 1 1" Q wn1sloW �j I v fig . 4 n to) tUBA03011 C st'iw In 1001 1*1ni 1 1w In I ki Z 4 B Ufa t - C �2 V w • • • It U to 0. 25 V J • • z � F LL iN a� u N 6� a� a� s a �o a� m� 0 N r JE ` ! 9i il iii M i ! U I I i 1 i i 3) ���91 II� °fI y '� � a1 !a!'�!v c I'�' i I�! ..� i ( 1 ° { i f I ° 5 f tii 78 iyF i • Cl� fY,i Im: i !� I !• -iq : � { e e i tl �q iy ° rqi °� � ib { �rd (6 { Q GI R 0 ' o 6q!WI ( ! Wkfi �•O li f ql ! { U ( j {^ �'(�� � N�Ni 'ra l,�.(�..I� a( U uj J 'U Ui I y UI 1 N q ,(m! ipopi {�.� ! 1 ( �3'�i i" > p i?I.OIG , I•c� .5 °i 3l9 6 °IQ did J�'+ C �abEO ' •O { I m }O l I f I ` { !a:ai za i i {3 N v ' 04 E— #s� o i enf S i { �.:`: �: � �I � ! f y N { DINT iX •C !A 9 5 jt '/: V` . O U G(Qi Oi .° � : .°+ { 0. {G {Mi ! i��aivll I i .C � �ql•� k ip3jj« w( � 3 b01 i of .�°. fij���� a a s UWn�0'J iTifi's:iS4:ii:7):iii C Is - g � •• V M Z � ''.'�iiii. :iii: i)::�:F: �:C: ?'::iihii5.icii C ::(isiii� i.`iili:i':� .'.( :�: _ ` �z <m° a 0!d '0 lod = 6 INI I = o 0 o f °o I °o'of o f o?tlia {O! 10 { io 0 8 0 I 0: ! U36uw3S o;o m im� 0 1 wl I ( �u' ( n { v ( lti! wl ! IoIOo t� I i0 CIO N V CIO O ! O [ CIO 1 O! V;N !N !O I { SO N i ( ! � ttl;Nl ; M i IN I I {�I i III 111 1 I i 1 0 111 1 i = ��IE� {934 �CG :04 i I 04 xixi iii {may lf;! —I I -- emis! qlq� ! -( SCI i � � � �3i 13 :p: t 3(313 i i =tee °wa� 1 I R Gn i'i UU ° eW�vF a ll ®. N {^ .- ;(M� � I�°( I�C�n�eo! �"' .' :�.� -•I ! ^,^'� � �NI ( ! u u S N a w e ' UUWm' �1 q{ ( { f ool ��� {^ i ' ►N , , iNl ; I 1 1 E+6 zz W b Z e C u Q tl : Uena <G R.�a f ! i l I l V J • • z � F LL iN a� u N 6� a� a� s a �o a� m� 0 N r APPENDIX A.4 EAST COVE AND (EC -12 THROUGH EC -19) SANDBAR (SAB -01 THROUGH SAB -08) SEDIMENT CORE LOGS • • a 0 O "s z 0 a N' s O III N N 'O C O O Q > H m p q V U R R .LLL V j E LYT. O M s ' 6L e R E ienaalul aldmes R R a L xavn IOO U� C y z W n m w ••• 5 'a y N N a' C f M M M w O F m .d m u O C 8 H.L0x3uZS L w VI w v e 3HIISsaoN1 3 3 3 3 3 3 3 3 R Q Q H d e O ty C h ti n � h p w Au3A003u � M w z x z Emww o w zwwzva 'IVAdHIMI3u00 w w p c 0 ;4 w 0 ? h FCLC9E2 U o U y a @ .7 ® N a 0 O "s z i • • i. l 0 N N m 0 f - mm a n W O R N a N 4 Z a pp s a N IL r7 6 'S Yt PQ a �y a - a m o > 1 0 0 0 0 c v a IuAialul aldmug o v E a z c ti �sz 3a" > x y a uwmoo w W o E � R N E� a �o Oi F a w Owin00 e E i � > E p W xsoHax.�s y } > � d w z® �v aunsslow 3 3 3 3 3 9 4 bm r I m � .n w V o 6 F A*daAOOHH ri N zzw 'TdA2i3.LAtI 3UO3 i • • i. l 0 N N m 0 f • • m m 0 i In- N N 0 a Y � C � d• oe m o = w O y N � V 2 W N w O U + Z O y U G y a ai Q W z p O u_ O N o M T e°D Q O . 0 h N pj' � I V O v. A y A '.D O T O •i a T m Y v o 0 0 0 s G L a" u lz"o)ai oldwes A � E a z 3 w z n W F GNUS U ° e. O N O m a — 0 a 0 O C "E = Y 4. � > �w xioN3zrys � s N zg ag �R as °. 3TIn1s[ow 3 3 3 3 C} � • O Y V � � U U o f*7 G � rn v7 AUTA03311 "' N1 m �az�cWC�w zz� 1 1VAK3SNI alloa ® U rn e.d.dGm • • m m 0 i In- N N 0 a m ° ° N r S O N m 0 � p S P o q u Yi Y W ' RE 4. > u =- � a 3 5 n n i U o 0 0 0 0 0 a� •• o Icualuy aidmeg c 5 V a a 'c xz Po uwmoo w z O q O (9 NNUO � e u Q xaouaxas s W v a� w axnisioau � 3 3 3 3 3 a e 'a 'C N ® B H <UZ v a o W e W W U 7dAxasnn aaoo o c ,°a F'aPf.OwE' m ° ° N r S O N m 0 � p S • ° ° N e 4 N N m 0 7 O ti Y O U P ''1 F ♦ � W _• R Z � 6 � v in .0 _ C n IL 0 N x ''�' � W '� • W b O f�1 ' A� y U .fl F I^ U b w r ti N E { v t Z e ai. u u G u A E iEA.1alU1 0l(IWE$ �zz 3 W C7 m .- 30 a t KIVE1100 e y W z w m o o tl N 0 0 h ° N M N h C 4 0 F e E E � HS9N3HSS S j ,0 0 o ti j H a E 3H[ISSIOW 3 3 3 3 3 3 z AH3A033H W h Iz a G v W Y H Q ' ti U EEW°° p 'IdAH3SN[ r z W W Q W 31HIO3 U wmQaav, ° ° N e 4 N N m 0 7 • • ) § § | (�} \+ § }/ b 2\ \ �® A __ ¥_ \\e \ § §E amm )\ Q2 . .. . !k ems s § 7 i ff nfus mw )k§; /a ƒ ! §!!$a k[C4 w . mqj ), / \ \ neon �( ; ;ƒ�( ! _ \t §» » / \§ �nm \ /! §(/ #nom • • ) § § .� •� 2 'go U � \!" - \ } s . | { § �IL 0 \ } k � 7 ; \\ \\ I |}( 2 D J {§ __ ¥_ e ke f) amm , \ i!■!� / � \ } \ ` ; )} �.,,0 \ | C4 \\ mmn# / \a !, en mw )k§. /;. <! ! . « , ; ! :J())k \!a ■!!a rj �/ „ § ' wama , ©ba§ ;) , Blo�,c #aa_ nm 2 • • � ] ƒ 77 L) !\ � 3` \ §�(■ B`i \ � � \Jƒ ° ) !!■!k - / ^ ` ! /} ,.moo \ a»na ® ® }) an mw I ) ) . uA09} - m§[�� ■, neon ) ® » = -2§ ! #na_ nm 1. LJILU ] � • — | B . ............. )/ � d / 2f . (° ± ¥_ (5 &k Tn :\ , § a ■- ! Ll f ) \ ƒ .| )§ �k !� I -!3! ! ) !a nam n B 'k)£E2k - ` anamnm \ � • �f \ ) ., :9 !a | �2i}2 §�(! - k \E ) \ ! \) | _ \i -� As I%!! \ /}} 4 k � ! |e - §! »2± amm it § \\ !\ ( ) ; ■!0 \ \ 2 - § .eu0 } . �k) ( - \ nn mw } ! ` ! 2sk!)§ ° 1 1-1 . . m § \ k ' namn ! k '2ie�E ;) \ 'IVw,JM am \ ) • • w k ® \\ /\ � �(§ / } \ � .\ . � / \\ \ �) � \\ / %\ , m \, E% � 9z pwalul oldweS .: �� / \�& &\ / \ — �\ , ; \\ mm� s 19 . zs C. Muslow d a I H u b w name It § z 3 ! ®« § - -IVAUg.LNII 31103 ) @228§$8 w � f k r : ) 2 � - BB - « \ \ ) )/% \ - _ � ! # ! i ®« 72 | !■ � ! N § - 1 1 1 It __¥_ \§ k(§ )) _mm §(§ §ƒ � \ 0 ) - ,. ) ! . ; EE - aONTUS \ ) ) } � )\ §�))) nn mw /\- \( \� . ° °\�� ],§4 nao , \§ ;k[$§k S -§ o \E( ° 7 \()) � f k r : ) 2 • §� \� t - § }\ . \\ lu"o4ul oldmuS NwIlloa MILSION .5 NUMODaH zw 'IVAd3lKl 3HO3 L gg � k • : ( § @ ƒ §`#■ ! 2 < t <_ } (} / § o ea$; . -\ }. . $\ �§ > k . (� / \ § § f| l u"a l u l ®mus \ \5 7§ mmm )/§ §) \ / \ \ & ` ! 7 \ � | }§ emna ) ) \ nn mw ) 01II ; ;� #amn .Gawk,( z „ e . K Wi §\[\ § §; .4 - o a aa_ nm / dke<3gz ( § @ � • ) ) (} \ ! ¥ i22 �- | �� \ {) __ ¥_ (te !( mmm a2] !! \ u ! { ; 00eoo }\ m«n# ] ! ] �! MUSTOW wi § ! wamn §I ®) §! §§ 2222;G@B nm ® r &e=� ~ e ) ) • • J i i 0 0 N n 0 0 N N W 0 m C. ® p Y co � R .•••• Y b0 O ' 0 E A O O ° w vi N � cc !Y O v � i L � d L c Ie,va;ul oldmes A 3 a �z ao > x F uwmoo � ym W o x C L' W G NU o y h h F P 1�I1 Q � E ° u HIDN"ss u u C u zeL;c 3xnzscow 3 3 3 3 3 U Uo W A�vi y� W moo .. w w p a 0j w O 3VAH3.LN UOO 0 W ak roa u N d A rn 0 0 N n 0 0 N N W 0 m C. APPENDIX A.5 EAST COVE GEOTECHNICAL BORINGS ECGT01 THROUGH ECGT03 O O ? �� �! i ��l 1 ] l l i�� i 1 ] 1 I_ ( EI l i i i i l�� � I �F (� &� 1 I ] I F i t �� ' F � : E I ? I i f i l l l , t� €l tj � I ? � I �i $ I �j I E 1 8 �� 1 �f � � I �I I �' � T € kl €.�� � i �� q € ? i � E i I E � � I s? 1 � � t � a � i I �': `; � I .�-�", � ? �l y { � E i � � � _ � �E I � � E �'� � � Is Ig:�.� ��1 Is M �t�i +�y� � Y i i 1�:$ FI 111iii�i fi. yl �! I ] i'€. �� —j Alf— al 7 11 a i E Is .0 a is ....... ..... 0 M Its i I s! I s I -1 112 1 5 A M i El j R 21 °, 1 1 �6 is A 4 P'l I I H I — i !!tl f� � b� Si i I i I k } m 7 zc; i —Ir �F [I E r It - 7 I v i I P I t, —al O O I at K� t ��1 ° { €g Ix � � � � ; j I B' E $��i�3�� #•I�( x €�f�� ! Q! �('��.�� �' �� I f I €,rii €� €�E�i . I >1 >1 tu llzi 4 1 - l u in to . ........... t:T go , =Ig 1z —1 E 1 V R p I a c a z a e a z G a a e WE��Tr )N APPENDIX A.6 .. AREA GEOTECHNICAL BORINGS D908 TH ROUGH .• C7 O a z LL 2. LL J LL 0 N N r� o� g ) 6 y m ax E f' O r A v. aLaw'c o A w ri O W R oZ. T' +� y F ya yea � ..a V V' T O O U M • y m � y p X 0000 u0�'O > Fmo of Oz Gy G �i Lsl 44 J Q' Q ,-7 r] O O O. 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G p e Y E: c: o •cim E o: c �� $ f ' ey C �: �� �� -06a O • C� m 2 ;5 : z < � Q'y uwnloo �zr aid r � yr.8uons •o•o•o: eo. o; o' ;oe i ' � c ar c z�z i; em s o n n,ni .n; . . r w C w F fieh000Ef :s &IIIeA•ti r i �: r: V: :en: NiC•: ih: x . . . . c :P: 1 w G C .r.Ci a s N � • nt� 4 6 C G �:�' °': :r":p iN �rliM i ± r a. • 2. LL v LL � N h e z e� N E� w � �o �a 0 u APPENDIX B.1 EXTRACTION WELL EW -01 SIEVE DATA APPENDIX B.2 EXTRACTION WELL EW -02 SIEVE DATA UNIQUE ?j�o7ak `f 464 — cm3 Sow S,\Pt,I- Z,O 1 Z w E. LL.- WELT. # CST ;t. Page k of � Geological Materials ^ Color TTarddess of Materials From To S� a rz R iu ut S 1 C7 h 5'taa+�s4 r^� $ 1U 15 p d RJ I sNo w F - F3 R 60 7 S NE 1 S M 7 g 2 S a^.aa d- J 9 2 11 " q, o- sib VIA t 4 t 2 c> J � '20 12 uYat motroo 13 IZ APPENDIX C EXTRACTION WELL AND PIEZOMETER CONSTRUCT LOGS EXTRACTION WELL CONSTRUCTION LOG I MN NO Northing: 4959120.60253 Easting: 507776.20251 781.23 TOC Elevation (fmsl) 767283 GND Elevation (fmsl) DRILLERS LOG Interval Site ID: CLIENT: Confidential Page SITE NAME Cottage Grove MN DATE OF WELL CONSTRUCAOh PROJECT NO: 02181.002.050.0001 we"COMPLETION ZONE: L DRILLING CO.: Traut Drilling Services DEPTH TO WATER I LOGGED BY. John Hunter TOTAL WELL DEPTH (fbgs): 73 -89 enuaacUTA� Wall Inaatad in south of D9 alone access road. _ Northing: 4959120.60253 Easting: 507776.20251 781.23 TOC Elevation (fmsl) 767283 GND Elevation (fmsl) Date Developed: 9 -22 Sept 2008. Method: " Water Jetting -60 hours 18 -5 Boring Diameter (in) (0-1`18 fbgs)) 90.02 Depth to Water (floc) Well Construction: 12.5 Boring Diameter (in) (118 -225 fbgs) 12 Woll Diameter (in) CS Riser Material SS IScreen Material 60 Screen Length (ft) It Interval (fbgs) of Sand of Screen Screen Interval 224.00 Bottom of Screen 225.00 Total Boring Depth Boring was constructed using Dual Rotary Reverse Circulation drilling techniques provided by Trout Drilling Services. The well annulus was constructed with a natural sand pack across the screen Interval. Grout consisted of a bentonite slurry installed using positive pressure tremmie pipe pumping techniques. Development consisted of continued water jetting across the screen and recirculation of the fluids (after particulate removal) to avoid high- volume groundwater pumping. The estimated well yield is 2000 gallons per minute fbgs: feet below ground surface Cs Carbon Ste.) pal. as stainless steel gpm ftoc: feet below top -of- casing Gallons Gallons Per Minute 02181 - 222 -001-0001 1111812008 DRILLERS LOG Interval Lithology 0 -5 Silty Sand 5 -7 Silty Sand and Clay 7 -11 Clay 11 -21 Sand & Gravel 21 -28 Sand & Gravel (Cobbles) 28 -33 Sand & Gravel 33 -38 Sand & Gravel (Cobbles) 38.73 Sand 73 -89 Sand 89 -94 Sand & Gravel 94-102 Sand 102 -106 Sandy Clay 106-135 Fine- grained Sand 165 -188 30% c.g. Sand, 20% Gr 188 -f 95 70% Gravel 195 -197 Sand 197 -202 Sand & Gravel 202 -206 Fine- grained Sand 206.208 Clay 208 -218 Sand 218.225 Sand & Gravel Date Developed: 9 -22 Sept 2008. Method: " Water Jetting -60 hours 18 -5 Boring Diameter (in) (0-1`18 fbgs)) 90.02 Depth to Water (floc) Well Construction: 12.5 Boring Diameter (in) (118 -225 fbgs) 12 Woll Diameter (in) CS Riser Material SS IScreen Material 60 Screen Length (ft) It Interval (fbgs) of Sand of Screen Screen Interval 224.00 Bottom of Screen 225.00 Total Boring Depth Boring was constructed using Dual Rotary Reverse Circulation drilling techniques provided by Trout Drilling Services. The well annulus was constructed with a natural sand pack across the screen Interval. Grout consisted of a bentonite slurry installed using positive pressure tremmie pipe pumping techniques. Development consisted of continued water jetting across the screen and recirculation of the fluids (after particulate removal) to avoid high- volume groundwater pumping. The estimated well yield is 2000 gallons per minute fbgs: feet below ground surface Cs Carbon Ste.) pal. as stainless steel gpm ftoc: feet below top -of- casing Gallons Gallons Per Minute 02181 - 222 -001-0001 1111812008 EXTRACTION WELL CONSTRUCTION LOG I MN N 0.1 767284 Site ID: I EW -Z CLIENT: Confidential Page 1 "0f SITE NAME: Cottage Grove, MN DATE OF WELL CONSTRUCTION:. 6- Oct -08 PROJECT NO.: 02181.002.050.0001 WELL COMPLETION ZONE: I Unconsolidated DRILLING CO.: Traut Drilling Services DEPTH TO WATER(n-o:1a 21..85 LOGGED BY. John Hunter. TOTAL WELL DEPTH(tbes); 150.00 n.......me. wen Inrefed •nnrnrima}elu SD feet west of the East Cove along seems read. _ Northing: 4958923.11486 Easting: 508413.44195 - 711.11 TOC Elevation (fmsl) (HAD 83 UTM Zen -15 Meter) 709.16 GND Elevation (fmsl) DRILLERS LOG Interval Lithology 18.5 Boring Diameter (in) (0 -118 fbgs)) 0 -5 Sand & Gravel 5-10 Sand, Gravel, Silty Clay 10.15 fg. Sand, Sand & Gravel 15 -55 Sand & Gravel 21.85 Depth to Water (floc) 55-60 f.g. Sand 60 -75 Sand with fines 75 -92 f.g. Sand 92 -117 Sand & Gravel Well Construction: 117 -120 £.g. Sand 120 -125 Sand & Gravel 12.5 Boring Diameter (in) (118 -225 fbgs) 125 -150 Sand & Gravel with weathered limestone 12 Well Diameter (in) CS Riser Material SS Screen Material 60 Screen Length (ft) 0.18 1 Grout Interval (fogs) 18.00 Top of Sand 90.00 I Top of Screen 90 -150 Screen Interval (fbgs) Date Developed: 7.13 October 2008 Method: Water Jetting —40 hours Screen Slot SIZe (in) 0.035 A 0.02 De th Interval s) 100.115 115 -125 125.150 150100 Bottom of Screen 150.00 1 Total Boring Depth Boring was constructed using Dual Rotary Reverse Circulation drilling techniques provided by Traut Drilling Services. The well annulus was constructed with a natural sand pack across the screen interval. Grout consisted of a bentonite slurry installed using positive pressure tremmie pipe pumping techniques. Development consisted of continued water jetting across the screen and recirculation of the fluids (after particulate removal) to avoid high- volume groundwater pumping. The estimated well yield is 2000 gallons per minute fbgs: feet below ground surface floc: feet below top -of- casing ' Y d ` 1 CS Czrbon Steel Uzi. Gallons SS Statniasa steal gpm Gallon Per Minute wzaoFSS a.a,- a- auauxn 02181 - 222 - 001.0001 1111712008 VT: Confidential Client NAME: Cottage Grove, MN IECT NO.: 02181- 002 -050 -0001 LING CO.: American Eng. & Testing 3ED BY: John Hunter Grade Cover DATE OF WELL DEPTH TO WATER (toc): 72.00 TOTAL WELL DEPTH (toc): 112.00 762.92 Elevation (toc - ft msi) 2.73 1 Stickup Height (ft.) Elevation (ground - ft msl) 2.00 Well Diameter (in) 0.01 Screen Slot (in) Well constructed with ten feet of 2 -inch diameter 0.01 -inch slotted stainless steel screen with 2 -inch black steel riser to the surface. F__ Top of Grout Seal (Fine- grained Sand) 100.00 Top of Sand 1 _ 025 _ 0 1 Top of Screen F - 7 - 2 5 .0 - 0 - 7 Depth to Water (TOC) F - 1 - 1 - 2. - OT - 1 Bottom of Screen F - 1 - 1 - 2 - .0 - 0 7 1 Boring Depth All depths are given in feet below ground surface unless otherwise indicated. 11/17/2008 CLIENT: Confidential Client SITE NAME: Cottage Grove, MN PROJECT NO.: 02181- 002 060 -0001 DRILLING CO.: American Eng. & Testing LOGGED BY: T. Frinak H Flush Mount Surface Cover X Above Grade Cover 2.00 Well Diameter (in) F Well Material Elevation (ground - ft msi) 43.00 46.50 All depths are given in feet below ground surface unless DATE OF WELL DEPTH TO WATER (too):. 2.49 TOTAL WELL DEPTH (toe): 44.09 691.75 Elevation (too -ft mail 2.66 Stickup Height (ft.) Bottom of Screen Boring Depth lI manS DEBnwEmmumm 11/17/2008 27.00 Top of Grout Seal (Fine- grained Sand) 32.00 Top of Sand 0.01 Screen Slot (in) r__3_3_._00_7 Top of Screen Well constructed with ten feet of 2 -inch diameter 0.01 -inch slotted PVC screen and riser to 2.49 Depth to Water (TOC) the surface. Screen sand pack (Artesian Level) natural, followed by a fine- Water Table -1.15 feet above grained sand grout seal and Top -of- Sediment cement/bentonite grout to the surface. 43.00 46.50 All depths are given in feet below ground surface unless DATE OF WELL DEPTH TO WATER (too):. 2.49 TOTAL WELL DEPTH (toe): 44.09 691.75 Elevation (too -ft mail 2.66 Stickup Height (ft.) Bottom of Screen Boring Depth lI manS DEBnwEmmumm 11/17/2008 VT: Confidential Client NAME: Cottage Grove, MN IECT NO.: 02181-002-060-0001 -ING CO.: American Ena. & Testing 3ED BY: T. Frinak 508518.322616 ;h Mount Surface Cover ve Grade Cover DATE OF WELL DEPTH TO WATER (toe): TOTAL WELL DEPTH (toe): [F 689.22 Elevation (toe - ft msI) 2.68 Stickup Height (ft.) 686.54 1 Elevation (ground - ft msl) 2_.0_01 Well Diameter (in) Top-of-Sediment approximately 0.2 feet below surface water level. PVC Well Material Screen Slot (in) Well constructed with ten feet of 2-inch diameter 0.01-inch slotted PVC screen and riser to the surface. Screen sand pack natural, followed by a fine- grained sand grout seat and cement/bentonite grout to the surface. 22. Top of Grout Seal (Fine-grained Sand) 2_7,0_0j Top of Sand Top of Screen 0.65 Depth to Water (TOC) (Artesian Level) Water Table -2.19 feet above Top-of-Sediment F All depths are given in feet below ground surface unless otherwise indicated. Bottom of Screen Boring Depth MUMRS %_,.0 DEMNEMMSULTAM 11/17/2008 r > Minnesota Pollution Control Agency The negotiated agreement meets and exceeds all of the needs expressed by the MPCA Board. Proposed Consent Order on PFCs A Summary of '•• • May 2007 At its April meeting, the Minnesota Pollution Control Agency (MPCA) Citizens' Board directed staff to attempt to negotiate a Consent Order (a legally binding agreement) with 3M on perfluorochernical (PFC) contamination in Minnesota. The Board directed staff to address seven concerns in the Order. MPCA staff believe they have reached an agreement with 3M that meets and exceeds the needs expressed by the Citizens' Board. The Board has received copies of the proposed Order, and is scheduled to consider approval at its regular May meeting. The issues, and how they are addressed in the proposed Order are summarized below: s. A rigorous, robust cleanup plan The proposed Consent Order contains language that will result in excavation of contaminated material at the three sites (Cottage Grove facility, Woodbury Disposal Site and the Oakdale Disposal Site). The cleanup standard reflected in the proposed Consent Order is significantly more stringent than the normal cleanup standard required by the PvIPCA. The MPCA would have had the ability to pursue excavation under the Request for Response Action proposed earlier, however, the State would have faced a risk of litigation, resulting in delays in either cleanup or cost recovery. Under the proposed Consent Order, waste that is removed will be permanently controlled either through containment in an underground lined vault that meets all hazardous waste disposal standards, or by incineration. After waste is removed from contaminated areas, those areas will still be capped, and pump- and -treat systems will be installed to address any residual releases that may occur. z. Recognition of Agency jurisdiction The proposed consent order has, as its legal foundation, the Minnesota Environmental Response and Liability Act (MERLA, the state Superfund law). While 3M reserves the right to disagree in other forums with the Agency's finding that MERLA applies, both parties agree that the Order is fully enforceable under MERLA. 3. Municipal and private drinking water supplies are addressed 3M commits to provide alternative drinking water if and when a Health Based Value (HBV) or Health Risk Limit (HRL) is exceeded as a result of contamination from the sites. This commitment will also apply to the chemical PFBA when an HB V is issued for it. As with the rest of the agreement, this is an enforceable requirement of the proposed Consent Order. Additionally, under the proposed Consent Order, the Agency has sufficient authority to require any groundwater investigation and Minnesota Pollution Control Agency = 520 Lafayette Rd. N., St. Paul, MN 55155 -4194 ^ www.pca.state.mn.us 651 - 296 -6300 - 800- 657 -3864 TTY 651- 282 -5332 or 800 -657 -3864 • Available in alternative formats monitoring necessary to fully understand the extent of the contamination, including in aquifers used for drinking water. y. Address future actions on PFBA The proposed Consent Order requires 3M to investigate and remediate discharges of PFBA regardless of whether an HBV or I-IRL is issued for PFBA. S. Address additional studies on health and environmental effects The proposed Consent Order addresses this issue in two ways. Any needed research that is directly connected to releases of PFCs at 3M sites is fully reimbursable to the State. There is no limit to the amount that can be recovered under this provision. Past costs associated with research on PFCs in the environment related to 3M sites are included in this agreement in the amount of $598,692. This includes the Agency's work investigating the effects of PFCs as part of the Agency's development of water - quality criteria, which includes understanding aquatic toxicity (chronic and acute affects on fish and other biota), human health consumption impacts, and wildlife impacts (bioaccumulation impacts from eating fish). This work, which is ongoing, is fully reimbursable under the proposed Consent Order. Additionally, the Order requires 3M to pay up to $5 million over the next four years to the Agency for research costs on the presence and effects of PFCs found in the environment but not directly connected to 3M sites. An example of this work is the investigation of PFCs in urban lakes. 6. Address cooperation from 3M on sharing research and information The proposed Consent Order requires 3M to fully cooperate with the Minnesota Department of Health and the MPCA on research, including a formal commitment to complete a 90 -day study of health effects of PFBA. The proposed Consent Order also provides MPCA with full access to all non- privileged 3M documents on PFCs, and provision of any such documents of interest to the Agency upon request. 7. Preserve the Agency's right to take action in the future The proposed Consent Order preserves the Agency's right to take additional action in the future either due to new information that is not known at the time of the agreement, or if for any reason the agreement is deemed to be inadequate to protect public health and the environment. Additional items In the proposed Consent Order, 3M has agreed to contribute up to $8 million to remediate the Washington County Landfill site. 3M is obligated to pay $5 million up front to the Agency for this purpose, and, subsequently, up to half of the remaining cost of remediation or $3 million, whichever is smaller. This site is managed under the State's Closed Landfill program, and 3M currently is under no legal obligation to address this site. Also included in the proposed Consent Order is an agreement that the Agency does not waive its right to pursue any natural - resource damage claims related to releases of PFCs from the sites. Next steps The proposed Consent Order will be presented to the MPCA Board on May 22, 2007 for consideration and approval. If approved by the Board and signed by the Commissioner, it will be a legally binding agreement that will address the PFC contamination now and in the future. Proposed Consent Order on PFCs • May 2007 W Minnesota Pollution Control Agency page 2 MINNESOTA DECISION DOCUMENT 3M Woodb.ury Mposal Site City /W p75 Washington County, MinneSota SITE DESCRIPTION SitqMap »a [toad W 04 e f s 0 =s The Site predates the the time of the actual type and quantities o': cubic yards be dry ini materials were, dispo! Act scrap rml l ing ft Filter trappings, discP on of the IMPCA and there are no historic rccords,avail,able at the M11 from f this landfill, In addition, no historic fccqTds were kep by 3M dc ailing the p s� I i disposed at the Site, but it hag been estimated that aprbxii 200,000 ,I waste Such as waste adhesive. rolls of it m rag-, resim and of f specification at the Site. In addition, it is estimated that approximately 400, 0 gallon of I Manufacturini7 orocess for scotch lane and sandixiner ducludinR wash water, were disposed of at the Site' . Acids, chiefly scMiric were durriped in [9 , the Minnesota Water Pollution Control Gdi9im scion informed 3M could occur as a result of their practices and recominended th-at dumping all Other wastes be placed in clay pits, The first clay lined pit was W tj 1 1I � K I qm W.66bbury r � fy O3h :.{ S Y •.gym U °. � r ( "IRE fn OW z �-" w {3KAt 'VVL +�°• Y tyrv. _ i.Mi wYLl JAW r E > c RaVind L ANK 3M Cdtfiige In 1992,3M entered the Site into the MPCA'sVoluntaTy hivesti Cleanup (VIC) program, under which various investimitiqns and response actions were con ducted 1 to further address contamination at The Site. To 19,96. Al backfilled open ,iTns and re- graded the Site. placed aPoil cap over the fd-ner disposal areas and, recorded, ii restrictive covenant on the praperty.fliese activities Were all aimed at rurther managing VOC contarnmation at the Site. In 2005- after IM discloied that industrial wastes corta requested 3M towileo ground Water Saffililes fforn die for )sed at the welts and to was STATV,MFNT OF PURPOSE Tbi NfirinqsotaPecisi6n Ddcum=l (MDD) pv=ts WICA's selected responseattions for PFC , " . conianihiation at the Site and 8umni anz es the facts and determinations made by the PCIk in S the responso act i . ons; The response actions., addmss rcldUes of P,FC§ to soil and ground water at the Si Previous response d I d aons h ave beet I i taken lay 3lvI'6 addrz s dew releases, Thy aelectcd response aefibris in ihls -Nflbbare d intofi6d'to prevent human receptors and the surrounding emaroninant fiorn being exfjow to releases of rlz&s �-oni the site. The Cgrimissipher or bis delegate has deteimined that the response actions set forth in this MDD are 0 11 r I cosohab) e'-,mA u I qeeissary I , t ii�6fec Lthe pubii c heat lh and welfare acr the' envi rdn 11*0 from I tho , itlease .in'd fbreateIWA rcle4R'0fPFN'Yrofh the Sale. DESCRIPTION OF PROBLEM PFCs at the Site Z4 to Melts found ME 'The MP(,�A has tested over 1,001 private and public wells in South Washington County for PrCs. As a result of that rdsting, the N4PCA orov'Wed 2 horres in The LAne-don and kivq Acres iieighWfhoods or id To 6! C �ooy� W� on ri n 6 f Cottage Grove and CIOL P�IiSlllp, RPC ti ith edwiterorinwborneeirb tilit (i i their privato well wAtet- ret(uired that istd rednp ng vas; prdmiuY MoSideration should goto thosaahernatives involving excavation and destnictiatx of the remaining PFC `wastes or excavation and dis} osal of PFC' wastes in a permuted isola egg- inered containment facility. The fat for the Sinsshowed tdsat,tii roundwater-pump out system at the site is preventing the ofttalte- migmdon ofPPC:s as well as VCK:s: l here are PF {.sin ilia groundwater at substantial distances away train the Site, but they are thought tolhave escaped or moved of[ site heforethe pumas -oust System was in place: and sour 6e reduction activrities Wale dompl�ted hi regard to PFC.s in soil. on tlx: Site, the Rt arid 'previous investigations of the Site Showed that some residual PFC:sreinained in parts ofalt fouro €the.forner disposal areas (blortheast Main and'2 Municipal FilL Areas), soil conccn;trations of PFC s vary widely, but wcee deemed sufdiefent iii Some cases to be acting as possible continuurig sources of PFCs to the l4cali7ed ground water at the Site (although contaminated gr6und.water is notmigrating otT =site because it is captured by the pump-out: system). In all cases, the PFCsoil concentrations that =are abovre >the N pC A °s soil reference v =alues are wall below the ground surface. (3 to ZCs feet) dueto earlier removal actions, bacidilling and soil cap installation (i -o;, there would be no pathway for human exposure to PFC'g in soil). "the objective; of tile FS ii to eviduate various.response action alternatives which address PFCs in sail and ground ivatcr at the Site, and to provide a recommendation for implemeination; a criteria developed by the U.S, The dry evaluates, compares, tuna contrasts cacti ,,botl and long -term cffceticeness reductiori of toxicity, mobility, of volurne thro tgh trea rent inipdemeniability cost effectiveness overall protuctionofhuman health and the environnient. The NT PCA reviewed and evaluated the alternatives presented in the FS and recommended a proposed cleanup plan for the Site. Summary of Alternatives Remedy alternativ=es- were.developed in three categories: Site-Wide (SW), Soils (S), and. Ground Water (GW) `l"he following alternatives were developed for thc1 Alternative SW -1. - -Nro Further Action. (ground water puntp out would continue and institutional control are already in place), Standard baseline option evaluated at all 5uperfund Sites, Estimated cost: S4$,000, Altemative S it -'2 institutional controls, access restriction. and ground water monitoring, Would continue existing restrictive covenant an the Site which requires the barrier well system remain operational tauff the Commissioner states in writing that it may be discontinued and to prevent future development and/or soil disturbance acuities in any of the disposal areas, install f`cncing to restrict access, and develop, in conjunction with the :Minnesota Department. of Health, special well construction areas ear 11rohibitions, in affected areas on new drinking- wetter welts, Ground water monitoring would continue for the long term. (30 year sminimum). Estimated cost S956,000. j Alternative C Continued groundwater recovery wctlitieatmentl)yrarl)ot pflorto discharge, This allf-MatiVe to operate the, gotind water extraction systarn 10 capture and pre I vent ofltsfte,nligration ofprc- in around water. A nbroberOfStUdieq have: concluded the .existing system is an eff6clive barrier to PFC rrdg atioul Currently tbWr eXtRICITUo w Is purnpontinuotisly at a combined rate gallous a day� The water is Conveyed via underground pipeline to 3W Cottage Grove and used as' Process or cooling water and discharge to the Mississippi River. Currebtly, only, a portion of the water is treated belbre discharge. but under this alternative all the water wout&bL treated with carbon filtraftonb6bre be sAjectto urnhs:66i)uiuicd: in all ?x , OCA, i ssued parr6it. F O? (G%W- I was flIQ 0111 Y WOUA 0 water alternative deVelopedin the FS because the MITA wit] require it as pan ofany Other remedies selected flor (he,Sf1c), so il itellatiV o a n es are al[desiiied and reduce migration of PFC946in Oils to gTound water, they difl mainly= in Volome of soil removed and Croni where, and in degree of source reduction to ground water, Alternative S-1, would remove 31 cubioyards of soils firorn the surf aca to bedrock in the area of lhe tkMel,108 ilftshe r crthost Mspo§al: Arcai, The soils would he tmOked to a panijifted landfitl disposal Safe foreng hwered isofqt1611 artdconiaimner(t, Estimated cost $7;83UQ0. &!•Z--Excavafioii of fornter Northeast Disposal Area disposal at off site : cover cat thC ain Disposal Area: Sinic as 5 -1 plW, addijibnal 6vicz selected par ts of the Main Area. Would brilng total cover over Northeast Area by hvo feet. Estimated e mit. S8,190MO. trenclies and selected :d i9olation and o6ntai nenent Same asS,- I and S-2 Jtatwjtjj selective excavation ofsolls to a depth 01 18 lect tladm)cl in the Nortbeast Area and in the Main Disposal Area to a depth of 12 'f6et, Final cover would be placed over all 1 cost S 12,695.0001 3M also submit d in Addendum to the FS which 6utlined,proposed off site disposal locations. 3M is recommending Wogesota,,SKA , 's recently reissued perriik al I lows SkB to bUifdI swparate engineered cell within its e.xistinmindustrial waste containnientfacilityat the ST(B disposal factlitytocOntailo the excavated PFC contaminated inaterial; This separato cell would also be used for PFC, wastes excavated rrom the Woo4bury'and Cottage GkovdDisposal Sites. ThaM.WCA has determined that this separate call at the SKB'Landfill for 66fitainment of Yk wastes front the 3M Disposal Sites niecf8 the terms of the 2007 CO for engineered isolation and,contamment. Leachatc from this separate Pre. waste disposal call will be collected acid taken to the 3M Cottage G I rove plant wastewater treatment facility for treatment prior to discharge- DOCUMFNTS RMENVED I LVIN dcelsion to select the remedy set forth in this MDD is based primarily on the following d6cunien1bq describing t all wall as the effectiveness and east analysis of -resporse action ahertialives for the Sitc, itemedizillnvcstigaHoTY'Ftasibilitv Study. Febntary2OO7 Fluorocliemica] Assessment NVoiikPla;i.F,-I)ruaiy2007 • Feasibility Study lVork Flan, July 2007 -6- • Woodbury Water Line Evaltattion Final R port.iulgy:2007 • Addendum to theHurochemie&1' (FC) Assessment Work Plan for the 3lul'Woodbury Site, August 2001 • I3ydraulic Evaluation of the Barrier Will Recovery System, September 200'7 • Addendum to the Hydraulic Evaluation ofthc Barrier 1krell Recovery System, 7arsuary 2008 • Addendum to the Feasibility_ Studies for- the�Oakdale, Woodbury and Conage Grove Sites, April 20013 • Attu Disposal Area Adcliironal Gcopr6be Sru'npling Programi May 2008 • .Addendurn 2 to the Ieasibility Study, July 2041 ESTABLISHMENT OF RESPONSE ;ACTION OBJECTIVES AND SOURCE AREA CLEAN -VP GC}: E" N TRATIO ti?S Response action; objectives have been developedby the WCAto mini inize human, exposure risk. Soil exposures will, be .tcldre5stil by femti`a1 of Pi C c nt in ;Hated sa4i1, its t c 11 as ht k C rllimp wiilt cic to soil. ontarninated- eround.tva'�ter tviiI be controlled from migratiiag oft-site to avoid impact to drdniting water, River excavation anddestruction or excavption and engtineered isolation and containment orPFC% at tine Site. Resparx.5c aetidnobjcetivesttav been developerdusing Aplilicablc.or Relevantand Appropriate P1 Rerljiiremcnts ( kRs) acid arcs based on soil: and g*round.watcr t6nta€binalion data present in the MPC;A Site tiles, The A:R.ARs and other criteria considered by MPC'f1 in selecting a remedy for the Site are listed below; 1, 2q CFR 1926'. OS14A regal €itions for persons engaged in site - related actr'Ittes. 2, 40 CFR 264. Standards fot Owners and Operators of E €azardous'Wriste Treatrnent; Storage and Disposal Facilities' 3, 40 CT-R265 ' li merim Status Standard's For Owners of FIawirdrrus W aste Treatment, Storage anti Disposal Facilities: 4, CFO CFR 265. Land Disposal R,:Mictiotts. 5; !Minn, Star t 133,A. Provides State jurisdiction over surface water features, including wetlands such as lakes and ponds, and other wetland types ft, MpCik Soil Reference Values (SRV's) 7; INMH Flealth Risk Limits (I4RL's) an6,'or Health Based "w"aIues (1 -1BVs) A. Itesponse Action Objedives The objectives for response actions at the Site area 1, To reduce uotacceptable ltzrtnan rjsk e�tjzosure to FFC" +sit r2rouayd Gvator; 2. Ic redtiict PFC concantrat ons,in thn soil and ground r+aten. To reduce PFC c;one€rstracicras in ctiscTtirtrges tsr suat;� §ce �vatez; $. To arralntam an open space as a natural asset to the community. RIB POINT- SIVRNESS :SLti'4fPvIARY Pursuant to Minn. Stet, § 1 158:17, subd. 2b (2006), the T4SF"CA issued a public notice describing the MP ;A•rec oamncmled response actions. The public notice, was published in the Woodbury Bulletin on -7- 7-3, 2008 If6r the purpose of soliciting cointneatt5 ftom the comraai riry. ` I)CA staff shm held a public [rig at the VvIodilbury pity ball on:Jtsly 24, Qtl , to discuss ahe iiatives and provide the public the i•tunity to ask questions and pra ;ride cammei is on the propnsedrenmdy: Tha MPCA>also held'tt �t3EC informational meeting with. the city of Cottage,Grove on August 13, - 7009�:::�"ir written comments reaeived'atthe publieof informational meetings V"liilen6comments were received at the public meeting, li ur any tment.Tctters w re received during the public cantment period. I. City ofcottagefrrose submi tted' a conmient letter which commended the MPCA lbr the Positive anug Ph in to prevent the spread of: P1' Cs in the environment, The City of ntedr that it „pret"erred i1natthe carbon liftration treatment of the pu mp•out water - cated at (lie Sitefmtherthan at the 3 M Cottage Grove Facility, Tr4attnent of flee ar el €ntinate concetos ovcrptiSfiible leaks from thepipglinc carrying the hater azeGroveNaciltt.. 7 -liecurrentplaralxprow'ed IPC'•A G `7h6.' -SPCA will relay this rcconimendation to 3111 for, careful consideration. 21ty of Cottage Grove requested that a copy of the RentedW Design Document I at cornincnts on truck haul routes and other matters may be submitted betore- will provide the City with a copy of the Rcmuliol Dcsi�m Document when it I Washington [`ounty A comment letter frorn the Washington Counq Bbai d and;the I' ashington County Mparameni o1'pobl'ic T- iealtheom,°riunded the MICA on the tleanup being.propnsed at the Site One issue that-the Washington Count} -woutd like to see evaluated further is thcpotential for tieneticialire -use of the pump -out water, The current plttncis to treat it co pump -out Bator before discharge to the river either before or after .sage at the 31%I Cartage Grove raci ity, mliil'e tho 'WPC:A cannot require 3lvt to use the pump -out water for bench cial purposes, the NIPCA can relay this mcoinmendation to 3w1 for further consideration; The primary concern: for the MP.C'A it that contaminated ground water is appropriately treated prior to 3. VAloodbury lresident A Woodbury resident submitted the c:orn ment that not enough ground water monitoring has been done to determine the vertical cxient of PVC or'VC C! :onu ntinatipn in deeper aquifers, such as the .St, Lawrence and Franconia foiinations. The resident stated that l rC comana €nation has bean detected in Jordan aaqui r r wells d6wrt *-adient of the - Woodburn Site disposal areas, and if hydraulic barriers are not present: this contamination may be movine dovmward rroin the Jordan into dccoc,r aquifers. Inrestaonse to concerns abtsut lht� pas5iUle impacts ofrlie PhC release on dS•inittng w��ater supplies, Elie MPC::?C and 1vlirtincsors Deltartatient of lilealtb attemiited to defame ilte full eytent and'ht z nitud'c of the PFC reltasc to pisblic aid prilate wells in southern Washington County. Over a tWo -year period over 1,900 private and public wells were tested far PrCs. upgrsdient and downgradient of the Site` Fells drawing water from all major aquifers Averc selected for testing. including approximately 60 .yells screened in the Francor is Tormation. 'Me great tnajoHt }t of xalts ate sci -etned in s}ie Prairie du Chien and Jordan formations, which provide the greatest volumo of water for &rnestid ;and industrial nse_Wells are ordinarily not installed in the rranconia formation, utiless no other large supply aquifers are present,.and only a limited number of Franconia wells were available for testing. The PrC testing program found, that nearly all ortho Franconia vvettswctY t of conttmma #ed wvith PFCs, Apprnxiinatcty 12 of the Franconia wclN had PFBA present: at voneettlt ations less than l hart per Billion (ppb), the ;v DH health based value for PFB A is 7 pph, The PFC testinSprogram indicated iliac just two isolated locations,. with 27 homes affected; had levels of PFCs above the health, based vad'ues, established -for PFCS. I'lie 1v4PC A staff has not definitively identifled the PFG sotirMe.thathas t`mpacted these neighborhoods, the release could have resulted fcomthhe use of fire = fighting �oa5ft nta large' industrial fire, `lluzs.. *itli only a -fete QxCeptions, thr gratmd water frbnr wells in''ot thetrt AArashin ton Countv is weft below levels of coneem. PFD >. irnpaeted wells in this area, before the puonp =oat welts were put i fao openallon. thismedits that the low concentrations of P'FCs that have- alreadymdveddoixrigradient fioni.the. Site should remain stable or ditrdmsh over tinge, iiacause MIPCA staff doesn "[believe thatPltC contamination is still moving away from the Site, there is much less probability that P1=Cs will>migraee downward from the Jordan aquifir and cause, greater impacts to deeper aquifers such as'tne Franconia fortnwloti. ground water moniloving and hydraulic testing ai . ice tFat the barrier welt system is containing the the M1PC A stafftielievms that will be impacted by PFCs front the Site. `Elie Woodbury, resident also questioned whether the pump -out water could he directed , towards a more licneticitil. erxtsuir tptivL use. such asanethanolplant .Air "hilethe MOCA cannotrequire. to use €lie putip -out water for benefit^.ial purposes, the ,VIPGA cats relay this reccitnntendat un to 3 vl for further consideratiom The primary concern for the ..Wic FA is that contaminated ground water is appropriately . created prior to discharge to ensure that receiving +waters are adequatety protected. 4. Law Film] rA aiurth continent tatter was received fioma lake firm representing the plaintiffs in civil action, against; 3'aT': `17he'comnienicc stated that 37%4 shauEd remain financially responsible for the hill cost of the cleinup as the Site, Under the 2007 CO, 3it/1 is Financially responsible 6or the entire oast of the cleanup, not only for 3T4'l's throe( cow ofthe cleanup, but for all Costs assucii} ed vOth oget'ation and `maintenance to ensure the selected remedy r'eiriams protected ;and for all.. M1PC'A costs to provide oxersi5ht nf-3iM actions. Ma cornmenter als f stated that 3$e citizens of Minnesota should receive the best etaanup plan regardless of costL As noted previously based an feasibility stndfes done at Minnesota Superfiind Sites the MPCA evaluates the alCcrna6ves, determines the effectiveness and implemctttability of each, reviews the cost effeofiveness and above all, determines if the proposed remedy is protective ofpublic health and the otiviionment, ln-this case ;1hd MPCA has determined that the selected remedy for cleanup of releases of PFCs at the 3Mt Woodbury Disposal Site is the best overall remedy. The commemer also stated that the excavated material be disposed a (more secure - location than proposed. As noted previously, the Sl .t3 permit recently' issued by the M1PCA allows the ctntstrueti rn of separate cell to contain PF'C contaminated wastes excavated froth the 3Ml Disposal Sites, This permit specified requirements for designs, construction anti monitoring of this separate cell. As also noted previously, this facility maces the terons of the 2007 Ct7 far disposal of PF'C contaminated wastes in art engineered isolation and containment facility. In addition, the law fitm noted in its August 22, 2008 comment letter regarding the proposed ei eanup plan for the Site. when MPCA .staff recommended issuance of Requests for Responsc .Actions (RFRAs) to 3M in April "- M MPCA staff took t €ae,aositi6o that WCA has jurisdiction to issue the RPR.Asurhderthe Njinnesota Environmental Responses and Liability Act (MERLA), because the release of PF OA and PFOS to the envirotunene at the 31%T dispit'sat siscs were releases of h3rrdoussubstttneesr as defined in MERLA.. The MPE'R Board deferred i ssuanec of the RFR+tis and NOCA eontinui d to assert its ;V4ERLk jurlsdiction in the 1007 CO (although 3M continued to ciislaure such,juris3iotfony. itshoulei be noted. however. that a detennination thatreleases of these two compounds constitute releases ofhaiafdous substances underTvITAL.,A-, is riot The sane as determining that remediati sn wastes containinglFC;s which are generated by'cleanup otthose releases lvould be considered hazardous wastes udder 4IPC'A rulcs. nIPCA has ant made any decision its classify PFQA or PFOS, w astcs as hazardous wastes tinder MPCj't's hazai'dtxus waste i��le; A copy of the Final NIDD will be. sent toINK the .Iyti)lL, Ilie-eities -of Woodbury and Cottage Ct ovc, the US: El'Aand thosesubm ttcng vvrit'terI caamnents regarding _the proposedremedy wIPCA°s gelected° Remedi tl Action& for the Site The, MPCA has selected a eumbination of tiler following altematives ouflired in the January ?C7! 9 Pq as the remedy fdr l''FC. releases -at and from the Site: Aliemative S+'` -2: Institutional Controls, Access Resiricfion. and Ground Wrrtrr Monitoring. Aldcrata tivt; C'~`� -lt C'o€:tSnuer? >;n'ound,ivator rccover; tyiih addition r. +fcurtn7rt flltrtition prior to cli�nEiatcce: This alternative ' ouM continue to operata the ground evatcx cxtracdton syst €;m to Capwrc"and prevent off- site: nvg7atiUn of3'PCs in rtiafer.'lhe granuGar activated carbon filtration tor discharge water would be adds 4 before disebarge to the Mississippi River: Via point of the Filtration either at the Sito'or at the Cottage Grace Facility would still recd to be deeitleds Refined Soil ..Alternative S -3i Excavation of the former Nortbeast Disposal Area trenches and selected areas in the Main Disposal e; disposal at existing off site landfill: for engineered isolatiowarid containment, with selective excavation of soils to a depth of 'I Sc feet or bedrock in the Northeast ekreaanti. in the Main Dlsposai Area Wit depth of 12 feet: Final cover would be placed'overall excavated areas.. The NOCA hasdetermined that the permitted SKl3 industrial waste diaposal tacifl*i iii Rosemount, wither seParate cell for the• PFC ,wastes, meets file tcrluirecnens of the 2007 CO foran isolatod, cngincccred containment fhoil4y for the excavated 'PFC waste material. The MPCA has further determined that the excavation and offwside disposal orprc contaminated math 1 from the Site is necessary, to protect pudic heakli andthe environment from pcite Yial risk asSF ciat d with the contuineed presenea of the PF' eoritamina "led nratenals. _JM $11011 stabniit t ay app or�at iCS tier ivfieun a vwtisie management pias5 for e management and disposal of P>i C- comarbinated mater.aFexcavated from the Site_ fir addition; under terms, of the 20177 CO;'L and'appmed by the NOCA. 3M has submitted plans to install a Soil Vapor. Extraction System As an Interim Response Action to reduce the concentrations of VOCs, in the areas of the Site to be excavated, Soils atul bidukrial Wiste not meeting the SolidWaste Management Plan for SX8 will be managed sepat•at'ety as requrimd by lave, the Response Action Man and the 2007 Consent Orden The MPCA has dctermined that this combination of alternatives best meets the response action objectives for the Site: and meets the terns and conditions of the 2047 CO between 3M and the .NAPCA. -10- STATUTORY DDT `R;+ttisiA IONS The selected responsc actions are consistent with theMintitsttta Environmental Response and Liability Act, Mina, St1at s5f I I5B.01 -20, end rove riot izlcoilslsteait avith the Federal Comprehensive Environmenvil Respont e_Compe:ns ition'And Lizibility Act, 42 USX. § 9601 er s r{„ amid the National Contingency Pldn, 40 CF R pt, 3W ]lie selectcd resparasd actions iire'protootNe of public- 14i°ablt iand ti olfare and 111c ei virannient, V (?�i Paul L;ger Bate Tempon.i v Cunimi ssgotier mihnawt Pollution Ctantrol'.Agoi y -11- 4?� y L Minnesota Pollution Control Agency PFCs Lateral Team c- pfc1 -01 • ■ M I a I � 0 I F T 7 R Wo, A 1i' c- pfc1 -01 • March 2009 erfluorinated chemicals (PFCs) were first found to have contaminated drinking water supplies in parts of the eastern Twin Cities in 2004. The MPCA and Minnesota Department of Health (MDH) identified contaminated wells and the MPCA provided clean drinking water. Most of the contamination was traced to four dumps or landfills. The known drinking -water problems are under control and cleanup plans for three of the four waste sites have been approved. The MPCA's focus on PFCs is shifting to investigating use of PFC- containing foams at firefighting training sites and PFCs in the ambient environment. This fact sheet is the second general update on current status of the MPCA's work on PFCs. Previous history of the agency's response to this complex problem is available on the MPCA's Web site at wv, MI. Background PFCs are a family of synthetic chemicals, initially developed by the 3M Company, that have been used for decades to make products that resist heat, oil, stains, grease, and water. 3M has phased out manufacture of some PFCs, but there are currently other manufacturers of PFCs around the world. discovered PFCs in ground water at and near some of these sites. In 2004, MPCA began sampling monitoring wells at the disposal sites and nearby private wells, and the MDH sampled city wells in Washington County to identify drinking -water supplies with PFCs. Sampling soon expanded to a wider area of the east Metro. More than 1,600 private wells were sampled, along with more than 50 community wells. Both private and community wells were affected, including a number of private wells in Lake Elmo, Cottage Grove, Grey Cloud Island Township, and several of the city of Oakdale's wells. Based on PFC levels found in some wells, MDH advised 83 households not to drink their water due to PFCs. Coincident with these activities, staff in the MPCA's Superfund Program and Closed Landfill Programs conducted and ordered investigations for PFCs related to the four waste sites. The sites had all been previously investigated for other contaminants, so a great deal was known about their subsurface geology, ground water, and past disposal practices. Current status From the 1950s through the early 70s, 3M disposed of wastes from PFC manufacturing primarily in four places: dump sites in Oakdale and Woodbury, the 3M manufacturing facility in Cottage Grove, and the Washington County Landfill. In late 2003, the MPCA Waste disposal sites In May, 2007, the MPCA Citizens' Board approved a Settlement Agreement and Minnesota Pollution Control Agency < 520 Lafayette Rd. N., St. Paul, MN 55155 -4194 • www.pca.state.mn.us 651 - 296 -6300 • 800 - 657 -3864 • TTY 651 - 282 -5332 or 800 - 6573864 • Available in alternative formats Consent Order negotiated between MPCA staff and 3M. The CO is a legally binding document that lays out timetables, deliverables and other requirements, including funding, for investigating and cleaning up PFCs at the three 3M sites. Because the Washington County site is in the MPCA's Closed Landfill Program, 3M has no legal liability for the site but did agree under the CO to provide up to $8 million to help fund the state's cleanup of the site. MPCA staff and management provide quarterly progress reports to the Citizens' Board on implementation of the CO. As of February 2009, the MPCA Commissioner had approved cleanup plans for the Washington County Landfill and the 3M Oakdale, and 3M Woodbury sites. A proposed cleanup plan for the 3M Cottage Grove site will go out for public comment later this spring. Construction of the selected remedies at all four sites should start in spring/summer 2009. Cleanup plans for the three 3M sites share basic similarities of 1) institutional controls, 2) excavation of remaining source areas, 3) continued and/or enhanced ground -water extraction and treatment, and 4) long -term monitoring. Excavated wastes from these sites will be placed in a specially built long -term containment cell at the SKB Industrial Landfill in Rosemount, Minn. The Washington County Landfill will be re- excavated and the wastes placed into newly constructed, triple -lined cells on -site. Plans for all four sites have gone or will go through the MPCA's public participation process used in Superfund cleanups. Public participation is not required in the Closed Landfill Program but because all four sites are in similar situations, MPCA management chose to apply the Superfund public participation process to the Washington County site as well. All work performed at the 3M sites and MPCA expenses under the Superfund program are funded by 3M under the CO's cost recovery provisions. Information on cleanup of the four sites is on the MPCA Web site at www_pea. state. mn .us /cleanup /pfc /pfcsites.hhnl Drinking water All of the households or communities with PFCs above MDH health standards have been provided with bottled water, carbon filtration, or municipal water hookups. 3M provided the city of Oakdale with large carbon filtration units which filter water from two of the city's affected wells at the treatment plant. 3M also provided funding for the city of Lake Elmo to extend clean city water to over 200 homes in the area affected by the contamination. In March 2008 MDH published a Health Based Value (HBV) of 7 parts per billion for PFBA (one of the PFCs of concern). Previously, MDH had provided a temporary drinking -water guidance of 1 ppb for PFBA, and issued advisories for wells near the Washington County and Oakdale disposal sites. The new limit means about 50 wells that received advisories are now below the HB V. Advisories will remain in place until MDH rescinds them. The agencies are developing a joint monitoring plan for the future to ensure safe drinking water. The 2007 Legislature directed MDH to study the effectiveness of point -of -use treatment systems for individual households. A number of water - treatment systems were found to be effective at removing PFCs. Final results of the study are on the MDH Web site at www.healtli.state.mn.us/divs/eh/hazardous/topicL/pfcs/l* dex.html East Metro PFC Biomonitoring Study MDH's East Metro PFC Biomonitoring Study is measuring exposure to PFCs in adults living in selected areas of Washington County where the drinking water is contaminated with PFCs. Although public health actions to prevent or reduce people's exposure to PFCs are now in place, some PFCs stay in the body for years and can likely still be measured. A report on the result of the study will be released later in 2009. PFCs in the ambient environment Over the last 10 years or so, scientists have found trace levels of PFCs nearly everywhere in the environment; low levels are found in people and animals around the globe. In Minnesota, it has been apparent since 2006 that PFCs may be present at concentrations of potential concern in areas that are not related to the waste disposal sites. Using funding provided by 3M under the CO, the MPCA has made a number of important discoveries regarding PFCs in Minnesota's ambient environment. For example: • Fish from several lakes in the Twin Cities and portions of the Mississippi River have elevated concentrations of PFOS (one of the PFCs of concern) in fish tissue, which has prompted MDH to issue fish - consumption advisories. Investigating PFCs in Minnesota: Current Status • C- pfc1 -01 - March 2009 page 2 MinnesmPollutIon Cnr&dl Ageney _ • Trace levels of PFCs are found in some shallow ambient ground water statewide, although levels are well within HBVs. • The chemicals have been found in the effluent of a number of wastewater treatment plants sampled by the MPCA. • PFCs were detected at permitted landfills, as well as in ground water up- and down- gradient of some facilities (also at levels within health -based limits). • The MPCA is beginning an investigation into whether PFCs used in firefighting foam may have entered soil and ground water at firefighter training sites. The MPCA is conducting more than a dozen ambient research projects, summarized in a report titled "PFCs in the Ambient Environment: 2008 Progress Report" (available on the Web at httl2://www.l)ca.state.mn.us/publications/C-pfel-02.12 These investigations will continue in 2009. PFCs are still widely used around the world even though 3M ceased production of PFO,A and PFOS in 2002. Other American manufacturers have phased out or will phase out production of some PFCs as well. Manufacturers in other countries continue to produce PFOA and PFOS for use in products that are legally exported and used for beneficial purposes here and around the globe. Research by the MPCA and others suggests that past and present PFC manufacture or end - usage provides pathways for release into the environment that cannot be directly attributed to 3M, which developed the original PFC chemistry. What does it all mean? MPCA investigations have shown that while PFCs are relatively widespread in Minnesota, concentrations are typically not present at levels triggering health concerns, except at a few small locations. The areas where concentrations of the three PFCs of concern, alone or in combination, exceed MDH limits are being addressed by treating city water (Oakdale) or providing bottled water or treatment systems to individual households (Lake Elmo, Cottage Grove, and Grey Cloud Island Township). MDH also prohibits construction of new wells in some aquifers that are contaminated with PFCs in portions of Oakdale and Lake Elmo. Cleanups of the four PFC disposal sites begirming this year will ensure that any residual PFC contamination at the sites is removed or contained. Sampling results indicate the ground -water plumes for PFCs related to the waste sites are stable, i.e. the areas of contamination are not expanding and the concentrations are not increasing. The chemicals may have left the Oakdale, Woodbury and Lake Elmo waste sites years ago, before existing ground -water pump -out systems had been installed at those sites. Long -term sampling of city and private wells is planned to assure that if the ground- water contamination changes, actions will be taken to protect public health. While some uncertainties remain, public health risks appear to be low. (For more information on PFCs and health, see www.health.state.mn.us/divs/eh/hazardous/topics/Sfcshe alth.html It is important to remember that these chemicals are critical components of many products on which human health and safety depend, for example hydraulic fluids in aircraft and firefighting foams. Eliminating their use could in some cases create unacceptable risk tradeoffs. While Minnesota has been in the forefront of investigating PFCs, scientists in other states and nations have begun conducting their own research as well. As with other emerging contaminants, we will continue to work to gain a better understanding of the potential health and environmental effects of PFCs. For more information MPCA: Ralph Pribble, 651- 757 -2657 or ralph.nribble@pca.state.mn.us MDH: Tannie Eshenaur, 651- 201 -4783 or tannie.eshenaur ,,health.state.mn.us NINA Web: www.pcastate.mn.us /cleanup /pfc /index.html MDH Web: www.liealth.state.mn.us/divs/eh/hazardous/tol)icL/pfcs/in dex.htrd Investigating PFCs in Minnesota: Current Status - c- pfcl -01 , March 2009 page 3 Q& minpesgo F©iiu'lan I T Minnesota Pollution Control Agency Remediation Division, Superfund Program c-pfc3 -02 MEN Cleanup /PFCs #Fpfc3 -02 • July 2008 T he Minnesota Pollution Control Agency is proposing a cleanup plan for the 3M Woodbury Disposal Site in Woodbury, Minn. The plan addresses contamination related to perfluorochemicals (PFCs) in wastes disposed of at the site by the 3M Company. This fact sheet describes the proposed plan and how the public can comment on it. Background The 3M Woodbury Disposal Site is located on the border of Cottage Grove and Woodbury, between Cottage Grove and Woodbury Drives and south of Dale Road. It comprises several former waste disposal areas that had received industrial wastes from the 3M Company from 1960 -66. In addition, municipal wastes from the cities of Woodbury and Cottage Grove were disposed of in two separate areas of the site from 1964 -66. The 656 -acre site (see map) is owned by 3M. cooling or process water and then discharged to the Mississippi River. Additional cleanup measures were taken at the site to consolidate and burn wastes, with the goal of reducing sources of VOC contamination to the ground water. About 200,000 cubic yards of wastes were excavated and burned on -site in 1968. In 1992 3M entered the site in the MPCA's Voluntary Investigation and Cleanup (VIC) program, under which various investigations and response actions were conducted to further address contamination at the site. In 1996 3M backfilled open areas and regraded the site, placed a soil cap over the former disposal areas, and filed an institutional control on the property deed. These activities were all aimed at further managing VOCs at and related to the site. PFCs at the 3M Woodbury disposal site 3M wastes were disposed of primarily in two areas, known as the Main and Northeast Disposal Areas. Municipal wastes were placed in the two other separate areas. Together these areas cover about 20 acres of the approximately 656 - acre site. Disposal methods included burial and open burning. Contaminants called Volatile Organic Compounds (VOCs, mostly solvents) were discovered in ground water at the site by 1966, after which 3M stopped further disposal and began a ground -water investigation. A ground -water extraction system was completed at the site by 1973 and has operated continuously since. The extracted ground water is pumped via pipeline to the 3M Cottage Grove manufacturing plant, where it is used as In 2005, PFCs were detected in pump -out wells at the Woodbury site. Prior to this time, the MPCA did not have analytical capabilities to sample and analyze for PFCs. PFCs are a family of synthetic compounds that have been used for decades to make products that resist heat, oil, stains, grease and water. 3M made PFCs from the late 1940s until 2002 at its Cottage Grove plant. PFC- containing wastes were legally disposed of in four dumps or landfills (including, besides the Woodbury site, the 3M Oakdale site, Washington County Landfill, and disposal areas at the 3M Cottage Grove facility). These wastes have contaminated ground water flowing beneath the disposal sites with PFCs, Minnesota Pollution Control Agency • 520 Lafayette Rd. N., St. Paul, MN 55155 -4194 • .pca.state.mn.us 651 - 296 -6300 • 800 - 657 -3864 TTY 651- 282 -5332 or 800 - 657 -3864 • Available in alternative formats which impacted several of the city of Oakdale's municipal wells. Some private wells in Cottage Grove and Grey Cloud Township also were found to have PFCs above advisory limits. Site investigations The MPCA and 3M signed a Settlement Agreement and Consent Order in May 2007 governing investigation and cleanup of PFCs at the four disposal sites used to dispose of PFC wastes. As part of the agreement, 3M completed or is completing Remedial Investigations (RI) and Feasibility Studies (FS) for the sites, the focus of which are to identify any remaining threats to public health or the environment from releases of PFCs at the sites. The Consent Order also required that in developing cleanup alternatives, primary consideration should go to those that excavate and destroy remaining PFC wastes; or As noted earlier, 3M had completed several investigations and response actions for the Woodbury site under the VIC Program; some were initiated by the company and some were requested by the MPCA. These took place previous to the signing of the Consent Order, with some of them relating to PFCs. For example, the site was regraded and capped with a two - foot cover, and a deed restriction was placed on the property to limit disturbance of the three disposal areas. Following the Consent Order, the site was transferred from the VIC program to the Superfund program. Investigations conducted under Superfimd included assessing the integrity of the pipeline conveying the pump -out discharge to 3M's Cottage Grove facility to determine if it could be a possible source for ground- water contamination further south of the Woodbury site. (The pipeline was found to be intact and not leaking.) Additional soil borings were conducted in the former 3M Woodbury site and disposal area locations e) is page 2 3M Woodbury site • c- pfc3 -02 - July 2008 Op M]"'WM edlu ion Control Agon6y nearby residences. In addition 27 homes in the Langdon and River Acres neighborhoods of Cottage Grove and Grey Cloud Township were provided with bottled water or in -home carbon filtration of their water. In regard to ground -water contamination at or related to the Woodbury site, the RI and previous investigations showed that the ground -water pump -out system at the site is preventing further off -site migration of PFCs as well as VOCs. There are PFCs in ground water downgradient and away from the site, but they are thought to have escaped or moved off -site before the pump -out system was in place and source- reduction activities were done. In regard to PFCs in soil on the site, the RI and previous investigations of the site showed that some residual PFCs remained in parts of all three of the former disposal areas (Northeast, Main, and Municipal Fill). Soil concentrations of PFCs vary widely, but were deemed sufficient in some cases to be acting as possible continuing sources of PFCs to the localized ground water at the site (although contaminated ground water is not migrating off -site because it is captured by the pump -out system). In all cases, the concentrations that are above the MPCA's soil reference values are well below the ground surface (5 to 16 feet) due to earlier removal actions, backfilling, and soil cap installation (i.e. there would be no pathway for human exposure to PFCs in soil). Feasibility study The objective of the FS is to evaluate various response- action alternatives which address PFCs in soil and ground water at the site, and to provide a recommendation for implementation. The MPCA has reviewed the alternatives developed by 3M and is now ready to present its proposed plan for the site. The FS for the Woodbury site was developed with guidance and screening criteria from by the U.S. Environmental Protection Agency which are used in the federal and Minnesota Superfumd programs. The FS evaluates, compares, and contrasts each alternative for: • short and long -term effectiveness • reduction of toxicity, mobility, or volume through treatment • implementability • cost effectiveness • overall protection of human health and the environment. 3M Woodbury site - c- pfc3 -02 • July 2005 The FS for the 3M Woodbury site is available on the MPCA's Web page at www.pea.state.mn.us/cleanup/pfc/pfcsites.htnl. Summary of alternatives Alternatives were developed in three categories: site - wide (SW), soils (S), and ground water (GW). The following alternatives were developed for the FS: Alternative SW -1 -- No Further Action (ground -water pump -out would continue and institutional controls are already in place). Standard baseline option evaluated at all Superfund sites. Estimated cost: $48,000. Alternative SW -2 — Institutional controls, access restriction, and ground -water monitoring. Would continue existing deed restrictions to prevent future development and/or soil disturbance activities, install fencing to restrict access, and develop prohibitions on new drinking -water wells. Ground -water monitoring would continue for the long term (30 years minimum). Estimated cost: $856,000. Alternative GW -1 — Continued ground -water recovery with carbon filtration prior to discharge. This alternative would continue to operate the ground -water extraction system to capture and prevent off -site migration of PFCs in ground water. A number of studies have concluded the existing system is an effective barrier to PFC migration. Currently four extraction wells pump continuously at a combined rate of 3,280 gallons per minute. The water is conveyed via underground pipeline to 3M's Cottage Grove facility and used as process water, then discharged to the Mississippi River. Currently only a portion of the water is treated, but under this alternative all the water would be treated with carbon filtration before discharge. The discharge would be subject to PFC effluent limits contained in an MPCA- issued permit. Estimated cost: $2,050,000. (GW -1 was the only ground -water alternative developed in the FS because the MPCA will require it as part of any other remedies selected for the site.) Alternative S -I —Excavation of the former Northeast Disposal Area trenches; disposal at existing off -site landfill. The three soil alternatives all are designed to remove PFCs in soils at the site and reduce migration of PFCs from soils to ground water; they differ mainly in volume of soil removed and from where, and in degree of source reduction to ground water. S -1 would remove soils from the surface to bedrock in the area of the former disposal trenches in the Northeast Disposal Area. The soils would be trucked to a licensed landfill o ft Mim"6ta polutla, ChnVcl dLw69 page 3 permitted to accept industrial wastes. Excavated areas would be replaced with clean fill. Estimated cost: $7,830,000. Alternative S -2 — Excavation of the former Northeast Disposal Area trenches; disposal at existing off -site landfill; augmentation of the soil cover on the former Main Disposal Area. Same as S -1 plus additional soil cover over selected parts of the Main Disposal Area. Would bring total cover over Northeast Area to two feet. Estimated cost: $8,190,000. Refined Soil Alternative S -3 -- Excavation of the former Northeast Disposal Area trenches and selected areas in the Main Disposal Area; disposal at existing off - site landfill. Same as S -1 and S -2 but with selective excavation of soils to a depth of 18 feet or bedrock in the Northeast Area and in the Main Disposal Area to a depth of 12 feet. Final cover would be placed over all excavated areas. Estimated cost: $12,695,000. 3M has submitted an amendment to the Feasibility Study which outlined proposed off -site disposal locations. 3M is recommending that excavated PFC - containing soils from the Woodbury site be taken to the SKB Landfill in Rosemount, Minnesota. 3M and SKB have proposed to build a separate engineered cell at the S: Table o f facility to contain the excavated material. r ms oisposai location would also be used for PFC wastes excavated from the Oakdale and Cottage Grove disposal sites. Other soils containing other constituents that may meet federal definitions of hazardous waste (e.g. PCBs, VOCs depending on concentration —PFCs alone are not classified as hazardous waste) would be segregated and transported to other disposal facilities licensed for hazardous wastes. MPCA's recommended alternatives The MPCA recommends implementing the following remedies at the Woodbury site: SW -2: Institutional controls, access restriction, and continued ground -water monitoring GW -1: Continued ground -water recovery with carbon pretreatment prior to discharge RSA S -3 (see footnote): Excavation of the former Northeast Disposal Area trenches and selected areas in the Main Disposal Area; disposal at existing off -site landfill. The MPCA has determined that the SKB facility in Rosemount, with the separate vault for the PFC wastes, does meet the requirement of the Consent Order for an isolated, engineered permitted facility to contain the PFC waste material. As noted above, soils found to contain hazardous wastes would be disposed of at other facilities. MPCA staff believes this combination best meets the cleanup goals for the site. GW -1 and SW -2 would be implemented regardless of other alternatives chosen. Alternative RSA S -3 will probably take two to three construction seasons to complete. alternatives fshad = MPCA Dreferred alternatives) I Alternative Description 1. SW -1 No further action 2. �S -2: WE <� .4,91 tionalconTo6ls-acce restriction -moni ort ng 3. G l Continued grou GliCpre reatmen pror o dirarge 4. S -1 Excavate NE Disposal Area to bedrock (approx. 18 feet), off -site disposal 5. S -2 Excavate NE Disposal Area, off -site disposal, cover Main Disposal Area 6. R S 3 xcavhon ofthe NE Dispos Are trenclies'and selec ed (see are sin .e a Matn Disposal Area,o site_ d�ts posa e footnote) What are the next steps? ' This alternative was submitted in an addendum to the Feasibility Study on July 14, 2008, and differs slightly from the original Alternative S -3 in the FSJie 3M Woodbury site • c- pfc3 -02 • July 2008 page 4 The MPCA will review any comments received and finalize the choice of remedial action(s), which will be documented in a Minnesota Decision Document (MDD). The MPCA's responses to comments received will be V lri minsm uPolluttun Ca TMI Agency'.. included in the Responsiveness Summary attached to the MDD. Unless significant modifications to the proposed remedies described in this fact sheet are needed, design and construction of the selected remedies should begin in late 2008 or early 2009. After the selection of the final remedy for the Site, 3M will prepare construction design documents for MPCA review and approval. These design documents will outline activities and have a more detailed schedule to complete the cleanup actions. Included in this plan will be such items as hours of operation, construction traffic flow, worker health, and safety, odor and noise controls. Public comment and meeting on proposed alternatives Public review and comment on the proposed cleanup plan for the Woodbury site is an important contribution to the remedy selection process. The public is invited to submit written comments on this proposed plan through August 22, 2008. Written comments may be sent to Gerald Stahnke, MPCA, 520 Lafayette Road, St. Paul, MN 55155 -4194 or email gerald .stahnkena The public is also encouraged to submit written comments in person at a public meeting on July 24, 2008 at the Woodbury City Hall. Where can I get more information? The full FS and addenda, along with other site - related information, are available on the MPCA Web site at http: / /www.pea.state.mn.us /cleanup /pfc /pfcsites.html, or by contacting Ralph Pribble at the MPCA, (651) 296- 7792 or ralph.pribble @pca.state.mn.us. 3M Woodbury site m c- pfc3 -02 • July 2008 page 5 �a �1 k Mi nnesota Pollution Control Agenc Remediation Division, Superfund Program pfc3 -04 • May 2009 T he Minnesota Pollution Control Agency is proposing a cleanup plan for the 3M Cottage Grove Site in Cottage Grove, Minn. The plan addresses contamination related to perfluorochemicals (PFCs) in wastes disposed of at the site by the 3M Company This fact sheet describes the proposed plan and how the public can comment on it. Background The 3M Cottage Grove Site encompasses a large industrial complex located along U.S. Highway 61 in Cottage Grove, Minn. The property covers about 1,700 acres but only about 200 acres on the southern portion are industrialized. High bluffs above the Mississippi River are on the southwest side of the property. Formerly known as the 3M Chemolite plant, the facility has been in operation since 1947. 3M currently manufactures a range of products there, including adhesive products, specialty paper, industrial polymers, abrasives, and reflective road -sign materials. The company also does proprietary research and development there. As was common in manufacturing before the advent of environmental regulations, 3M disposed of various industrial wastes, including those from PFC manufacture, on the property as well as at three other disposal sites in Washington County. Disposal methods on the Cottage Grove property included burial and disposal pits. The site was placed on the Superfund list in 1984 due to soil and groundwater contamination from volatile organic compounds (VOCs), typically solvents. 3M completed site investigations and cleanup actions to address VOCs at the Cottage Grove site in both soil and groundwater. A groundwater pump -out system was installed to prevent VOCs in groundwater at the site from reaching the Mississippi River. The pump -out system is still in operation today. PFCs at the 3M Cottage Grove site PFCs are a family of synthetic chemicals that were initially developed in the 1950s and manufactured by 3M at the Cottage Grove facility. PFCs are used in a wide variety of products made around the world because of their unique abilities to resist heat, oil, stains, grease, and water. 3M phased out manufacture of some PFCs by 2002, most notably perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). As a result of the discoveries starting in 2004 that drinking water in parts of Washington County had become contaminated with PFCs, the MPCA directed 3M to look for PFC contamination remaining in soil or groundwater from past disposal practices on the Cottage Grove property. Investigation began in 2005 and continued into 2009 under MPCA oversight. Site investigations The MPCA and 3M signed a Settlement Agreement and Consent Order in May 2007 governing investigation and cleanup of the three 3M PFC disposal sites (i.e., Oakdale, Cottage Grove, and Woodbury). As part of the agreement, 3M completed a Remedial Investigation (RI) and Feasibility Study (FS) for the Cottage Grove site, the focus of which were to identify any remaining risks to public health or the environment from releases of PFCs at Minnesota Polluflon Control Agency • 520 Lafayette Rd. N., St. Paul, MN 55155 -4194 • www.pca.state.mn.us 651 -296 -6300 • 800 - 657 -3864 TTY 651 - 282 -5332 or 800 - 657 -3864 • Available in alternative formats the site. The Consent Order also required that in developing cleanup alternatives, primary consideration should go to those that excavate and destroy remaining PFC wastes, or that excavate and dispose of PFC wastes in a permitted, isolated, engineered containment facility. The RI for the Cottage Grove site showed that previous cleanup actions for VOCs had not removed all residual PFCs on the property. A number of areas were found to contain elevated levels of PFCs in soil and in groundwater beneath the property. These areas had been used in the past for a range of purposes including storage, disposal, or treatment of various types of solid or liquid wastes. Groundwater under the property flows toward the Mississippi River. PFCs are also found in treated wastewater discharged from the site to the Mississippi River, and in sediments in a cove at the foot of the bluff and near shore. Feasibility study The objective of the FS is to evaluate various response- action alternatives which address PFCs in soil and groundwater at the site, and to provide recommendations for implementation. The MPCA has reviewed the alternatives and is now ready to present its proposed plan for the site. The FS for the Cottage Grove site was developed with guidance and screening criteria of the U.S. Environmental Protection Agency which are used in the federal and Minnesota Superfund programs. The FS evaluates, compares, and contrasts each alternative for: • short and long -term effectiveness • reduction of toxicity, mobility, or volume through treatment • implementability • cost effectiveness • overall protection of human health and the environment. The FS for the 3M Cottage Grove site is available on the I rPCA's Web page at www.Rca. state.mn.uLpublications/pfc-cottapegrove- feasibilitystudypdf Summary of Alternatives Alternatives were developed in three categories: site - wide (SW), groundwater (GW), and soils and sediments (S /S). The following alternatives were developed for the FS: Alternative SW -1 -- No Further Action. Standard baseline option evaluated at all Superfund sites. No additional work to address soil and sediment contamination. No changes in current groundwater monitoring. Estimated cost: $148,000. Alternative SW -2 — Institutional controls, access restriction, and groundwater monitoring. Would include deed restrictions to ensure the area remains zoned industrial/commercial. The site is already fenced securely and new drinking -water wells near the property are prohibited. Existing groundwater monitoring would continue. Estimated cost: $653,000. Alternative GW -1 --Enhanced groundwater recovery with treatment prior to discharge. Would expand and improve the existing groundwater extraction system to prevent off -site migration of groundwater beneath the Eastern Disposal Area and the East Cove, as well as the main plant area. Discharge from the system would be treated in the facility's existing wastewater treatment plant, which has a large Granulated Activated Carbon finishing system that removes PFCs. Discharge to the river would be required to meet MPCA- imposed limits for PFCs. Estimated cost: $5.1 million. (GW -1 was the only groundwater alternative developed in the FS because this type of system has proven effective at destroying PFCs when carbon filters are thermally regenerated.) Alternative S /5 -1 — Treated wastewater from the facility is currently discharged via a flow channel to the Mississippi River at the East Cove. This alternative would: Stabilize the flow channel to prevent scouring; remove PFC - containing sediments in portions of the cove and remove portions of sandbar at cove outlet; dewater excavated sediments and transport them to long- term containment cell at the SKB Industrial Landfill in Rosemount; cover (cap with clayey soils) Disposal Areas Dl, D2, and D9. Estimated cost: $9.4 million. Alternative S/S 2 — Includes all elements of S /S -I plus removal of PFC - containing soils above Industrial Soil Reference Values (SRVs) for PFOA and/or PFOS in selected portions of Disposal Areas Dl, D2 and D9. Excavated land areas would be backfilled with clean soil. Estimated cost: $14.7 million. Alternative S /S -3 (refined) — Same as S /S -2 plus removal of concrete basin previously used for disposal in Area D 1 and overlying soils. Under this refined alternative, 3M conducted MPCA- required supplemental investigations, and identified additional soils in Disposal Areas Dl, D2, and D9 that will be removed. In addition, 3M Cottage Grove site , pfc3 -04 • May 2009 Minnesota Pollution Control Agency page 2 PFC contaminated sediments from throughout the East Cove will be removed, not just portions. Estimated cost: $15 million. Long -term containment of excavated PFC- containing material. Any soil, sediment, or other material excavated during cleanup that contains PFCs above the Industrial SRVs will be removed and placed in a permitted, engineered, long -term containment facility that is being built for these 3M materials at the SKB Industrial Landfill in Rosemount, Minnesota. This disposal facility will also be used for materials excavated and removed from the 3M Woodbury and 3M Oakdale disposal sites. All leachate from these PFC - containing materials will be collected and taken to the 3M Cottage Grove facility for treatment. MPCA's recommended alternatives The MPCA recommends implementing the following remedies at the Cottage Grove site (see summary table). SW -2: Institutional controls, access restriction, and groundwater monitoring. GW -1: Enhanced groundwater recovery with treatment prior to discharge. S /S -3 (refined): Stabilize flow channel to East Cove and remove PFC - containing sediments throughout the cove; remove portions of sandbar at cove outlet; remove concrete basin previously used for disposal in Area Dl and overlying soils; Remove PFC- containing soils in Disposal Areas DI, D2, and D9 that exceed Industrial SRVs for PFOA and /or PFOS; transport excavated materials to newly constructed containment facility at the SKB Industrial Landfill in Rosemount; backfill excavated Disposal Areas with clean soil and shape to reduce infiltration; collect leachate at SKB containment facility and take to 3M Cottage Grove facility for treatment. MPCA staff believes this combination best meets the cleanup goals for the site. The selected remedies will take an estimated three years to complete. What are the next steps? This proposed cleanup plan is available for public comment (see below) from May 20 through June 19, 2009. After the comment period closes, MPCA will review any comments received and finalize the choice of remedial action(s), which will be documented in a Minnesota Decision Document (MDD). The MPCA's responses to comments received will be included in the Responsiveness Summary attached to the MDD. Unless significant modifications to the proposed remedies described in this fact sheet are needed, design and construction of the selected remedies should begin in fall 2009. Table of alternatives (shaded = MPCA preferred alternatives) Alternative Description SW -1 No further action , MEN �;W 2 �ns�n h�u �. on o ntr ols '�access�Testrrctto�md`itormg G-lihhanced groundwater recd ,ery�andr�eatm S /S -1 Remove sediments in portions of East Cove; remove portions of sandbar at cove outlet; dispose of excavated soils /sediments off -site; cover Eastern Disposal Area S /S -2 Same as S /S -1 plus remove soils which have concentrations of PFOA or PFOS above Industrial Soil Reference Values (SRVs) from portions of Disposal Areas Dl, D2 and D9 07 ii`$d ame as 5 5 2p1gs remove concr e basm an d al gover ymg soils 0 rea B and remove PFC contaminated sediments from throughout the East Cove. Additional soil and sediment will be removed from D 1, D2 and D9, and the East Cove as a result of MPCA- required supplemental investigations. All excavated PFC contaminated soil/sediments will be disposed off site at the SKB Industrial Landfill in Rosemount, Minnesota. 3M Cottage Grove site • pfc3 -04 - May 2009 After the selection of the final remedy for the Site, 3M will prepare construction design documents for MPCA review and approval. These documents will outline activities and provide a more detailed schedule for completing the cleanup actions. Included in this plan will be such items as hours of operation, construction traffic flow, worker health, and safety, odor and noise controls. Public comment and meeting on proposed alternatives Public review and comment on the proposed cleanup plan for the 3M Cottage Grove site is an important contribution to page 3 the remedy selection process. The public is invited to submit written comments on this proposed plan through June 19, 2009. Written comments may be sent to Gary Krueger, MPCA, Remediation Division, 520 Lafayette Road, St. Paul, MN 55155 -4194 or email gary.krueger @pca.state.mn.us. Written comments may also be submitted at a public meeting on May 27, 2009 at the Cottage Grove City Hall. 3M Cottage Grove site ^ pfc3 -04 - May 2009 Where can 1 get more information? The full FS, along with addendums and other site - related information, is available on the MPCA Web site at http : / /www.pca.state.mn.us /cleanup /pfc /pfcsites.litnil, or by contacting Ralph Pribble at the MPCA, (651) 757- 2657 or ralph.pribble@pca.siqte.mn.us a ft tatsnnes'ta volikMan Cantmi Agency page 4 Aerial view of Cottage Grove site, showing disposal areas D1, D2 and D9, and East Cove 3M Environmental; Health and Safety Operations January 30, 2008 Hand Delivered PO Box 33331 St. Paul, MN 55133.3331 651 7786442 Ms. Kathryn J. Sather, Director Remediation Division Minnesota Pollution Control Agency 520 Lafayette Road St. Pan), MN 55 155-4194 Subject: Sctrternent Agreement and Consent Order (SACO), May 22, 2007 October 1 — December 31, 2007 Progress Report Dear Ms, Sather: In accordance with Part XIII.A of the subject Consent Order, 3M has prepared and enclosed a progress report summarizing key activities for the time period from October I through Deeember3l, 2007 and outlining actions anticipated for January - March 2008. If there are any questions ar comments concerning this matter, please contact me at the above address or call me at (651) 778 -5150. Sincerely, G-iiy lzHohcnsfeih-' Environmental Manager, Special Projects Building 42 -213-27 Enclosure Settlement Agreement and Consent Order 3M and MPCA, May 22, 2007 QUARTERLY PROGRESS RE PORT 93 October I — December 31, 2007 On May 22, 2007, 3M and the Minnesota Pollution Control Agency (MPCA) entered into a Settlement Agreement and Consent Order (Consent Order) for the investigation and assessment of fluorochemicals (PCs) at sites in Washington County and for the execution of certain other related matters. This report is provided to fulfill the requirement outlined in Part XIII.A of the Consent Order. REPORTING PERIOD: October t, 2007 to December 31, 2007 ACTIVITIES COMPLETED: Remedial Investigations (Part VI) and Pe asibiiiiy Studies (PartVIl) Given the interrelatedness of the remedial investigation (RJ) work and the feasibility studies (FS), these sections have been combined with the intent of providing a simpler, more straightforward update. Cottage Grove 3M had previously submitted (July 20, 2007) a feasibility Study Field Activities Work Plan for the site. Areas included in this plan included a geophysical survey, confirmatory soil borings, a groundwater recovery well evaluation, a biological inventory of the East Cove area and identification of possible Penn itslapprovals. The field work associated with the geophysical survey and the soil borings was completed during the July - September 2007 tmeframe. The entireties of all the activities outlined in the Work Plan were completed in the October- December 2007 period. 3M began preliminary discussions with representatives from Burlington Northern Santa Fe Railway, the Minnesota Department of Natural Resources and the U.S. Army Corps of Engineers concerning potential approvals that may be required for remedial activities in the vicinity of the Gast Cove at the site. All of these stakeholders have expressed willingness to work with 3M on [his project. Work continued towards completion of the FS Report, due for submittal by March 13, 2008 Settlement Agreement and Consent Order— 3M and MPCA Fourth Quarter 2007 Prorross Report Page 2 of 6 Oakdale 3M [lad previously submitted (July 20, 2007) a Feasibility Study Field Activities Work Plan for the site. Areas included in this plan included collection and analysis of a groundwater sample, a geophysical survey, confirmatory soil borings and a groundwater recovery well evaluation. The Field work associated with these activities was completed during the July- September 2007 timcfiame. The entireties of all the activities outlined in the Work Plan were completed in the October- December 2007 period. lnstalladon of a temporary fence on the north side of Highway to secure the site was completed the week of December 3, 2007. 3M had previously conferred with city officials concerning this matter and completed a Feld survey in anticipation of construction. Personal letters were also sent to approximately sixty nearby residences to inform them about the fence and the upcoming public meeting. A public meeting was held on December S, 2007 at Skyview Middle School, 1100 Heron Avenue, in Oakdale for the purpose of informing interested individuals about results from the Remedial Investigation and seeking their input concerning alternatives under consideration for the feasibility Study. The format for the meeting included a one -hour, informal poster session followed by a one -hour general session that included presentations and a time for questions and answers. Approximately 80 people attended and a constrictive dialogue took place concerning options being evaluated and issues of interest to the public. Woodbury The field assessment of the former Main Disposal Area and Municipal Disposal areas was completed during the week of October 1, 2007. The work was performed as defined in the Addendum to the FC Assessment Work Plan and included modifications as detailed in the MPCA letter dated September 4, 2007. A Minnesota licensed surveyor located and staked the borings as presented in the Addendum to the FC Assessment Work Plan on October 1, 2007. A Geoprobe rig was used to complete 18 borings in these areas. Soil samples were collected from the backfill material present in the trenches and from native soils beneath the trenches. The samples were collected by WCSTON and delivered to the 3M Gnvirounental Laboratory for analysis of five FCs (PFOA, PFOS, PFHS, PFBA and PFBS). The report titled "Hydraulic Evaluation of the Barrier Well Recovery System, Former 3M Woodbury Disposal Site, Woodbury, MN" was submitted by 3M to the MPCA on October 3, 2007. 3M and WI:,STON met with the MPCA to provide an update on site activities on October 9, 2007. The third round of groundwater sampling was performed during the week of October 29, 2007. The work was perforttred as per the February 2007 Groundwater Monitoring Plan. A contractor Settlement Agreement and Consent Order— 3M and MPCA Fourth Quarter 2007 Progress Report Page 3 of 6 for the MPCA was on site on October 31, 2007 and collected split samples from the following sentinel wells: SOIJS, SOIPC, S02JS, S02PC, S03JS, S03PC, S061S and S06PC. 3M and WESTON met with the MPCA on December 4, 2007 to review the Main Disposal Area soil sample data and to receive preliminary comments on the report titled, Hydraulic Evaluation of the Barrier Well Recovery System. Based on comments received, work began to prepare an addendum to the hydraulic evaluation report and a work plan for performing additional sampling in the Main Disposal Area. Presentation materials were prepared and logistical arrangements made in anticipation of the January 10, 2008 public meeting concerning the Woodbury Disposal Site RUTS. All Sites 3M has begun a process to locate appropriately permitted landfills as candidate disposal locations for excavated soils generated at any or al I of the three sites. Information- Sharing Process (Part XIII.B) A regular schedule of meetings (generally every 2 -3 weeks) has been employed to enable 3M and MPCA personnel to discuss specific items relative to this information- sharing requirement under the Consent Order. A standard format to summarize and periodically update (he various information requests has been used to guide the discussions. The most recent version of this summary is attached. The following items were completed and submitted to the MPCA during the October - December 2007 timeframe: • Health and environmental studies for PFCs beyond those already provided on the eight CD set of information and the C4 submittal. • Compilation of documents addressing actions considered by 3M in managing wastes containing PFCs (Part XIILB.2). • Compilation of documents addressing any characteristics of PFC relative to MCRLA or MN hazardous waste rules (Part XIII.B.3). • Response to MPCA inquiry concerning information on emissions of PFCs from 3M facilities in Minnesota. Beyond (lie regular meetings and the submittals noted above, the following specitie information - sharing event also occurred: Settl'ementAgreemcnt and Consent Order -3M and MPCA Fourth Quarter 2007 Progress Report Page 4 of 6 On October 18, 2007, a meeting was held with MPCA staff in which 3M presented information concerning the development of PFC analytical techniques and current issues relative to generating valid data. On December 20, 2007, a seminar was held with MPCA staff in which Dr. Jennifer Field from Oregon State University presented information on the characterization of 1 at landfills, publicly owned treatment works and fire training areas. She also shared research Findings in the area of fate and transport of PFCs in the environment. Health and Toxicological Studies (Part X1fJ.C) 3M has continued to cooperate with the Minnesota Department of Health (MDH) in developing and implementing health and toxicological studies needed to develop drinking water criteria for FCs. The process established in May -June of 2007 to share specific updates on various studies as they are underway has continued to be Followed with 3M ptoviding monthly written summaries to the MDl-1. For informational purposes, copies of these updates are now also being provided to MPCA management. In addition to the written correspondence noted above, meetings and/or phone calls involving 3M and MDH personnel have also occurred to discuss the most significant developments in a timely and thorough manner. Settlement Agreement and Consent Order— 3M and MPCA Fourth Quarter 2007 Progress Report Pape 5 of 6 ACTIVITIES UNDERWAY & /OR PLANNED FOR JANUARY - MARCH 2008: Remedial Investigations (Part VI) and Feasibility Studies (Part VII} Given the interrelatedness of the remedial investigation (RI) work and the feasibility studies (FS), these sections have been combined with the intent of providing a simpler, more straightforward update. Cottage Grove Work is underway relative to completion of the FS Report, due for submittal by March 13, 2008. As part of the process of developing this report, 3M will be facilitating a public meeting to review the results from the Remedial Investigation and to outline and seek public input on remedial action options under consideration in the Feasibility Study. This meeting is scheduled for January 31, 2008 at Cottage Grove Junior High School, 9775 Indian Blvd. in Cottage Grove. A one -hour, informal poster session followed by a one -hour general session to include presentations and a time for questions and answers has been planned. Oakdale The FS Report was submitted to the MPCA on January 28, 2008, as outlined by the Consent Order. 3M will continue preliminary planning activities to be in a position to implement a remedy following MPCA final selection. Woodbury A public meeting was held on January 10, 2008 at Middleton Elementary School for the purpose of informing interested individuals about results from the Remedial Investigation and seeking their input concerning alternatives under consideration for the Feasibility Study. Approximately 200 people attended and a constructive dialogue took place concerning options being evaluated and issues of interest to the public. On January 17, 2008, 3M submitted an addendum to the Hydraulic Evaluation oj'ihe Barrier Well Recovery System report and a work plan for conducting additional sampling in the Main Disposal Area at the site. Following MPCA approval, additional soil samples from the Main Disposal Area will be collected and analyzed to further characterize this area. It is anticipated that this work will be completed by March 2008. it is anticipated that analytical results for the third round of groundwater samples collected in October 2007 will be finalized by March 2008. In addition, collection of the fourth round of samples is being scheduled for the same time period. Work will continue towards completion and submission of the Rl/FS Report to the MPCA by February 17, 2008, as specified in file Consent Order. Beyond this date, 3M will continue Settlement agreement and Consent Order -3M and MPCA Fourth Quarter 2007 Progress Report Page 6 of 6 preliminary planning activities to be in a position to implement a remedy following MPCA final selection. All Sites 3M will continue to work towards a feria) selection and necessary arrangements with an appropriately permitted landfill for the disposal of excavated soils generated at any or all of the three sites. Information Sharing Process (Part XJILB) With regard to the specific items identified in Part XIII.B, 3M understands that with the October- December 2007 submissions of information (described above), all obligations under Part XIILB have been met. Based on discussions with MPCA staff, 3M and agency personnel plan to continue to meet on it regular basis to review new developments and information that could be helpful in understanding PFC issues in Minnesota. 'This may include additional meetings or seminars where subject matter experts are brought in to share knowledge on particular topics of interest. Health and Toxicological Studies (Part XIILQ 3M will continue to share health and toxicological information on perfluorochemicals with MDH as it becomes available. Monthly summary reports as Previously described will continue to be provided. Relative to the 90 -day feeding study for PFBA, the final report was recently completed and an electronic version of the full study report was sent to the Minnesota Department of Health on January 11, 2008. Status of Requested hht'ormation Pursuant to Paragraph XlTT.B of May 212007 Consent Order Between MPCA and .3,M Rem or Information (requested Date Status of [request Requested Heal or Environmental Eff ects Studies, in CPA's AR -226 Docket 5/22/2007 Completed 6/22/2007 — contains studies on PFOA, PFOS and its salts, PFFIS, PFDS, AFFP (fire- Fighting foam), POSF and several POST derivatives (including alcohols, amides, acetates and acrylates) Copies of Customer Studies 8/21/2007 Completed 09 /25/2007 Identified in Bibliography Submitted Under CBI Claim Studies, on Other PFCs 5/22/2007 Completed 09/28/2007 for C4 PFCs; completed 11/3012007 for retnainin , PFCs Ongoing. Health Effects Studies 5/22/2007 Providing MPCA with copies of the monthly reports to MDH Ongoing Environ. Effects Studies 5/22/2007 Being addressed in status meetings _._. __. _ Precautions .. 1 See XIIJ.13(2) of Consent Order 5/22/2007 Completed 10 /31/2007 For C4 through C16 PFCs; completed 11/30/2007 for CI through C3 PFCs (see note below) Characteristics See X111,13(3) of Consent Order 5/22/2007 Completed 10/31!2007 for C4 through C16 PFCs; completed 11/30/2007 for CI through C3 PFCs (see: note below) Other Requests Communications "timeline — Offered in Completed 6129!2007 through 12/31/89 5/2007 negotiations Connrtuttications "l'imelinc — Offered in Completed 8/3012007 1/1/90 through 5116100 5/2007 negotiations MDH !request for Monthly 6/1/2007 First monthly update provided to MDH 6/22/2007; Updates (PFC research planned, in future updates are being provided to MDH on a progress, or conducted but not yet monthly basis with copies to MPCA published). Questions on Emissions of PFCs _ 7/12/2007 Completed 11/30/2007 from 3M Facilities in Minnesota Note; Documents relating to precautions and characteristics (X111.13(2) and XIII.B(3) of Consent Order) include waste manifests, waste stream profiles, material safety data sheets and product environmental data sheets. Due to the large volume of that material (approximately 30 boxes), 3M gave MPCA samples of those documents on October 31, 2007 and is holding on to the rest of those documents pending further instructions from the agency. Version Number: 4 Version Date: November 30, 2007 3Nt Environmental, health and Safety Operations October 29, 2007 Hand Delivered PO Box 33331 St, Paul, MN 55133 -3331 65 f 778 6442 Ms. Kathryn J. Sather, Director Remediation Division Minnesota Pollution Control Agency 520 Lafayette Road St. Paul MN 55155 -4194 Subject: Settlement Agreement and Consent Order (SACO), May 22, 2007 Third Quarter (July 1— September 30) 2007 Progress Report Dear Ms. Sather: In accordance with Part XM A of the subject Consent Order, 3M has prepared and enclosed a progress report summarizing key activities for the time period from July 1 through September 30, 2007 and outlining actions anticipated for October — December 2007. If there are any questions or comments concerning this matter, please contact me at the above address or call me at (651) 778 -5150. Sincerely, Gary A: Hohenstein Environmental Manager, Special Projects Building 42 -2E -27 Enclosure Settlement Agreement and Consent Order 3M and MPCA, May 22, 2007 QUARTERLY PROGRESS REPORT 42 July 1 — September 30, 2007 On May 22, 2007, 3M and the Minnesota Pollution Control Agency (MPCA) entered into a Settlement Agreement and Consent Order (Consent Order) for the investigation and assessment of fluorochemicals (FCs) at sites in Washington County and for the execution of certain other related matters. This report is provided to fulfill the requirement outlined in Part XIII.A of the Consent Order. REPORTING PERIOD: July 1, 2007 to September' 0, 2007 ACTIVITIES COMPLETED: Remedial Investigations (Part VI) and Feasibility Studies (Part VII) Given the interrelatedness of the remedial investigation (RI) work and the feasibility studies (FS) these sections have been combined with the intent of provided a simpler, more straightforward update. Cottage Grove On July 20, 2007, 3M submitted a Feasibility Study Field Activities Work Plan for the site. In summary, the plan identified significant activities to be completed in the following areas: • Geophysical survey • Confirmatory soil borings • Groundwater recovery well evaluation • Biological inventory of East Cove • Identification of possible permits/approvals Following MPCA authorisation, execution of the work plan commenced. Significant field work was completed including assessment of subsurface geology using geophysical measurements along four transects at the site and the installation of two soil borings. Third Quarter 2007 Progress Report Page 2 of 7 In a letter dated August 15, 2007, the MPCA approved the RI Report and FS Work Plan previously submitted by 3M. The approval was subject to 3M addressing several technical comments, raised by MPCA staff in the August 15 letter, in the final FS Report. Based on 3M's review of the technical continents provided by MPCA and the status of field activities underway pursuant to the MPCA - approved "FS Field Activities Work Plan ", it was concluded that the added work at the site would affect the overall FS work schedule. Accordingly, pursuant to Section HI.D of Exhibit A to the Consent Order, 3M provided both verbal and written (August 24) notification to the MPCA concerning this matter. In order to clarify the technical comments provided by MPCA staff and to advance the assessment of the site, a meeting of 3M, Weston and MPCA personnel was held on August 22, 2007. In a letter dated September 17, 2007, 3M documented the agreements reached in the August 22 meeting and submitted a request for an extension of one hundred and twenty (120) days to prepare the FS Report for the site. The MPCA subsequently approval this extension request in a letter dated October 3, 2007. Oakdale On July 20, 2007, 3M submitted a Feasibility Study Field Activities Work Plan for the site. In summary, the plan identified significant activities to be completed in the following areas: • Collection and analysis of groundwater sample • Geophysical survey • Confirmatory soil borings • Groundwater recovery well evaluation Following MPCA authorization, execution of the work plan commenced. Significant field work was completed including collection of the groundwater sarnple. assessment of subsurface geology using geophysical measurements along four transects at the site and the installation of two soil borings. In a letter dated July 31, 2007, the MPCA approved the RI Report and FS Work Plan previously submitted by 3M. The approval was subject to 3M addressing several technical comments, raised by MPCA staff in the July 3I letter, in the final FS Report. Based on 3M's review of the additional RI activities requested by MPCA, it was concluded that these added items would adversely affect the work schedule and require significant revisions to the approved. RI and FS Work Plan. Accordingly, pursuant to Section III.D of Exhibit A to the Consent Order, 3M provided both verbal and written (August 10, 2007 letter) notification to the MPCA concerning this matter. In order to clarify the technical comments provided by MPCA staff and to advance the assessment of the site, a meeting of 3M, Weston and MPCA personnel was held on August 22, 2007. In a letter dated August 31, 2007, 3M documented the agreements reached in the August 22 meeting and submitted a request for an extension of ninety (90) days to prepare the FS Third Quarter 2007 Progress Report Page 3 of 7 Report for the site. The MPCA granted this extension request in a letter dated September 24, 2007. In a letter dated August 10, 2007, 3M outlined a security plan for the site, as requested in the MPCA letter dated July 31, 2007. Woodbury In a letter dated July 1.3, 2007, the MPCA approved, with modifications, the "Fluorochemical Assessment Work Plan for the 3M Woodbury Site" that had been received by the agency in early Match. The work plan, subject to modifications, was determined to meet the requirements to conduct a remedial investigation of the site as outlined in the Consent Order. To address the modifications, on August 22, 2007, 3M submitted an "Addendum to the FC Assessment Work Plan". This work plan was approved by the MPCA in a letter dated September 4, 2007, On July 20, 2007, 3M submitted a Feasibility Study Work Plan to the MPCA for review and approval. This work plan was approved, with modifications, in a letter from the MPCA dated August 17, 2007. As requested by the MPCA and as outlined in 3M's "FC Assessment Work Plan for the 3M Woodbury Site ", an integrity evaluation was completed for the pipeline that conveys water from the Woodbury Disposal Site to the 3M Cottage Grove facility. The report summarizing this evaluation was submitted to the MPCA on July 17, 2007. Furthermore, in a letter dated July 27, 2007 3M provided additional information in response to questions raised earlier in the year by the MPCA concerning the Woodbury water conveyance line. Following MPCA staff review of this information, further technical comments/questions were outlined in an MPCA letter dated August 17, 2007. 3M responded to these items in a letter dated September 19, 2007. The report entitled "Hydraulic Evaluation of the Barrier Well Recovery System, Former 3M Woodbury Disposal Site, Woodbury, MN" was finalized in September 2007. Preliminary results from this work had been reviewed in an August 22, 2007 muting with MPCA staff (this report was also submitted to the agency on October 3, 2007). The following field work was completed at the site: • Second round of quarterly groundwater sampling.— weeks of August 6 and 13 °t • Collection of soil samples from the former Main Disposal Area at the site. Response Action Plan and Response Action Implementation (Part VIII.B) In a letter dated August 17, 2007, the MPCA informed 3M that six private residences in the Landgon area of Cottage Grove, MN had been issued drinking water advisories by the Minnesota Department of health (MDH) due to levels of perfluorooctanoic acid (PFOA) above the Health Third Quarter 2007 Progress Report Page 4 of 7 Based Value (HBV) established by the MDH. In the same letter, the MPCA requested 3M to submit a Work Plan to provide a long -tern alternative drinking water source for the six residences pursuant to Section VIII of the Consent Order. In a letter dated August 31, 2007, 3M supplied the requested Work Plan committing to reimburse the MPCA for installation, operation and maintenance costs associated with the installation and operation of granular activated carbon filters on the well water supply lines of the six residences. Information- Sharin Pa rocess (Part XIII.B) A regular schedule of meetings (generally every. 2 -3 weeks) has been established to enable 3M and MPCA personnel to discuss specific items relative to this information- sharing requirement under the Consent Order. A standard format to summarize and periodically update the various information requests has been used to guide the discussions. The most recent version of this summary is attached. The following items were completed and submitted to the MPCA during the third quarter: Bibliography of customer studies on PFCs (provided on August 6 as CBI). Once the actual studies were assembled and reviewed, they were also provided to the MPCA on September 25. Second installment of communications timeline regarding PFCs and the 3M Cottage Grove facility for the time period from 111!90 through 5116100. • Compilation of studies on the health or environmental effects of four- carbon (C4) PFCs. Beyond the regular meetings and the submittals noted above, the following specific information- sharing event also occurred: On September 20, 2007, a meeting was held with MPCA staff in which 3M presented background information leading up to its decision to phase out of perlluorooetartyl chemistries. As part of this dialogue, 3M also provided an overview of the U.S. EPA Significant New Use Rule (SNUB) that was established for perfluorooctane sulfonate (PFOS) shortly after 3M's phase-out announcement. 3M received MPCA's letter date July 12, 2007 containing a request for infornation on emissions of PFCs from 3M facilities in Minnesota. Several internal meetings have been conducted and numerous individuals are working to address this request. Given the scope of the information being sought and in order to provide a comprehensive response, 3M requested, and the MPCA subsequently granted, an extension for the submittal date on this request. Health and Toxicological Studies (Part XIII.C) 3M has continued to cooperate with the Minnesota Department of Health (MDH) in developing and implementing health and toxicological studies needed to develop drinking water criteria for 'Third Quarter 2007 Progress Report Page 5 of 7 FCs. The process established in the second quarter of this year to share specific updates on various studies as they are underway has continued to be followed with 3M providing monthly written sunnnaries to the MD14. For informational purposes, copies of these updates are now also being provided to MPCA management. In addition to the written correspondence noted above, meetings involving 3M and MD1-I personnel have also occurred to discuss the most significant developments in a timely and thorough manner. One such meeting took place during this reporting time period on August 1 5 ` (subsequent meetings also occurred on October 4` and 9 Recovery of Expenses — Environmental Studies (Part XXIII.D) In a letter dated July 25, 2007, the MPCA requested the initial payment in the amount of $2,000,000 towards 3M's environmental studies commitment. This payment was provided to the MPCA on August 21, 2007, Liability Insurance (Part XXIV) hx a letter dated July 11, 2007, 3M provided the MPCA with a current certificate of insurance showing that the required coverage outlined in the Consent Order would be met for work at the three Sites. Third Quarter 2007 Progress Report Page 6 of 7 ACTIVITIES UNDERWAY & /OR PLANNED FOR OCTOBER - DECEMBER 2007: Remedial Investigations (Part VI) and Feasibility Studies (Part VII) Given the interrelatedness of the remedial investigation (RI) work and the feasibility studies (FS), these sections have been combined with the intent of providing a simpler, more straightfonvard update, Cottage Grove Work will continue towards completion of the activities outlined in the MPCA- approved FS Field Activities Work Plan (of note, the field work component of the biological inventory was completed the week of October 2, 2007). This, in turn, will contribute towards the completion of the ITS Report, now due for submittal by March 13, 2008. As part of the process of developing the FS Report, 3M will be facilitating a public meeting to review the results from the Remedial Investigation and to outline and seek public input on remedial action options under consideration in the Feasibility Study. This meeting is tentatively scheduled for January 31, 2008 at Cottage Grove City Hall. Oakdale Work will continue towards completion of the activities outlined in the MPCA - approved FS Field Activities Work Plan. This, in turn, will contribute towards the completion of the FS Report, now due for submittal by January 28, 2008. As part of the process of developing the PS Report, 3M will be facilitating a public meeting to review the results from the Remedial Investigation and to inform and seek public input on remedial action options under consideration in the Feasibility Study. This meeting is scheduled for 6:00 -9:00 p.m. on December 5, 2007 at Skyview Middle School, 1.100 heron Avenue, in Oakdale. A one -hour, informal poster session followed by a one -hour general session to include presentations and a time for questions is being planned. One specific action, scheduled for completion is November 2007, is the installation of a temporary fence on the north side of Highway 5 to secure the site. 3M has already conferred with city officials concerning this matter and completed a field survey in anticipation of construction. Personal letters have also been sent to approximately sixty nearby residences to inform them about the fence and the upcoming public meeting. Woodbury Work will continue towards completion of the MPCA - approved FS Work Plan. As outlined in the Consent Order, the FS work is to be completed by December 19, 2007 and the FS Report is to be submitted to the MPCA by February 17, 2008. As pail of the process of developing the FS Report, 3M will be facilitating a public meeting to review the results from the Remedial Investigation and to inform and seek public input on remedial action options under consideration Third Quarter 2007 Progress Report Page 7 of 7 in the Feasibility Study. This meeting is tentatively scheduled for January 10, 2008 at King of Kings Church, 1583 Radio Drive, in Woodbury. Information Sharing Process (Part XIILB) As outlined by the process that has been approved by the MPCA, 3M and the agency will continue to meet on a regular basis to review status of 3M's document production and to discuss MPCA's information needs. The status of this production will be tracked using the summary forni that was developed as part of the information sharing process. In addition to the aforementioned regular meetings to address this item, 3M will be making its subject matter experts available for meetings with MPCA and MDI-I staff to provide background information about particular topics and to answer questions about those topics or any related documents. (One such meeting has already taken place; on October 18, 3M led a discussion on the "evolution" of fluoroehemical analytical techniques and the importance of Quality Assurance/Quality Control elements in generating analytical data. In addition, MPCA management has indicated that they will seek to develop within the agency a list of possible topics for future meetings.) In a letter dated July 13, 2007 to Mr. Michael Santoro, the MPCA requested information pertaining to emissions from 3M facilities in Minnesota. As previously noted, given the scope of this request and in order to provide a comprehensive response, 3M requested, and the MPCA subsequently granted, an extension for the submittal date on this request. 3M will be preparing a response to this inquiry with a revised anticipated submittal date of November 30. The following summarizes additional items that are in progress and should be completed and submitted to the MPCA in the fourth quarter: Health and environmental studies for PFCs beyond those already provided on the eight CD set of information and the CA submittal. Compilation of documents addressing actions considered by 3M in managing wastes containing PFCs (Part XIII_I3.2). • Compilation of documents addressing any characteristics of PFC relative to MFRI,A or MN hazardous waste rules (Part XIII.B.3). health and Toxicological Studies (Part XIII.C) 3M will continue to share health and toxicological information on perlluorochemicals with MDI I as it becomes available. Monthly sunmzary reports as previously described will continue to be provided. Relative to the 90 -day feeding study for PFBA, completion of the final report is expected by the end of the year. Copies of this work will be provided to MDH as soon as they are available. 33N1 Environmental, Health and Safety Operations July 27, 2007 Hand Delivered PO Box 33331 St. Paul, MN. 55133 -3331 651 778 6442 Ms. Kathryn J. Sather, Director Remediation Division Minnesota Pollution Control Agency 520 Lafayette Road St. Paul, MTI 55155 -4194 Subject: Settlement Agreement and Consent Order (SACO), May 22, 2007 May 22 June 30, 2007 Progress Report Dear Ms. Sather: In accordance with Part XULA of the subject Consent Order, 3M has prepared and enclosed a progress report summarizing Ivey activities for the time period from May 22 through June 30, 2007 and outlining actions anticipated for July — September 2007. If there are any questions or comments concerning this matter, please contact me at the above address or call me at (651) 778 -5150. Sincerely, , Gary .I-Iohenstein Environmental Manager, Special Projects Building 42 -2E -27 Enclosure Settlement Agreement and Consent Order 3M and MPCA, May 22, 2007 QUARTERLY PROGRESS REPORT #1 On May 22, 2007, 3M and the Minnesota Pollution Control Agency (MPCA) entered into a Settlement Agreement and Consent Order (Consent Order) for the investigation and assessment of fluorochemicals (FCs) at Sites in Washington County and for the execution of certain other related matters. This report is provided to fulfill the requirement outlined in Part XIILA of the Consent Order. REPORTING PERIOD: May 22, 2007 to June 30, 2007 ACTIVITIES COMPLETED: Technoloav Transfer Relative to Washinaton County Landfill (Part V.F On June 27, 2007, a meeting was conducted at MPCA offices for 3M to provide technical resources and to transfer technical knowledge that might be relevant to identifying possible remedial approaches for the closed Washington County Landfill. MPCA staff provided a summary of background information on the site and the current status of technology evaluations. 3M shared an overview of technologies being assessed for their potential to treat or destroy fluorochemicals (FCs) and highlighted key approaches that might be most relevant to groundwater remediation such as that being considered at the Washington County Landfill site. Remedial Investigations (Part VI, Exhibit A — Part I.A, Exhibit C — Part LA) The Remedial Investigation (RI) Report for the Oakdale Disposal Site was completed and submitted to the MPCA on June 15, 2007. The RI Report for the 3M Cottage Grove Site was completed and submitted to the MPCA on June 29, 2007. An overview of these two reports was presented to MPCA staff at a meeting on June 27, 2007. At this meeting, the status of the RI for the Woodbury Disposal Site was also reviewed and discussion occurred relative to the exact content of the RI/FS Work Plan obligation for this site, as outlined in the Consent Order. Feasibility Studies (Part VII, Exhibit A — Part 11I.13, Exhibit C — Part III.B, Exhibit E — Parts I.A & I11.13) The Feasibility Study (FS) Work Plan for the Oakdale Disposal Site was completed and submitted to the MPCA on June 15, 2007. The FS Work Plan for the 3M Cottage Grove Site was completed and submitted to the MPCA on June 29, 2007. An overview of these two work plans was presented to MPCA staff at a meeting on June 27, 2007. The FS Work Plan for the Woodbury Disposal Site was being developed during this reporting period. May 22 — June 30, 2007 Progress Report Page 2 of 4 Information Sharing Process art XIILB) A regular - schedule of meetings was established for 3M and MPCA personnel to discuss and begin development of the process outlined in Part XIILB of the Consent Order. In this reporting period, meetings were held at MPCA offices on June 8 and June 22. As an outcome of these meetings, on June 28, 3M provided a proposal for a process to ensure that MPCA has access to documents and information as provided in Part XIII.B. In addition, 3M has provided a set of eight CDs containing 3M's submissions to the EPA's AR -226 docket, a searchable index to the documents on those CDs and the first of two installments of a communications timeline regarding FCs and the 3M Cottage Grove facility. Beyond development of the basic information sharing process described above, the following specific information sharing events also occurred: On June 25, 2007, a meeting was held with Mr. Rich Sandberg and Mr. Todd Biewen of MPCA to continue dialogue relative to air emission, production, manufacturing and other related informational items that had begun prior to execution of the Consent Order. 3M provided a broad overview and perspectives relative to the history of FC manufacturing at the Cottage Grove facility and the general availability and quality of data in the areas under consideration.. In an e -mail dated June 27, 2007 to Mr. Dann White, MPCA, 3M provided results from the Static Range - finding Tests on PFBA that were performed using nine different environmental species. Health and Toxicological Studies(Part_ 3M has continued to cooperate with the Minnesota Department of Health (MDH) in developing and implementing health and toxicological studies needed to develop drinking water criteria for PCs. Specifically, Dr. Larry Zobel, 3M Staff Vice President and Medical Director, has sent letters dated June 22 and June 28, 2007 to Mr. John Line Stine addressing certain questions raised by MDI-I staff and providing updates on important issues, including scientific studies and analyses currently underway. As part of this dialogue, a process has been established to provide monthly written summaries to MDH. The first of these summaries was submitted as part of the June 22, 2007 correspondence. Project Managers (Part XV) On May 31, 2007, 3M provided written correspondence indicating the names of 3M Project Managers and Alternates for each of the three Sites addressed by the Consent Order. May 22 — June 30, 2007 Progress Report Page 3 of 4 Recovery of Exnenses — Reimbursement for Site Costs (Part XXIII.A On June 20, 2007, 3M provided a check to the MPCA in the amount of $598,692 as reimbursement of the MPCA's costs as provided in Part XXIILC of the Consent Order. Recovery of Expenses — Environmental Studies (Part XXIII.D) On June 28, 2007, a meeting was held at MPCA offices to share experiences and exchange thoughts concerning the conducting of environmental assessments for FCs, 3M provided an overview of the general approach that the company followed for executing such studies and highlighted key elements that the company has found to be essential for success. Significant past and present assessments were used to illustrate important lessons learned, MPCA provided an update of current and planned research efforts in various media and areas of the state. Retain Consultant — Exhibit C — Part II Exhibit E — Part II On June 13, 2007, 3M notified the MPCA that it would continue to retain Weston Solutions, Inc. as its consultant for both the Oakdale and Woodbury Disposal Site assessments. Weston also continues to be the consultant for the Cottage Grove site investigation. May 22 — June 30, 2007 Progress Report Page 4 of 4 ACTIVI'T'IES UNDERWAY &/OR PLANNED FOR JULY- SEPTEMBER 2007: Remedial Investigations (Part VI, Exhibit E — Part I.A) 3M will be completing the Remedial Investigation that has been approved for the Woodbury Disposal Site and will submit a report summarizing this assessment according to the Consent Order schedule. Feasibility Studies (Part, VII, Exhibit E —Parts LA & III.B) The due date for the FS Work Plan for the Woodbury Disposal Site was July 21, 2007. This document was submitted to the MPCA on July 20, 2007. Pending MPCA approvals of the various FS Work Plans that have been submitted, 3M will commence implementation of these plans. On July 20, 2007, 3M submitted two separate FS Field Activities Work Plans, one for the Oakdale Disposal Site and one for the 3M Cottage Grove Site. The activities described in these plans were recommendations from the RI Reports for each site and are intended to gather additional data to support the respective Feasibility Studies. Pending MPCA approvals of these work plans, 3M will commence with the field activities, Information Sharing Process (Part XIII.B) As outlined by the process that has been approved by the MPCA, 3M and the agency will continue to meet on a regular basis to review status of 3M's document production and to discuss MPCA's information needs. The status of this production will be tracked using the summary form that was developed as pat of the information sharing process. Furthermore, 3M will be making its subject matter experts available for meetings with MPCA and MDH staff to provide background information about particular topics and to answer questions about those topics or any related documents. In a letter dated July 13, 2007 to Mr. Michael Santoro, the MPCA requested information pertaining to emissions from 3M facilities in Minnesota. 3M will be preparing a response to this inquiry as requested in the letter. Health and Toxicological Studies (Part XIII.C) 3M will continue to share health and toxicological information with MDH, particularly findings from the 90 -day feeding study for PFBA, as it becomes available and in particular, specific findings from the 90 -day feeding study for PFBA. Monthly summary reports as previously described will continue to be provided. L Table of Contents PFCAcronym Glossary ......................................................... ..............................1 ExecutiveSummary ............................................................. ..............................2 Introduction ......................................................................... ..............................2 Investigation of PFCs in the Ambient Environment .......... ..............................5 AIR AND PRECIPITATION MONITORING ................................................................................................ ..............................5 AQUEOUS FILM - FORMING FOAM (AFFF) USE ..................................................................................... ..............................5 FISH TISSUE AND SURFACE WATER MONITORING .................................................................................. ..............................5 FOODWEB STUDIES ........................................................................................................................ ..............................5 GROUNDWATER MONITORING ......................................................................................................... ..............................5 LAKE CALHOUN PFOS SOURCE INVESTIGATION ................................................................................... ..............................5 LAND USE INFLUENCE OF PFOS CONCENTRATIONS IN FISH TISSUE .......................................................... ..............................5 LITERATUREREVIEWS ....................................................................................................................... ..............................6 MISSISSIPPIRIVER SAMPLING ............................................................................................................ ..............................6 SOIL MICROCOSM STUDIES WITH EPA LABS ........................................................................................ ..............................6 URBANWATERSHED STUDY .............................................................................................................. ..............................6 WASTEWATER TREATMENT PLANT PFC RELEASE ASSESSMENT ............................................................... ..............................6 WATER QUALITY CRITERIA DEVELOPMENT ........................................................................................... ..............................6 WILDLIFE /ECOLOGICAL RISK ASSESSMENT ..............................................................:........................... ..............................6 Sources, Fate and Transport of PFCs in the Ambient Environment ...............7 Distribution of PFCs in Minnesota's Environment ............ ..............................9 TWIN CITIES METRO AREA LAKES - FISH AND WATER ............................................................................ ..............................9 MISSISSIPPIRIVER SAMPLING ......................................................................................................... ............................... I1 GROUNDWATER.......................................................................................................................... ............................... 11 AIRMONITORING ......................................................................................................................... ............................... I 1 AFFFFIRE - FIGHTING FOAM ........................................................................................................... ............................... I I WASTEWATERTREATMENT PLANTS ................................................................................................. ............................... 12 PERMITTEDLANDFILLS .................................................................................................................. ............................... 12 SOILMICROCOSMS ....................................................................................................................... ............................... 12 PFCs in Humans and Wildlife: Exposure and Effects ........ .............................13 HUMAN EXPOSURE VIA DRINKING WATER .......................................................................................... ............................. 13 HUMAN EXPOSURE VIA FISH CONSUMPTION ..................................................................................... ............................... 14 HUMANHEALTH RISK ................................................................................................................... ............................... 14 HUMANHEALTH CRITERIA ............................................................................................................. ............................... 15 EcoTOxtaTYOFPFCs .................................................................................................................... .............................17 PFCS AS POTENTIAL ENDOCRINE DISRUPTORS .................................................................................. ............................... 17 Summaryand Outlook ....................................................... .............................17 References ........................................................................... .............................19 Appendix A: PFC Monitoring Data Collected by the MPCA Appendix B: Sources, Fate and Transport of PFCs in the Environment Appendix C: Summary of Available Toxicity Data PFC Acronym Glossary Groups PFCs — perfluorochemicals or perfluorinated compounds PASS — perfluoroalkyl surfactants PFCAs — perfluorocarboxylic acid PFSAs — polyfluotinated alkyl substances FTOH — fluorotelomer alcohols PFAAs — perfluoroalkyl acids Individual PFBA — perfluorobutanoic acid PFBS — perfluorobutane sulfonate PFPeA — perfluoropentanoic acid PFHxA — perfluorohexanoic acid PFHxS — perfluorohexane sulfonate PFHpA — perfluoroheptanoic acid PFOA — perfluorooctanoic acid PFOS — perfluorooctane sulfonate PFOSA — perfluorooctane sulfonamide PFNA — perfluorononanoic acid PFDA — perfluorodecanoic acid PFUnA — perfluoroundecanoic acid PFDoA — perfluorododecanoic acid N- EtFOSE — N -ethyl perfluorooctanesulfonamidoethanol N- McFOSE — N- methyl perfluorooctanesulfonamidoethanol Other Acronyms AFFF — aqueous fire fighting foam ECF — electrochemical fluorination W W= — wastewater treatment plant Executive Summary Perfluorochemicals (PFCs) are a group of fully- fluorinated carbon -based compounds that repel both oil and water and are very resistant to breakdown in the environment. These properties have led to their use in numerous industrial and consumer products. Specific PFCs of interest in Minnesota include PFOS (perfluorooctane sulfonate), PFOA (perfluorooctanoic acid) and PFBA (perfluorobutanoic acid). Manufacture of PFCs in Minnesota began in the late 1950s by 3M Corporation at its Cottage Grove Facility. 3M ceased production of PFOS and PFOA in 2002 after several studies showed that PFCs were bioaccumulating in humans and wildlife worldwide. In 2004, PFCs were detected in drinking water supplies in several eastern Twin Cities suburbs; sources of the contamination were traced to legal disposal of 3M manufacturing wastes. The Minnesota Pollution Control Agency (MPCA) and the Minnesota Department of Health (MDH) have since identified contaminated wells and provided clean drinking water to affected consumers. PFCs are released to the environment through manufacturing processes, industrial use, and the use of PFC- containing consumer products. PFCs, like PFOS and PFOA, are also formed from the breakdown of other fluorinated compounds such as fluorotelomer alcohols produced by DuPont. In order to identify potential sources of PFCs to the environment it is critical to understand the fate and transport processes governing these compounds. It is now known that PFCs are ubiquitous environmental contaminants. This is a concern because some PFCs (such as PFOS and PFOA) are persistent, bioaccumuladve and toxic. The worldwide presence of PFCs in humans and animals provides strong evidence that exposure to this group of chemicals is through general environmental exposure and is not limited to known point sources or areas of contamination. Although all routes of exposure have yet to be clearly defined, exposure likely occurs through a variety of pathways including drinking water, food and food packaging, and use of consumer products containing PFCs. In Minnesota, it has been apparent since 2006 that PFCs may be present at concentrations of potential concern in the ambient environment (i.e., away from 3M disposal sites). The MPCA negotiated a Consent Order with 3M in May 2007. The Consent Order provided funding for additional monitoring of PFCs around M nnesota and intense remediation efforts at the 3M manufacturing and waste disposal sites. Since then, the MPCA has made a number of important discoveries regarding PFCs in Minnesota's ambient environment. Some of the results to date presented in this report include the following findings. Several lakes in the Twin Cities and portions of the Mississippi River have elevated concentrations of PFOS in fish tissue, which has resulted in fish consumption advisories. Sampling indicates that, although present, PFC concentrations in shallow ambient ground water are well below health advisory concentrations. Most sampled waste water treatment plant influent, effluent, and sludge has detectable concentrations of PFCs. PFCs were detected in permitted landfills leachate, landfill gas, and landfill gas condensate, as well as in ground water upgradient and downgradient of the facility. More detail and additional results are presented in the report, including several extensive data sets in the appendices. Introduction Perfluorochemicals (PFCs) are a group of fully- fluorinated carbon -based compounds that repel both oil and water and are very resistant to breakdown in the environment. These properties have led to the use of PFCs in numerous industrial and consumer products. PFOS (perfluorooctane sulfonate), PFOA (perfluorooctanoic acid), and PFBA ( perfluorobutanoic acid) are examples of individual PFCs of concern in Minnesota. Common applications of PFCs include non -stick coatings for cookware, stain repellants, paper coatings, food packaging, fire- fighting foams, lubricants, wetting agents, corrosion inhibitors, cleaning products, cosmetics, and pesticide applications. Manufacture of PFCs in Minnesota began in At thlis Gimme, PFM PFOA and PF&A are the PFCs of ! the late 1950's by 3M Corporation at its greates iinterestt drn Minnesota due to their Cottage Grove Facility. After research found PersrsGemee, ttottreiW, and nor awifdesPread d'ettectfan' that PFOS could be measured in not just firm the enl4imtnmtentt andllota. wildlife but also humans from around the world, 3M began the process of phasing out of the manufacture of the 8-carbon PFCs (PFOS and PFOA) and PFOS - related products in 2000. The phase out of PFOS production in Minnesota was completed in 2002. Since that time, 3M has worked to develop new technologies based on shorter chain PFCs such as perfluorobutane sulfonate (PFBS). Although PFCs have been in commercial use for nearly 50 years they have only recently been detected in the global environment. It is now known that PFCs are ubiquitous environmental contaminants; they have been detected globally in lakes, rivers, oceans, sediment, soil, precipitation, air, biota, sewage sludge, and wastewater effluent. This is a concern because some PFCs are persistent, bioaccumulative and toxic. Several studies indicate that most wildlife and humans worldwide have at least some PFCs in their blood. While many sources of PFC exposure remain unknown, it is likely that exposure to PFCs occurs through consumption of contaminated food and water, and the use of numerous PFC - containing commercial products. In 2004, PFCs detected in drinking water supplies in several eastern Twin Cities suburbs were traced to legal disposal of 3M manufacturing wastes, which occurred in the 1950s and later at four different locations. The Minnesota Pollution Control Agency (MPCA) and the Minnesota Department of Health (VIDH) have since identified contaminated wells and provided clean drinking water to affected consumers. Most of the drinking -water problems have been characterized and brought under control. However, PFCs have been detected in all other environmental settings tested to date in Minnesota. `Please refer to the acronym glossary at the beginning of this document for a complete list of acronyms used. The May 2007 Consent Order with 3M paid for additional monitoring of PFCs around Minnesota as well as intense remediation efforts at the 3M manufacturing and waste disposal sites. From this work, the MPCA has learned that: • The use of PFCs in industrial, commercial and consumer product applications continues even though 3M ceased production of PFOA and PFOS in 2002. Manufacturers in other countries continue to produce PFOA and PFOS for use in products that are legally exported and used for beneficial purposes in the U.S. and around the globe. • Past and present PFC usage provides pathways for release into the environment that cannot be solely attributed to 3M, which developed the original PFC chemistry. The MPCA is therefore pursuing a broader approach to addressing PFCs effectively, both in the short and long term: Consent Orden with 3M thi 2Og7/ „tlhe MIPGk negpiiated al Consen1t0r,dos (vegallyi.trindi[,t91 a9TeemenU) witM,3tn+ll.on: the:' RfC cantarninaton in Mlonesotet The issues aftessedl`i rn the Consent Eder ane as fml lhws •, Rigmraus„rolSus ¢ elearrup,rrlan, •:.. RdcognitiornofMPq \jurisd6¢nfani • tA! Pnniai£ rallandi�riwatedrirrlhingwratee supplies I • Future act'ronsornPFRAI; • Additional[ studies on health and enviro �nentalleffects • Cooperationfrom3Mansharingi reseaceh and iutf mg; n • Preservation ofMPCWsrighttotake action in the future • Investigations — ongoing studies to understand the presence, extent, sources, movement and fate of PFCs in the environment • Remediation— vigorous and effective completion of cleanups at the 3M PFC waste disposal areas in Woodbury, Oakdale, Cottage Grove, and the Washington County Landfill • Regulation — monitoring at wastewater treatment plants (W WTPs) and operating solid waste facilities; establishment of water quality criteria (site - specific standards) to protect fish for human consumption; permit requirements for facilities discharging into impaired waters • Partnerships — with MDH, Minnesota Department of Natural Resources (MDNR), United States Environmental Protection Agency (EPA) and others to better characterize the risks of exposure to PFCs in the environment • Data Management — efficient tracking, storage, retrieval and usage of all data including environmental samples; remedial investigations • Communications — regular meetings with affected local officials and legislators; extensive web pages detailing agency actions and findings The MPCA's investigation of PFCs in the ambient environment, along with supporting information gleaned from the scientific literature, is presented in this interim report. Several studies are still in progress, and more studies will likely be proposed in the future. investigation of PFCs in the Ambient Environment A number of PFC projects have been completed or are underway. Brief descriptions of projects underway or completed by the MPCA and its partners are provided below, alphabetically. Air and Precipitation Monitoring Ambient air and precipitation samples are being collected to screen for PFC concentrations in urban and rural environments. Aqueous Film- Forming Foam (AFFF) Use Two AFFF projects are underway. One is a survey of PFC - containing AFFF users in Minnesota regarding their use of AFFF in fire fighting training. The other is a case study of PFC concentrations in sediment and shallow ground water at a site of known AFFF discharge during fire fighting training. Fish Tissue and Surface Water Monitoring Fish tissue and surface water samples are being collected in selected urban and rural lakes for two purposes. The first is to better understand the extent and magnitude of PFC contamination in commonly harvested fish species in lakes and rivers with high fishing pressure. Second, results will be used to evaluate bioaccumulation of PFCs in fish fillet tissue. Food Web Studies Two studies are underway at Lake Johanna to help develop better understanding about how PFCs move through the aquatic food web. Water, sediment, and aquatic organisms from Lake Johanna are being analyzed for PFC content as part of an aquatic food web study. Additionally, swallow eggs, chicks, and their food insects are being analyzed to determine differences in PFC concentrations in different locations and environmental media, identify which PFCs contribute to the differences, and to calculate accumulation rates. Ground Water Monitoring Samples of ground water were collected from wells in vulnerable, shallow aquifers in urban and agricultural areas. Sample results provided information about PFC impacts to ground water from potentially many different sources: industrial and municipal stormwater infiltration, land use, precipitation infiltration, surface water infiltration, pesticides, land application of biosolids, and /or atmospheric deposition. Lake Calhoun PFOS Source Investigation Elevated concentrations of PFOS in fish tissue from Lake Calhoun were a surprise. Storm water and rain water samples from the Lake Calhoun storm watershed will be collected to identify major sources of PFCs to Lake Calhoun, if major sources exist. This study is still in progress. Land Use Influence of PFOS Concentrations in Fish Tissue This project will utilize GIS, statistical analysis, and other information to analyze watershed characteristics and other factors that may influence PFOS concentrations in fish tissue. Literature Reviews On an ongoing basis, science indices, journals, reports, and regulatory news about PFC research results or policy development are searched. Review of the current literature keeps the MPCA and MDH up -to -date on research being conducted worldwide on PFC fate and transport, toxicology, risk assessment, and standard setting. Mississippi River Sampling The EPA is coordinating an effort to evaluate the range of concentrations of PFCs in water of the Mississippi River from the headwaters in Minnesota to the confluence with the Ohio River in Cairo, Illinois. In conjunction with the Water Quality Task Force members of the Upper Mississippi River Basin Association, approximately 200 surface water samples are being collected from key locations in the Mississippi River between Lake Itasca, Minnesota, and Cairo, Illinois. Soil Microcosm Studies with EPA Labs In cooperation with EPA, soil microcosms are being used to evaluate the potential for particular PFC compounds to break down in ground water and to measure the adsorption characteristics and mobility of PFCs in the ground water environment. Microcosms have been constructed using aquifer sediment spiked with PFC compounds. Periodic analysis of the microcosms will provide data on PFC fate and transport in ground water. Urban Watershed Study Stormwater inputs to PFC - impaired lakes will be sampled to develop better understanding about how PFCs move through an urban watershed to a lake. Wastewater Treatment Plant PFC Release Assessment Influent, effluent and sludge from W WTPs were sampled to assess the contribution of these facilities as potential sources of PFCs in Minnesota's environment. Facilities were selected to represent a variety of treatment technologies and influent sources (i.e. residential, commercial, industrial). Sources, environmental fate, and potential exposure pathways of PFCs detected at wastewater treatment facilities will be evaluated. Water Quality Criteria Development Water quality criteria were developed for PFOS and PFOA; PFBA is still in process. The process involves literature reviews of toxicity data, including 3M aquatic toxicity tests. Site - specific criteria are in place for PFOS and PFOA in Lake Calhoun and the Mississippi River. In Lake Calhoun, the chronic criteria (protective of both human health and aquatic life) are 12 ng /L for PFOS and 1.62 µg /L for PFOA. In the Mississippi River, the chronic criteria are 6 ng /L for PFOS and 2.7 gg /L for PFOA. Go to htm: / /-,vxvw.pca.state.inn.us /cleanup /pfe /index.htinl #pfos for more information. Wildlife /Ecological Risk Assessment To assess ecological risks from PFCs, MPCA filled a gap in National Park Service sampling, and expanded the study area for assessing targeted "persistent, bioaccumulative, toxicants" (PBTs), including PFCs, in bald eagles that nest along portions of the Mississippi and St. Croix Rivers. The sampling will allow monitoring of trends in PFC concentration and bald eagle nesting success over time. The number and development of young in nests are assessed in the study area, and eagle nestling blood samples were collected for analysis of PFCs. The purpose of these studies is to determine the distribution and extent of PFC contamination in Minnesota's ambient environment. However, these studies can only assess concentrations of PFCs in various media. In order to give context and meaning to the data, it is critical to first understand the fate and transport of PFCs in the environment. The following section provides a brief discussion of direct and indirect sources of PFCs, as well as fate and transport in relevant environmental media. Sources, Fate and Transport of PFCs in the Ambient Environment* *Please refer to Appendix B for a more detailed discussion of the fate and transport of Ms. The variety and number of fluorinated compounds currently in production comprise an enormous number of chemicals. Drugs, anesthetics, chemotherapeutic agents, pesticides, refrigerants, such as chlorofluorocarbons (CFCs), as well polymers such as Teflon and Goretex, are a few of the thousands of products made from fluorinated carbon compounds [2]. PFOA and PFOS are examples of perfluorinated Perfluarnated,compoundl —a surfactants. They are often found in surface water samples Qopotcmt6imi��Q�fpQ�Qt� and are almost always found in wildlife and humans. While it is clear that these are not naturally occurring eafxom atoms are bound to fYtaorume compounds — they are entirely human -made — how these atom . compounds have become so widely distributed in our environment in often very remote locations is less understood. Studies have shown that PFOA, for example, is likely "ubiquitous in the northern hemisphere" [3]. The direct release of these compounds to the environment through manufacturing processes represents one way chemicals like PFOA or PFOS get into the environment. However, several recent studies show that PFOA and PFOS can be generated as byproducts when other fluorinated compounds break down. This means that the fate of other fluorinated compounds is important to understanding how chemicals like PFOA and PFOS are released to and persist in the environment. Perfluorinated surfactants are made either through electrochemical fluorination (ECF) or through a telomeri�Zation manufacturing process [2, 4]. ECF is the process that 3M used to produce fluorinated compounds. ECF was used to produce the fluorinated surfactants PFOA and PFOS that are used in fire - fighting foams (AFFF), paints, polishes, films, and lubricants. ECF is the only process used to directly produce PFOA and PFOS, with over 6 million pounds produced in 2000 [4]. The major contributors to environmental loads appear to be through the use of PFOA and perflumononanoic acid (PFNA) [5]. Other chemicals produced through ECF include the compounds used to make fabric stain repellents, carpet treatments, and paper coating materials [2, 4]. DuPont uses the telomerization process to make fluorinated compounds [2]. Unlike the PFCs made through 3M's ECF process, Dupont's method is often used to make fluorotelomer alcohols (FT OHs) [2]. FTOHs are not used directly in products. Instead, FTOHs are used as intermediates in the manufacture of other products, where they are often present in residual amounts of up to 4% by weight [6]. There are many types of fluorinated compounds that are used in a wide variety of products. Chemicals like PFOA and PFOS are resistant to degradation which makes them persistent in the surface water, soil, and ground water. Moody et ad. [7] studied a creek into which fire- fighting foam (AFFF) was spilled. PFOA, perfluorohexanoic acid (PFHxA, a chemical similar to PFDA), and PFOS were present in the surface water and in fish tissue for several years after the spill. They were also detected in ground water underneath a site where AFFF fire- fighting foam was used [8]. These studies focused on surface water or ground water contamination where there was a clear source or a spill. The widespread, low -level contamination of soil, ground water, and surface water in remote locations is difficult to explain, however, because it is unlikely that PFDA and similar chemicals that are non - volatile could be transported to areas far from a likely source. Unlike PFOA, the FTOHs produced by DuPont are volatile and can be found in the air. FTOH will break down into PFOA (Fig. 1) and related chemicals in the atmosphere [3, 9] such as perfluorodecanoic acid (PFDA, a compound similar to PFDA). With over 10 million pounds of FTOH produced per year, enough FTOH is manufactured yearly to maintain the current observed concentrations of PFOA and related compounds in the environment [9]. FTOHs also break down in wastewater treatment plants, where up to 10% of FTOH can be converted to PFOA and similar compounds [10, 11]. Figure 1. Conversion of 8:2 fluorotelomer alcohol into PFOA. The degradation of FTOHs to PFOA and related chemicals can explain other observations: • The appearance of PFDA in fish samples in Minnesota is consistent with the breakdown of FTOH to PFDA, because PFDA has no significant history of intentional industrial production [12]. • According to DeSilva and Mabury (2006), 89% of PFOA in human blood samples from the Midwest is attributable to PFOA that originated from telomerization production methods [12]. • Recent MPCA studies show that various perfluorinated surfactants — including PFOA and PFOS — were present in air samples in 2008 [13]. The presence of these compounds in the air can be partially explained by the breakdown of FTOH molecules in the atmosphere. 3M discontinued manufacture of these PFCs in 2002. • Minnesota ground water monitoring shows PFOA, perfluoropentanoic acid (PFPeA), perfluorohexanoic acid (PFHxA), perfluoroheptanoic acid (PFHpA), and perfluorononoic acid (PFNA) at trace or low concentrations that are widespread under ambient conditions, with no known or likely sources of these compounds [14]. The degradation of FTOH compounds in the air or in the soil is a plausible source of these detections in the ambient environment. Polymers made from fluorinated chemicals are produced in far greater volumes than the fluorinated surfactants discussed above. Very little information, however, has been published regarding their fate in the environment [4]. Polymers typically resist breaking down. The breakdown of polymers made from fluorinated chemicals is expected to add only a very slight amount of PFOA and similar chemicals to the environment [15]. However, the polymers used widely for oil and water - resistant coatings on food - contact paper products have been found to degrade into FTOH and subsequently to PFOA [16]. The degradation of this water - resistant coating chemical was found to occur in the intestinal tract and the blood of laboratory animals, representing a significant source of exposure to PFCs [16]. Indoor air concentrations of fluorinated chemicals used to make fabric and carpet coatings are roughly 10 -20 times greater than outdoor concentrations of the same chemicals [17]. These compounds may, in turn, break down into PFOS [18]. This could expose people to PFOS through ingestion and inhalation inside of homes that contain fabric coating products. In soil, PFOS has been found to adsorb to various minerals, with adsorption increasing with PFOS concentration [191. However, PFOS apparently adsorbs to soil less than other pollutants [19]. Some research shows that the mobility of PFOS and PFOA in ground water can change depending on the ground water conditions [20]. Adsorption variability might be important in how far and how fast these contaminants spread in aquifers away from spills or disposal sites. Distribution of PFCs in Minnesota's Environment In Minnesota, it has been apparent since 2006 that PFCs may be present at concentrations of potential concern beyond the disposal sites and the groundwater contamination associated with them. Since then, the MPCA has made a number of important discoveries regarding PFCs in Minnesota's ambient environment. The following section provides a brief discussion of the results to date of several completed and on -going studies at the MPCA. For more detailed analytical results, please refer to Appendix A. Twin Cities Metro Area Lakes - Fish and Water In April 2007, the MPCA found elevated concentrations of PFOS in fish taken from Lake Calhoun in Minneapolis. PFOS is the most bioaccumuladve PPC in fish, and this finding was of concern to the city of Minneapolis and people who fish in this popular lake. MDH issued new fish consumption advisories for the lake. Sampling was expanded to other metro -area fishing lakes, and additional findings were announced later in 2007 and early 2008. In addition to Calhoun, Lake Johanna and Lake Elmo received one meal per month fish - consumption advisories. For the most part these lakes have no groundwater connection with the waste sites, and the source(s) of contamination are still not identified [21]. Figure 2 illustrates the 2006 -2008 Twin Cities metro area fish sampling results. MPCA has ongoing projects underway, including an aquatic food web study and a stormwater runoff study, to better understand the distribution of PFCs in Minnesota's aquatic environment. 0 �� \\ ! ^ \� } iv; I A $�� } � ` � � ! \ Eli Mississippi River Sampling Fish have been collected from various reaches of the Mississippi River and analyzed for PFCs since 2005. Elevated concentrations of PFOS in fish tissue have resulted in MDH fish consumption advisories for at least one species in Pool 2, Pool 3, Pool 4, and Pools 5, 5a, and 6 (Fig. 2). Fish were sampled in the Mississippi River near Brainerd, and the PFOS concentrations in the Brainerd- area fish were low. Ground Water Ambient shallow ground water was sampled for PFCs in urban and agricultural areas of Minnesota during 2006 and 2007. Sampling was conducted by MPCA in cooperation with the Minnesota Department of Agriculture (M DA). Wells were selected in vulnerable aquifers. PFCs were detected in ambient shallow ground water at concentrations below MDH health guidelines. PFBA was the most commonly detected PFC, and it was the PFC detected at the highest concentration. Most of the PFC detections above the reporting limit were in the Twin Cities Metro Area. Land uses associated with the wells that had detected PFC concentrations were Industrial, Commercial, Sewered Residential, and Agricultural [22]. Air Monitoring Air samples have been collected at two Minnesota sites, one urban and one rural. PFOS, PFOA, and PFBA were detected in air at both locations. Total concentrations were approximately 50% higher in the urban location. Additionally, 7 PFCs not detected in the rural location were detected at the urban location. Very few studies have measured and reported air concentrations of PFOS and PFOA. Minnesota's air results are within the range of PFOS and PFOA concentrations in air reported by others [23, 24]. A suburban location is currently being monitored for PFCs in air, but results are not yet available. AFFF Fire- Fighting Foam In 2008, MPCA hired a contractor to survey likely users of PFC - containing fire- fighting foam regarding their use of foam in both fire suppression training and in fire fighting. Survey questions were related to frequency of foam use, volume of foam used, location of foam used, and brands /types of foam used. Approximately 67% of municipal fire departments (522 of 785), all 16 fire training school, all three airports with fire departments, and both refineries with fire departments responded to the survey. Identified fire training locations were screened and ranked for relative risk based on type of foam used and proximity to potential human or environmental receptors: drinking water wells, well head protection areas and source water protection areas, surface water, wetlands, and karat geology. Approximately 20 current or former fire training areas were identified as having a high potential for PFC contamination to drinking water, ground water, soil, and /or surface water. MDH and MPCA are conducting follow -up sampling and investigations of high -risk sites. The first round of sampling will focus on drinking water wells in proximity to fire training activities. 11 Wastewater Treatment Plants The MPCA conducted a survey for PFCs in wastewater effluent at 28 municipal and industrial WWTPs across the state in 2007. A number of sample locations showed low concentrations of PFCs. The city of Brainerd's plant had elevated concentrations (see box). The Brainerd finding, traced to a chrome - plating facility, raised questions about the potential for PFCs to enter surface waters through permitted W WTP discharges to surface water. More facilities were sampled in 2008, and results were consistent with 2007 findings [21]. Permitted Landfills Through monitoring conducted in 2006 -7, the MPCA found PFCs in ground water, leachate, landfill gas, and gas condensate at a number of landfills. These findings suggest that PFCs may be released from consumer, commercial and demolition wastes. However, the concentrations were very low in ground water, and in most cases, results suggested that landfills were not acting as sources of PFC impacts to ground water. No drinking -water wells were affected [21]. Soil Microcosms In collaboration with EPA's National Exposure Research Laboratory, MPCA is investigating the fate of PFCs in ground water. Soil collected from beneath the ground water table at the Washington County Landfill was brought to the laboratory. Microcosms were prepared using this soil under anaerobic conditions, and PFOS and PFOA were added to the microcosms at known concentrations. Samples of these microcosms on a quarterly basis showed that, while these compounds resist degradation, the adsorption of these compounds to the soil changes with time. This is possibly due to changing oxidation /reduction conditions within the microcosms. These results have important implications to the fate of PFC in the vicinity of landfills where oxidation /reduction status changes spatially. Brainerd tt1WTP Case Study The PFOS concentrations in the Brainerd wastewater treatment plant influent, effluent and sludge were significantly higher than other W WfPs sampled around the state. In response to the noteworthy result, Brainerd Public Utilities (BPU), operator of the W WFP, hired a consultant' to collect wastewater samples from locations around the city to try to determine the source of the PFOS. PFOS was detected in samples from five locations. Four concentrations ranged from 0,08 - 1.18 pg /L. The fifth sample concentration, collected at manhole in an industrial park, had a PFOS concentration of 49.8 pg/L. [11. Keystone Automotive, a chrome plating operation specializing in automobile bumpers, is located in the industrial park adjacent to the manhole with the highest PFOS concentration sample. Keystone used a PFOS- containing surfactant product in its chrome plating bath. The ` PFOS- containing surfactant product reduces surface tension, which in turn helps reduce emissions of hexavalent chromium from the plating solution — an important worker - safety' issue. In September 2007, Keystone switched to a different mist suppressant that does not contain PFCs. Ongoing monitoring is being conducted to monitor the effectiveness of the new . mist suppressant. Monitoring will continue to document the effect that the product change has over time on PFOS discharge concentrations [1]. 12 PFCs in Humans and Wildlife: Exposure and Effects That PFCs are found throughout the world is not surprising due to their presence in a wide variety of industrial, commercial, and consumer products. The world -wide presence of PFCs in humans and animals provides strong evidence that exposure to this group of chemicals is through general environmental exposure and is not limited to known point sources or areas of contamination. The exact sources and routes of a ll exposures are unknown, although efforts are underway to evaluate the primary sources. Several studies of human blood samples from around the world have found that nearly all people tested have some PFCs in their blood [25, 26]. A number of studies have also tried to assess potential routes of exposure [27 -30]. Although all routes of exposure have yet to be clearly defined, exposure likely occurs through a variety of pathways, including drinking water, food and food packaging, and use of consumer products containing PFCs. Once people are exposed to PFCs, they are very slowly eliminated and stay in the body for many years [31]. PFCs have also been shown to bioaccumulate in wildlife, including top predators such as polar bears, bald eagles, mink, and seals; PFCs also bioaccumulate in fish. However, unlike other persistent organic pollutants, PFCs bind to protein rather than fatty tissues making it difficult to predict tissue concentrations using typical bioaccumulation models. Human Exposure via Drinking Water As a result of the manufacturing activities in Minnesota and the accompanying waste disposal, some eastern Twin Cities suburbs were found to have higher concentrations of PFCs in ground water when compared to the general environment. Several studies suggest that PFCs readily move through the soil and enter the ground water. Through investigations conducted by MDH and MPCA, it was discovered that some area residents were being exposed to PFCs through their drinking water (Table 1). Over 1,300 wells in the eastern Twin Cities suburbs have been tested, and MDI-I, MPCA, and 3M have worked with affected parties to provide safe drinking water by supplying alternative sources of water or assisting with water filtration to remove PFCs. Testing of ground water in the eastern Twin Cities suburbs over the past several years suggests concentrations of PFCs have remained stable and have not increased. MDH and MPCA staff continues to test wells in the area to monitor any changes in concentrations or movement of the PFC ground water plume. To date, most of the drinking water supplies located away from the eastern Twin Cities suburbs that have been tested have no detectable PFCs. Although PFBA was detected in several wells, the concentrations found were below levels of health concern established by the MDH. Testing of additional drinking water sources throughout Minnesota will continue to evaluate potential exposure to PFCs through drinking water. 13 Table 1. PFCs detected in Minnesota Drinking Water 'Concentrations are in gg /L (ppb, parts per billion) bND = not detected cin September 2008, MDH proposed lowering the HRL for PFOA to 0.3 gg /L. Human Exposure via Fish Consumption There are numerous reports documenting the presence of PFCs in fish and animals throughout the world [32 -36]. In cooperation with the DNR and MDH, the MPCA has been testing fish in Twin Cities metro area lakes and rivers as well as selected outstate water bodies for the presence of PFCs to evaluate the potential for human exposure through the consumption of fish. Fish from 56 different lakes as well as several reaches of the Mississippi and St. Croix Rivers have been tested for PFCs. PFOS, the primary PFC found to accumulate in fish fillet tissue, has been found in various fish species from several different lakes and river reaches at concentrations such that the MDH has issued site specific consumption guidelines for fish for the affected waters. Other PFCs detected in Minnesota fish include PFPeA, PFHxA, PFHxS, PFOSA, PFNA, PFDA, and PFUnA (Appendix A). Human Health Risk Although there are only a few studies investigating the effects of PFCs on human health, it is an area of active scientific research. The majority of studies evaluating the human health effects of PFCs have been conducted using animal models. While most studies have focused on PFOS and PFOA, information is growing for other PFCs such as PFBA and PFHxS. In studies evaluating the health of 3M workers exposed to PFCs during manufacturing processes, no clear associations between adverse health effects and exposure were found [37]. It should be noted that the people evaluated in these studies were healthy workers who may not represent the average population. Three recent studies evaluated the health effects of PFCs on newborn babies associated with concentrations of PFCs in the blood of their mothers [38 -40]. Each study found PFC concentrations in the mother's blood correlated to decreases in measures of growth in the newborns. Participants in these studies were exposed to PFCs through typical life activities, not as a result of known point sources of contamination. As part of an agreement in a class action lawsuit against DuPont, a health study (The C8 Health Project) of 70,000 people in West Virginia and Ohio exposed to PFOA in drinking water is being undertaken to determine if there are any health effects related to PFOA exposure. Participants in this project live in areas of known drinking water contamination due to industrial activities. 14 PFOS' PFOA' PFBA' East Metro Area Municipal wells ND — 0.9 ND — 0.9 ND — 2.2 Private wells ND - 3.5 ND - 2.2 ND - 12 Other Areas Municipal wells ND ND ND — 0.4 Private wells ND ND ND - 0.5 Criteria set by MDH Health Risk Limit HRL 0.3 0.5` - Health Based Value (HBV) 7 'Concentrations are in gg /L (ppb, parts per billion) bND = not detected cin September 2008, MDH proposed lowering the HRL for PFOA to 0.3 gg /L. Human Exposure via Fish Consumption There are numerous reports documenting the presence of PFCs in fish and animals throughout the world [32 -36]. In cooperation with the DNR and MDH, the MPCA has been testing fish in Twin Cities metro area lakes and rivers as well as selected outstate water bodies for the presence of PFCs to evaluate the potential for human exposure through the consumption of fish. Fish from 56 different lakes as well as several reaches of the Mississippi and St. Croix Rivers have been tested for PFCs. PFOS, the primary PFC found to accumulate in fish fillet tissue, has been found in various fish species from several different lakes and river reaches at concentrations such that the MDH has issued site specific consumption guidelines for fish for the affected waters. Other PFCs detected in Minnesota fish include PFPeA, PFHxA, PFHxS, PFOSA, PFNA, PFDA, and PFUnA (Appendix A). Human Health Risk Although there are only a few studies investigating the effects of PFCs on human health, it is an area of active scientific research. The majority of studies evaluating the human health effects of PFCs have been conducted using animal models. While most studies have focused on PFOS and PFOA, information is growing for other PFCs such as PFBA and PFHxS. In studies evaluating the health of 3M workers exposed to PFCs during manufacturing processes, no clear associations between adverse health effects and exposure were found [37]. It should be noted that the people evaluated in these studies were healthy workers who may not represent the average population. Three recent studies evaluated the health effects of PFCs on newborn babies associated with concentrations of PFCs in the blood of their mothers [38 -40]. Each study found PFC concentrations in the mother's blood correlated to decreases in measures of growth in the newborns. Participants in these studies were exposed to PFCs through typical life activities, not as a result of known point sources of contamination. As part of an agreement in a class action lawsuit against DuPont, a health study (The C8 Health Project) of 70,000 people in West Virginia and Ohio exposed to PFOA in drinking water is being undertaken to determine if there are any health effects related to PFOA exposure. Participants in this project live in areas of known drinking water contamination due to industrial activities. 14 Preliminary reports suggest a relationship between PFOA exposure and elevated cholesterol levels. Additional reports are pending [41]. In animal studies, PFCs have been associated with adverse effects including, but not limited to, altered cholesterol and thyroid hormone levels, suppression of the immune system, and developmental effects such as increased neonatal mortality, decreased body weight and weight gain in newborns and delayed eye opening. Animal studies generally form the basis of establishing human health criteria. Human Health Criteria Minnesota Department of Health Following the discovery of PFCs in ground water in the East Metro Area, the MDH developed drinking water criteria for PFOS, PFOA and PFBA. Under emergency rule making authority enacted by the Minnesota Legislature, the MDH promulgated in rule Health Risk Limits (HRLs) of 0.3 µg /L` for PFOS and 0.5 gg /L for PFOA in August 2007. In September 2008, MDH proposed lowering the HRL for PFOA from 0.5 gg /L to 0.3 µg /L. In February 2008, MDH established a health based value (HBV) of 7 gg /L for PFBA. PFBA is thought to be less toxic than PFOS and PFOA because of its shorter half -life in rodents. HRLs and HBVs are concentrations of chemical - specific ground water contaminants that MDH has determined would result in little or no appreciable harm to people drinking the water daily over a lifetime. The process of determining HRLs and HBVs are the same; however, HBVs have not been promulgated in rule. Due to limited toxicity information available for other PFCs, such as PFBS, PFHxS, and PFHxA, which have been found at very low concentrations in some wells, drinking water criteria cannot be developed for these chemicals at this time. The MDH continues to monitor PFC research activities and will re- evaluate criteria as new information becomes available. In addition to the health criteria for PFOA, PFOS and PFBA established by the MDH for drinking water, values for the protection of human health have also been developed by other regulatory and health agencies in the U.S as well as in Europe. As described below, drinking water values developed by other agencies range from 0.04 - 9 µg /L for PFOA and 0.1 - 0.9 µg /L for PFOS. Newlersey In 2007, the New Jersey Department of Environmental Protection ( NJDEP) provided preliminary guidance to the Pennsgrove Water Supply Company to assess public health implications due to PFOA in the system's drinking water [42]. The NJDEP recommended a preliminary health -based guidance in drinking water of 0.04 µg /L PFOA, which is the lower end of the range of several values derived from non - cancer and cancer endpoints in different species. The drinking water value the NJDEP developed is based on comparisons between target blood levels of humans and actual or predicted blood levels of experimental animals. The difference between the New Jersey and the Minnesota values for PFOA is primarily due to use of a larger uncertainty factor and different water intake rates. MDH had several concerns regarding the New Jersey approach, including the ability to accurately estimate a serum concentration associated with observed effects, the potential for episodic serum * gg /L (micrograms per liter) = ppb (parts per billion) concentrations given the short half -life of PFOA in the female rat, and the uncertainty regarding the serum to water ratio. In developing its HBVs for PFOA and PFOS, MDH has chosen to utilize an animal model that it believes is more relevant to humans and a more traditional risk assessment methodology. EPA In 2006, the EPA set a site - specific drinking water action level of 0.5 µg /L for PFOA for the communities surrounding the DuPont Washington Works Facility in West Virginia [43]. Based on the scientific information available regarding the toxicity and the toxicokinetics of PFOA, EPA recommends that steps be taken to eliminate or reduce exposure to PFOA in the vicinity of the Washington Works Facility. Through a Consent Order, the EPA determined, "As required by Section 1431 of the SDWA (Safe Drinking Water Act) and for purposes of this Order, EPA has determined that C -8 [PFOA and its salts] is a contaminant present in or likely to enter a PWA [public water system] or a USDW [under ground source of drinking water] which may present an imminent and substantial endangerment to human health at concentrations at or above 0.50 µg /L in drinking water"[44]. In 2009, the EPA established provisional health advisories for PFOS and PFOA of 0.2 pg /L and 0.4 gg /L, respectively. North Carolina In 2007, the North Carolina Division of Water Quality in the Department of Environment and Natural Resources established a. Public Health Goal of 0.63 µg/l, for PFOA [45, 46] based on the same studies used by MDH. The difference between the North Carolina and the Minnesota values for PFOA is primarily due to use of a different water intake rate. United Kingdom The Food Standards Agency issued Tolerable Daily Intakes (TDIs) that are equivalent to drinking water concentrations of 9 gg /L for PFOA and 0.9 pg /L for PFOS. The evaluation conducted by the Food Standards Agency was based on the same experimental studies used by MDH; however, a dose - metric (a measurable physical /chemical property that corresponds to a compound's ability to cause a biological effect, such as toxicity) adjustment to account for species differences in half -life was not included [47 -49]. Germany In 2006, the German Ministry of Health established maximum tolerable concentrations for combined total exposure to PFOA and PFOS in drinking water and recommended that concentrations of PFOA and PFOS be combined in evaluations as they are considered to have comparable toxicity[50]. The Ministry issued a "strictly health -based guide value" for combined total exposure to PFOA and PFOS in drinking water of 0.3 pg /L. As a "health -based precautionary value ", the Ministry established a drinking water value of 0.1 pg /L to account for exposure to other perfluorinated chemicals in addition to PFOA and PFOS due to the possibility of toxic risks which have yet to be identified and which may be attributed to additional perfluorinated chemicals with shorter or longer carbon chains than PFOA and PFOS. The Ministry recommends that efforts are to be made to reduce levels of total perfluorinated chemicals to less than the health -based precautionary value. 16 Ecotoxicity of PFCs Several laboratory studies have demonstrated the toxicity of PFOS to aquatic organisms such as algae, invertebrates, fish, and ducks; PFOS toxicity in bobwhite quail has also been detemlined[51]. Mysid shrimp and chironomids, aquatic invertebrates that are important components in fresh water food webs, appear to be the most sensitive aquatic organisms tested to date. PFOS exhibits moderately acute toxicity in fathead minnows (Pimepbales promelas). See Appendix C for a more detailed description of the available toxicity data. A recent study of the effects of PFCs on marine mussels indicated that some PFCs (PFDA, PFNA, PFDA, and PFHxS) act as cbemoseositi .Zers (compounds that increase sensitivity to other chemicals) by interfering with a cell's ability to rid itself of toxic chemicals [52]. This interference could allow toxic substances that would normally be excreted to accumulate in the cell where they may have an adverse effect. Humans and other animals have cellular defense mechanisms similar to marine mussels. PFCs as Potential Endocrine Disruptors Several studies have shown that various PFCs have the potential to disrupt the endocrine systems of animals [53 -59]. Laboratory studies of rats indicate that exposure to PFDA interfered with cholesterol transport and the production of steroid hormones, which resulted in reduced serum testosterone [56]. Exposure of rodents to PFDA has been associated with adverse effects on the testes [54]. PFOS has been shown to disrupt circulating levels of thyroid hormones in rats [57]. In cell cultures, FTOHs increased the number of estrogen receptors and induced MCF -7 breast cancer cell proliferation [55]. FTOHs were shown to be estrogenic in vivo in the male medaka (Ory�das latipes) as indicated by the induction of vitellogenin (a protein typically produced only in females) [58]. PFOS, PFDA, and certain FTOHs were also shown to be estrogenic in vitro [59]. Summary and Outlook PFCs have a number of beneficial uses in myriad industrial, commercial, and consumer products due to their unique ability to repel both water and oil, and to resist breakdown. However, these same properties also contribute to their persistence, toxicity, ability to travel long distances to remote areas, and propensity to bioaccumulate in animals and humans. It is now known that PFCs are ubiquitous environmental contaminants that have been detected in a variety of settings, including humans and biota, worldwide. There are many potential sources of PFC release to the environment, and humans and wildlife are exposed to PFCs through a variety of pathways. Several effects of exposure to PFCs have been documented in laboratory studies, including decreased growth and altered development in newborns, immune suppression, endocrine disruption, and increased sensitivity to other chemicals. Drinking water criteria and fish consumption advisories have been established to protect human health in Minnesota. MPCA has conducted a number of studies of PFCs in the ambient environment, and several studies are still in progress. The goal of these studies is to determine the extent and distribution of PFC contamination in MN, and to determine likely sources of contamination. To date, PFCs have been detected in variety of environmental settings in Minnesota including surface water, ground water, air, soil, and fish. 17 The current PFC investigations are providing important clues to the origins, fate and consequences of PFCs in Minnesota's ambient environment, and will guide follow -up studies in the coming year. There is still much to learn, however. What do detections in fish, water, blood and other settings mean to people and the environment? How do PFCs move to remote parts of the planet? What are the ongoing sources of PFC release to the environment? Despite having few human health studies, enough concerns are raised from existing human- and animal -based PFC toxicity studies to suggest that further environmental monitoring and health risk assessments are appropriate and necessary to answer questions of human and ecological risk. There are few established benchmarks against which to compare concentrations found in sampling work. Fortunately, the MPCA and MDH are not alone researching these challenging questions. As is fitting for a global problem, scientists in government, academia and industry around the world are regularly adding to the scientific knowledge about environmental fate, movement, degradation, exposure and risks to humans and animals. The EPA is also becoming more active in the analytical and regulatory aspects of PFCs. Minnesota agencies are in frequent contact with researchers worldwide and are partnering in some projects to represent Minnesota's interests. 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E.; Cook, J. C., Effects of Ammonium Perfluorooctanoate on Leydig -Cell Function: In Vitro, in Vivo, and ex Vivo Studies. Toxicology and Applied Pharmacology 1995,134, (1),18-25. 55. Maras, M.; Vanparys, C.; Muylle, F.; Robbens, J.; Berger, U.; Barber, J. L.; Blust, R.; De Coen, W., Estrogen -Like Properties of Fluorotelomer Alcohols as Revealed by MCF -7 Breast Cancer Cell Proliferation. Environmental Health Perspectives 2006,114, (1), 100. 56. Shi, Z.; Zhang, H.; Liu, Y.; Xu, M.; Dai, J., Alterations in gene expression and testosterone synthesis in the testes of male rats exposed to perfluorododecanoic acid. Toxicol Set 2007, 98, (1), 206 -15. 57. Thibodeaux, J. R., Perfluorooctane Sulfonate- Induced Thyroid Hormone Disruption in the Rat. 2005. 58. Ishibashi, H.; Yamauchi, R.; Matsuoka, M.; Kim, J. W.; Hirano, M.; Yamaguchi, A.; Tominaga, N.; Arizono, K., Fluorotelomer alcohols induce hepatic vitellogenin through activation of the estrogen receptor in male medaka (Oryzias latipes). Chemosphere 2008, 71,(10),1853-9. 59. Liu, C.; Du, Y.; Zhou, B., Evaluation of estrogenic activities and mechanism of action of perfluorinated chemicals determined by vitellogenin induction in primary cultured tilapia hepatocytes. Aquatic Toxicology 2007, 85, (4), 267 -277. 22 Jonuary2009 Report Coordinator: Summer Streets Primary Contributors: Mindy Erickson, PhD, Mark Eerrey, Paul Hoff, Laura Salem, PhD, Summer Streets LA14 Minnesota Pollution Control Agency 520 Lafayette Road Saint Paul, MN 55155 RMM pra.state.ann.us 23 U , PFC Monitoring Data Collected by the MPCA k k \ / ) k \ \\ \) ())])! \ \ } \)\ PFBA in Shallow Ground Water i Rural Areas October 200.7 639515 74701 623617 a 747018 244492 431151 244529 747009 492127 0 25 50 100 Miles Legend Sample locations PFBA Q Not detected Q <25 ng /L 25 - 63 ng /L = County boundary 0 Fine Oak.. �..2� Rainy NO Minnesota Pollution Control Agency Q N p OJ ` O M ll� N 4 t O V N M N r N V� O) N 0 m N N W Z O a- 4J O N N O LL O. V V V � 2 O� N (V y V� V V� O V V O V V V V V V V Y V V V V y V V y y N h N V N O N OJ M fO W M N N W O m m �- N N O ' W� C O n N N W� N Cl W �D N N N N N !J N N W a d m M V V v r N V V V V m V V Y V V V V V v N LL M tp H O 4N N N CI tP N M b N a4 d N N m N N N N N V) (V v v v a y v ^ v v v v v v vvvv v v v v v v v Q Nv v� o PW)h (O iU Pao f rO P � v v v v v v v v v '- v v a Z h M M 2 K p h c O N C N a ' "' v v v v v v v .- v i N v v v v v v LL N V V I N V� V` V N N O M N N N N N CI N LO (v M v v ^ N V V V V v V V 6 V V v v V v v 4 V v yy Q N r n` M ep W NN m 7 m C, 0 N s M V1 O W M O M N m O O 0 n M �. V m a < a M N V N ip b N N A N N N O M C V N r' y h y NBC) y V ° m % E E QqQ fGK 61- ---F - -S --- --O L L L °c m 15 Q 7 Z Z Z 4] d j c 9 mMM I M C _.� m $ L 2' S : . y . > > E- a 3 3 0 ° E >>� 3 3. i � c a E E a d d m a a' a' a a 3 d m m c' 0 9 a d m m d d '� o o O c y y y C C c C C y y (O O( j° C m y (O N 8W^ 8888W 882,020 8888,88 oP80o0088000oc N N N N N N N N N N N N N E E E E E E E E E E E E m E E E E E E E E E E E E E E E m � m m o m o > o o >o $ an d > > > > > o o > o > o � . > o ' `� ' > > > E ' 0 0 0 0 0 0 m m Z O Z 2 o Z Z � o 0 0 0 Z o Z Z o 2 Z 2 Z Z Z Z Z 2 2 Z 2 Z Z Z Z O O O r r r O O O m m O O O m�� 0 IT T Q I T U O a 0 w � m C Er � 0 w d m h 9 J n T ® N ` w f 0 N a v d K 5 El a p O r 0 can 'o m m 3 ® g u o c E mz'v a g m 5 3 `a OLL .0 v am nm °Cwm m — C LL w m d o c q ro N `ma my `o E a p a d d O Z Beltrami Hubbard 0 Todd Hennepin Scott 4Anoka Legend n PFCs in shallow wells PFOA Anoka Was ington O Not detected Q < 25 ng /L Hennepin Ra se 2 7.5 ng /L county Dakota 0 rol J N Dakota [1. 5 10 20 Source: Ambient Ground Water Monitoring Miles 0 25 50 I 10Miles Environmental Analysis and Outcomes Division January 2007 k, e Minnesota Pollution Control Agency SIM9, t M11, Anoka O Was Hennepin Rams y Dakota Scott 0 5 10 20 Beltrami Hubbard Todd Legend cs U L PFCs in shallow wells PFBA Steams 0 Not detected 0 Anoka — 4 25 () 40 - 65 5 n g /L Was ingto (D 250 - 500 ng /L Hennepin Re se ® 922 ng /L county do ton Dakota N A 0 25 50 100 Source: Ambient Ground Water Monitoring leS Miles Environmental Analysis and Outcomes Division January 2007 ,. �. Minnesota Pollution Control Agency PFOS in Shallow Ground' Whater k X,- Aer. ®- 1,1j, "I I *Afff 6 .t, UQUIj Anoka 0 An W Anoka 00 Hennepin Rams 0 0 Dakota SCott 10 5 10 Beltrami Hubbard 0 Im. 0 Legend 0 Stearns o Benton PFCs in shallow wells PFOS Was ington 0 Not detected 0 < 25 ng/L Hennepin Re se 0 31 - 37 ng/L = county ir, 4+,,Dkota N 0 25 50 100 Source: Ambient Ground Water Monitoring Miles Environmental Analysis and Outcomes Division January 2007 , 'n Minnesota Pollution Control Agency E N C 3 a ' U, e a L a' t m a a a m R q LQ a 0 P' N N N N N N N tV a v v v v v v v v v a of vi v v vi vi vi vi y v v v v v v v v v v o m ai a a in . v m a 0 v N N V V CI N v v N N a V V V p V V V V N LR P LL P N N CI N N CI N a v v v v v v v v v a Y N v N N N N N N a v v v v v v v v v m u a N m n � m a LL a v N N N O N lV N v v v v v v v 6 M V 0 O m N m N N LL V v P v v v M N N t7 N (V a v v v v v P m vi, n m m w v m v LL v N v v fV v v v N N V a v v LL V a v v v v v v v v v m n m N h m N LL W N v v O N m V w v 6 V V V V N V V y vi vi vi v P t" vi � v N V v N N N a V V V m P V Y V m m vi v v M O vi vi v 6 V V V V M V V V N N m N N n [ P M m J N N N N N N p W p W J M M C1 lh t M M M O C V Q V P < C 00 y 9 $ $ 9 L ry {Q a mm m d 1] Y n Q O O u L 9 9 O `9 y v V w d d C N 9 9 = N m n a 6 y m o O m 3 3 F- C c r- r h n r p n h n N_ N N n � . �Y 0 1 0 + h ti h I0- n M1 O D m m O m O!a O m O m O T O m O m O m$ Q N r N M M N r N N M ROMP O 0 N M N N N N N v N N v a v v v v v v m$ M y m m m P M N N N m N Oj 1(j m �- N m 0 v N N lV N a v v v v v v v v v v v M N N$ h N N $ N %$ Z 1n W N m m r n r VI N M N CI fJ CI C N N N y V V V N N' V V V V V V V V m h N N M N ppV P N b {{ v N N m N N N LL N O) m r $ r m f m 1 [V v v N N v v N N v v N v a v v v° v v v v O O s Y N h [O P m P, P O r m O$ m CI Y N lV N P N N V N V V O V y R' O V V V V O V a V V V V V V 4 P w M M w P N P O N m M O Nl N IN {7 M lh m CI M M M " d V V V V V V V V V V V v v v V V V V V Or[O rw mwr rr �O LL N N v N N CI N N vvvvvvv dav vv v v vvv C Z W py r m OI N N m y $ m � N N N N N N N N ' 6 v V V V V V V V V V Y V V V Q Pw a ,�. mwmM d' v 6 V V V V V � a V V �i ° m m •- • vv v v v " v v v v v v �mm t mrin ry o nao� 00 `- y V v v ° v c vi v v v v v v v v Q N N `� i1'POV N m N m V O P N '�'N N P 'P_,omwr00 7 7 7 LL a N P tV V V V M N 1[I P V V V V V V V v V Q r m r r N N P. N r gi p$ CJ r N CI d (7 y N L U V m Y m U U d U� t t f p U g > > ? m m m $ C o y� ie E `m `m % C a ,S E p L m o'm Zl�n p w M m n r n = �Wp}r Y M M Mu s a a m t a m 1� b O OO' 6 a a W d A C G C J J g C b b b % m m m_ >> Y N N qq U U U O g O O O N N N N y y C g q J m ggUUU F-F jNm E N C 3 a ' U, e a L a' t m a a a m R q LQ a 0 P' N N N N N N N tV a v v v v v v v v v a of vi v v vi vi vi vi y v v v v v v v v v v o m ai a a in . v m a 0 v N N V V CI N v v N N a V V V p V V V V N LR P LL P N N CI N N CI N a v v v v v v v v v a Y N v N N N N N N a v v v v v v v v v m u a N m n � m a LL a v N N N O N lV N v v v v v v v 6 M V 0 O m N m N N LL V v P v v v M N N t7 N (V a v v v v v P m vi, n m m w v m v LL v N v v fV v v v N N V a v v LL V a v v v v v v v v v m n m N h m N LL W N v v O N m V w v 6 V V V V N V V y vi vi vi v P t" vi � v N V v N N N a V V V m P V Y V m m vi v v M O vi vi v 6 V V V V M V V V N N m N N n [ P M m J N N N N N N p W p W J M M C1 lh t M M M O C V Q V P < C 00 y 9 $ $ 9 L ry {Q a mm m d 1] Y n Q O O u L 9 9 O `9 y v V w d d C N 9 9 = N m n a 6 y m o O m 3 3 F- C c r- r h n r p n h n N_ N N n � . �Y 0 1 0 + h ti h I0- n M1 O D m m O m O!a O m O m O T O m O m O m$ O O N m C 7 N E Ec" m N ; y o n v °u L A 'C o � N - `m E C � 2 m V! m N o •y _u N y �L 0 - N E B m Q m N r0 m p W O r o o r r Q p r N r b m N fV v� V N N 10 m N Y V 10 (V CI O N N N V N N Iq N N V Y N CI O W N V' Y m {V CI Y< N CI Y N N V V v V V V V V V V V V V V V V V V V V V V a Om ° o wm tO •m mn mwa�,mn mo °dim m V ' tO N fG W 'El `f 6 4 m Y 4 V C W C v 6 V V 4 a y v V V V V V V V V V V V N m )t O m N �p Nm m m O W < p o W D✓ a V W W m W m n m m W O o a W m m W W LL m N m v IO Y Y V V N i a V , v v v v v v v v v v v v v v v v v v v v v LL i 6 V N v V V v W V V V' v V V V 10 V V v IO V q V V v V V V C W V V Q m V V v v V V V v V V N N N N N N N N N V N N N N 0 v N v v v V v N N v v N v v v v v {V v v v v (Y fV v v v v v v o , Q m cyl m m o avla W r n n o n N m n m N LL N vl v,m N N m N V N [J N N V � N N lV v, V N N W N Y v,m N N In V CI N v,o N N a V V V V V V V V V V v v v v v v v v v v v v ° m,v ¢ u LL N N N N N N N N N N N N N N V N N N N N N L J a v v v v v v v v v v v v v v v v v v v v v v v c Q m m m N O N O r O O p n a m n N VI n Z mmvrnm LL N N v N V ainamain N N N N N .n N v a N a N V V vl N N vleaa N N N N 6 V V V V V V V V V V V V V V V V V V V V V V 0 M m 0 F p m m N N m 0 W N r yy V V (mp y N 16 C' t7 N m Q m m M1 O h r n O m m O O m V O r N 0 h m N Z W N V m m I m m !n m O V W V n 1n V N C R lV d m m V m V v V V V V V V V V V v V V V V v v V V V V m 0 V V m V V M V V M y m V 0 V V y N N 0 a Q I m m o m o m m m r m n o a m m n a n m v O W r m V w Iq n v m N v c LL M l7 V F N N N N N N N V' N N v lV N N a v v v v v v v v v v v v v v v v v v v v v v �in� a`oNra memnrym m nmm m m m m m m N N N N N N N N N N N O O O O O O O O O O O O O O O O O O O O D 8 0000000000 aaaaaaaaamm o000000000a aaaaaaaaaaa G L N m M m < N 1p M M N M M i W O �tV N N N N N N N N N N N N N (4 V b d' C1 VIV a N VI V V V V V V V vv v v V V V V/'W V N i6 -i 000�o�o I M. . m M M m P M a m v N v M M v v Y v M m W v M M v v v v v v m M vo ° a �oo. - orooim m.... Z b 1[1 N N 4 MMYI N 0NY1 �PM m a v v v v v v v v v v v v v m v M M�m m� P�w mm Nmmm�m P� N. fp N m.l m m m m m n,m ,' a W v v v v v v lw a' v m u v y m, o M M P w ve uo �M O N CI NN MNMN �M NPV ''NN mj d Y v, I v , U' V Vi V/W V Vi W W/ V V V' i W ¢ RNi M rm Ra Om �mP 6N m -� N C1i PI iP W N N 0.4 04 N 4b a Wi v' W V Iv, W v, v w m W V' V j V W j ' ¢ m rN M rm m�mm�N N MM M M. b m y, M lV mM fV M Cl CI PM N lV tV N N CI N (V N PI RI VIi" b a v v v v v v v v v v v v 7d a m I r !!qq I I E4 �l6r LL N W NN N'.�LY N R a V V W W V V' Vpp V I V V I V V i W V W ¢ N N N N V b A T m e- P' N R N (V N t N CI Vl N V P rz R N N P m V V V W V V V V V V V v d W WIV' WI m Pa m Z RI AJ� N NI Ni..N O m NIO IT ENllrt M m d W W W N V V� V'j1L V V V VW W INI c?P m i m mom v a mlm nr mm mm ai�P mb O i6 >m .ti ai.lrci�e; N ?� u a m W Piatil W W W m� Wv W v W v W v �a v m m VMVCI mIn C YI'.ym,V1� rN Mi Mid P�E4A mm`N6Y?p ev r�r m' We' d fV m m' m bM (V Itl Rlb P'A• M' C V d � N P O N O O V M Q m N N M b Li °U a o m mmm c mmm ommo000om p 'P ve � oa �<PPPP aP@ P v U 2 Z L 9 Q O O o NOp O- m E E: E E V W c z o p v ua m `mE cy'c oc`om � a w wKz v 222 W W 0 ` �tV SRI f`Ii 4V N (4 V b d' C1 VIV i V' N VI N N ViV I VVV W ' N V m'V N V W'm b �N C b U a w rn U d O O b a a E b rn 3 b d C c G m C d _M O q� N F Q a N N m 10 N N m N N m m m N W N Q ul n w N n O O O m G m m P Q w Q m N N N V Q O Q a N N N N N N fV N ry CI [V N N N fV N a 1n 6 v v v v v v v v v v v v v v v v v v v v v v v b0 m W M m n N o w o 0 E Q r w o m w m m w w o W o W w W W o ohm a Ui 1p Q' VI Q' V' O V 1 .... d' m a v v v v v v v v v v v v v v v x v v v v v v v 2SSo'm. -gym P m dS mo ° o mm'8i$ LL P w 1n 1N Q N Q P w Q Q N 10 P P v P' 6 m V V V V V V V V V V V I V V v V V v O W b 1N Q 1A O Vl O' — V wm LL a V V V V P v v v N V' N v m ' V' V' ' Q' v Q v 4 V m P m w m m m N^ O O W O O N Q m m o m o O W v v v v v v v v v v v v v v v S b m P N N 1N N au> N .°nvNvcmvl°d yj 6 1 N P P P IQ ' a V N N N N N N N N V' N N N N N N N o , V v v vvvvv vvvvvvvv v v V m W N 10 10 Q Q V! b P Q Q w Q M m N P 1 0 Q Q N N CI iV N N v o , V V v v v v v v v v v v v v v v v v v 4 y N 1 N Yi N N m N Y m Qm M N W m e`�i,QewQ�i r W N n N o m o m m mQlgc v, O LL N N N N N N N N N V' N N iV N FI fV N a 1n v v v v v v v v v v v v v v v v v v Z v O N N I Y N Y V m N O w a n V � °i N N Q ci M V V V v Q V V n M V V' N M Y N N N N N N N N N N N N m N1 M o m IQ PNP n m N o m o m P1q� 1nNMmN a a v v v v v v v v v N v v v v v v v v v v v v v v a w N Yl w m N n w N r O O O m O m V = N N Q N N N N N Q Q w Q 10 N N Q m P N N N N N N N N a a N M v v v v v v N N v v v v v v v v v v v v Q M V V V V N Q m M O w m m m V m n w N O O N W p m m w M N YI LL 10. i1fF N CI N N N N M N N N N N N N a 1 N N V v v V V V V v V V V V V V V V V V 4 N m Q YI M O w m 1 N Q 1 n w N n O O O m O m m V Q w P M m m P N P Q 6 a N N N N N N N N Q N N N N N N N N a l m N v v v v v v v v v v v v v v v v v a m N V t P N N V V V V v v d N V N M M Vl Q M Q Q N m': VI' •M CJ YI (+1 N O 9 d dE h O on O m N O PP .-P h N n m m w O m m O lno j6 N N 1n it) 1N m'm'w' O O U V V v v V V N N N N V m N N m Q 10 d� P 10 W N 1p Q N V tq N N N fV N m N m m P N m M n' p N N (V N (J m m R! W W w w w W 0 mro W W w rn rn w W o 0 0 0 N N N m `mm mmaf romm3 V V V V V V F W N m < r Z 9 > � 2 m Q P m r r m m m m O m 1n m N M P P 0 0 O a Z z = 0 N Z �- N Z m N y 6i N m m SSB O m m m m m SwS S o m S W W W W rn W w W w W m m N Z 3 0 r 0 m Z Z d d 2 y a m D °a ov y .a m a ra m E �° c ° � N c 2mCL 9 N N •y� •ry• pL� 1 d y L d d ry' L p� O d c a_a�_rca�_a_a_aarcaaaa_��_ d d v w m s v `m r d d 22 S m~ M s a C I IM 1 11 N N N m 10 N N m N N 10 h h N C YI N N N N N N N N N N N N N N N N N N 1n 6 v v v v v v v v v v v v v v v v v v o ° o owo�oNm�rr ohm a Mo m 1` (G Ld N P Y) v v v v v v v v v v v v v v v v y v P m W ro M m N P n n m o m o W m O N O O W O O N O 1( N P Y] N YI 10 m m O W b 1N Q 1A O Vl O' — V v V V V V V V V V V W W V V V V V V O P m w m m m N^ O O W O O N Q m m o m o O W W O M m b m P N N 1N N m m yj 6 1 m O ' V v V V V M V V V V v V � v v V V V V V V N N N sY m n n N 1f] m m m m M N V m W N 10 10 Q r N N N N N N iV N N N N N N N CI iV N N V V V V V� V V V V V V V v V V V V V v V N y N 1 N Yi N N m N Y N N h N V N t r N N N N N N N'N N N N N N [J N N fV 1n v v v v v v v v v v v v v v v v v v 0 10 1fI o M rQm Ih N 4i YI 0 m 10 i[l m m n V � °i N N Q 1 N N N N N N N N N N N N N N N N N v v v v v v v v v v v v v v v v v v v INN hN< N h v V N N N N N N N N N N N N N N N 1n V V V V V V V V V V V V V V V V V T.�jO � m m N N 10. i1fF M f6i V N Y N t[ r 1 N N Q O Qp'-lr N W m lm` W OiI N N N v N 11 IP V V V V V v V m l m N b ml 'd'NW N M 10 Q P N r N V N w m N N m T P V m m V V m P N N V V V V v v N V N V t N H fp m N N n m P N 0 N N h r N in t m N Y V V V V v v V V N N N N V m N N m Q 10 d� P 10 W N 1p Q N V tq N N N fV N m N m m P N m M n' p N N (V N fV V V V V V V V V V V V V 14 O1 W N m < r m Q P m r r m m m m O m 1n m N M P P 0 0 O a 0 0 0 9 m a O O o N 0 N �- 6i N m m SSB m m m m m m m m SSSSSSSS m m m m m SwS S o m S W W W W rn W w W w W W W a j 6 a � N c L O 5 d d v w m s v `m r d d 22 S m~ M s a C y M LL d c= x s s s o 0 o a a 9 n Y> O LL LL Z N N Z 2 N 2 C 6 W W a m m m m u m m m p •• •• •• m p •• Y m m > Y> Z.Z ._._._.L .2L a> > Y K� > aa �mrc�mmm� p E I m g g g 2005 MPCA PFC Fish Data < = less than the detection limit; number following this symbol represents the detection limit 2005 MPCA PFC Fish Data MISSISSIPPI MPCA Species & Sample DD # xiver Lahe Sample Date Fe in Fish PFC Analyzed as Fillet or Whole Fish analysis Wt (g) Ln (cm) Age/ sex (Yrs/ m PFOA ng/g (ppb) PFOS ng/g (ppb) PFOSA ng/g (ppb) PFPeA ng/g (ppb) PFDA ng/g (ppb) PFUnA ng/g (ppb) PFDoA ng/g (ppb) Walleye WE -1 1014105 Fillet 741 42 llfl <0.603 47 1.52 75.88 <0.668 <0.593 <0908 WE -2 1014105 Fillet 861 47 2/f 10.574 63.1 2.34 75.60 1.53 <0.565 <0.674 WE -3 1015105 Fillet 2483 55 3/f 10.605 49.4 1.77 <5.90 <0.670 <0.595 <0.710 WE -4 1015105 Fillet 1079 47 2/f <0.579 83.4 2.14 <5.65 1.2 <0.569 <0.679 WE -5 1015105 Fillet 2252 60 51f <0.907 39.3 1.38 7L86 <0.670 <0.595 <0.710 WE -6 1015105 Fillet 1180 47 3/m <0.581 47.4 1.83 <130 1.07 <0.572 <0.682 Car C -1 9/27/05 Whole Fish 3011 52 4/f 70.587 65.5 2.9 <s.72 1.2 1.12 <0.688 Ca -2 9/27/05 Whole Fish 2626 53 41m <0,585 903 1.6 <5.71 2 1.21 <0.687 C -3 9/27/05 Whole Fish 3019 54 4/m <0.594 99.6 1.64 <5.79 3.07 1.6 0.876 C -4 9/27/05 Fillet 4975 59 6/f <0.603 46.3 <0.573 1 <5.88 <0.668 <0.593 <0.708 Carp-5 9/27/05 Fillet 2730 56 6/m <0.598 59.9 0.724 <5.83 1.17 0.662 <0.701 Carp-5 (du 9/27/05 Fillet(du licate 2730 56 6/m <0.607 Sl.l 0.581 1 <5.92 0.926 0.602 <0.712 SMBass SMB -1 9/27/05 Fillet 792 35 3/m <0.583 103 2.69 <1.42 1.92 1.07 SMB -1 (dup) 9/27/05 Fillet du licate 792 35 3/m <0.647 116 2.56 Q.05 2.31 1.21 SMB -2 9127/05 Fillet 553 35 41f 70. 592 66.2 9 71.45 04 <0.582 M0.924 SMB -3 9/27/05 Fillet 729 36 4/f <0.673 95.6 1.79 2.56 1.85 0.692 SMB -4 9/27/05 Whole Fish 303 27 3/m <0.584 175 3.98 Q.52 3.57 1.28 SMB -5 9/27/05 Whole Fish 1205 39 5/f 70611 72 3.28 3.2 1.25 . White Bass WB -1 1014105 Fillet 640 33 4/m <0.603 114 3.37 <2.78 1.06 <0.594 <0,708 WB -2 10/4/05 Fillet 812 36 4/f <0.605 100 2.08 <1.80 1.45 <0.595 <0.710 WB -3 10/4105 Whole Fish 692 33 3!m 70.604 223 5.71 71.77 4.26 1.89 1.61 WB -4 10 15 105 Whole Fish 446 28 1/f 70.599 194 4.45 71.46 3.3 1.1 1.12 WB -4(du 1 1015105 Whole fish(dup) 446 28 1/f <0.585 165 4.24 <1.43 3.11 1.52 1.14 WB -5 1015105 Whole Fish 664 33 4lm <0.576 248 4.92 <1.40 3.37 1.47 1.26 Other Gizzard Shad 9/23/05 Composites of 38 whole fish 1436 -15 na A<0.672 B <0.581 C<0.588 37.9 33.4 47.1 2.27 1.87 2.45 18.5 17.2 17.8 0.694 0.817 <0.651 <0.594 <0.571 <0.578 <0.709 <0.681 <0.690 Emerald Shiner 9/27/05 Composites of 40 whole fish 117 -8 na A <0.579 B <0.607 C<0.602 105 107 90.9 2.15 0.706 1.4 2.17 2.44 2.02 2.57 2.6 2.59 0.877 1.17 0.927 <0.679 <0.712 <0.707 < = less than the detection limit; number following this symbol represents the detection limit 2006 MPCA PFC Fish Data numbers listed are: average PFOS concentration (# of fish) <dl — less than the detection limit = 5 ng/g ns — not sampled Samnles were analvzed for the 13 different Derfluorochemicals listed. Average PFOS Concentration n/ b PFBA Bluegdl Smallmouth Largemouth White Walleye Northern White Channel C -5 perfluoropentanoic acid Bass Bass Bass perfluorohexanoic acid Pike I Sucker Catfish Mississippi 170 (5) ns ns 132 (5) ns ns ns ns River vool 3 PFOS C -8 perfluoroo ctane sulfonate 1763 -23 -1 PFOSA C -8 perfluorooctane sulfonamide 754 -91 -6 Mississippi 85 (5) ns ns ns ns ns ns ns River pool 4 perfluoroundecanoic acid 2058 -94 -8 PFDoA C -12 perfluorododecanoic acid 307 -55 -1 Mississippi 65 (5) 96 (5) 85 (5) ns 54 (4) 111 (5) ns 10 (2) River pool 5 Mississippi 61 (5) 73 (5) ns ns 65 (5) ns ns 14 (4) River pool 5a St. Croix River: Taylors Falls to <dl (5) <dl (5) ns ns <dl (5) <dl (5) <dl (5) ns Danbu Lake Calhoun 319 (5) ns ns ns ns ns 49 (5) ns numbers listed are: average PFOS concentration (# of fish) <dl — less than the detection limit = 5 ng/g ns — not sampled Samnles were analvzed for the 13 different Derfluorochemicals listed. CAS # PFBA C -4 perfluorobutanoic acid 375 -22 -4 PFBS C -4 perfluorobutane sulfonate 375 -73 -5 PFPeA C -5 perfluoropentanoic acid 2706 -90 -3 PFHxA C -6 perfluorohexanoic acid 307 -24 -4 PFHxS C -6 perfluorohexane sulfonate 355 -46 -4 PFH A C -7 perfluoroheptanoic acid 375 -85 -9 PFOA C -8 perfluorooctanoic acid 335 -67 -1 PFOS C -8 perfluoroo ctane sulfonate 1763 -23 -1 PFOSA C -8 perfluorooctane sulfonamide 754 -91 -6 PFNA C -9 perfluorononanoic acid 375 -95 -1 PFDA C -10 perfluorodecanoic acid 335 -76 -2 PFUnA C -11 perfluoroundecanoic acid 2058 -94 -8 PFDoA C -12 perfluorododecanoic acid 307 -55 -1 2006 MPCA PFC Fish Data Mississippi River Pool 3 Fish PFC analysis MPCA Species & Sample 1D Sample Date Fillet or Whole Fish Wt (g) Ln (cm) Age/ sex mrl) PFOS (pPb) PFOA (Ppb) PFBA (pP) PFOSA (P b) PFDA (pPb) PFUM (pP) PFDoA (P ) Blue ill BG -1 11/9/06 Fillet 102 17 3/M 440 <1.52 <6.70 1.42 8.05 5.09 4.41 BG -1 11/9/06 Whole Fish 102 17 3/M 815 <1.46 <1.75 6.5 12.3 6,13 4.70 BG -2 11/9/06 Fillet 135 17 3/M 108 1 <1.46 <8.68 3.62 5.36 5.79 14.6 BG -2 1119106 Whole Fish 135 17 31M 187 <1.48 <1.76 10.2 7.6 6.46 14.2 BG -3 11/9/06 Fillet 152 18 3/M 123 <1.51 4.81 <1.41 3.17 <2.01 1.55 BG -3 11/9/06 Whole Fish 152 18 3/M 186 <1.28 0.91 1.03 5.59 2.17 2.34 BG -4 5/2006 Fillet 177 18.5 3/F 87.5 <1.48 <1.77 <1.38 2.36 <1.98 <1.51 BG -5 5/2006 Fillet 160 18 3/M 92.1 <1.47 <1.75 <1.37 <1.67 4.96 <1.50 White Bass WB -1 11/9/06 Fillet 33 12.5 i/J 122 <1.48 <8.00 IL5 4.88 <1.98 2.28 WB -I 11/9/06 Whole Fish 33 12.5 J/J 134 <1.79 <1.70 14.5 6.11 1.73 3.09 WB -2 11/9/06 Fillet 34 13 1/1 154 <1.49 <3.14 8.75 5.9 2.83 2.23 WB -2 11/9/06 Whole Fish 34 13 1/1 161 4.51 <186 10.3 9.5 2.53 2.73 WB -3 11/9/06 Fillet 34 13 1/1 150 <2.51 <1.80 10.9 5.28 2.09 192 W13-3 11/9/06 Whole Fish 34 13 1/1 148 <1.51 <6.58 15.1 73 2.75 4.06 W13-4 11/9/06 Fillet 44 13 1/J 148 <1.48 <2.65 10.6 4.55 4.90 2.71 WB -4 11/9/06 Whole Fish 44 13 1/1 153 <L48 <499 17 7 2.06 4.13 WB -5 11/9/06 Fillet 41 14.5 1/J 86.7 <1.51 <6.24 6.58 4.14 <2.01 <1.54 WB -5 1119106 Whole Fish 41 14.5 1/J 114 <2.10 1.3 7.9 6.33 134 L18 Other Emerald Shiner 11/9/06 Composite of 38 whole fish ^4.5 84.2 <1.43 <1.71 5.21 4.33 <1.91 2.17 Gizzard Shad 11/9/06 Composite of 33 whole fish -9 17.9 <1.25 <1.94 1.53 <1.42 <1.66 <1.27 Mississippi River Pool 4 Fish PFC analysis MPCA Species & Sample ID Sample Date Fillet or Whole Fish Wt (g) Ln (cm) Age/ sex (Yr i) PFOS (P) PFOA (pP) PFBA (pP) PFOSA (pPb) PFDA (pP) PFUnA (PPb) PFDoA (ppb) Blue ill BG -1 5/2006 Fillet 262 20 4/F 98.3 <1.43 <1.70 <1.33 2.51 <1.90 <1.46 BG -2 5/2006 Fillet 152 17.5 3/M 28.1 4.47 <1.75 <1.37 <1.67 4.96 <1.50 BG -3 5/2006 Fillet 158 18 3/F 45.5 <1.52 <1.82 <1.42 4.73 <2103 <1.55 BG -4 1 5/2006 Fillet 125 1 1 3/M 152 <1.48 <1.76 <1.37 3.26 2.76 2.7 BG -5 5/2006 Fillet 146 18 3/M 101 <1.39 4.66 <1.29 2.04 2.46 2.13 2006 MPCA PFC Fish Data Mississippi River Pool 5 Fish PFC analysis MPCA Species & Sample ID Sample Date Fillet of Whole Fish Wt (g) La (cm) Age/ sex (YO/ 0 PFOS (pP) PFOA (PP) PFBA (pPb) PFOSA (PPb) PFDA (pP) PFUnA I (pP) PFDoA (P ) Blue ill BG -1 11/6/06 Fillet 172 19 4/F 40.3 <1.51 1 <1,81 <1.41 <1.72 <2.01 11.54 BG -2 11/6/06 Fillet 252 20 45 94.7 <1.38 <1.64 <1.28 2.17 <1.83 <1.40 BG -3 11/6/06 Fillet 199 21 4/M 42.7 <1.43 <1.71 <133 1.74 <1.91 11.46 BG -4 11/6106 Fillet 189 19 4/F 69.6 <L54 <1.84 4.44 1.97 72.06 11.57 BG -5 11/6/06 Fillet 114 17 3/F 77.2 4.51 71.81 <1.41 2.4 <2.01 <1.54 Smallmouth Bass SMB -1 5/2006 1 Fillet 1512 45 8/F 150 <1.48 <1.76 1.63 3.27 <1.97 <1.50 SMB -2 5/2006 Fillet 131 19 2/J 83.5 <1.45 4.73 <1.35 2.49 <1.93 <1.48 SMB -3 5/2006 Fillet 449 29 41M 47.7 <1.50 <1.80 1.86 2.13 1,00 <1.53 SMB -4 5/2006 Fillet 262 26.5 3/F 93.5 <1.48 <1.77 11.38 2.59 <1.9g 11.51 SMB -5 5/2006 Fillet 565 33 5/M 104 <1.45 <1.74 1.35 2.25 494 11.48 Largemouth Bass LMB -1 5/2006 Fillet 456 30 6/F 82.9 <1.43 <1.70 <1.33 2.59 <1.90 446 LMB -2 5/2006 Fillet 1043 39 7/M 74.3 <1.45 4.73 <1.35 1.66 <1.93 <1.48 LMB -3 5/2006 Fillet 689 34 6/F 85.8 <1.38 <1.64 <1.28 2.48 <1.83 <1.40 LMB -3 (du 5/2006 Fillet 689 34 6/F 96.5 <1.36 <2.56 <1.27 2.74 <1.82 4.39 LMB -4 512006 Fillet 455 29 4/M 107 <1,41 <1.69 <1.32 3.74 <1,88 <1.44 LMB -5 5/2006 Fillet 502 31 5/M 74.6 4.50 <1,80 <1.40 2.57 <.00 <1.53 Walleye WAE -1 5/2006 Fillet 1000 47 7/M 34.3 4.54 11.83 11.43 11.75 1.05 <1.57 WAE -1 ( du p) 5/2006 1000 47 7/M 26.5 <1.54 <1.84 <1.44 4,76 <2.06 <1.57 WAE -2 5/2006 Fillet 339 31 3/J 60.6 <1.48 <1,76 1.94 1.73 <1.97 <1.50 WAE -3 5/2006 Fillet 362 33 3/J 93.2 4.47 <1.75 1.49 <.67 <L96 77.50 WAE -4 5/2006 Fillet 965 43 5/M 27.1 <1.48 <1.77 1.97 1.69 <1.98 <1.51 Northern Pike NOP -1 5/2006 Fillet 1457 58 81F 91.2 <1.45 <1.74 3.43 1.79 4.94 4.48 NOP -2 5/2006 Fillet 2568 64 8/F 224 1.47 <1.75 5.54 2.34 <1.96 <1.50 NOP -2 du 5/2006 Fillet 2568 64 8/F 235 <1.37 <1.64 4.98 2.39 <1.82 <1.40 NOP -3 5/2006 Fillet 214 28 2J 130 <147 <1.75 2.87 2.63 <1.96 <1.50 NOP -4 5/2006 Fillet 710 45 6/J 12.2 <1.42 <1.70 2.52 <1.62 <1.89 <145 NOP -5 5/2006 Fillet 1498 42 6/F 97.5 <13 <1.80 2.86 1.93 <2.00 <1.53 Channel Cat uh CCF -1 5/2006 Fillet 485 31 ffi 9.59 <1.51 <1.81 <1.41 <1.72 1.01 <1.54 CCF -2 5/2006 Fillet 1956 52 5/M <3.32 <1.44 <1.72 <1.34 <1.64 <1.92 <1.47 Other Gizzard Shad 11/6/06 Composites of 40 whole fish -13 20.1 1.48 <1.76 <1.37 <1.68 1.97 <1.50 2006 MPCA PFC Fish Data Mississippi River Pool 5a Fish PFC analysis MPCA Species & Sample 1D Sample Date Fillet or Whole Fish Wt (B) Ln (cm) Age/ sex (Y" l) PFOS (PPb) PFOA (pP) PFBA (Ppb) PFOSA (pP) PFDA (P) PFUnA (P) PFOSA (� ) Blue ill BG -1 5/2006 Fillet 164 17 3/M 34.6 <1.32 <1.58 4.23 4.50 <1.76 <1.35 BG -2 5/2006 Fillet 168 18 3/M 99.2 <1.50 <2.18 <1.39 <1.70 <2.00 <1.53 BG -3 5/2006 Fillet 284 20 4/M 82.9 4.26 <1.55 <1.17 1.65 <1.68 4,29 BG -4 5/2006 Fillet 199 20 4/M 34 <1.60 <1.91 <1.49 <1.82 <2.13 <1.63 BG -5 5/2006 Fillet 188 19 41F 55.5 4.36 <L63 <1.27 <1.55 <L82 <1.39 Smallmouth Bass SMB -1 5/2006 Fillet 813 36 71M 52.3 <1.50 <1.79 <1.39 <1.70 <2.00 <1.53 SMB -2 5/2006 Fillet 819 36 7/M 116 4.41 <1.68 1.39 2.89 <1.88 <1.44 SMB -3 5/2006 Fillet 746 35 61F 67.1 4.50 <1.79 1.43 <1.70 <2.00 <1.53 SMB -4 5/2006 Fillet 377 28 4/M 84.6 <1.48 <1.77 <1.38 2.74 <1.98 <1.51 SMB -5 5/2006 Fillet 672 34 6/M 45 <1.45 <2.38 4.35 <1.65 <1.93 <1.48 Walle e WAE -1 5/2006 Fillet 740 41 5/F 56.4 <1.48 <1.76 1.83 <1.68 <1.97 <1,50 WAE -2 5/2006 Fillet 1454 49 6/F 49.3 <1.49 <1.78 2.15 4.70 <1.99 <1.52 WAE -3 5/2006 Fillet 1125 47 6/F 41 <1.54 <1.84 1.53 <1.76 ¢.06 <1.57 WAE -4 - 5/2006 Fillet 195 25.5 25 75.4 <141 <2.14 <1.32 <1.61 <1.88 <1.44 WAE -5 5/2006 Fillet 2158 55 9/F 103 <1.47 495 1.66 2.74 <1.96 <1.50 Channel Cat ish CCF -1 5/2006 Fillet 2086 57 6/M <3.26 <1.41 <1.69 <132 4.61 <1.88 <1.44 CCF -2 5/2006 Fillet 1489 46 4/F 18.3 <1.38 <1.64 4.28 2.34 <1.83 <1.40 CCF -3 5/2006 Fillet 1147 41 3/F 9.55 <1.55 <1.85 <1.44 <1.77 <2.07 <1.58 CCF -4 5/2006 Fillet 738 39 2/F 1 3.4 <1.46 <1.99 <1.36 <1.66 <1.95 <1.49 2006 MPCA PFC Fish Data St. Croix River Fish PFC anal sis MPCA Sample Fillet or Wt Ln Age/ PFOS PFOA PFBA PFOSA PFDA PFUnA PFDoA Species & Date Whole Fish ly sex s/ ng/g ng/g ng/g ng/g ng/g ng/g ng/g Sample ID (g) (cm) m fl (PPb) (PPb) (PPb) (PPb) (PPb) (PPb) (Pik) Blue ill BG -1 BG -1 u BG -1 BG -2 BG -2 BG -3 BG -3 BG 4 BG -4 BG -5 BG -5 8/11/06 8/11/06 8/11/06 8/11/06 8/11/06 8/11/06 8/11/06 8/11/06 8/11106 8/11/06 8/11/06 Fillet Fillet Whole Fish Fillet Whole Fish Fillet Whole Fish Fillet Whole Fish Fillet Whole Fish 94 94 94 60 60 78 78 76 76 73 73 16.5 16.5 16.5 13 13 4.5 14.5 14 14 15 15 3/F 3/F 31F 2/M 2M 2 F 2/F 2/M 2!M 2/J 2/1 73.57 73.48 <338 74.21 4.22 73.38 3.40 73.37 4.07 <3.48 <3.54 71.93 71.51 <L47 71.54 <1.46 71.47 71.53 <1.46 71.41 <1.51 <1.54 73.85 71.81 <1.75 74.56 <1.75 7188 71.82 7.49 71 .69 <4.78 <1.83 71.44 71Al <1.37 71.44 <1.36 71.37 71.42 71.36 71.32 <1.41 4.43 7177 71.72 <1.67 71.76 <1.66 <1.67 7174 71.66 . <16t 71.72 4.75 7.07 72.01 <1.96 Q.06 <1.95 71.96 7.04 <1.95 718 g ¢.01 7.05 71.58 71.54 <1.50 71.57 <1.49 7150 71.56 <1.49 71.44 <1.54 <1.57 Smal/mouth Bass SMB -1 8/11/06 Fillet 926 37 6/M <3.41 <1.51 <8.80 <138 <1.69 <1.98 <1.51 SMB -1 8/11/06 Whole Fish 926 37 6M tsz <1,50 <lso SMB -2 8/11/06 Fillet 435 29 4/M 73.50 <t.52 71.82 71.42 71.73 7.03 71.55 SMB -2 8/11/06 Whole Fish 435 29 4/M 1.16 71.45 71.74 71.35 7166 71.94 71.48 SMB -3 8/11/06 Fillet 428 30 4/F <3.41 <1.48 <1.77 <1.38 <L69 <1,98 <1.51 SMB -3 8/11/06 Whole Fish 428 30 4/F <3.32 <1.44 7,80 <1.34 2 <1.47 SMB -4 8/7/06 Fillet 419 27 4/F <3.48 <1.51 <1.81 <1.41 1 4.54 SMB -5 8/7/06 Fillet 440 28 4/M <3.52 4.53 <1.82 <1.42 4 4.56 M<116 Walleye WE -1 8/15/06 Fillet. 796 40 5/M <3.48 <1.51 <1.81 <1.41 1 <1.54 WE -2 8/4/06 Fillet 1124 46 6/F 73.57 71.55 <1.85 <t.44 7 7158 WE -3 8/4/06 Fillet 401 33 3/J <3.37 <1.46 <1.75 71.36 5 <1.49 WE -4 8/4/06 Fillet 287 28 3/J <3.40 <1.48 <2.38 <1.37 <1.68 <1.97 WE -5 8/7/06 Fillet 405 32 3/1 73.29 71.43 71.70 71.33 <1.62 <1.90 Northern Pike R<1.40 NOP -1 8/16/06 Fillet 629 43 6/J <3.33 <L45 <1.73 <1.35 4.65 71.93 NOP -2 8/15/06 Fillet 476 42 6/F 73.17 71.38 71.64 <1.28 71.57 71.83 NOP -3 8/16/06 Fillet 1068 48 M <3.30 4.43 <1.71 71.33 7163 <1.91 NOP -3 No) NOP -4 8/16/06 8/7/06 Fillet Fillet 1068 1365 48 58 7?/ M 8/M <3.27 1 <3.27 <1.42 <L42 <1.70 <1.70 <1.32 <1.32 <1.62 1 <1.62 71.89 <1,89 71.45 <1.45 NOP -5 8/16/06 Fillet 526 43 6/F <3.48 <1.51 <1.81 <1.41 <1.72 <.O1 <1.54 White Sucker WTS -1 8/15/06 Fillet 358 31 34 <3.33 <1.45 <L73 <1.35 <165 71.93 4.48 WTS -2 8/15/06 Fillet 572 36 3/F <3.21 <1.39 <1.67 <1.30 <1.59 <1.86 <1.42 WTS -3 8/15/06 Fillet 519 33 31F <3.33 <1.45 <1.73 <1.35 <1.65 <1.93 <L48 2006 MPCA PFC Fish Data Lake Calhoun Fish PFC analysis MPCA Species & Sample ID p Sample Date Fillet or Whole Fish Wt lg) Age/ sex lyrs/ m•f) PFOS ng/g (Ppb) PFOA ng/g (Ppb) PF13A ng/g (Ppb) PFOSA ng/g (PPb) PFDA ng/g (PPb) PFUnA ng/g (PPb) PFDoA n9/9 (ppb) Blue ill d15.5 BG -1 11115106 Fillet 59 3/F 373 <1.40 <I.88 1.63 7.13 2.92 4.23 BG -1 11/15/06 Whole Fish 59 3/F 493 <1.43 1.38 2.60 14.9 4.92 5.53 BG -2 11/15/06 Fillet 62 2/F 356 <1.42 1 <1.70 3.46 7 4.1 6.18 BG -2 11/15/06 Whole Fish 62 13 2/1 438 <1.43 <2.74 4.27 13.34 1 6.82 9.19 BG -3 11/15106 Fillet 65 is 3/F 181 4.50 4.80 1.95 3.28 2.79 4.49 BG -3 11/15/06 Whole Fish 65 15 3/F 280 <1.39 <2.09 5.51 6.9 4.63 5.92 BG -4 11/15/06 Fillet 60 16 3/F 311 <1,46 <135 4.69 5.64 3.34 4.72 BG -4 11/15/06 Whole Fish 60 16 3/F 590 <1.50 <239 6.43 12.0 5.67 8.10 BG -5 11115106 Fillet 68 16 3/F 373 <1.51 <1.81 3.92 8.02 4,01 5.9 BG -5 I1 /15/06 Whole Fish 68 16 3/17 528 <1.45 <1.97 3.47 119 7.73 9.96 White Sucker WTS -1 11115106 Fillet 250 29 21M <3.52 <1.53 <1.82 <1.42 <1.74 <.04 <1.56 WTS -1 11/15/06 Whole Fish 250 29 2/M 2.91 <1.50 <1.79 <1.39 0.92 <.00 <1.53 WTS -1 ( du p) 11115106 Whole Fish 250 29 2/M 1.96 <1.52 <1.82 <1.42 <1.73 <.03 <1,55 WTS -2 11115106 Fillet 309 31 2/J <3.40 <1.48 <1.76 <1.37 <1.68 <1.97 <1.50 WTS -2 du 11115/06 Fillet 309 31 2/J X3.37 <1.46 <1.75 <1.36 <1.66 <1.95 <1.49 WTS -2 11/15/06 Whole Fish 309 31 2/J <3.23 <.29 <L67 <1.30 <1.59 <1.87 <1.43 WTS -3 11/15/06 Fillet 179 27 2/J <3.54 <1.54 <1.83 <i.43 <1.75 <,05 <1.57 WTS -3 11/15/06 Whole Fish 179 27 24 <3.24 <1.41 <1,68 <1.60 <L60 <1.88 <1.44 WTS -4 11/15/06 Fillet 660 35 3/J 49.1 2.39 <1.82 <1.42 4.39 <104 L98 WTS -4 11115106 Whole Fish 660 35 3/J 77 2.28 <1.82 3.72 5.44 1.76 2.65 WTS -5 11/15/06 Fillet 335 29 21J <3.26 <1.41 <1.69 4.32 <1.61 <1.88 4.44 WTS -5 I1 /IS /OG Whole Fish 335 29 2/7 <3.40 4.48 <6.33 q.47 <1.68 <1.97 <1.50 < = less than the detection limit; number following this symbol represents the detection limit 2007 MPCA PFC Fish Data Twin Cities Metro Lakes 2007 MPCA PFC Fish Data River Reaches numbers listed are: average PFOS concentration (# of fish) <dl — less than the detection limit = 5 ng /g ns — notsampled comp — composite; tissue from several fish is combined then PFCs are measured Sam les were anal zed for the 13 different perfluorocheinicals listed Average PFOS Concentration fn g/% ; ppb - Bluegill Bluegill Smallmouth Largemouth White Walleye Northern White Channel perfluoropentanoic acid 2706 -90 -3 ( comp) Bass Bass Bass PFHxS Pike Sucker Catfish MUISSissippi River C -7 perfluoroheptanoic acid 375 -85 -9 PFOA C -8 perfluomoctanoic acid 335 -67 -1 PFOS Brainerd verfluorooctane sulfonate 1763 -23 -1 PFOSA C -8 Perfluorooetane sulfonamide 754 -91 -6 PFNA C -9 perfluorononanoic acid 375 -95 -1 10 (2) ns 13 (5) ns ns 9 (5) 7 (3) ns ns area perfluorododecanoic acid 307 -55 -1 St Croix River Washington County Bluff 23 (5) 12 (5) 15 (5) ns 82(l) 17 (5) ns ns ns Park area numbers listed are: average PFOS concentration (# of fish) <dl — less than the detection limit = 5 ng /g ns — notsampled comp — composite; tissue from several fish is combined then PFCs are measured Sam les were anal zed for the 13 different perfluorocheinicals listed CAS# PFBA C -4 I perfluorobutanoic acid 375 -22 -4 PFBS C -4 verfluorobutane sulfonate 375 -73 -5 PFPeA C -5 perfluoropentanoic acid 2706 -90 -3 PFHxA C -6 Perfluorohexanoic acid 307 -24 -4 PFHxS C -6 pertluorohexane sulfonate 355 -46 -4 PFH A C -7 perfluoroheptanoic acid 375 -85 -9 PFOA C -8 perfluomoctanoic acid 335 -67 -1 PFOS C -8 verfluorooctane sulfonate 1763 -23 -1 PFOSA C -8 Perfluorooetane sulfonamide 754 -91 -6 PFNA C -9 perfluorononanoic acid 375 -95 -1 PFDA C -10 perflucrodecanoic acid 335 -76 -2 PFUnA C -11 perfluoroundecanoic acid 2058 -94 -8 PFDoA C -12 perfluorododecanoic acid 307 -55 -1 2007 MPCA PFC Fish Data Bald Ea le Lake Fish PFC analysis Wt Ln Age/ PFOS PFDA PPBA PFOSA PFDA PFUnA PFDoA Species & Sample Tissue sex (em) ng/g nglg ng/g ng/g ng/g ng/g ng/g Sample ID Date (g) ( b ( rs) ( b b ( b ( b ( b b) Blue Z1 Sample Date Tissue Wt (g) Ln (em) Age/ sex is PFOS ng/g ( b PFOA ng/g ( b PFBA ng/g ( b) PFOSA ng/g ( b PFDA ng ( b b PFUnA ( ppb b ) PFDoA ng/g (ppb BGS -1 5/2/07 Fillet 22 9.5 211 <4.98 <2.49 12.49* Q.49 2.49 2.49 Q.49 BGS -4 5/2/07 Fillet 11 8 1/1 <4.39 Q.19 <2.19* Q.19 2.19 <2.19 Q.19 BGS -5 5/2/07 Fillet 25 11 21M <4.93 Q.46 <2.46* <146 <2.46 <2.46 2.46 BGS -6 5/2/07 Fillet 79 15.5 5/M <4.76 <2.38 Q.38* 2.38 2.38 Q.38 238 BGS -9 5/2/07 Fillet 88 16 5/M 14.61 2.30 <2.30* <2.30 Q.30 Q30 2.30 BGS -comp 5/2/07 Fillet 50a 12a 2/1 <4.78 2.39 <2.39 Q.39 <2.39 <2.39 Q.39 BGS -comp 2007 Fillet 3la t2a 34 Q.42 12.42 12.42 2.99 2.42 2.56 Black Crapp ie BKS -1 5/2/07 Fillet 95 17.5 4/F 10.5 Q.50 <2.50* 2.50 2.50 <2.50 Q.50 BKS -2 5/2/07 Fillet 98 17 41F 7.24 <2.39 Q.39* 2.39 2.39 2.39 Q.39 BKS -3 - 5/2/07 Fillet 236 24 7/F 7.89 <235 2.35 2.35 12.35 12.35 Q.35 BKS -4 5/2/07 Fillet 104 19 511 4.69 2.30 2.30 Q.30 12.30 Q.30 2.30 BKS -5 5/2/07 Fillet 97 18 5/F 7.54 2.58 12.58 Q.58 12.58 Q.58 Q.58 LMB- 4(dnp) Fillet 1 103 12.45 2.45 1 12.45 6.3 1 5.02# Lar emouth Bass LMB -1 5/2/07 Fillet 992 38 7/F <5.00 <2.50 2.50* <2.50 <2.50 Q.50 2.50 LMB -2 5/2/07 Fillet 684 34 6/F <4.69 235 12.35* Q.35 <2.35 <2.35 2.35 LMB -3 5/2/07 Fillet 764 34 6/F 6.18 <2.35 Q.35* Q.35 <2.35 Q.35 <2.35 LMB -4 5/2/07 Fillet 452 31 51F 14.81 12.40 Q.40* Q.40 Q.40 Q.40 <2.40 LMB -5 5/2/07 Fillet 560 31.5 51M <5.03 <2.51 2.51* 1 <2.51 1 12.51 Q.51 Q.51 Cedar Lake Fish PFC analysis Henne in Coun Species & Sample ID Sample Date Tissue Wt (g) Ln (em) Age/ sex is PFOS ng/g ( b PFOA ng/g ( b PFBA ng/g ( b) PFOSA ng/g ( b PFDA ng ( b b PFUnA ( ppb b ) PFDoA ng/g (ppb Blue gill BGS -1 2007 Fillet 24 1 12 3/F 33.5 Q.50 <2.50 2.50 2.50 <2.50 2.50 BGS -5 2007 1 Fillet 56 1 15.5 5/J 31 2.39 <2.39 2.39 2.46 2.39 Q.39 BGS -6 2007 Fillet 25 1 11.5 2/F 17.9 2.50 2.50 2.50 2s0 <2.50 12.50 BGS -8 2007 Fillet 47 145 4/F 30.9 12.37 2.37 2.37 3.11 <2.37 2.37 BGS -10 2007 Fillet 24 12 2/1 27.8 2.51 2.51 12.51 5.25 3.77 Q.51 BGS -comp 2007 Fillet 3la t2a 34 Q.42 12.42 12.42 2.99 2.42 2.56 Largemouth Bass LMB -1 2007 Fillet 531 33 51M 53.8 2.46 Q.46 <2.46 4.88 3.54 2.58 LMB -2 2007 Fillet 488 31 5/F 70.8 2.40 <240 <2.40 6.7 3.49 3.39# LMB -3 2007 Fillet 1166 43 10/F 56.3 2.48 2.48 2.48 8.27 4.61 3.25# LMB -4 2007 Fillet 1592 46 li/F 108 2.42 2.42 2.42 5.22 3.67 5.270 LMB- 4(dnp) Fillet 1 103 12.45 2.45 1 12.45 6.3 1 5.02# 2007 MPCA PFC Fish Data Cedar Lake Fish PFC analysis Scott Coun Species & Sample ID Sample Date Tissue Wt (gl Ln (eml Age/ sex rs PFOS ng/g b PFOA ng/g ( b ) PFBA ng/g (ppb PFOSA ng/g b PFDA ng/g b PFUnA ng/g b PFDoA ng/g ( b Blue ill BGS -1 8/24/07 Fillet 16 9 1/1 <4.81 <2.40 <2.40 2.40 2.40 2.40 2.40 BGS -4 8/24/07 Fillet 19 10 2/J <6.76 2.49 <2.49 2.49 2.49 2.49 2.49 BGS -5 8/24/07 Fillet 97 17 6/M <4.81 2.40 2.40 Q.40 2.40 <2.40 2.40 BGS -6 8/24/07 Fillet 31 NA 4/M <4.95 2.48 <6.43 2.48 2.48 <2.48 2.48 BGS -9 8/24/07 Fillet 82 16 5/M <4.81 2.40 2.40 2.40 2.40 2.40 <2.40 BGS -comp 8/24/07 Fillet 59a 12a <4.85 2.43 2.43 2.43 2.43 2.43 2.43 Largemouth Bass LMB -1 8/24/07 Fillet 1292 41 9/M 6.24 2.46 <2.46 2.46 2.46 <2.46 2.46 LMB -2 8/24/07 Fillet 1528 NA 9/F <4.90 2.45 Q.45 2.45* <2.45 <2.45 2.45 LMB -3 8/24/07 Fillet 1264 40 8/F <4.67 2.34 2.34 2.34* 2.34 2.34 2.34 LMB -4 8/24/07 Fillet 857 40 8/M <4A <244 <2.44 2.44* 2.44 2.44 2.44 LMB -5 8/24/07 Fillet 1110 42 9/M <4.74 <3.85 2.37 2.37* 237 2.37 2.37 LMB -5(du 2007 Fillet 1546 65 5/M <5.03 <151 2.51 2.51* <2.51 Q.51 <251 NP -7 2007 Fillet 896 5] 4/M 10.6 2.44 Q.44 72.44 72.44 2.44 72.44 Walleye W&1 8/24/07 Fillet 714 43 7M 1 <4.95 <2.48 <4.04 2.48* 2.48 <2.48 2.48 Centerville Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln (em) Age/ sex rs PFOS ng/g ( b ) PFOA ng/g (ppb PFBA ng/g b PFOSA ng/g b PFDA ng/g b PFUnA ng/g ( b ) PFDoA ng/g (ppb Blue gill BGS -1 2007 Fillet 69 15 4/F 12.8 2.43 2.43 <2.43 2.43 2.43 243 BGS -2 2007 Fillet 62 14.5 4/M 6.24 2.45 2.45 2.45 <2.45 2.45 <2.45 BGS -4 2007 Fillet 42 12.5 3/J 9.94 <2.45 <2.45 2.45 2.45 2.45 2.45 BGS -8 2007 Fillet 61 15 4/F <4.95 2.48 2.48 2.48 2.48 <2.48 2.48 BGS -9 2007 Fillet 74 15 41M 6.74 2.48 <2.48 2.48 2.48 <2.48 <2.48 BGS -comp 2007 Fillet 72a 15a 8.71 <2.23 2.23 2.23 <2.23 2.23 2.23 Northern Pike NP -1 2007 Fillet 1609 58 41F 9.01 2.49 <2.49 2.49 2.49 <2.49 2.49 NP -2 2007 Fillet 878 49 4/1 10.2 2.48 2.48 <2.48 2.48 <2.48 <148 NP -3 2007 Fillet 793 46 4/J 9.03 243 Q.43 2.43 2.43 <2.43 2.43 NP -4 2007 Fillet 1067 56.5 48 6.3 2.74 2.50 2.50 2.50 2.50 2.50 NP -5 2007 Fillet 1183 54 4/M 7.84 2.51 2.51 <2.51 2.51 2.51 2.51 NP -6 2007 Fillet 1546 65 5/M 11.4 <2.40 2.40 72 .40 72.40 <2.40 2.40 NP -7 2007 Fillet 896 5] 4/M 10.6 2.44 Q.44 72.44 72.44 2.44 72.44 4 2007 MPCA PFC Fish Data Colbv Lake Fish PFC anal sis Species & Sample ID Sample Date Tissue Wt (g) Ln (em) Age/ sex ( rs PFOS ng/g b PFOA n ( b PFBA ( b ppb PFOSA b 2pb PFDA ( b T)Pb PFUnA ng/g ( b ) PFDoA ng/g (PPb Blue 'll BGS -4 6/6/07 Fillet 21 9.5 1/M 213 <A4 <2A Q.44 3.09 12 .44 12.44 BGS -5 6/6/07 Fillet 31 12 2/F 23.99 Q.46 <4.03* Q.46 12.46 1 Q.46 12.46 BGS -7 6/6/07 Fillet 34 12.5 25 32.8 Q.49 <3.10* <2.49 Q.49 Q.49 Q.49 BGS -9 6/6/07 1 Fillet 35 12 2/F 13# Q.50 <2.50* Q.50 Q.50 <2.50 <2.50 BGS -10 6(6/07 Fillet 29 tl 2/F 18.94 Q.49 <2 .49* <2.49 Q.49 Q.49 <2.49 BGS -owo 6/6/07 Fillet 23a NA 23.4 Q.40 Q.40 Q.40 Q.40 <2.40 12.40 Black Cravvie BKS -2 6/6/07 Fillet 4z 14 3 F 16.6 <2.50 12.50* Q.50 2.84 12.50 12.50 BKS -4 6/6(07 Fillet 47 14.5 3/M 13.2# QV<2.43<2.43 45 <2.45 <2.45 Q.45 <2.45 Q.45 BKS -5 6/6/07 Fillet 47 14.5 3/M 104 Q.36* Q.35 Q.35 12.35 Q.35 BKS -7 1B 6/6/07 Fillet 46 15 3/M 57.6 Q.30* 12.44 Q.44 Q.44 Q.44 _8 6/6/07 Fillet 34 13.8 3/F 63.4 Q.50* 12.48 Q.48 12.48 Q.48 BKS -com 6(6/07 Fillet 37a 13a fl<.40 Q.43 <2.43 12.43 12.43 Como Lake Fish PFC anal sis Species & Sample ID Sample Date Tissue Wt (g) Ln (em) Age/ sex rs PFOS ng/g ( b PFOA ng/g ( b b PFBA ng/g ( b ) PFOSA ng/g ( b PFDA ng/g ( b PFUnA ng/g b) PFDoA ng/g ( b) Blue ill BGS -3 5/1/07 Fillet 31 II 2/F 394 12.34 Q.34* 154 3.71 4.66 5.99 BGS 4 5/1/07 Fillet 29 t 2 3 32.69 12.50 12.50* 3.8 188 3.84 5.21 BGS -6 5/1/07 Fillet 99 16 5/M 34.2 2.50 12.50* 4.2 Q.50 <2.50 4.03 BGS -8 5(1/07 Fillet 61 14.5 4/M 20.6 Q.43 <2.43* 2.84 12.43 2.75 3.72 BGS -10 5/1/07 Fillet 93 16 5/F 23.1 Q.49 12.49* Q.49 Q.49 2.65 3.08 BGS -cem 5/1/07 Fillet. 47a 13a 28.1 Q.49 12.49 2.98 Q.49 12.49 4.45 Black Cra le BKS -1 5/1(07 Fillet 141 17 4/M 59.7 Q.42 <2.42* 3.09 10.6 7.93 BKS -2 5/1(07 Fillet 69 16 4/M 44.9 12.53 Q.53* Q.53 6.69 K4.97 6.07 BKS -3 5(1/07 Fillet 408 28 8/F 104 Q.36* 3.14 15.2 10.5 BKS -4 5(1/07 Fillet 158 20.5 5/M 57.6 Q.30* Q.30 10.6 6.95 BKS -5 5/1/07 Fillet 817 32 ION 63.4 Q.50* Q.50 10.3 5.88 fl<.40 Lar emouth Bass LMB -1 5/1/07 Fillet 867 37 7/F 29.5 Q.40* 2.42 4.04 4.35 6.68 Northern Pike NP -1 5/1/07 Fillet 2129 66 SIM 54.4 12.48 Q.48* 20 7.7 3.93 5.08 NP -I(dup 5/1/07 Fillet 45.2 12.36 <2.36* 18.6 7.69 5.03 6.22 NP -2 5/l/07 Fillet 838 49 4/M 34.6 Q.45 12.45* 15.8 5.92 4.83 8.47 NP-3 1 4 5/1(07 Fillet 858 48 4 M 44.7 Q.48 12.48* 15.6 5.5 5.12 6.45 NP 5/1/07 Fillet 746 49 4/M 47.3 Q.43 Q.43* 19.1 7.51 5.23 7.42 2007 MPCA PFC Fish Data Demontreville Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln (cm) Age/ sex rs PFOS ng/g b PFOA n g/g n b PFBA gig n (ppb) PFOSA gig n b PFDA rig ( b PFUnA g/g n b PFDoA g/9 (ppb) Blue ill BGS -1 4/30/07 Fillet 26 11 2/F 27.1# <2.49 <2.49* <.49 3.04 <2.49 <2.49 BGS -5 4/30/07 Fillet 20 11 2/F 35.39 <.42 <242* <.98 <2.42 <2.42 <2.42 BGS -6 4/30/07 Fillet 75 14 4/M <5.00 <2.50 <.50* <2.50 <2.50 <2.50 <2.50 BGS -8 4/30/07 Fillet 137 17.5 6/M 11.9 <2.42 <.42* <.42 <2.42 <.42 <2.42 BGS -10 4/30/07 Fillet 134 18.5 7/M <5.00 <2.50 <.50* <2.50 <.50 <.50 <.50 BGS -COm 4/30/07 Fillet 64a 13a 8.46 <2.42 <2.42 <2.42 <.42 <.42 <.42 Black Cra ie Largemouth Bass BKS -1 LMB-1 4/30107 Fillet 686 33 5/M 41.8 <.42 <.42* <2.42 <2.42 <2.42 <.42 LMB -2 4/30/07 Fillet 1012 39 7/F 32.9 <2.50 <.5* <.50 <2.50 <2.50 <2.50 LMB -2dup) 4/30/07 Fillet 25.5 7/F 550 25.8 <.43 <.43* <.43 <2.43 <2.43 243 LMB -3 4/30/07 Fillet 612 33 5/F 27 <.40 <.40* <.40 <A0 <.40 <.40 LMB -4 4/30/07 Fillet 1023 39 7 M 44.9 <.48 <.48* <.48 <.48 <2.48 <.48 LXM 4/30/07 Fillet 877 37.5 7 M 84.4 <.30 <30* <.30 <.30 2.88 <.30 Elmo Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln (ern) Age/ sex rs PFOS ng/g b PFOA ng/g b PFBA ng/g b PFOSA ng/g b PFDA ng/g b PFUnA ng/g ( b ) PFDoA ng/g (ppb Blue ill BGS -2 5/2/07 Fillet 16 10 2/3 291!1 <2.48 <.48* <.48 <2.48 <2.48 <2.48 BGS -4 5/2/07 Fillet 19 10 2/M 2174 <.49 <.49* <.49 <.49 <2.49 <.49 BGS -8 5/2/07 Fillet 42 13 3/7 149 <.48 <.48 <.48 <.48 <.48 <.48 BGS -9 5/2/07 Fillet 30 12.5 3/S 233 20.1 <4.24 <4.24 <4.24 <4.24 <4.24 BGS -10 5/2/07 Fillet 35 13 3/F 345 <3.11 <3.11 <3.11 <3.11 <3.11 <3.11 BGS -comp 5/2/07 Fillet 25a lla 302 <2.43 <.43 <.43 <.43 <.43 <.43 Black Cra ie BKS -1 5/2/07 Fillet 228 24 7/1 374 <.36 <.36 <2.36 3.13 <.36 <236 BKS -2 5/2/07 Fillet 369 28 8/F 574 <2.42 <2.42 <.42 6.38 <2.42 <.42 BKS -3 5/2/07 Fillet 292 25.5 7/F 550 <2.34 <.34 <.34 3.42 <2.34 <.34 BKS -4 5/2/07 Fillet 209 22 6/F 534 <2.63 <.36 <.36 3.82 <.36 <.36 BKS -5 5/2/07 Fillet 189 23 6/F 443 <2.56 <.56 <.56 3.14 <.56 <2.56 Largemouth Bass LMB -1 5/2/07 Fillet 470 31 5/M 643 <2.54 <.54 <.54 4.44 <2.54 <.54 LMB -2 5/2/07 Fillet 672 35 6/17 431 <2.43 <.43* <.43 <.43 <.43 <.43 LMB -3 5/2/07 Fillet 894 37 7/17 653 <.50 <.50* 2.50 3.94 <.50 <.50 UM-3(du) 5/2/07 Fillet 660 <.51 <.5t* <.51 4.06 <2.51 <.51 LMB -4 5/2/07 Fillet 1062 39 7/F 711 1.40 <.40* <.40 4.32 to LMB -5 5/2/07 Fillet 698 33 5/M 281 <2.55 <2.55 <.55 <.55 <.55 <2.55 2007 MPCA PFC Fish Data Gervais Lake Fish PFC anal sis Age/ PFOS PFOA PFBA PFOSA PFDA PFUnA PFD-A Wt Ln Species & Sample sex Tissue ng/g ngJg ng/g ng/g ng/g ng/g nag Sample ID Date (g) (em) b ( b ) (ppb) b rs b b ( ) (ppb Blue gill Blue ill BGS -2 5/1/07 Fillet 6 7.5 1/1 1754 107# ¢.69 12.69* <3.50* ¢.69 5.73 2.7 12.69 BGS -5 5/1/07 Fillet 6 7 t/J <3.50 <3.50 5.43 3.57 <3.50 BGS -7 5/1/07 Fillet 75 16 5/F 148 Q.31 12.31 Q.31 6.444 2.574 <2.3t ¢.3t BGS -9 5/1/07 Fillet 90 17 6/F 90.5 <146 <2.46 12.46 ¢.46 ¢.46 BGS -10 5/1/07 Fillet 68 15 4/F 399 <2.30 12.30 ¢.30 1230 ¢.30 ¢.30 BGS -com 5/1/07 Fillet 34a 10a Fillet 100 12.45 12.45 <7.35 3.8 <2.45 12.45 Q.44 1 <2.44 1 <2.4a ¢.44 Black Crapp ie EHEEI Lar emouth Bass MFillet373 t294/J BKS -1 5/1/07 Fillet 171 23 6/F 132 <2.36 ¢.36 Q.36 4.33 Q.36 12.36 BKS -2 5/1/07 Fillet 86 16 4/M 166 ¢.31 12.31* ¢.31 9.5 3.37 ¢31 BKS -3 5/1/07 Fillet 122 19 51M 206 <2.35 <2.35 ¢.35 11.4 4.08 2.78 BKS -4 5/1/07 Fillet 180 22 6 M 170 12.29 12.z9* ¢.38* <2.29 10.9 5.09 8.41 BKS -5 5/1/07 Fillet 65 16 4/F 112 Q.38 <2.38 4.65 ¢.38 <2.38 1 Q.42 1 10.1 1 4.65 1 3.66 Lar emouth Bass LMB -1 5/1/07 Fillet 2268 47 1 I 159 ¢.49 <2.49* Q.49 6.23 2.97 12.49 LM13-2 5/1/07 Fillet 488 31 5/M 153 ¢.31 12.31 <2.31 6.24 3.95 12.31 LMB -3 5/1/07 Fillet 385 29 4 M 227 <2.36 Q.36* <2.36 10.7 5.79 2.38 LMB -4 5/1/07 Fillet 661 33 S M 221 <2.13 12.13 <2.t3 8.67 6.23 5.87 LMB -5 5 /U07 Fillet 311 28 4 F 58 ¢.19 <2.19 ¢.19 7.42 3.85 Q.19 Green Mountain Lake Fish PFC anal sis Age/ PFOS PFDA PFBA PFOSA PFDA PFUnA PFDoA Wt Ln sex Species & Sample Tissue ng/g ng/g ng/g ng/g ng/g nag Sample ID Date ( (em) b ) ( ppb rs ( b b b b ( b b ) { b Blue ill Blue ill BGS -1 5/9/07 Fillet 50 13.5 3/J <4.85 ¢.43 12.43 ¢.43 <2.43 Q.43 Q.43 BGS -3 5/9/07 Fillet 118 17.5 6/M <4.98 Q.49 12.49 <2.49 ¢.48 12.48 <2.48 BGS -5 5/9/07 Fillet 133 19 7Rv[ <4.40 Q.45 12.45 ¢.45 Q.45 ¢.45 Q.45 BGS -6 5/9/07 Fillet 85 16 5/F 1 <4.85 1 <2.43 1 <2.43 1 Q.43 1 Q.43 1 <2.43 I ¢.43 BGS -8 5/9/07 Fillet 50 13.5 3/M 1 <4.85 1 12.43 1 <2.43 <2.43 Q.43 ¢.43 <2.43 BGS -comp I 5/9/OZ Fillet 65a I 14a <4.88 ¢.4a ¢.46 <2.44 Q.44 1 <2.44 1 <2.4a Harriet Lake Fish PFC anal sis Age/ PFOS PFOA PFBA PFOSA PFDA PFUM PFDoA Wt Ln sex Species & Sample Tissue ng/g ng/g ng/g ng/g ng/g ng/g ng/g Sample ID Date (g) (cm) b) ( b ( b b) ( s ( b b) Blue ill BGS -5 8/17/07 Fillet 17 9 1/1 108 ¢.40 <2.40 Q.40 01 12.40 <140 BGS -6 8/17/07 Fillet 42 10 2/F 78.1 <2.48 Q.48 ¢.48 12.48 <2.48 <2.48 BGS -7 8/17/07 Fillet 12 7 15 124 12.43 <2.43 <2.43 6.98 <2.43 12.43 BGS -9 8/17/07 95.9 <2.46 ¢.46 Q.46 12.46 ¢.46 Q.46 BGS -10 8/17/07 163 ¢.40 ¢.40 <2.40 4.98 5.27# 4.12 BGS -co 8/17/07 89.3 <2.44 <2.44 <2.44 2.59 <2.44 ¢.44 EHEEI Lar emouth Bass MFillet373 t294/J LMB -1 8/17/07 146 <538 <249 ¢49* 87 UM-2 8/17/07 205 <166 LMB -3 8/17/07 150 ¢.39 12.39 <2 39* 9.25 3.71 3.64 LMB -4 8/17/07 Fillet 963 39 8/M 254 <4.20 <2.43 12.43* 0 5.28 7.1 LMB -5 8/17/07 Fillet 866 40 8/F 170 ¢.42 1 Q.42 1 Q.42 1 10.1 1 4.65 1 3.66 2007 MPCA PFC Fish Data Hiawatha Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln (cm) Age/ sex rs PFOS neg b PFOA ng/g b PFBA ng/g b PFOSA ng/g ( b ) PFDA ng/g ( b ) PFUnA ng/g ( b ) PFDoA ng/g (PPb Blue gill BGS -2 2007 Fillet 73 16 5/M 35 <2.48 <2.48 <2.48 <2.48 <.48 <2.48 BGS -6 2007 Fillet 94 18 61M 15.7 <.48 <.48 <148 <.48 <.48 <.48 BGS -7 2007 Fillet 36 13 3/F 15.5 <A8 <2.48 <.48 <.48 <2.48 <.48 BGS -9 2007 Fillet 8 8 1/1 31.8 <2.43 <.43 <.43 <.43 <.43 <.43 BGS -10 2007 Fillet 5 7.8 1/1 31.9 <3.55 <3.55 <3.55 <3.55 <3.55 <3.55 BGS -comp 2007 Fillet 42a 12a 27.3 <.42 <.42 <.42 <.42 <.42 <2.42 Black Cra de BKS -1 2007 Fillet 73 19 51F 36.6 <.50 <.50 <2.50 2.7 <.50 <150 BKS -2 2007 Fillet 103 21.5 6/M 71.7 <.35 <2.35 <.35 3.94 <.35 4.75 BKS -3 2007 Fillet 71 18 4/F 35.1 <.30 <230 <2.30 2.32 <.30 <30 BKS -4 2007 Fillet 83 18 4/F 33.5 <.45 <.45 <.45 <.45 <.45 <2.45 BKS -5 2007 Fillet 64 17 4/F 21 <2.50 <2.50 <2.50 <.50 <.50 <2.50 Northern Pike NP -1 6/19107 Fillet 1140 56 4/M 17.1 <2.49 <2.49 3.65 <2.49 <2.49 <2.49 NP -2 6/19/07 Fillet 738 46 41F 36.7 <4.60 <2.49 2.64 <2.49 2.98 158 NP -3 6/19/07 Fillet 927 51 4/M 163 <2.51 <2.51 2.95 <2.51 <2.51 <2.51 NP -4 6/19/07 Fillet 1192 NA 4/F 59.5 <2.46 <2.46 6.2 433 3.6 4.99 NP- 4(dup) 65.4 <2.46 <2.46 5.25 4.86 106 5.58 NP -5 6/19/07 Fillet 2530 74 6/F 14.5 <2.46 <2.46 4.17 <2.46 <2.46 <2.46 NP -6 6/19/07 Fillet 3700 77 6/F 25.6 <2.49 <2.49 3.86 <2.49 2.72 <2.49 2007 MPCA PFC Fish Data H des Lake Fish PFC its sis Wt Ln Age/ PFOS PFOA PFBA PFOSA PFDA PFUnA PFDoA Species & Sample Tissue (g) (g) (em) n ppb nglg ppb ppb ppb ng/g Sample ID Date ( s ( b b) ( b ( b ( b) ( b ) (pgb) Blue ill Sample Date Ti55U0 L . (cm Age/ sex rs PFOS ng/g ( b PFOA ng/g b PFBA ng/g ( b) PFOSA nglg b) PFDA ng/g ( b PFUnA ng/g ( b PFDoA ng/g b) BGS -1 7/24/07 Fillet 9 7 1/1 X5.05 <2.53 ¢.53 Q.53 ¢.53 Q.53 2.53 BGS -5 7/24/07 Fillet 9 9 18 <5.08 2.54 2.54 2.54 Q.54 2.54 <2.54 BGS -6 7/24/07 Fillet 130 17 61F <4.85 .43 I 2.43 <143 2.43 2.43 ¢.43 BGS -7 7/24/07 Fillet 127 17 6/M <4.83 .42 2.42 2.42 <2.42 2.42 Q.42 BGS -10 7/24/07 Fillet 123 17.5 6/F <4.95 2.48 2.48 <2.48 2.48 2.48 <148 BGS- 10 du 7/24/07 Fillet 55 15 4/M <4.90 2.45 2.45 <2.45 2.45 <2.45 2.45 BGS -comp 7/24/07 Fillet 62a 12a <4.41 2.20 2.20 2.20 2.20 <2.20 2.20 Black Crapp ie Black Crappi e BKS -1 BKS -1 7/24/07 Fillet 124 20 5/F <4.88 ¢.44 ¢.45 ¢.44* 2.44 <2.44 Q.44 BKS -1 (du) Fillet Fillet 19 5/1 <4.65 <4.93 Q.46 ¢.46 ¢.46* ¢.46 <2.46 2.46 BKS -2 7/24/07 Fillet 178 23 6/F <4,90 2.95 2.45 ¢.45* 2.45 2.45 <2.45 BKS -3 7/24/07 Fillet 167 22.5 6/F <4.78 <4,24 2.39 2.39* 2.39 2.39 2.39 BKS -4 7/24/07 Fillet 206 24 7/F <4.88 2.44 2.44 2.44* 2.44 2.44 2.44 BKS -5 7/24(07 Fillet 224 25 7/M <4.90 2.45 <2.45 2.45* 2.45 2.45 2.45 BKS -6 7/24/07 Fillet 220 25 7/F <4.90 2.87 <2.45 <2.45* 2.45 2.45 2.45 Fillet 2000 57 4/F <5.54 <2.40 2.40 <2.40 2.40 2.40 2.40 NP -2 7/24/07 Northern Pike 3700 76 6/M <4.90 2.45 2.45 <2.45 2.45 <2.45 2.45 NP -2 du NP -1 7/24/07 Fillet 2170 68 5/M <4.93 ¢.46 ¢.46 ¢.46 ¢.46 2.46 Q.46 NP -2 7/24/07 Fillet 631 48 4¢.20 <2.20 ¢.zo ¢.zo 2.2o Q2o NP -3 7/24/07 Fillet 741 46 <2.26 ¢.26 ¢.26 2.26 ¢.26 2.26 7/24/07 Fillet 2342 68 2.35 <2.35 2.35 ¢.35 2.35 2.35 ¢.33 ¢.33 <2.33 Q.33 <2.33 NP -5 7/24/07 Fillet 3445 74 <2.37 1 2.37 i Q.37 2,37 2.37 2.37 Inde endence Lake Fish PFC anal sis Species & Sample ID Sample Date Ti55U0 L . (cm Age/ sex rs PFOS ng/g ( b PFOA ng/g b PFBA ng/g ( b) PFOSA nglg b) PFDA ng/g ( b PFUnA ng/g ( b PFDoA ng/g b) Blue ill E14 BGS -4 7/24/07 Fillet 10 2/J 5.1 2.50 2.50 <2.50 2.50 2.50 <250 BGS -6 7/24/07 Fillet l0 2/J <4.88 Q.44 2.44 Q.44 2.44 Q.44 <2A4 BGS -7 7/24/07 Fillet 9.5 15 5.41 2.50 1 2.50 2.50 2.50 <2.50 <150 BGS -8 7/24/07 Fillet 45 14 4/1 <4.83 2.42 2.42 2.42 2.42 2.42 2.42 BGS -9 7/24/07 Fillet 55 15 4/M <4.85 <2.43 <2.43 2A3 2.43 2.43 2.43 BGS -cOm 7/24/07 Fillet 45a 13a <4.88 2.44 <2.44 <2.44 2.44 2.44 2.44 Black Crapp ie BKS -1 7/24/07 1 Fillet 70 18 4/F <4.95 248 ¢.48 Q.48 <2.48 2.48 2.48 BKS -2 7/24/07 Fillet 78 19 5/1 <4.65 2.33 2.33 <2.33 ¢.33 ¢.33 2.33 BKS -3 7/24/07 Fillet 81 18 4/M <5.00 2.50 <3.22 <2.50 2.50 Q50 2.50 BKS -4 7/24/07 Fillet 81 19 5/M <4.93 ¢46 2.46 2.46 2.46 2.46 2.46 BKS -5 7/24/07 Fillet 139 22 6/F <4.93 246 2.46 2.46 2.46 2.46 2.46 Northern Pike NP -1 7/24/07 Fillet 2000 57 4/F <5.54 <2.40 2.40 <2.40 2.40 2.40 2.40 NP -2 7/24/07 Fillet 3700 76 6/M <4.90 2.45 2.45 <2.45 2.45 <2.45 2.45 NP -2 du <4.95 Q.48 ¢.48 ¢.48 2.48 <2.48 2.48 2007 MPCA PFC Fish Data Jane Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln (em) Age/ sex ( rs) PFOS ng/g ( b PFOA ng ( b b PFBA i)pb b PFOSA PPb b PFDA vb b PFUnA Ppb b PFDoA ng/g ( b Blue gill BGS -4 6/07 Fillet 16 10.5 25 20.7 <2.46 Q.46* Q.46 Q.46 Q.46 Q.46 BGS -6 6/07 Fillet 99 18 61F 8.62# Q.50 Q.50* Q.50 <2.50 2 50 <2.50 BGS -7 6/07 Fillet 73 17.2 6/M 463 Q.44 Q.44* Q.44 Q.44 Q.44 <2.44 BGS - 7 du 6/19/07 Fillet 42 13 3/M 36.5# <2.48 <2.48* Q.48 Q.48 Q.48 Q.48 BGS -8 6/07 Fillet 18 10.6 2/J 12.2# <2.50 <2.50* <2.50 <2.50 Q.50 Q.50 BGS -10 6/07 Fillet 95 NA 4/M <4.95 Q.48 <2.48* Q.48 <2.48 <2.48 Q.48 BGS -comp 6/07 Fillet 43a He 7.76 QA6 Q.46 Q.46 <2.46 <2.46 <146 Black Crappie BKS -1 6/07 Fillet 65 15 3/M 13.64 Q.40 <2.40* <2.40 Q.40 a.40 Q.40 BKS -2 6/07 Fillet 109 18.2 5/M 26.2 Q.40 <2.40* QAO Q.40 Q.40 <2.40 BKS -3 6/07 Fillet - 78 17.8 4/F 10.24 <148 <148* Q.48 Q.48 <2.48 <2.48 BKS -4 6/07 Fillet 63 16.5 41M 39.7 Q.49 Q.48 Q.48 Q.48 Q.48 <2A8 BKS -5 6/07 Fillet 96 19.5 51M 34.2 Q.45 Q.45 Q.45 Q.45 Q.45 Q.45 BKS -6 6/07 Fillet 99 21 6/F 19.5 <2.46 Q.46 Q.46 Q.46 <2.46 Q.46 BKS -7 6/07 Fillet 115 20 5/M 34.84 Q.43 Q.43 Q.43 Q.43 Q.43 <2.43 BKS -7 (dup) 21.9# <142 Q.42 <2.42 Q.42 <2.42 Q.42 BKS -8 6/07 Fillet 108 19 5/M 21.7 <2.46 Q.46 <2.46 <146 Q.46 Q.46 Lar emouth Bass LMB -1 6/07 Fillet 507 33 5/M 35.1 <2.49 Q.49 <2.49 Q.49 Q.49 <2.49 LMB -2 6/07 Fillet 535 36 7/M 38.1 <2A9 Q.49 <2.49 Q.49 Q.49 Q.49 LMB -3 6/07 Fillet 599 33 5/M 83.4 <3.65 <5.00 <2.49 3.32 2.82 Q.49 LMB -4 6/07 Fillet 525 36 7/M 25.8 Q.43 Q.43 Q.43 Q.43 <2.43 Q.43 LMB -5 6/07 Fillet 809 1 NA I 6/F 53.6 <2.44 Q.97 Q.44 <2.44 Q.44 Q.44 Johanna Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln (CM) Age/ sex rs PFOS ng/g b PFOA ng/g b PFBA ng/g ( b) PFOSA ng/g b) PFDA ng/g ( b ) PFUnA ng/g ( b ) PFDoA ng/g ( b) Blue ill BGS -1 6/19/07 Fillet 71 16 5/M 183 Q.44 <2.44* Q.44 Q.44 <2.44 Q.44 BGS -2 6/19/07 Fillet 56 14.5 41M 1844 Q.43 Q.43* Q.43 4.02 Q.43 Q.43 BGS -3 6/19/07 Fillet 94 18 6/M 176# Q.40 Q.40* <2.40 3.85 3.86 7.34 BGS -6 6/19/07 Fillet 42 13 3/M 207# Q.46 Q.46* <2.46 5.69 4.3 3.58 BGS -7 6/19/07 Fillet 55 16 4/M 230 Q.49 <2.52* Q.49 3.73 Q.49 Q.49 BGS -8 6/19/07 Fillet 57 15.5 4/M 292 <2.44 Q.44* Q.44 Q.44 Q.44 Q.44 BGS -comp 6/19/07 Fillet 55a Ma 250 Q.45 <2.45 Q.45 3.24 <2.45 2.65 Black Crappi e BKS -1 6/19/07 Fillet 89 NA 4/M 384 <2.34 Q.34 Q.34 8.92 3.94 3.31 BKS -2 6/19/07 Fillet 83 20 51F 213 Q.44 <3.06 Q.44 4.51 <2.44 Q.44 BKS -3 6/19/07 Fillet 94 20 5/F 70.3 Q.48 Q.48 Q.48 2.66 Q.48 Q.48 m 2007 MPCA PFC Fish Data Jose hive Fish PFC an sis Wt Ln Age( PFOS PFOA PFBA PFOSA PFDA PFUnA PFDoA Species & Sample Tissue sex ng/g ng/g ng/g ng/g ng/g ng/g ng/g Sample ID Date (g) (cm) (zs ) (ppb) ( b) ( t, ) (ppb) ( b ) ( b) b) Blue '11 Sample ID Date b ( b b ( b ( b ( b ( y Blue ill BGS -1 7/07 Fillet W15 26.2 <2.45 ¢.45 BGS -1 5/24/06 Fillet 37 11 2M 73.4 <2.43 <2.43 <2.43 <2.43 12.43 12.43 BGS -2 5/24/06 Fillet 58 14 4/F 52.5 <2.49 <2.49 <2.49 <2.49 <2.49 12.49 BGS- 55/24/06 Fillet 68 16 5/M 50.2 <2.46 <2.46 <2.46 <2.46 <2.46 <2.46 BGS -5 BGS -10 5/24/06 5/24/06 Fillet Fillet 44 38 13.1 13.2 3/F 3M 102 55.6 <2.51 <2.46 <2.51 <2.46 12.51 12.46 12.51 12.46 <2.51 <2.46 <2.51 <2,46# BGS -12 5/24/06 Fillet 36 13 3/M 188 <2.50 <2.50 <2.50 3.07 <2.50 <250 BGS -com 5!24/06 Fillet 42a 14a 92.6 <2AS <2.48 <2.49 <2.48 2.98 <2.48 Keller Lake Fish PFC anal sis PFOS PFOA PFBA PFOSA PFDA PFUnA PFDoA Species & Sample Tissue ng/g ng/g ng/g ng/g ng/g ng/g ng/g Sample ID Date b ( b b ( b ( b ( b ( y Blue ill BGS -1 7/07 Fillet W15 26.2 <2.45 ¢.45 ¢.45 <2.45 <2.45 ¢.45 BGS -2 7/07 Fillet <2.45 <2.45 <2.45 64.6 ¢.35 <2.35 ¢.35 2.5 <2.35 <2.35 BGS -5 7/07 Fillet <2.46 <2.46 <2.46 97.1 ¢.46 ¢.46 ¢.46 4.88 4.31 ¢.46 BGS -7 7/07 Fillet <2.49 <2.49 <2.49 50.1 ¢.46 <2.46 ¢.46 4.47 2.99 ¢.46 BGS -10 7/07 Fillet 58 1 15 4/M 106 1 ¢.49 1 ¢.49 ¢.49 4.81 3.77 2.73 BGS -comp 7/07 Fillet 53a I 15a <2.49 1 70 1 ¢.t0 L <2.10 ¢.10 1 2.67 12.10 12.10 Minnetonka Fish PFC anal sis Wt Ln Age/ PFOS PFDA PFBA PFOSA PFDA PFUnA PFDoA Species & Sample Tissue sex n n n ng/g Sample ID Date (g) (cm) ng/g ng/g ng/g ng/g ng/g Pig rs ( b) b) b ( b ) ( b ) < b ( b Blue ill BGS -1 6/21/07 Fillet 72 15.5 51F <4.90 <2.45 <2.45 <2.45 <2.45 <2.45 <2.45 BGS -4 6/21/07 Fillet 69 13.2 31F <4.93 <2.46 <2.46 <2.46 <2.46 <2.46 <2.46 BGS -5 6/21/07 Fillet 54 12 2/F <4.98 <2.49 <2.49 <2.49 <2.49 <2.49 <2,49 BGS -9 6/21/07 Fillet 16 10 2/J 15.03 <2.51 <2.51 <2.51 <2.51 <2.51 <2.51 BGS -10 6/21/07 Fillet 15 10 2/J 14.98 <2.49 12.49 <2.49 <2.49 <2.49 <2.49 BGS -corn Fillet 49a 13a 7.47 <2.50 <2.50 <2.50 <2.50 <2.50 <2.50 Black Cra ie BKS -1 6/22/07 Fillet 464 34 11iF 7.16 <2.51 <2.51 <2.51 <2.51 12.51 12.51 BKS -1(du) BKS -2 6/22/07 Fillet 300 28 8/F 8.04 6.22 12.37 <2.49 12.37 <2.49 12.37 12.49 12.37 12.49 12.37 12.49 12.37 12.49 BKS -3 6/22/07 Fillet 192 24 7/M 10.9 <2.46 <2.46 <2.46 <2.46 <2.46 <2.46 BKS -4 6/22/07 Fillet 121 21 61F <4.92 <2.46 <2.46 <2.46 <2.46 <2446 <2.46 BKS -5 6/22/07 Fillet 90 19 5/F <5.03 <2.51 <4.18 <2.51 <2.51 <2.51 <2.51 Northern Pike NP -1 6/15/07 Fillet 2987 71 5/F 10.3 <2.48 <2.48 <2.48 <2.48 <2.48 <2.48 NP -2 6/15/07 Fillet 3700 80 6/M 7.83 <2.50 <2.50 <2.50 <2.50 <2.50 <2.50 NP -3 6/15/07 Fillet 1830 62 4/F 7.61 12.49 12.49 <2.49 <2,49 1 <2.49 <2.49 11 2007 MPCA PFC Fish Data Nokomis Fish PFC analysis Species & Sample ID Sample Date Tissue Wt �) Ln ( Age/ sex ( rs PFOS ng /g ( b b PFOA ng/g b PFBA n b PFOSA ng/g ( b PFDA ng/g ( b PFUnA ❑ p ( b b PFDoA ng/g b Blue ill ing/g BGS -1 7/17/07 Fillet 25 11 2/M 10.8 <2.44 ¢.34* ¢.44 ¢.44 ¢.44 ¢.44 BGS -2 7/17/07 Fillet 73 16 5/M 9.21 ¢.38 <2.50* ¢.38 ¢.38 <138 ¢.38 BGS - 3 7/17/07 Fillet 58 15 41M 13.4 ¢30 ¢.50 ¢.50 ¢.50 ¢.50 <2.50 BGS -4 7/17/07 Fillet 31 11 2/M 7.71 ¢.49 <3.00 ¢.49 <2.49 <2.49 ¢49 BGS -5 7/17/07 Fillet 55 14 4/F 6.45 ¢.45 ¢.45 ¢.45 ¢.45 <2.45 ¢.45 BGS -6 7/17/07 Fillet 49 14.5 41F 7.23 <143 ¢.43 ¢.43 ¢.43 <2.43 ¢.43 BGS -7 7/17/07 Fillet 69 15 4/M 11.4 ¢.45 <2.45 ¢.45 ¢.45 <2.45 ¢.45 Largemouth Bass LMB -1 Black Cra ie Fillet 1148 41 91M 45.7 <140 <2.40* ¢.40 2.84 2.87 ¢.40 BKS - 7/17/07 Fillet 84 18.5 5/M 11.7 ¢.49 <2.49 ¢.49* ¢.49 <2.49 ¢.49 BKS -2 7/17/07 Fillet 74 17.8 4/M 10.1 ¢.46 <246 ¢.46* ¢.46 ¢.46 ¢.46 BKS -3 7/17/07 Fillet 72 17.5 4/F 12.3 <2.45 <2.45 <2.45* ¢.45 ¢.45 <145 BKS -4 7/17/07 Fillet 67 - 16.2 4/M 7.66 <2.45 <4.34 <245* ¢.45 ¢.45 ¢.45 BKS -5 7/17/07 Fillet 9 19 5/M 8.18 ¢.79 ¢.44 ¢.44* ¢.44 <2.44 ¢.44 Olson Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt g) Ln O Age/ sex e PFOS n b PFOA n b PFBA n b PFOSA ng/ b PFDA n b PFUaA ng/ PFDoA ( b Blue ill BGS -1 4/30/07 Fillet 19 10 2/F 7.89 ¢.34 ¢.34* <2.34 <2.34 <2.34 ¢.34 BGS -2 4/30/07 Fillet 21 10 2/J 21.14 <2.50 <2.50* ¢.50 ¢.50 ¢.50 <2.50 BGS -5 4/30/07 Fillet 33 13 3/J 24.7 <197 <3.97 <197 <197 <3.97 <3.97 BGS -8 4/30/07 Fillet 51 15 4/J 9.28 <2.44 ¢.44 ¢.44 <2.44 <2.44 ¢.44 BGS -9 4/30107 Fillet 85 15 4/F <4.85 <2.43 <2.43 ¢.43 ¢.43 ¢.43 <2.43 BGS -comp 4/30/07 Fillet 40a 13a 14.5 ¢.46 ¢.46 ¢.46 ¢.46 ¢.46 <2.46 Largemouth Bass LMB -1 4/30/07 Fillet 1148 41 91M 45.7 <140 <2.40* ¢.40 2.84 2.87 ¢.40 LMB -2 4/30/07 Fillet 1170 39 71M 43.6 ¢.44 ¢.44* ¢.44 2.51 2.85 ¢.44 LMB -3 4/30/07 Fillet 1159 39 7/M 19.7 ¢.45 <2.45* ¢.45* ¢.45 3.04 ¢.45 LMB -4 4/30/07 Fillet 1379 42 9/M 77.5 ¢.40 ¢.40* ¢.40* 2.87 ¢.40 ¢.40 LMB - 5 4/30/07 Fillet 1024 37 7"7 ¢.40 <2.40* ¢.40 ¢.40 ¢.40 ¢.40 LMB -5(du) 4/30/07 Fillet i 1 24.5 ¢.49 ¢.49* ¢.49 ¢.49 ¢.49 <2.49 12 2007 MPCA PFC Fish Data Peltier Lake Fish PFC anal sis Species & Sample ]D Sample Date Tissue Wt (g) L. (CM) Age/ sex s PFOS ( b ) PFOA ng/g ( b ) PFBA ng/g ( b ) PFOSA ng/g ( b) PFDA ng/g b) PFUnA ng/g ( b ) PFDoA ng/g (ppb Blue gill BGS -1 2007 Fillet 58 15 4/M 17.6 ¢.44 ¢.44 <2.44* <144 ¢.44 Q.44 BGS -2 2007 Fillet 87 15.8 5/F 9.52 <2.48 ¢48 Q.48* Q.48 <2.48 Q.48 BGS -3 2007 Fillet 50 13 3!F 15.1 <4.27 Q.45 ¢.45* Q.45 Q.45 T <2.45 BGS -4 2007 Fillet 34 12.3 311 10.9 <2.50 Q.50 <2,50* ¢.50 Q.50 ¢.50 BGS -5 2007 Fillet 30 115 2/F 753 <3.43 ¢.50 <2.50* Q.50 <2.50 ¢.50 BGS -comp 5/1107 Fillet 53a 12a 45.3 <2.42 <2.42 ¢.42 Q.42 ¢.42 Q.42 Northern Pike 5/1/07 Fillet 55 Q.24 ¢.24 ¢.24 Q.24 <2.24 NP -1 2007 Fillet 607 45 4/J 20.7 Q.78 Q.65 <2.49 <2.49 Q.49 Q.49 NP -2 2007 Fillet 658 43 4/J 14.5 ¢.43 Q.43 Q.43 ¢.43 Q.43 ¢.43 NP -3 2007 Fillet 764 51 4/J 8.2 <2.40 Q.40 Q.40 ¢.40 Q.40 Q.40 NP -4 2007 Fillet 883 50 4 F 3.6 <2.49 < Q.49 <2.49 <2.49 ¢.49 NP -5 2007 Fillet 1161 54 4/J 13.1 Q.48 ¢.48 <2.48 3.05 <2.36 Q.36 Lake Phalen Fish PFC analysis Species & Sample & Sample Data Tissue Wt (B) Ln (cm) Age/ sex rs PFOS ng/g ( b PFOA ng/g b) PFBA ng/g b PFOSA ng/g (rob) PFDA ng/g b PFUnA ng/g ( b ) PFDoA ng/g ( b Blue ill BGS -2 5/1/07 Fillet 19 1 10 1 2/1 156# Q.49 ¢.49* Q.49 5.23 2.99 ¢.49 BGS -4 5/1/07 Fillet 25 11.5 2/J 82.7# Q.50 ¢.50* <2.50 3.14 ¢.50 ¢.50 BGS -6 5/1/07 Fillet 55 11.5 2/F 60.6 Q.36 ¢.36 ¢.36 <2.36 Q.36 <2.36 BGS -9 5 /1/07 Fillet 101 16 5/M 93.4 <2.48 Q.48 ¢.48 2.48# <2.48 <2.48 BGS -10 5/1/07 Fillet 73 15 41F 53.8 ¢.38 Q.38 <2.38 2.61# Q.38 ¢.38 BGS -comp 5/1107 Fillet 53a 12a 45.3 <2.42 <2.42 ¢.42 Q.42 ¢.42 Q.42 BGS- com du ) 5/1/07 Fillet 55 Q.24 ¢.24 ¢.24 Q.24 <2.24 ¢.24 Blac rapp ie BKS -1 5/1/07 Fillet 26 12 2/J 42.1# Q.39 ¢.39* Q.39 ¢.39 <2.39 Q.39 BKS -2 5/1/07 Fillet 58 14 3/M 104 Q.42 ¢.42* Q.42 5.29 <2.42 <2.42 BKS -3 5/1/07 Fillet 67 17 4/M 67.7# Q.36 ¢.36* Q.36 3.05 <2.36 Q.36 Largemouth Bass LMB -1 5/1/07 Fillet 1212 41 9/F 183 <2.49 ¢.49* ¢.49 9.46 3.99 2.66 LMB -2 511/07 Fillet 596 33.5 5/M 136 ¢.45 Q.45 ¢.45 7.64 4.67 ¢.45 LNM -2(du) 5/1/07 Fillet 129 Q.48 ¢.48 ¢.48 6.14 3.88 <2.48 LMB -3 5/1/07 Fillet 1279 43 10/F 128 <2.34 <2.34* Q.34 5.38 3.08 Q.34 LMB -4 5/1/07 Fillet 1415 42 9/F 1474 Q.35 ¢.35* Q.35 4.96 Q.35 Q.35 LMB -4(dup ) 5/1/07 Fillet 147# <2.44 Q.44* Q.44 5.28 3.61 Q.44 LNM -5 5/1/07 Fillet 1872 43 ION 120 <2.34 Q.34* Q.34 3.63 1 Q.34 Q.34 13 2007 MPCA PFC Fish Data Powers Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln ( Age/ sex ( rs PFOS ng/g ( b) PFOA pp b b PFBA ng/g (])Pb) PFOSA T)pb b PFDA ng/g b b PFUnA ng/g b PFDOA ng/g ( b Blue ill BGS -I 7/07 Fillet 31 13 31F 48.5 <2.48 <2.48 <2.48 12.48 12.48 2.48 BGS -2 7/07 Fillet 66 15 4/M 45 <.50 <2.50 <2.50 <2.50 <2.50 <2.50 BGS -6 7/07 Fillet 59 16.5 6/M 44.8 <.48 <2.48 <A8 <2.48 4148 2.48 BGS -9 7/07 Fillet 58 17 6/M 26.6 <.40 <2AO 1.40 1.40 <2.40 <.40 BGS -10 7/07 Fillet 40 NA 51F 32.7 <2.45 <2.45 <.45 1.45 <2.45 <.45 BGS -comp 7/07 Fillet 43a 13a 65.3 <2.48 1.48 <2.48 <.48 1.48 1.48 Black Crappie BKS -I 7/07 Fillet 99 20 5/M 63.9 1.39 <.39 2.39* <2.39 <2.39 1.39 BKS -2 7/07 Fillet 100 20 5/F 59.9 <135 <2.35 1.35* 2.49 <.35 2.35 BKS -3 7/07 Fillet 109 19 51F 53.3 <4.84 <2.45 <2.45* 2.47 <.45 2.45 BKS-4 7/07 Fillet 108 20 5/F 33.6 1.49 <4.64 1.49 1.49 <2.49 1.49 BKS -5 7/07 Fillet 105 19 5/F 42.9 <2.34 1.34 1.34 <.34 <2.34 1.34 Northern Pike NP -1 7/07 Fillet 2233 70 61M 71.1 <2.49 <2.49 <.49 3.08 2.64 2.49 NP -2 7/07 Fillet 1680 64 5/M 71.9 <2.50 <2.50 12.50 3.04 12.50 1.50 NP -3 7/07 Fillet NA 70 65 62.8 1.48 1.48 4148 2.73 2.56 1.48 Yellow Perch YP -comp 7/07 Fillet 34. 15a 41.6 <2.36 1 <2.36 12.36 12.36 12.36 2.36 Prior er Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln ( Age/ sex ( Ls ) PFOS nF /g (ppb PFOA ng/g ( b) PFBA ng/g ( b) PFOSA ng/g ( b) PFDA ng/g b PFUnA ng/g ( b ) PFDoA ng/g ( b) Blue ill BGS -2 8/23/07 Fillet 29 12 3/M 5.25 2.46 <.46 1.46 <.46 <2.46 2.46 BGS -4 8/23/07 Fillet 27 11 2/F <4.95 248 2.48 2.48 <.48 <.48 2.48 BGS -6 8/23/07 Fillet 41 13 31F <4.81 1 2.40 <2.40 <140 2.40 2.40 12.40 BGS -8 8/23/07 Fillet 48 13 3/F <5.00 <2.50 2.50 <.50 <.50 <.50 2.50 BGS -10 8/23/07 Fillet 85 16 5/M <4.98 <.49 2.49 2.49 <2.49 2.49 <.49 BGS -comp 8/23/07 Fillet 38a 12a <4.98 2.49 <149 2.49 2.49 2.49 2.49 Lar emouth Bass LMB -I 8/23/07 Fillet 576 33 51M <4.90 2.8 2.45 <2.45* <2.45 2.45 2.45 LMB -2 8/23/07 Fillet 653 35 61F 6.14 <2.49 <19.6 12.49* 2.62 2.49 2.49 LMB -3 8/23/07 Fillet 503 32 51M <4.93 <2.46 1.46 2.46* 2.46 <2.46 2.46 LMB-4 8/23/07 Fillet 370 31 51F <4.76 2.38 <.38 2.38* <.38 2.38 1.38 LMB -5 8/23/07 Fillet 744 37 7/F 14.95 2.48 2.48 2.48* <2 2.48 2.48 14 2007 MPCA PFC Fish Data Ravine Lake Fish PFC anal sis Wt Ln Age/ PFOS PFOA PFBA PFOSA PFDA PFUnA PFDoA Species & Sample sex TlSSUe Sample ID Date (g) (em) ng g ng/g ppb ) ( ng/g ppb ppb ng/g ng/g rs) ( b ( b ( b b b ( b) ( b Blue ill BGS -1 BGS -4 4/30/07 4/30/07 Fillet Fillet 30 35 10 12 2/M 3/1 10.3 10.8 <2.46 <4.67 <2.46 <4.67 4.46 <4.67 2.46 <4.67 <2.46 14.67 2.46 14.67 BGS -5 BGS -9 4/30/07 4/30/07 Fillet Fillet 23 206 10 19.5 2/M 7/M 45.1 29.3 4.49 4.29 4.49 2.29 ¢.49 4.29 4.49 Q.29 <2A9 4.29 4.49 4.29 BGS- 9(dup) BGS -10 4/30/07 4/30/07 Fillet Fillet 97 16 51M 30.3 19.3 4.45 4.48 <2.45 4.48 <2.45 4.48 4.45 2.48 4.45 2.48 4.45 4.48 BGS -comp 4/30/07 Fillet 60a 13a 5/M 19.4 <2.43 <2.43 <2.43 2.43 ¢.43 2.43 BGS -9 8/17/07 Fillet 130 18.2 7/M 58.3 12.45 Q.45 ¢.45 4.45 2.45 Black Cr ie 8/17/07 Fillet 57 14 4/F 29.2 ¢.44 <2.44 4.44 <2.44 BKS -1 4/30/07 Fillet 52 15 3/F 55.9 <2.48 12.48* ¢.48* 4.48 4.48 Q.48 BKS -2 4/30/07 Fillet 43 15 3/J 64.5 2.42 Q.42* ¢.42* 4.42 12.42 Q.42 BKS -3 4/30/07 Fillet 42 14 3/J 77.8 2.69 4.56* 4.56 12.56 4.56 Q.56 BKS -4 4/30/07 Fillet 50 15 3/J 60.4 2.31 ¢.31* 12.31 4.31 12.31 4.31 BKS -5 4/30/07 Fillet 45 14 3/F 41.3 2.35 Q.35* 4.35* <2.35 2.35 4.35 BKS -3 8/17/07 Fillet 149 21 6/M 153 2.49 4.49 3.69 ¢.49 4.49 Lar emouth Bass 8/17/07 Fillet 283 27 8/F 115 <2.43 ¢.43 4.43 3.62 4.43 LMB -1 4/30/07 Fillet 725 32.5 5/M 50.6 <2.40 4.40* 2.40* 2.40 4.40 4.40 LNM -2 4!30/07 Fillet 890 35 61M 36 Q.13 12.13* 2.13* 2.13 <2.13 2.73 LMB -3 4/30/07 Fillet 911 34.5 61F 65.2 12.38 4.38* 2.38* Q.38 ¢.38 2.38 LNM -4 4/30/07 Fillet 1084 36.5 7/M 107 4.40 <2.40* 4.40* 2.40 4.40 4.40 LMB -5 4/30/07 Fillet 1011 1 33 1 5/M 53.8 4.31 4.31* 2.31* 2.31 Q31 231 Red Rock Lake Fish PFC anal sis Wt Ln Age/ PFOS PFDA PFBA PFOSA PFDA PFUnA PFDoA Species & Sample Tissue sex ng/g ng ppb ppb ppb np ng Sample ID Date (g) (em) pb ( rs) ( b ( b ( b ( b ( b b) ( b Blue gill BGS -6 8/17/07 Fillet 5 10 21J 42 <2.40 2.40 <2.40 4.40 ¢.40 4.40 BGS -7 8/17/07 Fillet 43 13.9 4/J 32.7 4.48 2.48 12.46 4.48 12.48 2.48 BGS -8 8/17/07 Fillet 61 15.2 5/M 42.2 2.43 <2.43 4.43 <143 4.43 <2.43 BGS -9 8/17/07 Fillet 130 18.2 7/M 58.3 12.45 Q.45 ¢.45 4.45 2.45 BGS -10 8/17/07 Fillet 57 14 4/F 29.2 ¢.44 <2.44 4.44 <2.44 2.44 BGS -comp 8/17/07 Fillet 27a Ila 35.2 4.38 <2.38 4.38 4.38 4.38 :<2.49 Black Cr ie BKS -1 8/17/07 Fillet 81 17 4/F 79.9 4.48 <2.48 4.48 2.73 <2.48 4.48 BKS -2 8/17/07 Fillet 102 20 5/F 97.1 <2.48 ¢.48 3.07 <2.48 4.48 BKS -3 8/17/07 Fillet 149 21 6/M 153 2.49 4.49 3.69 ¢.49 4.49 BKS-4 8/17/07 Fillet 283 27 8/F 115 <2.43 ¢.43 4.43 3.62 4.43 4.43 BKS -5 8/17107 Fillet 122 19 5/F 68.6 12. 49 4.49 4.49 2.95 4.49 4.49 Lar emoutls Bass LMB -1 8/17/07 Fillet 666 38 71M 85.7 2.76 4.42 <2.42* 2.67 ¢.42 4.42 LMB -2 8/17/07 Fillet 527 33 51F 60.6 12 60 Q.44 <2.44* 2.69 <2.44 4.44 LMB -3 8/17/07 Fillet 566 33 5/J 64.5 12.46 <2.46 4.46* 3.22 4.46 2.46 LMB -4 8117/07 Fillet 591 33 S1F 57.4 4.48 <2.48 4.48* 4.48 12.48 4.48 LNO -5 8/17/07 Fillet 716 36 7/M 74.4 <3.99 4.33 4.33* 3.07 4.33 <2.33 15 2007 MPCA PFC Fish Data Sarah Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln (cm) Age/ sex PFOS ng/g b PFOA 49/9 b PFBA ng/g b PFOSA ngIg b PFDA ng/g ( b PFUnA ng(g b PFDoA ng/g b Blue ill BGS -3 BGS -3 7/16/07 Fillet 70 17 65 6.12 2.48 <2.48 2.48 2.48 <2.48 2.48 BGS -4 7/16/07 Fillet 86 18 7/M 6.21# 2.49 <149 2.49 2.49 <249 <2.49 BGS -6 7/16/07 Fillet 74 17 6/F 7.97 2.49 Q.49 249 2.49 2.49 <2.49 BGS -7 7/16/07 Fillet 10 7 1/J 8.51 2.43 1 243 <2.43 <2.43 2.43 2.43 BGS -9 7/16/07 Fillet 1s 9.2 vJ <5.00 2.50 1 <2.50 <2.50 <2.50 <2.50 BGS -comp BGS -comp 7/16/07 Fillet 52a 13a 33.7 <4.90 2A5 2.45 2.45 <2.45 <2.45 Black Crappie Black Cra ie i<2.38 BKS -1 7/16/07 Fillet NA 21 6/F <4.95 <2.48 <2.48 2.48 2.48 2.48 BKS -2 7/16/07 Fillet NA 20 5/M <5.00 <2.50 <250 2.50 2.50 2.50 BKS -3 7/16/07 Fillet NA 24 7/F <4.83 2.42 <2.42 2.42 2.42 2.42 BKS -4 7/16/07 Fillet NA 20 5/M <4.76 <2.38 <9.45 <2.38 <2.38 2.38 BKS -5 7/16/07 Fillet NA 21 6/M <4.93 2.46 <2.46 3.77 108 <2.46 2.46 26.2 2.44 2.44 2.65 12.44 12.44 2.44 BKS -com Northern Pike Fillet 110 19 34.9 2.45 2.45 2.45 <2.45 2.45 2.45 BKS- com du NP -1 7/16/07 Fillet 3440 70.7 6/F 7.88 2.64 <2.45 2.48 <2.48 <2.45 <2.45 NP -2 7/16/07 Fillet 4052 85 7/F 10.8 2.49 <2.49 139<2 2.49 2.49 NP -2(du Fillet 14.4 2.43 <2.43 2.43 2.43 NP -3 7/16/07 Fillet 3821 85 8/F 13.6 2.45 2.45 2.40 240 2.45 <2.45 NP -4 7/16/07 Fillet 3229 81.5 7/F 7.45 2.42 2.42 2.42 <2.42 <2.42 2.42 NP -5 7/16/07 Fillet 1757 66 5/M 9.6 2.39 2.39 2.85 Q.44 2.39 2.39 Silver Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln (em) Age/ sex rs) PFOS ng/g ( b) PFOA ng/g b PFBA ng/g b PFOSA ng/g b PFDA ng/g ( b ) PFUnA ng/g ( b) PFDoA. ng/g ( b Blue ill BGS -3 5/4/07 Fillet 64 16 5/M 24 2.40 2.40 2.40 2.40 3.38 <2.40 BGS -4 5/4/07 Fillet 38 13 3/F 19.6 2.43 2.43 2.43 2.43 2.53 <2.43 BGS -5 5/4/07 Fillet 36 13 3/F 24.49 2.42 <2.42 <2.42 <2.42 2.42 <2.42 BGS -7 5/4/07 Fillet 43 14 4/F 31.3 <2.48 2.48 Q.48 <148 12.48 Q.48 BGS -9 5/4/07 Fillet 32 13 3/F 21.4 <2.42 2.42 242 12.42 <2.42 2.42 BGS -comp 5/4/07 Fillet 59a 14a 33.7 <2.44 <2.44 2.44 2.44 2.44 2.89 Black Crappie BKS -1 5/4/07 Fillet 69 16 5/F 26.64 2.46 2.46 2.46 2.92 <146 2.46 BKS -4 5/4/07 Fillet 63 17 4/M 36.6 2.48 2.48 2.48 3.39 2.48 3.38 BKS -6 5/4/07 Fillet 67 18 5/M 45 2.49 <2.49 2.49 4.52 <2.49 2.89 BKS -7 5/4/07 Fillet 67 18 5/M 28.6 <2.50 2.50 Q.50 3.88 3.11 3.05 BKS -10 5/4/07 Fillet 296 27 8/F 29.3# 2.43 2.43 2.43 3.77 108 2.43 BKS- 10(dup) 26.2 2.44 2.44 2.65 12.44 12.44 2.44 BKS -com 514/07 Fillet 110 19 34.9 2.45 2.45 2.45 <2.45 2.45 2.45 BKS- com du 33.5 2.48 2.48 2.48 2.48 <2.48 2.48 eve WE -1 5/4/07 Fillet 453 50 9/M 10.2 2.40 <4.84 2.71 2.40 2.40 240 WE -1(du) 10.8 <2.42 2.42 4.2 <2.42 2.42 <2.42 WE -2 5/4/07 Fillet 486 52 10/M 18.8 12.44 2.44 4.65 2.8 2.85 Q.44 WE -3 5/4/07 Fillet 371 27 47M 10.5 12.49 2.49 5.31 2.49 2.49 2.49 WE -4 5/4/07 Fillet 1200 46 8w 26.6 12.33 2.33 4.82 2.99 2.49 2.96 16 2007 MPCA PFC Fish Data Square Lake Fish PFC anal sis Wt Ln Age/ PFOS PFDA PFBA PFOSA PFDA PFUM PFDoA Species & Sample Tissue sex ng/g ng/g ng/g ng/g ng/g ng/g ng/g Sample ID Date (g) (cm) (. ( b ) (ppb ( b) ( b ) ( b ) (ppb) b Blue ill BGS -2 5/2/07 Fillet 15 18.5 7/17 <4.57 <2.28 2.28* Q.28 2.28 <2.28 <z.28 BGS -4 5/2/07 Fillet 21 10 2/F <4.69 Q.35 <2.35* 2.35 2.35 2.35 Q.35 BGS -8 5/2/07 Fillet 44 12.5 3/F <4.72 2.36 Q.36* 236 2.36 2.36 <2.36 BGS -9 512107 Fillet 84 16 5/M <4.88 <2.44 2.44* 2.44 <2.44 2.44 <2.44 BGS -10 5/2/07 Fillet Ill 17.5 6/M <4.95 <2.48 2.48* Q.48 2.48 <148 2.45 BGS -comp 5/2/07 Fillet 53a 13a <4.72 2.36 2.36 2.36 2.36 <2.36 <2.36 Black Crappie BKS -1 5/2/07 Fillet 74 16.5 4/tvt <4.93 <2.46 2.46* <146 2.46 <2.46 <146 BKS -2 5/2/07 Fillet 125 18.5 5/M 75.9 Q.46 <2.44* 2.44 Q.44 <2.44 <2.44 BKS -3 5/2/07 Fillet 94 18 5/M 91.2 Q.38 2.38 <2.38 Q.38 <2.38 2.38 BKS -4 5/2/07 Fillet 80 17 4/17 94.6 9 2.45 12.45 Q.45 2.45 2.45 BKS -5 5/2/07 Fillet 126 20 5/M 64 %<4.90<2.45 Q.49 Q.49 2.49 <2.49 <2.49 Lar emouth Bass 1<2.44 LMB -1 5/2/07 Fillet 309 26.5 3/M 96.5 3 <2.34* 2.34 2.34 <2.34 12.34 LMB -2 5/2/07 Fillet 301 28 3/M <4.88 2.44 2.44* 2.44 2.44 <2.44 2.a4 LMB -3 5/2/07 Fillet z8a 27.5 3/F <4.81 <2.40 <2.40* 2.40 <2.40 2.88 <2.40 LMB -4 5/2/07 Fillet 383 29.5 4/F <5.00 2.50 2.50* 2.50 2.50 <2.50 2.50 LNO -5 5/2/07 Fillet 316 28 3/M <5.03 1 2.51 <2.51* 1 2.51 2.51 Q.5t 1 2.51 Tanners Lake Fish PFC anal sis Wt Ln Age/ PFOS PFDA PFBA PFOSA PFDA PFUnA PFDoA Species & Sample Tissue sex Sample ID Date (g) (CM) ng/g ng/g ng/g ng/g ng/g ng/g ng/g ( rs ) ( b) ( b) ( b) b b ( b) b Blue gill BGS -1 6/12/07 Fillet 89 17 6/M 61.1# Q.46 <2.46 <2.46 <2.46 2.46 2.46 BGS -2 6/12/07 Fillet 32 12.5 3/17 87# 2.30 2.30 2.30 12.30 2.30 230 BGS -5 6/12/07 Fillet 93 18 IF 56.6 12.48 <z.48 <2.48 Q.48 12.48 <148 BGS -7 6/12/07 Fillet 89 16.5 6/F 70.4 12.44 2.44 Q.44 Q.44 <2.44 2.44 BGS -10 6/12/07 Fillet 12 10 2/1 t05 <2.49 Q.49 <2.49 4.36 12.49 <2.49 BGS -com 6/12/07 Fillet SOa 13a 55 12.44 2.59 <2.44 <2.44 2.44 2.44 Black Cra e BKS-F 6112/07 Fillet 69 18 4/M 265 <2.45 <2.45 1 2.45* 6.3 2.45 <2.45 BKS -2 6/12/07 Fillet 63 15 3/M 75.9 Q.46 2.46 2.46 2.46 Q.46 2.46 BKS -3 6/12/07 Fillet 56 18 4/17 91.2 Q.38 13.96 <2.38 2.82 Q.38 2.38 BKS -4 6/12/07 Fillet 80 t8.5 4/M 94.6 9 2.39 2.39 2.39 <2.39 2.39 BKS -5 6/12/07 Fillet 56 17 4/F 64 1 Q.40 2.40 Q.40 2.40 2.40 Lar emouth Bass 1<2.44 LxM -1 6/12/07 Fillet 378 NA 4/F 96.5 3 <3.18 2.43 6.05 4.62 4.11 LMB -2 6/12/07 Fillet 619 NA 5/F 75.7 <z.44 <z.44 4.86 4.42 8.37 LMB -3 6/12 07 Fillet 576 35 6 F 76.6 9 2.39 12.39 3.56 4.73 3.4 LMB-4 6/12/07 Fillet 823 37 7/M 74.9 <2,44 2.44 2.44 3.44 2.44 4.2 LMB -5 6/12/07 Fillet 1570 50 12/17 74.1 2.56 <2.56 <2.56* 3.33 2.56 2.56 17 2007 MPCA PFC Fish Data White Bear Lake Fish PFC analysis Species & Sample ID Sample Date Tissue wt (g) L. ( Age/ sex ( rs ) PFOS ng/g (ppb PFOA ng/g b PFBA ng/g b PFOSA ng/g ( b ) PFDA ng/g (ppb PFUnA ng/g b PFDoA ng/g ( b Blue ill BGS -2 5/2/07 Fillet 26 10 2/F <4.88 <2.44 Q.44* <2.44 Q.44 ¢.44 ¢.44 BGS -3 5/2/07 Fillet 8 7 1/1 <8.13 <4.07 <4.07* <4.07 <4.07 <4.07 <4.07 BGS -5 5/2/07 Fillet 32 12 3/J <4.81 Q.40 <2.40* 12.40 <2.40 <2.40 ¢.40 BGS -7 5/2/07 Fillet 171 19 7/M 4.77 12.28 12.28* Q.28 ¢.28 <2.28 <2.28 BGS -8 5/2/07 Fillet 111 25.5 S/F 5.08 <2.34 <2.34* ¢.34 ¢.34 ¢.34 <2.34 BGS -comp 5/2/07 Fillet 64a 13a 6.06 ¢.31 <231 ¢.31 ¢.31 <2.31 Q.31 BGS- com du ) 16.4 Q.46 <2.46 <2.46 <2.46 <2.46 Q.46 Black rqppi e BKS -1 5/2/07 Fillet 172 21 6/F 18.4 <2.44 <2.44* ¢.44 Q.44 12.44 Q.44 BKS -2 5/2/07 Fillet 525 30 10/F 30.8 <154 12.54* 12.54 3.51 12.54 Q.54 WE -2 7/19/07 Fillet 695 44 7/M 13.8 ¢.35 Q.35 <2.35* <235 Q.35 ¢.35 Lar emouth Bass 7/19/07 Fillet 641 42 6/M 12 <242 12.42 Q.42* <2.42 Q.42 LMB -1 512107 Fillet 811 35 6/M <4.81 <2.40 Q.40* ¢.40 <2.40 ¢.40 12.40 LMB -2 5/2/07 Fillet 845 36.5 7/17 9.07 ¢.49 ¢.49* ¢.49 ¢.49 <2.49 Q.49 LMB -3 5/2/07 Fillet 638 34 61M <4.76 <2.38 ¢.38* <2.38 <2.38 12.38 Q.38 LMB -4 5/2/07 Fillet 515 31 5/M <4.85 <2.43 <2.43* 12.43 <2.43 12.43 Q.43 LMB -5 5/2/07 Fillet 503 31 5/M <4.85 ¢.43 12.43* 12.43 Q.43 ¢.43 ¢.43 St. Croix River Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln (cm) Age/ sex rs PFOS ng/g b PFOA ng/g b PFBA ng/g b PFOSA ng/g b PFDA ng/g ( b ) PFUnA ng/g (ppb PFDoA ng/g b Blue ill BGS -3 7/19/07 Fillet 86 15.5 51F <4.83 <142 <142 Q.42 <2.42 Q.42 12.42 BGS -5 7/19/07 Fillet 83 14.5 4/F 33.1 Q.45 Q.45 Q.45 <2.45 ¢.45 <2A5 BGS -7 7/19/07 Fillet 122 18.5 7/M <4.95 <2.48 <2.48 ¢.48 ¢.48 ¢.48 Q.48 BGS -8 7/19/07 Fillet 76 15 4/M 22.3 <2.40 ¢.40 12.40 12.40 12.40 Q.40 BGS -10 7/19/07 Fillet 80 15 4/M 13.1 12.44 ¢.65 12.44 Q.44 Q.44 Q.44 BGS -comp 7/19/07 Fillet 82a 15a 12 <142 <2.42 <2.42 Q.42 ¢.42 12.42 BGS- com du ) 16.4 Q.46 <2.46 <2.46 <2.46 <2.46 Q.46 Walleye WE -1 7/19/07 Fillet 670 45 8/M 8.34 Q.45 <3.85 ¢.45* ¢.45 Q.45 Q.45 WE -2 7/19/07 Fillet 695 44 7/M 13.8 ¢.35 Q.35 <2.35* <235 Q.35 ¢.35 WE-3 7/19/07 Fillet 641 42 6/M 12 <242 12.42 Q.42* <2.42 Q.42 12.42 WE -4 7/19/07 Fillet 919 48 9/M 40.2 Q.42 Q.42 ¢.42* <2.42 <2.42 Q.42 WE -5 7/19/07 Fillet 890 48 9/M 12.7 <2.49 ¢.49 ¢.49 12.49 Q.49 Q.49 White Bass WHB -1 7/19/07 Fillet 403 34 51F 81.8 <2.50 Q.50 ¢.50 2.63 <150 Q.50 Smallmouth Bass SMB -1 7/19/07 Fillet 573 35 31M 12.3 Q.29 <2.29 Q.29 <2.29 12.29 Q.29 SMB -2 7/19/07 Fillet 730 38 41M 29.1 ¢.45 ¢.45 1245 <2A5 Q.45 ¢.45 SMB- 2(dup) 31.4 ¢.22 1 12.22 Q.22 Q.22 <2.22 Q.22 SMB -3 7/19/07 Fillet 425 30 I/M <4.90 <2.45 Q.45 ¢.45 ¢.45 12.45 Q.45 SMB -4 7/19/07 Fillet 286 29 I/M 5.44 ¢.33 Q.33 ¢.33 <2.33 Q.33 ¢.33 SMB -5 7/19/07 Fillet 252 27 1/M 11.2 ¢.48 ¢.48 12.48 <2.48 Q.48 <2.48 M 2007 MPCA PFC Fish Data 19 G = less than the detection limit; number muowmg uun ....... .. - - - - -- - -- * estimated values with a negative bias # estimated values with a positive bias 2008 MPCA Metro Lakes Fish PFC Data Twin Cities Metro Lakes Numbers listed are: average PFOS concentration (9 of fish) <dl - less than detection limit (approx. 2.5 ng/g) as - not sampled comp - composite; tissue from several fish is combined prior to analysis Average P Concentration n / ; p Blue ill Bluegill (comp) Black Crappie Black Crappie (comp) Largemouth Bass Northern Pike Pumpkinseed Pumpkinseed (com Alima net - 24.27(6) 24.7(6) 31.38(6) 31.60(6) as ns ns ns Bennett 40.12(6) 36.8(6) 46.52(5) 58.50(4) ns 51.38(5) as ns Calhoun 203.80 (5 ) 267 (4 ) 267.17 (6) as 425.60(5) as ns ns Case ns as 12.45 5 14.50(5) as as as as Cedar (H ennepin) 50.09 8 ns 68.15(2) ns 136.74(5) ns as ns Fish 76.08(6) 73.70 6) 101.68 5 98.60(6) as 134.60(5) 17.48(5) 15.70(6 Harriet 137.00 5 as 138.40 5 as 227.40(5) as ns as Hyland 12.44(5) ns 23.92(5) ns 43.06(5) ns ns ns Isles 68.40(3) as 166.97 (6 ) as 197.00(5) as as as Lee 22.47(6) 20.80 6 38.24(5) 29.30(4) as ns as ns Pelican <dl 5 as <dl (5) ns <dl 5 ns ns ns Starring 5/30108 22.27(3) as ns as 26.40(4) ns as ns Starring 6/24/08 10.07(2) as 1 15.86 5 ns 1 32.50(l) ns I ns I ns Steiger 1 5.75(3) as 5.69 1 ns 9.55(5) ns ns ns Sweene 26.20(5) ns 28.47 (3 as 49.52(5) as ns ns Twin 396.80 6 as 419.00 5 as 480.40(5) ns ns ns Numbers listed are: average PFOS concentration (9 of fish) <dl - less than detection limit (approx. 2.5 ng/g) as - not sampled comp - composite; tissue from several fish is combined prior to analysis 2008 MPCA Metro Lakes Fish PFC Data Note: This summary table is only for concentrations of PFDA in fish from lakes listed below. Twin Cities Metro Lakes Numbers listed are: average PFDA concentration (# of fish) <dl - less than detection limit (approx. 2.5 ng/g) ns - not sampled comp - composite; tissue from several fish is combined prior to analysis Avera e PFDA Concentration n / ; b Blue ill Bluegill (comp) Black Crappie Black Crappie (comp) Largemouth Bass Northern Pike Pumpkins Pumpkinseed com Alima net 3.69 1 <dl 5) 3.93(5) 5.57(6) ns ns ns ns Bennett 4.74(4) 3.38(6) 6.67(5) 6.66(4) ns 5.92(5) ns ns Calhoun 4.60(5) 5.12(4) 7.28(6) ns 11.00(5) ns ns ns Casey ns ns <dl 5 <dl 5 ns ns ns ns Cedar ( Hennepin) 4.15(6) ns 5.23(2) ns 9.03(5) ns ns ns Fish 2.91(4) 4.16(6) 5.48 5 6.17 6 ns 7.24(5) <dl 5 <dl 5 Harriet 4.03 5 ns 4.8(5) ns 8.03(5) ns ns ns H land ns 3.96(4) ns 4.83(5) ns ns ns Isles - 2.55(l) 4.14(3) ns 8.87(6) ns 8.85(5) ns ns ns Lee 3.03(3) <dl 6 4.70(5) 3.82(4) ns ns ns ns Pelican <dl 5 ns <dl 5 ns <dl 5 ns ns ns Starring 5/30/08 <dl 3) ns ns ns 2.59(l) ns ns ns Starring 6/24/08 <dl 2 ns <dl 5 ns <dl 1 ns ns ns Steiger <dl (4 ) ns <dl 2 ns <dl (5) ns ns ns Sweeney 3.17 4 ns 5.00 3 ns 5.66(5) ns ns ns Twin 3.04(6) ns 1 5.04(5) ns 5.02(5) ns ns ns Numbers listed are: average PFDA concentration (# of fish) <dl - less than detection limit (approx. 2.5 ng/g) ns - not sampled comp - composite; tissue from several fish is combined prior to analysis 2008 MPCA Metro Lakes Fish PFC Data Note: This summary table is only for concentrations of PFUnA in fish from lakes listed below. Twin Cities Metro Lakes Numbers listed are: average PFUnA concentration (# of fish) <dl — less than detection limit (approx. 2.5 ng /g) as — not sampled comp — composite; tissue from several fish is combined prior to analysis Avera a PFUnAConcentration [ n / b Blue ill Bluegill (comp) Black Crappie Black Crappie (comp) Largemouth Bass Northern Pike Pumpkinseed Pumpkinseed (comp) Alima net 3.65(2) <dl (51 <dl 5 2.65(6) ns ns ns ns Bennett 3.06(6) 3.09 6 <dl (5) 3.01(4) ns 4.51(3) ns ns Calhoun 1 2.71(2) 2.93(4) 3.28 3 ns 6.21(5) ns ns ns Casey ns ns <dl 5 <dl 5 ns ns ns ns Cedar ( Hennepin) 2.66(2) ns 3.050) ns 5.75(5) ns ns ns Fish 2.74(3) <dl 6 <dl (5) <dl 6 ns 5.11(5) <dl 5 <dl 5 Harriet 2.84 3 ns <dl 5 ns 3.85(5) ns ns ns H land <dl 5 ns <dl 5 ns 3.80(3) ns ns ns Isles 2.62(2) ns 5.49(4) ns 6.67(5) ns ns ns Lee <dl 6 <dl 6 3.61(l) <dl 4 ns ns ns ns Pelican <dl (5) ns <dl (5) ns <dl (5 ) ns ns ns Starring 5/30/08 <dl 3 ns ns <dl 4 ns ns ns Starring 6/24108 <dl 2 L ns <dl 5 ns <dl 1 ns ns ns Steiger <dl 4 <dl 2 ns <dl 5 ns ns ns Sweene 4.44 (3) 4.87 1) ns 4.73(5) ns ns ns Twin 4.58(6) ns 4.58 4 ns 6.07(5) ns ns ns Numbers listed are: average PFUnA concentration (# of fish) <dl — less than detection limit (approx. 2.5 ng /g) as — not sampled comp — composite; tissue from several fish is combined prior to analysis 2008 MPCA Metro Lakes Fish PFC Data Note: This summary table is only for concentrations of PFDoA in fish from lakes listed below. Twin Cities Metro Lakes Numbers listed are: average PFDoA concentration (# of fish) <dl — less than detection limit (approx. 2.5 ng /g) as — not sampled comp — composite; tissue from several fish is combined prior to analysis Avera e PFDoA Concentration Blue ill Bluegill (comp) Black Crappie Black Crappie (comp) Northern Pike Pumpkinseed Pumpkinseed (com Alima net 2.57 1 <dl 5 <dl (5 <dl 6 E6.322s(5) ns ns ns Bennett 3.02(l) <dl (6 <dl 5 <dl (4 3.26(4) ns ns Calhoun 3.68(2) 4.15(4) 2.90(2) ns ns ns ns Casey ns ns <dl 5 <dl 5 ns ns ns ns Cedar (H ennepin) 2.76(l) ns 2.68 1 ns 5.51(5) ns ns ns Fish 3.21 M <dl 6 <dl 5 <dl 6 ns 3.84 5 <dl 5 <dl 5 Harriet 2.80(l) us <dl 5 ns 3.38(3) ns ns ns Hyland <dl 5 ns <dl 5 ns <dl 5 ns ns ns Isles <dl 3 ns 6.24(5) ns 7.27(5) ns ns ns Lee <dl 6 <dl 6 <dl 5 <dl 4 ns ns ns ns Pelican <dl 5 ns <dl 5 ns <dl 5 ns ns ns Starring 5/30/08 <dl (3 ) ns ns ns <dl 4 ns ns ns Starring 6/24/08 <dl 2 ns <dl 5 ns I <dl 1 ns ns ns Steiger <dl 4 ns <dl 2 ns <dl 5 ns ns ns Sweeney 3.66(5) ns 4.49(l) ns 5.90(5) ns ns ns Twin 1 2.84(l) ns 2.88 3 ns 3.46(4) ns ns ns Numbers listed are: average PFDoA concentration (# of fish) <dl — less than detection limit (approx. 2.5 ng /g) as — not sampled comp — composite; tissue from several fish is combined prior to analysis ¢ m O� m O m m M^ r O O M M N M M N 'p M tD C, M< y N V< .. bJ Ci y v v v v v v v v v v V V V V V V V v V , V w v v v v v 1w; f . 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Z w � o U d m E ?r�rm�opaoov?o d 9 "E p p p p m p p OMIT 0 Z Z Z Z - Z Z Z Z a Nn1 � 42 °g000 oac; V v V V V V V V V V v m K '-n d Emm momNUminnu°°o, °o,mN n C h 0 0 O' m di O O CI O I v " Ev°.N p q H N d o N o m N o N N 0 o v°o� d"^ N o �- g c v v v v v v v v Y v v v d ' cc m E . 2 m - a x O Z m� 0 m 2 0 0 m o LL LL a a LL LL a a LL LL a a IY LL a a LL LL a a LLLL a a LL a w E N N 3 E Y W d N E W O f E m Ih E T d m N E m N E O w d E N h a H " m s G 4 S 0 m g a - �E v E w LL 5 F 1 4 \\ {) \\ \ }\ \\ { !{ ) ) }\ \! ( / ( ) :2::§: )m f 0, \ 0 Sources, Fate, and Transport of PFCs in the Environment Direct Sources of Perfluorinated Chemicals to the Environment The variety and number of fluorinated compounds currently in production comprise an enormous group of chemicals including drugs, anesthetics, chemotherapeutic agents, many pesticides, and refrigerants, as well polymers such as Teflon and Goretex [1]. The environmental fate of most of these compounds is unknown. This summary is focused primarily on perfluorinated surfactants which include perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS) and related compounds that have been the focus of intense environmental study. Perfluorinated surfactants are consistently detected in almost every surface and ground water sample and are almost always found in wildlife and humans. While it is clear that these are not naturally occurring compounds — they are entirely human -made — how these compounds have become so widely distributed in our environment in often very remote locations is less understood. Studies have shown that PFOA, for example, is likely "ubiquitous in the northern hemisphere" without a clear source of that widespread contamination [2] The direct release of these compounds to the environment through manufacturing processes represents one route of exposure to chemicals like PFOA or PFOS. However, several recent studies show that they can also be generated through the degradation of other fluorinated compounds or products that are not of serious environmental concern. Fluorinated surfactants are synthesized via two primary methods: through electrochemical fluorination (ECF) or through a telomerization manufacturing process [1, 31. ECF is the process that 3M uses to produce fluorinated compounds. This process begins with sulfonyl fluorides, fluoroalkyl iodides, or carbonyl fluorides, and results in numerous perfluorinated carbon (PFC) compound isomers and byproducts. It results in isomeric mixtures of PFC that are typically 30 branched isomers and 70% straight carbon chain isomers [1, 31. ECF was used to produce the fluorinated surfactants PFOA and PFOS, non - volatile perfluorinated surfactants that are used in fire- fighting foams (aqueous film- forming foams, or AFFF), paints, polishes, films, and lubricants. ECF is the only process used to directly produce PFOA and PFOS, with over 6 million pounds produced in 2000 [3]. The major contributors to environmental loads appear to be direct sources from the use of PFOA and the ammonia salts of perfluorononanoic acid (PFNA.) in fluoropolymer manufacturing [4]. The chemicals produced through ECF from sulfonyl fluorides include PFOS, N- methylperfluorooctanesulfonamidoethanol (N- McFOSE), and N- ethylperfluorooctanesulfonamidoethanol (N- EtFOSE) [1, 31. The latter two volatile sulfonamide alcohols are themselves building blocks for a variety of polymers, chemical intermediates, and other perfluoroalkyl substances, and were used to produce carpet treatments and paper coating materials [3]. Due to their volatility, N- McFOSE, and N- EtFOSE have been found in atmospheric samples. A primary use of fluorinated chemicals is in the synthesis of fluorinated polymers. Polyfluoroalkylphosphate surfactants (PAPs), for example, are produced from N- EtFOSE and have been used in food contact paper products since 1974. N- McFOSE was the primary ingredient in the production of polymers used for coating fabrics and carpets, such as 3M's ScotchGard products [5]. sOf the compounds produced through the ECF process, 3% were used in fire- fighting foams, 10% were used as industrial surfactants and coatings, 37% were used in textile, leather, and carpet coatings, and 41% of fluorinated alkyl substances were used for paper and packaging. Telomerization, is DuPont's process of manufacturing fluorinated alkyl compounds[l]. In this process, only chemicals that consist of straight - carbon chains are produced (as opposed to straight or branched perfluorinated chains produced by ECF process). This is the now the major fluorotelomer manufacturing process since 3M phased out production of PFOA and PFOS in 2000. Unlike the ECF process, telometization is often used to make fluorotelomer alcohols (FTOHs) [1], which are characterized by the presence of a terminal ethanol group. FTOHs vary in the number of fluorinated carbons that are attached to the alcohol group. Due to the feedstock and the chemical manufacturing method, they always contain an even number of carbons. FTOHs are not used directly in commercial applications. Rather, they are used as reactive intermediates in the manufacture of other fluorosurfactants and PFC polymer products, where they are often present in residual amounts of up to 4 by weight [6]. Indirect Sources of Fluorinated Chemicals to the Environment Fluorotelomer Alcohols The fate of fluorinated and perfluorinated compounds is dependent on the particular chemical in question and the surrounding environment. Due to the high strength of the fluorine - carbon bond, fluorinated chemicals are typically very stable and highly resistant to biological and abiotic degradation. However, some carbon- fluorine bonds are biodegradable under aerobic conditions [7], and recent studies have demonstrated that some fluorinated chemicals can degrade in ways that partially explain patterns of PFC contamination observed in the environment. Several studies have demonstrated that perfluorocarboxylic acids (PFCAs, which include PFOA and PFBA, perfluorobutanoic acid) and perfluoroalkanesulfonates (such as PFOS and PFBS, perfluorobutane sulfonate) are extremely persistent in surface water, soil, and ground water, and are unlikely to break down. Moody, et al. [8] reported that the PFCAs PFOA and perfluorohexanoic acid (PFHxA) as well as PFOS, were very persistent in surface water into which fire- fighting foam was spilled, and were detected in fish liver tissue over years of sampling after the spill. PFCAs were also persistent in ground water where AFFF fire- fighting foam was used for training[9]. These studies focused on surface water or ground water contamination that was attributable to an identifiable source or spill. The reasons for widespread, low -level contamination of soil, ground water, and surface water in the ambient environment, however, are not clear, because it is difficult to explain how non - volatile PFCA salts such as PFOA could be transported to areas far from a likely source of these chemicals. FTOHs are usually precursors to the production of fluoropolymers used in paper and carpet treatments, paints, adhesives, waxes, and polishes. They are considered semi - volatile, but their environmental fate is dictated by their partitioning behavior [10]. They have a vapor pressure of 140 — 990 Pa and partition into the atmosphere, where they have been detected at concentrations of 17 -135 picograms m' [11]. FTOH is known to break down abiodcally in the atmosphere with roughly a 20 day half -life, yielding the corresponding PFCAs such as perfluorodecanoic acid (PFDA) [2, 11]. With over 10 million pounds of FTOH produced per year, Ellis et al. [11] concluded that enough FTOH is manufactured yearly to maintain currently observed concentrations of PFCAs in the environment. The process of FTOH degrading to PFCAs may account for the estimated 0.4 tons of PFOA deposited in the arctic annually [2]. FTOHs can also undergo biological breakdown to PFCAs (e.g. PFOA), during aerobic treatment of wastewater treatment plant (W WIP) sludge via beta - oxidation. Between 1 —10% of FTOH is converted to PFOA in this treatment process [7, 101. The degradation of FTOHs to PFCAs is consistent with the observations made of the distribution of PFC in other studies: • The appearance of PFDA in fish samples in Minnesota is consistent with the breakdown of 10:2 FTOH to PFDA. The longer chain PFCAs have no significant history of intentional industrial production [12], and there is no known natural source of long -chain PFCAs [11]. • DeSilva and Mabury [12] report that 98% of human blood samples from the Midwest in 2004 -2005 consist of straight - chain, telomere -based PFDA, implying that only 11% of the PFOA exposure was to ECF- derived PFDA. They attributed 89% of the PFOA to fluorotelomer -based production methods. • Recent MPCA studies show that various perfluorinated surfactants — including PFDA and PFOS —were present in the atmosphere in 2008. The presence of these compounds in the air can be explained by the photodecomposition of FTOH molecules in the atmosphere. 3M discontinued manufacture of these PFCs in 2000. • Minnesota ground water monitoring shows PFOA, PFPeA ( perfluoropentanoic acid), PFHxA, PFHpA (perfluoroheptanoic acid), and PFNA at low concentrations that are widespread under ambient conditions, with no known or likely sources of these compounds. The degradation of FTOH compounds to these corresponding PFCAs is a plausible source of these PFCA detections in the ambient environment. Fluorinated Polymers Fluorinated polymers are produced in far greater volumes than the fluorinated surfactants. However, very little has been published regarding the fate and behavior of fluorinated polymers in the environment [3] Synthetic polymers in general are typically very resistant to biological or non - biological degradation. Studies on fluoroacrylate polymers indicate that these compounds have a 1200 year half -life and the biodegradation of fluoroacrylate polymers is expected to add only a very slight amount of PFCA to the global pool of PFCAs [13]. However, PAPs — polymers used extensively for oil and water- resistant coatings on food contact paper products — degrade into FTOHs and subsequently to a toxic fluorotelomer aldehyde intermediate, which, in turn, degrades to fluorotelomer carboxylic acids such as PFOA [5]. The degradation of PAPS was found to occur in the gastrointestinal tract and bloodstream of laboratory animals. With PAPr representing 20% of all PFCs produced forpaper coatings, this represents a significant source of exposure to PFCAs like PFOA. [5]. PAPS are typically generated from monomers of N- EtFOSE, which are produced through the ECF process described above. Studies conducted by 3M indicated that N- EtFOSE can aerobically degrade to PFOS in wastewater in 35 days. Another study found that biodegradation of N- EtFOSE in wastewater did not generate PFOS in wastewater [14], although it did anaerobically degrade to related compounds. This work suggested that the transformation of N- EtFOSE to PFOS may not occur within the typical hydraulic residence time of a WWIT, and implied that any PFOS in WW'IP effluent is likely due to PFOS present in the in influent. It appears that much of the PFOS in a W WTP is removed. Shultz et al [3] estimated that 98% of PFOS was removed in W WTPs. N- McFOSE was typically used to manufacture fluorinated - polymer coatings for fabric and carpet. Shoeib et al [15] found that indoor air concentrations of N- McFOSE and N- EtFOSE were roughly 10 -20 times greater than outdoor concentrations. It has been suggested that these compounds can break down into PFOS directly in the atmosphere [16] thereby providing a route of human exposure to PFOS ingestion and inhalation inside the home where these products have been used. The breakdown of N- McFOSE and N- EtFOSE to PFOS may also explain in part the presence of PFOS in remote environments, since N- McFOSE and N- EtFOSE volatilize and can be transported through the atmosphere, eventually breaking down to PFOS [17]. However, it may also be possible for PFOS to condense onto atmospherically mobile aerosol particles that are then transported over long distances and eventually deposited in remote locations [17]. In soil, PFOS has been found to adsorb to various iron minerals, with adsorption increasing with PFOS concentration [18]. However, PFOS apparently adsorbs to soilless than hydrocarbons of similar size [18]. Other studies with PFC surfactants show that the organic carbon concentrations in the soil and PFC size are the most important factors influencing sorption to soil [19]. In addition, low pH and high Ca" in soil solution increases the adsorption of these compounds, suggesting that electrostatic interactions are important in the sorption of PFOS and other PFC surfactants to soil and sediment [19]. Microcosm studies conducted on ground -water sediment collected from the Washington County landfill [20] indicated that adsorption of PFOS and PFOA may be dependent on the oxidation /reduction status of the ground water, implying that these compounds may become more mobile in highly reduced ground water aquifers. References 1. Banks, R. E.; Smart, B. E.; Tatlow, J. C., Organofluorine Chemistry: Principles and Commercial Applications. Plenum Press: New York, 1994; p 644. 2. Wallington, T. J.; Hurley, M. D.; Xia, J.; Wuebbles, D. J.; Sillman, S.; Ito, A.; Penner, J. E.; Ellis, D. A.; Martin, J.; Mabury, S. A.; Nielsen, O. J.; SulbaekAndersen, M. P., Formation of C71 (PFOA) and Other Perfluorocarboxylic Acids during the Atmospheric Oxidation of 8:2 Fluorotelomer Alcohol. Environ. Sci. Technol. 2006, 40, (3), 924 -930. 3. Schultz, M.; Barofsky, D.; Field, J., Fluorinated Alkyl Surfactants. Environmental Engineering Science 2003, 20, (5), 487 -501. 4. Liu, J.; Lee, L. S., Effect of Fluorotelomer Alcohol Chain Length on Aqueous Solubility and Sorption by Soils. Environ. Sci. Technol. 2007, 41, (15), 5357- 5362. 5. D'Eon, J. C.; Mabury, S. A., Production of Perfluorinated Carboxylic Acids (PFCAs) from the Biotransformation of Polyfluoroalkyl Phosphate Surfactants (PAPS): Exploring Routes of Human Contamination. Environ. Sci. Technol. 2007, 41, (13),4799-4805. 6. Dinglasan - Panlilio, M. J. A.; Mabury, S. A., Significant Residual Fluorinated Alcohols Present in Various Fluorinated Materials. Environ. Sci. Technol. 2006, 40, (5), 1447 -1453. 7. Wang, N.; Szostek, B.; Folson, P. W.; Solecki, L. M.; Capka, V.; Buck, R. C.; Berti, W. R.; Gannon, J. T., Aerobic biotransformation of 14C- labeled 8 -2 telomer B alcohol by activated sludge from a domestic sewage treatment plant. Environmental Science and Technology 2005, 39, 531 -538. 8. Moody, C. A.; Martin, J. W.; Kwan, W. C.; Muir, D. C. G.; Mabury, S. A., Monitoring Perfluorinated Surfactants in Biota and Surface Water Samples Following an Accidental Release of Fire- Fighting Foam into Etobicoke Creek. Environ. Sci. Technol. 2002, 36, (4), 545 -551. 9. Moody, C. A.; Hebert, G. N.; Strauss, S. H.; Field, J. A., Occurrence and persistence of perfluorooctanesulfonate and other perfluorinated surfactants in groundwater at a fire- training area at Wurtsmith Air Force Base, Michigan, USA J. Environ. Monit. 2003, 5, 341 -345. 10. Ning Wang, B. S., Robert C. Buck, Patrick W. Folsom, Lisa M. Sulecki, Vladimir Capka, William R. Berti, and John T. Gannon Fluorotelomer Alcohol Biodegradation- Direct Evidence that Perfluorinated Carbon Chains Breakdown Environ. Sci Technol. 2005, 39. 7516 -7528. 11. Ellis, D. A.; Martin, J. W.; DeSilva, A. O.; Mabury, S. A.; Hurley, M. D.; SulbaekAndersen, M. P.; Wallington, T. J., Degradation of Fluorotelomer Alcohols: A Likely Atmospheric Source of Perfluorinated Carboxylic Acids. Environ. Sci. Technol. 2004, 38, (12), 3316 -3321. 12. DeSilva, A. O.; Mabury, S. A., Isomer Distribution of Perfluorocarboxylates in Human Blood: Potential Correlation to Source. Environ. Sci. Technol. 2006, 40, (9), 2903 -2909. 13. Russell, M. H.; Berti, W. R.; Szostek, B.; Buck, R. C., Investigation of the Biodegradation Potential of a Fluoroacrylate Polymer Product in Aerobic Soils. Environ. Sci. Technol. 2008, 42, (3), 800 -807. 14. Boulanger, B.; Vargo, J. D.; Sclmoor, J. L.; Hornbuckle, K. C., Evaluation of Perfluorooctane Surfactants in a Wastewater Treatment System and in a Commercial Surface Protection Product. Environ. Sci. Technol. 2005, 39, (15), 5524 -5530. 15. Shoeib, M.; Harper, T.; Wilford, B. H.; Jones, K. C.; Zhu, J., Perfluorinated Sulfonamides in Indoor and Outdoor Air and Indoor Dust: Occurrence, Partitioning, and Human Exposure. Environ. Sci. Technol. 2005, 39, (17), 6599- 6606. 16. Martin, J. W.; Muir, D. C. G.; Moody, C. A.; Ellis, D. A.; Kwan, W. C.; Solomon, K. R.; Mabury, S. A., Collection of Airborne Fluorinated Organics and Analysis by Gas Chromatography /Chemical Ionization Mass Spectrometry. Anal. Chem. 2002, 74, (3), 584 -590. 17. Wania, F.; Mackay, D., Tracking the distribution of persistent organic pollutants. Environmental Science and Technology; VOL. 30; ISSUE: 9; PBD: Sep 1996 1996, pp. 390A-396A; PL:. 18. Johnson, R. L.; Anschutz, A. J.; Smolen, J. M.; Simcik, M. F.; Penn, R. L., The Adsorption of Perfluorooctane Sulfonate onto Sand, Clay, and Iron Oxide Surfaces. J. Chem. Eng. Data 2007, 52, (4),1165-1170. 19. Higgins, C. P.; Luthy, R. G., Sorption of Perfluorinated Surfactants on Sediments. Environ. Sci. Technol. 2006, 20. Ferrey, M.; Adair, C.; Wilson, J. T. In Sorption of PFOA and PFOS to aquifer sediment., PFAA Days: Recent Advances in Perfluoroalkyl Acid (PFAA) Research., Research Triangle Park, North Carolina, 2008; Research Triangle Park, North Carolina, 2008. Appendix C Summary of PFC Toxicity Studies Please note: This is not an exhaustive list and other studies may exist that the author was not aware of at the time of printing. Species or Compound and Endpoint Effect Reference Type of Assay Exposure Concentration Concentrations (mg /kg bw /day (mg /kg bw /day unless unless otherwise otherwise noted ) noted) Rat PFOS potassium salt Death LC50 = 100 Goldenthal et al., 90 day oral 0, 30, 100, 300, 1000, 1978 3000 Changes in organ and LOAEL = 30 exposure body weight Rat PFOS potassium salt Significant reduction LOAEL = 0.4 Christian et al., 1999 2 generation 0.1, 0.4, 1.6, 3.2 by pup weight gam in F3 reproductive wage generation NOAEL = 0.1 toxicity Rat PFOS Histopathological LOAEL (both sexes) Covance 2 -year dietary 0.06 — 0.23 (males) changes in liver = 40.08 µg /g in liver Laboratories, Inc. study 0.07 — 0.21 (females) And 13.9 mg /L in 2002 serum Rhesus monkeys PFOS potassium salt l00% Death 4.5 Goldenthal et al., 90 day gavage 0, 0.5, 1.5, 4.5 1978 Gastrointestinal LOAEL = 0.5 toxic Cynomolgus PFOS Thymic atrophy LOEL = 0.03 Covance monkeys (females) Corresponding to Laboratories, Inc. 26 weeks mean concentrations 2002 Reduced HDL, in female and male cholesterol, triiodo- sera and liver of 19.8 thyronine, total µg /mL and 14.5 bilirubin (males) µ / , respectively Fathead minnow PFOS lithium salt Death LC50 (96h) = 4.7 OECD, 2002 (Pimepbales mg/L promelas) 96 h and 42 d NOEL (42d) = 0.3 m /L Mysid shrimp PFOS lithium salt Death LC50 (96h) = 3.6 OECD, 2002 (Mysis ba&a) mg /L NOEC = 0.25 m /L Aquatic midge PFOS Growth and survival NOEC (10d) = Macdonald et al., (Cbironomous 0.0491 mg /L 2004 tentans Green Algae PFOS Cell density ICso (96h) = 48.2 Boudreau et al., 2003 (Pseudokircbmrilla mg /L subcapitata) NOEC = 5.3 m /L Mallard duck PFOS Reduced testes size 10 mg /kg diet 3M, 2003 (Arras and decreased corresponding to platyrbyncos) spermatogenesis serum and liver concentrations of 21 weeks in feed 87.3 µg /mL and 60.9 µg /g, respectively Species or Type Compound and Endpoint Effect Reference of Assay Exposure Concentration Concentrations (mg /kg b-/day (mg /kg bw /day unless otherwise unless otherwise noted) noted Bobwhite quail PFOS Increase in liver 10 mg /kg diet 3M, 2003 (Colinus virginianus) weight (female) 21 weeks in feed Increased incidence of small testes size (male) Reduced chick survivability as a percentage of eggs set Marine Mussel PFNA Inhibition of p- IC50 (PFNA) = 4.8 Stevenson et al., 2006 (Mytilus PFDA glycoprotein cellular pM califormanus) efflux transporter resulting in IC50 (PFDA) = 7.1 chemosensitization JAM Male Rats PFDoA Decreased absolute 10 Shi et al., 2007 14 day oral 1, 5, 10 testes weight Increased total serum 10 cholesterol Increasedlutehilzing 10 hormone Decreased 5 and 10 testosterone Reduced mRNA 5 and 10 expression of genes involved in cholesterol transport and steroid synthesis Medaka (Ory;,ias lati es MCF -7 Breast 6:2 and 8:2 FTOH Breast cancer cell 10 µM Maras et al., 2006 Cancer Cells proliferation In vitro Tilapia PFOS Estrogenicity 3.1 x 10 Liu et al., 2007 Hepatocytes PFOA determined by 5.1 x 10 In vitro 6:2 FFOH vitellogenin induction 1.1 x 10 M 8:2FI'OH 1 1 7.5x10 Other useful toxicity studies: 3M, 2008. Ecotoxicity of and Derivation of Preliminag Safe Wlater Concentrations for Perfluorobudyri, Acid (PFBA). Presented at North American SETAC, Tampa, Florida, 2008. Jensen, A and H. Leffers, 2008. ReviewAnicle.- Emerging endocrine disrupters: perfluoroalkylated substances, International Journal of Andrology, 31,161-169. Perfluorochemials and the 3M Cottage Grove Facility: Minnesota Dept. Of Health Page 1 of 3 R — 9 - 50 - i EFPLNiUI!NidiNFklBP Hazardous Waste Sites in Minnesota The 3M Cottage Grove Facility and Perfluorochemicals On this page: Introduction How were PFCs released on site? Where is the PFC contamination now? What do we know about PFCs? Are they harmfull Have oeoole been exposed in the past? What does MDH recomm More Inform Introduction The 3M Company produced perfluorochemicals (PFCs) at its Cottage Grove facility from the late 1940's until 2002. Perfluorooctanoic acid (PFOA) was the main type of PFC made at this site. PFOA is used in the making of products that resist heat, oil, stains, grease and water. Common uses include nonstick cookware, stain- resistant carpets and fabrics, and other industrial applications. How were PFCs released on site? For a time, wastes from the production process were disposed on site in a specially prepared pit; there may be other disposal sites as well. The water treatment plant on site that processed water from production activities did not remove PFCs, so PFCs were in the waste water that went into the Mississippi River. Some sludge left over from the water treatment process also contained PFCs and was disposed on site, On the west side of the site, firefighting foams containing PFCs were used in training exercises. PFCs may also have been released into the air Where is the PFC contamination now? Preliminary environmental testing shows that the groundwater beneath the 3M Cottage Grove site is contaminated with PFOA, a related chemical, perfluorooctane sulfonate (PFOS), and other PFCs. In some areas, the levels of PFOA and PFOS exceed the Minnesota Department of Health (MDH) drinking water criteria. More testing needs to be done to define the extent of contamination. However, testing of the water from four residential drinking water wells just to the east of the facility did not find either chemical. These wells are deep and not "downstream" from the contamination. An extensive system of wells contains and collects much of the groundwater from under the site so that the wastewater treatment plant can process it. Recently, a large granular activated carbon filter was added to the plant to remove PFCs from the water before it goes into the river. Shallow groundwater near the disposal pit is not collected by the well system and may still allow PFCs to enter the river. What do we know about PFCs? Are they harmful? PFOA and PFOS are very stable chemicals that do not change or break down in the environment. There are a few studies indicating that PFCs easily enter groundwater and move long distances. Some experts also suggest that during the years of PFC production, PFCs in air emissions from the facility could have deposited on soil and leached into the groundwater. The PFC family of chemicals is relatively new and there are not many studies of health effects in people. In animals, high concentrations of PFCs cause harm to the liver and other organs. Perfluorochemials and the 3M Cottage Grove Facility: Minnesota Dept. Of Health Page 2 of 3 Exposures to high concentrations of PFOA over a long period of time also cause cancer in animals. Developmental problems have been seen in the offspring of rats exposed to PFCs while pregnant. Have people been exposed in the past? Workers at the facility were exposed to PFCs in the course of their work and also through the facility's water supply. 3M has been monitoring PFCs in the workers' blood since the 1970's. Epidemiological studies of these workers show no impact of PFCs on worker mortality. There is no similar epidemiological information on PFCs in the general population. Studies do show that everyone has some PFCs in their blood, regardless of age. Concentrations of PFCs in the general population are many times less than that of the 3M workers. The way PFCs get into human blood is not known at this time. People could be exposed through food, water, use of commercial products or from the environment. PFCs stay in the human body for many years. PFCs have also been found in the blood of several species of wildlife around the world; the highest concentrations are in bald eagles and mink in the midwestern U.S. Studies also show that PFOS bioconcentrates: large fish have more PFOS in their bodies than small fish. What does MDH recommend? We cannot fully assess the impact of PFCs from the Cottage Grove facility on public health at this time. More testing of the soil, groundwater, surface water, sediments and biota is planned. Understanding the different pathways for human exposure to PFCs in the environment is critical. MDH will continue to work with the Minnesota Pollution Control Agency and 3M to collect environmental data and assess the public health impacts of this site. Printab information sheet (PDF: 30Ke /2 pages) For more information If you have questions, please contact: Jim Kelly, Site Assessment and Consultation Unit, 651- 201 -4910 or 1 -800- 657 -3908, press "4" or the Minnesota Relay Service (TTY) at 1- 800 - 627 -3529 health. hazard @state•mn.us Additional information on the web: Health Consultation 3M Chemolite Perfluorochemical Releases at the 3M Cottage Grove Facili (PDF• 4 975KB/89 napes) Minnesota Department of Health Minnesota Pollution Control Ayency: Perfluorochemicals Attention: Non -MDH link. Environmental Protection Agency: Perfluorooctanoic acid Attention: Non -MDH link. This information sheet was prepared in cooperation with the U.S. Agency for Toxic Substances and Disease Registry For more information about this page, please contact us at health.hazard Ca)state.mn.us call 651- 201 -4897, or toll -free 1- 800- 657 -3908 and press "4•' to leave a message. h rfr.• / /.,� :,.,, Hotel+ 1...+..+,.«.«..../ A:_.../ �Ln-,..... ,_A_- __ /_:.__L_.__te.__.._._i�w c__.._ v . .. ,. �,....... Perfluorochemials and the 3M Cottage Grove Facility: Minnesota Dept. Of Health Page 3 of 3 Updated Tuesday, 06 -Jan -2009 13:34:14 CST • .. 11 s YY /Y / f tt v / / 9 . /nW F •.. 1.x..9 /B /t! //1A1/� •I L • •: ptw-u4 • iviay zuuu Remediation Division, Superfund Program pfc3 -04 T he Minnesota Pollution Control Agency is proposing a cleanup plan for the 3M Cottage Grove Site in Cottage Grove, Minn. The plan addresses contamination related to perfluorochemicals (PFCs) in wastes disposed of at the site by the 3M Company. This fact sheet describes the proposed plan and how the public can comment on it. The 3M Cottage Grove Site encompasses a large industrial complex located along U.S. Highway 61 in Cottage Grove, Minn. The property covers about 1,700 acres but only about 200 acres on the southern portion are industrialized. High bluffs above the Mississippi River are on the southwest side of the property. Formerly known as the 3M Chemolite plant, the facility has been in operation since 1947. 3M currently manufactures a range of products there, including adhesive products, specialty paper, industrial polymers, abrasives, and reflective road -sign materials. The company also does proprietary research and development there. As was common in manufacturing before the advent of environmental regulations, 3M disposed of various industrial wastes, including those from PFC manufacture, on the property as well as at three other disposal sites in Washington County. Disposal methods on the Cottage Grove property included burial and disposal pits. The site was placed on the Superfund list in 1984 due to soil and groundwater contamination from volatile organic compounds (VOCs), typically solvents. 3M completed site investigations and cleanup actions to address VOCs at the Cottage Grove site in both soil and groundwater. A groundwater pump -out system was installed to prevent VOCs in groundwater at the site from reaching the Mississippi River. The pump -out system is still in operation today. PFCs at the 3M Cottage Grove site PFCs are a family of synthetic chemicals that were initially developed in the 1950s and manufactured by 3M at the Cottage Grove facility. PFCs are used in a wide variety of products made around the world because of their unique abilities to resist heat, oil, stains, grease, and water. 3M phased out manufacture of some PFCs by 2002, most notably perfluorooctanoic acid (PFOA) and perfluorooctane sulfonate (PFOS). As a result of the discoveries starting in 2004 that drinking water in parts of Washington County had become contaminated with PFCs, the MPCA directed 3M to look for PFC contamination remaining in soil or groundwater from past disposal practices on the Cottage Grove property. Investigation began in 2005 and continued into 2009 under MPCA oversight. Site investigations The MPCA and 3M signed a Settlement Agreement and Consent Order in May 2007 governing investigation and cleanup of the three 3M PFC disposal sites (i.e., Oakdale, Cottage Grove, and Woodbury). As part of the agreement, 3M completed a Remedial Investigation (RI) and Feasibility Study (FS) for the Cottage Grove site, the focus of which were to identify any remaining risks to public health or the environment from releases of PFCs at Minnesota Pollution Control Agency a 520 Lafayette Rd. N., St. Paul, MN 55155 -4194 • www.pca.state.mn.us 651- 296 -6300 - 800 - 657 -3864 TTY 651 - 282 -5332 or 800 - 6573864 • Available in alternative formats the site. The Consent Order also required that in developing cleanup alternatives, primary consideration should go to those that excavate and destroy remaining PFC wastes, or that excavate and dispose of PFC wastes in a permitted, isolated, engineered containment facility. The RI for the Cottage Grove site showed that previous cleanup actions for VOCs had not removed all residual PFCs on the property. A number of areas were found to contain elevated levels of PFCs in soil and in groundwater beneath the property. These areas had been used in the past for a range of purposes including storage, disposal, or treatment of various types of solid or liquid wastes. Groundwater under the property flows toward the Mississippi River. PFCs are also found in treated wastewater discharged from the site to the Mississippi River, and in sediments in a cove at the foot of the bluff and near shore. Feasibility study The objective of the FS is to evaluate various response- action alternatives which address PFCs in soil and groundwater at the site, and to provide recommendations for implementation. The MPCA has reviewed the alternatives and is now ready to present its proposed plan for the site. The FS for the Cottage Grove site was developed with guidance and screening criteria of the U.S. Environmental Protection Agency which are used in the federal and Minnesota Superfund programs. The FS evaluates, compares, and contrasts each alternative for: • short and long -term effectiveness • reduction of toxicity, mobility, or volume through treatment • implementability • cost effectiveness • overall protection of human health and the environment. The FS for the 3M Cottage Grove site is available on the MPCA's Web page at www.pea.state.mn, us /publications /pfc- cottage¢rove- feasibil itystudv.pdf Summary of Alternatives Alternatives were developed in three categories: site - wide (SW), groundwater (GW), and soils and sediments (S /S). The following alternatives were developed for the FS: 3M Cottage Grave site - pfc3 -04 • May 2009 Alternative SW -1 -- No Further Action. Standard baseline option evaluated at all Superfund sites. No additional work to address soil and sediment contamination. No changes in current groundwater monitoring. Estimated cost: $148,000. Alternative SW -2 — Institutional controls, access restriction, and groundwater monitoring. Would include deed restrictions to ensure the area remains zoned industrial /commercial. The site is already fenced securely and new drinking -water wells near the property are prohibited. Existing groundwater monitoring would continue. Estimated cost: $653,000. Alternative GW -1 -- Enhanced groundwater recovery with treatment prior to discharge. Would expand and improve the existing groundwater extraction system to prevent off -site migration of groundwater beneath the Eastern Disposal Area and the East Cove, as well as the main plant area. Discharge from the system would be treated in the facility's existing wastewater treatment plant, which has a large Granulated Activated Carbon finishing system that removes PFCs. Discharge to the river would be required to meet MPCA- imposed limits for PFCs. Estimated cost: $5.1 million. (GW -1 was the only groundwater alternative developed in the FS because this type of system has proven effective at destroying PFCs when carbon filters are thermally regenerated.) Alternative S /5 -1 — Treated wastewater from the facility is currently discharged via a flow channel to the Mississippi River at the East Cove. This alternative would: Stabilize the flow channel to prevent scouring; remove PFC - containing sediments in portions of the cove and remove portions of sandbar at cove outlet; dewater excavated sediments and transport them to long- term containment cell at the SKB Industrial Landfill in Rosemount; cover (cap with clayey soils) Disposal Areas Dl, D2, and D9. Estimated cost: $9.4 million. Alternative S/S 2 — Includes all elements of S /S -1 plus removal of PFC - containing soils above Industrial Soil Reference Values (SRVs) for PFOA and /or PFOS in selected portions of Disposal Areas Dl, D2 and D9. Excavated land areas would be backfilled with clean soil. Estimated cost: $14.7 million. Alternative S /S -3 (refined) — Same as S /S -2 plus removal of concrete basin previously used for disposal in Area Dl and overlying soils. Under this refined alternative, 3M conducted MPCA- required supplemental investigations, and identified additional soils in Disposal Areas DI, D2, and D9 that will be removed. In addition, '" Minnesota Pollution '.r Control AgeneY page 2 PFC contaminated sediments from throughout the East Cove will be removed, not just portions. Estimated cost: — $15 million. Long -term containment of excavated PFC - containing material. Any soil, sediment, or other material excavated during cleanup that contains PFCs above the Industrial SRVs will be removed and placed in a permitted, engineered, long -term containment facility that is being built for these 3M materials at the SKB Industrial Landfill in Rosemount, Minnesota. This disposal facility will also be used for materials excavated and removed from the 3M Woodbury and 3M Oakdale disposal sites. All leachate from these PFC - containing materials will be collected and taken to the 3M Cottage Grove facility for treatment. MPCA's recommended alternatives The MPCA recommends implementing the following remedies at the Cottage Grove site (see summary table). SW -2: Institutional controls, access restriction, and groundwater monitoring. GW -1: Enhanced groundwater recovery with treatment prior to discharge. S /S -3 (refined): Stabilize flow channel to East Cove and remove PFC- containing sediments throughout the cove; remove portions of sandbar at cove outlet; remove concrete basin previously used for disposal in Area Dl and overlying soils; Remove PFC - containing soils in Disposal Areas DI, D2, and D9 that exceed Industrial SRVs for PFOA and/or PFOS; transport excavated materials to newly constructed containment facility at the SKB Industrial Landfill in Rosemount; backfill excavated Disposal Areas with clean soil and shape to reduce infiltration; collect leachate at SKB containment facility and take to 3M Cottage Grove facility for treatment. MPCA staff believes this combination best meets the cleanup goals for the site. The selected remedies will take an estimated three years to complete. What are the next steps? This proposed cleanup plan is available for public comment (see below) from May 20 through June 19, 2009. After the comment period closes, MPCA will review any comments received and finalize the choice of remedial action(s), which will be documented in a Minnesota Decision Document (MDD). The MPCA's responses to comments received will be included in the Responsiveness Summary attached to the MDD. Unless significant modifications to the proposed remedies described in this fact sheet are needed, design and construction of the selected remedies should begin in fall 2009. Table of alternatives (shaded = MPCA Dreferred alternatives) Alternative Description SW -1 No further action SV✓ =2! ry lYStituhonai `cbntfiols, access_restnchori�rnonitorui G =li Enhanced grhundwater recovery and treatment S /S -I Remove sediments in portions of East Cove; remove portions of sandbar at cove outlet; dispose of excavated soils /sediments off -site; cover Eastern Disposal Area S /S -2 Same as S /S -1 plus remove soils which have concentrations of PFOA or PFOS above Industrial Soil Reference Values (SRVs) from portions of Disposal Areas Dl, D2 and D9 S` /S 3 (refiried) Sametas SIS 2 plus zmove conccete and all oveilyirig soil`s i' "pArea D1, and remove PFC contaminated sediments from throughout the East Cove. Additional soil and sediment will be removed from DI, D2 and D9, and the East Cove as a result of MPCA- required supplemental investigations. All excavated PFC contaminated soil /sediments will be disposed off site at the SKB Industrial Landfill in Rosemount, Minnesota. 3M Cottage Grove site • pfc3 -04 ^ May 2009 page 3 After the selection of the final remedy for the Site, 3M will prepare construction design documents for MPCA review and approval. These documents will outline activities and provide a more detailed schedule for completing the cleanup actions. Included in this plan will be such items as hours of operation, construction traffic flow, worker health, and safety, odor and noise controls. Public comment and meeting on proposed alternatives Public review and comment on the proposed cleanup plan for the 3M Cottage Grove site is an important contribution to " - mtnnesola pollution _ Control Agency the remedy selection process. The public is invited to submit written comments on this proposed plan through June 19, 2009. Written comments may be sent to Gary Krueger, MPCA, Remediation Division, 520 Lafayette Road, St. Paul, MN 55155 -4194 or email gary.krueger @pca.state.mn.us. Written comments may also be submitted at a public meeting on May 27, 2009 at the Cottage Grove City Hall. 3M Cottage Grove site • pfc3 -04 • May 2009 Where can I get more information? The full FS, along with addendums and other site - related ` — information, is available on the MPCA Web site at http: / /www.pca.state.mn.us /cleanup /pfc /Pfesites.html, or by contacting Ralph Pribble at the MPCA, (651) 757- 2657 or ralnh nribble ]2ca state mn us Mtnn¢ ota.Pollutlon _ ControlAgoncy page 4 Aerial view of Cottage Grove site, showing disposal areas D1, D2 and D9, and East Cove 2wf °1 . ;x Minnesota Pollution Control Agency PFCs Lateral Team c- pfc1 -01 rr a c- pfc1 -01 • March 2009 P erfluorinated chemicals (PFCs) were first found to have contaminated drinking water supplies in parts of the eastern Twin Cities in 2004. The MPCA and Minnesota Department of Health (MDH) identified contaminated wells and the MPCA provided clean drinking water. Most of the contamination was traced to four dumps or landfills. The known drinking -water problems are under control and cleanup plans for three of the four waste sites have been approved. The MPCA's focus on PFCs is shifting to investigating use of PFC- containing foams at firefighting training sites and PFCs in the ambient environment. This fact sheet is the second general update on current status of the MPCA's work on PFCs. Previous history of the agency's response to this complex problem is available on the MPCA's Web site at www.pea.state.iiin.us/cleanut)`/`gfc/index.ht mi. PFCs are a family of synthetic chemicals, initially developed by the 3M Company, that have been used for decades to make products that resist heat oil stains, grease, and water. 3M has phased out manufacture of some PFCs, but there are currently other manufacturers of PFCs around the world. From the 1950s through the early 70s, 3M disposed of wastes from PFC manufacturing primarily in four places: dump sites in Oakdale and Woodbury, the 3M manufacturing facility in Cottage Grove, and the Washington County Landfill. In late 2003, the MPCA discovered PFCs in ground water at and near some of these sites. In 2004, MPCA began sampling monitoring wells at the disposal sites and nearby private wells, and the MDH sampled city wells in Washington County to identify drinking -water supplies with PFCs. Sampling soon expanded to a wider area of the east Metro. More than 1,600 private wells were sampled, along with more than 50 community wells. Both private and community wells were affected, including a number of private wells in Lake Elmo, Cottage Grove, Grey Cloud Island Township, and several of the city of Oakdale's wells. Based on PFC levels found in some wells, MDH advised 83 households not to drink their water due to PFCs. Coincident with these activities, staff in the MPCA's Superfund Program and Closed Landfill Programs conducted and ordered investigations for PFCs related to the four waste sites. The sites had all been previously investigated for other contaminants, so a great deal was known about their subsurface geology, ground water, and past disposal practices. Current status Waste disposal sites In May, 2007, the MPCA Citizens' Board approved a Settlement Agreement and Minnesota Pollution Control Agency 520 Lafayette Rd. N., St. Paul, MN 55155 -4194 • www.pca.state.mn.us 651- 296 -6300 - 800 -657 -3864 = TTY 651- 282 -5332 or 800 -657 -3864 • Available in alternative formats Consent Order negotiated between MPCA staff and 3M. The CO is a legally binding document that lays out timetables, deliverables and other requirements, including funding, for investigating and cleaning up PFCs at the three 3M sites. Because the Washington County site is in the MPCA's Closed Landfill Program, 3M has no legal liability for the site but did agree under the CO to provide up to $8 million to help fund the state's cleanup of the site. MPCA staff and management provide quarterly progress reports to the Citizens' Board on implementation of the CO. As of February 2009, the MPCA Commissioner had approved cleanup plans for the Washington County Landfill and the 3M Oakdale, and 3M Woodbury sites. A proposed cleanup plan for the 3M Cottage Grove site will go out for public comment later this spring. Construction of the selected remedies at all four sites should start in spring/summer 2009. Cleanup plans for the three 3M sites share basic similarities of 1) institutional controls; 2) excavation of remaining source areas, 3) continued and /or enhanced ground -water extraction and treatment, and 4) long -term monitoring. Excavated wastes from these sites will be placed in a specially built long -term containment cell at the SKB Industrial Landfill in Rosemount, Minn. The Washington County Landfill will be re- excavated and the wastes placed into newly constructed, triple -lined cells on -site. Plans for all four sites have gone or will go through the MPCA's public participation process used in Superfund cleanups. Public participation is not required in the Closed Landfill Program but because all four sites are in similar situations, MPCA management chose to apply the Superfund public participation process to the Washington County site as well. All work performed at the 3M sites and MPCA expenses under the Superfund program are funded by 3M under the CO's cost recovery provisions. Information on cleanup of the four sites is on the MPCA Web site at vlrww.12ca.state.iian.us/cleaiiup/pfc/pfcsites.litmi Drinking water All of the households or communities with PFCs above MDH health standards have been provided with bottled water, carbon filtration, or municipal water hookups. 3M provided the city of Oakdale with large carbon filtration units which filter water from two of the city's affected wells at the treatment plant. 3M also provided funding for the city of Lake Elmo to extend clean city water to over 200 homes in the area affected by the contamination. In March 2008 MDH published a Health Based Value (HBV) of 7 parts per billion for PFBA (one of the PFCs of concern). Previously, MDH had provided a temporary drinking -water guidance of 1 ppb for PFBA, and issued advisories for wells near the Washington County and Oakdale disposal sites. The new limit means about 50 wells that received advisories are now below the HBV. Advisories will remain in place until MDH rescinds them. The agencies are developing a joint monitoring plan for the future to ensure safe drinking water. The 2007 Legislature directed MDH to study the effectiveness of point -of -use treatment systems for individual households. A number of water - treatment systems were found to be effective at removing PFCs. Final results of the study are on the MDH Web site at www.liealtli.state.mn.us/divs/eli/liazardous/tol)ics/l)fcs/in dex.html East Metro PFC Biomonitorinn, Study MDH's East Metro PFC Biomonitoring Study is measuring exposure to PFCs in adults living in selected areas of Washington County where the drinking water is contaminated with PFCs. Although public health actions to prevent or reduce people's exposure to PFCs are now in place, some PFCs stay in the body for years and can likely still be measured. A report on the result of the study will be released later in 2009. PFCs in the ambient environment Over the last 10 years or so, scientists have found trace levels of PFCs nearly everywhere in the environment; low levels are found in people and animals around the globe. In Minnesota, it has been apparent since 2006 that PFCs may be present at concentrations of potential concern in areas that are not related to the waste disposal sites. Using funding provided by 3M under the CO, the MPCA has made a number of important discoveries regarding PFCs in Minnesota's ambient environment. For example: ® Fish from several lakes in the Twin Cities and portions of the Mississippi River have elevated concentrations of PFOS (one of the PFCs of concern) in fish tissue, which has prompted MDH to issue fish - consumption advisories. l Investigating PFCs in Minnesota: Current Status , c- pfc1 -01 - March 2009 page 2 Minnesota Pd ,von Centrd Agency • Trace levels of PFCs are found in some shallow ambient ground water statewide, although levels are -- well within HBVs. • The chemicals have been found in the effluent of a number of wastewater treatment plants sampled by the MPCA. • PFCs were detected at permitted landfills, as well as in ground water up- and down - gradient of some facilities (also at levels within health -based limits). • The MPCA is beginning an investigation into whether PFCs used in firefighting foam may have entered soil and ground water at firefighter training sites. The MPCA is conducting more than a dozen ambient research projects, summarized in a report titled "PFCs in the Ambient Environment: 2008 Progress Report" (available on the Web at httl2://www.pea.state,mn.us/publications/c fl These investigations will continue in 2009. PFCs are still widely used around the world even though 3M ceased production of PFOA and PFOS in 2002. Other American manufacturers have phased out or will phase out production of some PFCs as well. Manufacturers in other countries continue to produce PFOA and PFOS for use in products that are legally exported and used for beneficial purposes here and around the globe. Research by the MPCA and others suggests that past and present PFC manufacture or end - usage provides pathways for release into the environment that cannot be directly attributed to 3M, which developed the original PFC chemistry. What does it all mean? MPCA investigations have shown that while PFCs are relatively widespread in Minnesota, concentrations are typically not present at levels triggering health concerns, except at a few small locations. The areas where concentrations of the three PFCs of concern, alone or in combination, exceed MDH limits are being addressed by treating city water (Oakdale) or providing bottled water or treatment systems to individual households (Lake Elmo, Cottage Grove, and Grey Cloud Island Township). MDH also prohibits construction of new wells in some aquifers that are contaminated with PFCs in portions of Oakdale and Lake Elmo. Cleanups of the four PFC disposal sites beginning this year will ensure that any residual PFC contamination at the sites is removed or contained. Sampling results indicate the ground -water plumes for PFCs related to the waste sites are stable, i.e. the areas of contamination are not expanding and the concentrations are not increasing. The chemicals may have left the Oakdale, Woodbury and Lake Elmo waste sites years ago, before existing ground -water pump -out systems had been installed at those sites. Long -term sampling of city and private wells is planned to assure that if the ground- water contamination changes, actions will be taken to protect public health. While some uncertainties remain, public health risks appear to be low. (For more information on PFCs and health, see www.health.state.mii.us/divs/eh/hazardous/topies/pfcshe alth.html It is important to remember that these chemicals are critical components of many products on which human health and safety depend, for example hydraulic fluids in aircraft and firefighting foams. Eliminating their use could in some cases create unacceptable risk tradeoffs. While Minnesota has been in the forefront of investigating PFCs, scientists in other states and nations have begun conducting their own research as well. As with other emerging contaminants, we will continue to work to gain a better understanding of the potential health and environmental effects of PFCs. For more information MPCA: Ralph Pribble, 651- 757 -2657 or ralph pribblegr ca state.ran.us MDH: Tannie Eshenaur, 651 -201 -4783 or tannie eshenaurna health state.mn.us MPCA Web: www pca state.inn.us/cleaiiup/pfc/index.lit ml MDH Web: www.health.state.mn.us/divs/eli/liazardous/topies/vfc s /in dex.htmI Investigating PFCs in Minnesota: Current Status • c- pfcl -01 • March 2009 page 3 Minnesota Pollution Control Agency -0 -------------------------- CL i z z z I z z z ❑ ❑ w g ❑ ❑ ❑ ❑ ❑ ❑ — 00 ❑ ❑ ❑ 0 r� 0 C� ❑ ❑ z ❑ U) z z Z Z Z Z Z Z (D Z z z I m z z z z Z z z z z z z z 00 1- m Cn C! 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U) U) 0) w co U) I m CL c OF N O 0 LO o Z Z Z Z Z o rn o 0 s N O LL IL c J2 CL a c rn m @ O o �O IQ N 7 N r Z M C @ p7 O O O o 0 o O v @ a O C CL d '0 IL oo c o j C a Q c M U c - d c 0 3 - LO N to N M V M h U CL y = 6 C 6 O -.t o 0 o 0 O t L _ m O L I LL Q O IL O m LL ) d Co d E U U U U V U U O O MO N N N N N N N N ai A 'a 12 A @ T @ A @ T @ T @ A @ @ I E O @ LL N a @ c `@ o c 3 c 0 n W U 3° w N @ c a O 0 O d U O o U m Y m K U vl 0 'a E 0 o ° U � N N w U c }} +� ` O O w- V (n f) fn In 0) fn V1 J N J g y m L N 0 a C O N d V N C U G 0O U O 0 C w () O 5 @ N O U p A m m ip Z ai N c 0 O) C N m A @ d N 0 `o_ CL d W b d C } o � d1 N N L c m W N 3 m @ N N a) N p N � V @ CL W s : Q m Z N ai 4 Sri Proposed • • on ■ A Summary of - Negotiations May zuut The negotiated agreement meets and exceeds all of the needs expressed by the MPCA Board. At its April meeting, the Minnesota Pollution Control Agency (MPCA) Citizens' Board directed staff to attempt to negotiate a Consent Order (a legally binding agreement) with 3M on perfluorochemical (PFC) contamination in Minnesota. The Board directed staff to address seven concerns in the Order. MPCA staff believe they have reached an agreement with 3M that meets and exceeds the needs expressed by the Citizens' Board. The Board has received copies of the proposed Order, and is scheduled to consider approval at its regular May meeting. The issues, and how they are addressed in the proposed Order are summarized below: s. A rigorous, robust cleanup plan The proposed Consent Order contains language that will result in excavation of contaminated material at the three sites (Cottage Grove facility, Woodbury Disposal Site and the Oakdale Disposal Site). The cleanup standard reflected in the proposed Consent Order is significantly more stringent than the normal cleanup standard required by the MPCA. The MPCA would have had the ability to pursue excavation under the Request for Response Action proposed earlier, however, the State would have faced a risk of litigation, resulting in delays in either cleanup or cost recovery. Under the proposed Consent Order, waste that is removed will be permanently controlled either through containment in an underground lined vault that meets all hazardous waste disposal standards, or by incineration. After waste is removed from contaminated areas, those areas will still be capped, and pump- and -treat systems will be installed to address any residual releases that may occur. 2. Recognition of Agency jurisdiction The proposed consent order has, as its legal foundation, the Minnesota Environmental Response and Liability Act (MERLA, the state Superfund law). While 3M reserves the right to disagree in other forums with the Agency's finding that MERLA applies, both parties agree that the Order is fully enforceable under MERLA. 3. Municipal and private drinking water supplies are addressed 3M commits to provide alternative drinking water if and when a Health Based Value (HBV) or Health Risk Limit (HILL) is exceeded as a result of contamination from the sites. This commitment will also apply to the chemical PFBA when an HBV is issued for it. As with the rest of the agreement, this is an enforceable requirement of the proposed Consent Order. Additionally, under the proposed Consent Order, the Agency has sufficient authority to require any groundwater investigation and Minnesota Pollution Control Agency - 520 Lafayette Rd. N., St. Paul, MN 55155 -4194 • wvW.pca.state.mn.us 651 - 296 -6300 • 800 -657 -3864 • TTY 651 - 282 -5332 or 800 -657 -3864 - Available in alternative formats monitoring necessary to fully understand the extent of the contamination, including in aquifers used for — drinking water. y. Address future actions on PFBA The proposed Consent Order requires 3M to investigate and remediate discharges of PFBA regardless of whether an HBV or HRL is issued for PFBA. 5. Address additional studies on health and environmental effects The proposed Consent Order addresses this issue in two ways. Any needed research that is directly connected to releases of PFCs at 3M sites is fully reimbursable to the State. There is no limit to the amount that can be recovered under this provision. Past costs associated with research on PFCs in the environment related to 3M sites are included in this agreement in the amount of $598,692. This includes the Agency's work investigating the effects of PFCs as part of the Agency's development of water - quality criteria, which includes understanding aquatic toxicity (chronic and acute affects on fish and other biota), human health consumption impacts, and wildlife impacts (bioaccumulation impacts from eating fish). This work, which is ongoing, is fully reimbursable under the proposed Consent Order. Additionally, the Order requires 3M to pay up to $5 million over the next four years to the Agency for research costs on the presence and effects of PFCs found in the environment but not directly connected to 3M sites. An example of this work is the investigation of PFCs in urban lakes. 6. Address cooperation from 3M on sharing research and information The proposed Consent Order requires 3M to fully cooperate with the Minnesota Department of Health and the MPCA on research, including a formal commitment to complete a 90 -day study of health effects of PFBA. The proposed Consent Order also provides MPCA with full access to all non- privileged 3M documents on PFCs, and provision of any such documents of interest to the Agency upon request. 7. Preserve the Agency's right to take action in the future The proposed Consent Order preserves the Agency's right to take additional action in the future either due to new information that is not known at the time of the agreement, or if for any reason the agreement is deemed to be inadequate to protect public health and the environment. Additional items In the proposed Consent Order, 3M has agreed to contribute up to $8 million to remediate the Washington County Landfill site. 3M is obligated to pay $5 million up front to the Agency for this purpose, and, subsequently, up to half of the remaining cost of remediation or $3 million, whichever is smaller. This site is managed under the State's Closed Landfill program, and 3M currently is under no legal obligation to address this site. Also included in the proposed Consent Order is an agreement that the Agency does not waive its right to pursue any natural- resource damage claims related to releases of PFCs from the sites. Next steps The proposed Consent Order will be presented to the MPCA Board on May 22, 2007 for consideration and approval. If approved by the Board and signed by the Commissioner, it will be a legally binding agreement that will address the PFC contamination now and in the future. Proposed Consent Order on PFCs • May 2007 page 2 NPinneso4a potivetturl, Co ®t[cl Rggrlcy NOT PFOS concentrations below 0 O10 pnb are approaching the limitations of analytical reliability PFOS b Influent Effluent Sludge Alexandria 0.022 0.018 99 Boise Cascade n.d. n.d. n.d. Brainerd 0.811 1.51 861 Fergus Falls 0.015 n.d. 21.4 Hibbing n.d. ** 0.013 8.18 Paynesville n.d. n.d. n.a Thief River Falls n.d. n.a. n.a. Western Lake Superior n.d. 0.016 18.7 Dodge Center 0.019 n.d. 24.6 Met. Co. Eagle Point n.d. n.d. 22.4 Flint Hills 0.055 0.058 n.a. Hutchinson 0.081 0.043 304 Marathon - Ashland 0.256 n.d. n.a. Maynard n.d. n.d. n.a. Melrose n.d. n.d. 3.94 Met. Co. Seneca 0.171 0.059 141 Metro Plant —1 0.036 0.110 267 Metro Plant — 2 0.035 0.087 261 MSP Airport - 1 0.024 n.a. n.a. MSP Airport - 2 0.393 n.a. n.a. Montevideo n.d. n.d. 39.7 St. Cloud n.d. 0.007 20.4 Willmar n.d. ** n.d. n.d. Austin 0.007 n.d. n.d. ** Morton -1 n.d. n.d. n.a. Morton - 2 n.d. n.d. n.a. Owatonna n.d. n.d. 30.8 Pipestone n.d. 0.010 n.a. Red Wing n.d. n.d. n.d. Rochester n.d. ** 0.015 21.2 Worthington n.d. n.d. 8.88 range 0.007 — 0.811 0.007-1.51 4-861 median 0.035 0.031 25 n.d. = not detected n.a. = no sample available 2008 MPCA Metro Lakes Fish PFC Data (Feb. 13, 2009) [This data table is excerpted from Appendix A of "PFCs in Minnesota's Ambient Environment: 2008 Progress Report. 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J O v A A P b cti C tl m dp � F ro � F m P �W e Al. g � w ry N N ° o A d w w R fD M A O O p O p N W F w b A y N C � � � A a A 00 y Q A b Q w P O P A t J O v A A P b dp ro � F P �W e Al. g � w ry N N ° o A d w w nnn-, n,mr A A/f + rn T .nkPS PFC Fish Data - first 10 of 30 lakes August 17, 2007 Como Lake Fish PFC on ins Wt Ln Age/ PFOS PFOA PFBA PFOSA PFDA PFUnA PFDoA Species & Sample Tissue sex n n nglg Sample 1D Date (g) (cm) ng/g �g gb ng/g nag ng/g rs b b b b b b b Bald Engle Lake Fish PFC anal sis PFBA PFOSA PFDA PFUnA PFDoA Agel PFOS PFDA Wt Ln Species& Sample Tissue sex ng/g ng/g ng/g ng/g ng/g ng/g ng/g Sample ID Date (g) (cm) b b b b b b rs b Blue "u 512/07 Fillet 22 9.5 2/1 <4.98 <2.49 Q.49* Q49 Q.49 449 4.49 BG -1 5/2/07 Fillet 11 8 I/J <4.39 4.19 Q.19* Q.t9 <2.19 4.19 4.19 BG - BG -5 5/2/07 Fillet 25 11 2/M <4,93 <146 4.46* Q.46 Q.46 <246 <2A6 BG -6 5/2/07 Fillet 79 15.5 5/M <4.76 438 Q.38* Q.38 Q.38 Q.38 <238 BG - 5/2/07 Fillet 88 16 5/M <4.61 Q.30 Q.30* Q.30 Q.30 <230 Q.30 BG -comp 5/2/07 Fillet <4.78 Q.39 Q.39 4.39 <2.39 Q39 Q.39 54.4 45.2 34.6 44.7 47.3 4.48 4.36 4.45 4.48 4.43 4.48* 4.36* 4.45* 4.48* 4.43* 20 18.6 15.8 15.6 9.1 7.7 7.69 5.92 5.5 7.51 3.93 5.03 4.83 5.12 5.23 5.08 6.22 8.47 6.45 742 Black Cr ie 5/2/07 Fillet 95 17.5 4/F 10.5 4.50 Q.50* Q.50 4.50 4.50 Q.50 BLC -1 BLC - 5/2/07 Fillet 98 17 4/17 7.24 439 Q.39* Q.39 Q39 <2.39 Q.39 BLC -3 5/2/07 Fillet 236 24 7/F 7.89 4.35 4.35 Q.35 Q35 Q.35 Q35 BLC4 5/2/07 Fillet 104 19 5/1 4.69 Q.30 4.30 Q.30 Q.30 4.30 Q.30 BLC -5 5/2/07 Fillet 97 18 5/F 7.54 Q.58 Q.58 Q.58 Q.58 4.58 Q.58 Larg emouth . Bass LMB -1 5/2/07 Fillet 992 38 71F <5.00 <2.50 Q.50* Q.50 Q.50 Q.50 Q.50 LMB -2 5/2/07 Fillet 684 34 6/F <4.69 Q.35 4.35* Q.35 4.35 Q.35 Q35 LMB -3 5/2/07 Fillet 764 34 6/F 6.18 4.35 4.35* Q.35 4.35 Q.35 Q.35 LMB - 5/2/07 Fillet 452 31 5/F <4.81 Q.40 4.40* Q.40 4.40 Q.40 Q.40 LMB -5 5/2/07 Fillet 560 31.5 51M <5.03 <2.51 4.51* Q.St 4.51 Q.51 4.51 Como Lake Fish PFC on ins Wt Ln Age/ PFOS PFOA PFBA PFOSA PFDA PFUnA PFDoA Species & Sample Tissue sex n n nglg Sample 1D Date (g) (cm) ng/g �g gb ng/g nag ng/g rs b b b b b b b Blue gill BG -3 BG -4 BG -6 BG -8 BG -10 BG -comp 5/1/07 5/1/07 5/1/07 5/1/07 5 /1/07 5/1/07 Fillet Fillet Fillet Fillet Fillet Fillet 31 29 99 61 93 11 it 16 14.5 16 2/F 2/1 5/M 4/M S/F 39# 320 341 20.6 23.1 28.1 Q.34 <2.50 4.50 4.43 4.49 4.49 4.34* <2.50* <2.50* <143* Q.49* Q49 3.54 3.8 4.2 2.84 Q.49 2.98 3.71 3.88 4.50 4.43 4.49 4.49 4.66 3.84 Q.50 2.75 165 Q.49 5.99 521 4.03 3.72 3.08 4.45 Black Cr ie BLC -1 BLC -2 BLC -3 BLC -4 BLC -5 5/1/07 5/1/07 5 /1107 511/07 5/1/07 Fillet Fillet Fillet Fillet Fillet 141 69 408 158 817 17 16 28 20.5 32 4MI 4/M 8/F 5/M 10/F 59.7 44.9 104 57.6 -- 6 - 34 - 4.42 Q.53 4.36 4.30 4.50 Q.42* 4.53* 4.36* 4.30* 4.50* 3.09 <2.53 3.14 <230 <2.50 10.6 6.69 15.2 10.6 10.3 6.52 3.16 9.09 5.96 4.97 7.93 6.07 K6.68 Lar ¢mouth Bass LMB - 5/1/07 Fillet 867 37 7/F 29.5 4.40 4.40* 2.42 4.04 4.35 Northern Pike NOP -1' NOP - 1(d NOP -2 NOP -3 NOP -4 5/1/07 5/1/07 5/1/07 5/1/07 5/1/07 Fillet Fillet Fillet Fillet Fillet 2129 838 858 746 66 49 48 49 51M 41M 4tM 4/M 54.4 45.2 34.6 44.7 47.3 4.48 4.36 4.45 4.48 4.43 4.48* 4.36* 4.45* 4.48* 4.43* 20 18.6 15.8 15.6 9.1 7.7 7.69 5.92 5.5 7.51 3.93 5.03 4.83 5.12 5.23 5.08 6.22 8.47 6.45 742 2007 MPCA Metro Lakes PFC Fish Data - first 10 of 30 lakes August 17, 2007 Demontreville Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt Wt Ln (CM) Age / sex s Pros ng/g b PFOA ng/g b PFBA ng/g b PFOSA ng/g b PFDA ng/g b PFUnA ng/g b PFDoA ng/g b Blue II BG -2 BG -1 4/30/07 Fillet 26 11 2/F 27.1# 2.49 2.49* <.49 3.04 2.49 <2.49 BG -5 4/30/07 Fillet 20 11 2/F 35.3# <.42 <2.42* 2.98 <.42 <.42 <.42 BG -6 4/30/07 Fillet 75 14 4/M <5.00 <2.50 <.50* <.50 <.50 2.50 <.50 BG -8 4/30/07 Fillet 137 17.5 6/M 11.9 <2.42 <.42* <.42 <2.42 <2.42 <2.42 BG -10 4/30/07 Fillet 134 18.5 7/M <5.00 <2.50 2.50* <2.50 <.50 <2.50 <2.50 BG -comp 4/30/07 Fillet 302 8.46 <.42 <2.42 2.42 2.42 <.42 2.42 Black Crappie Largemouth Bass BLC -1 5/2/07 Fillet LM13-1 4/30/07 Fillet 686 33 5/M 41.8 <.42 <.42* <2.42 <2.42 <2.42 2.42 LMB -2 4/30/07 Fillet 1012 39 7/F 32.9 <50 <2.5* <.50 <2.50 <.50 2.50 LMB -2 (du) 4/30/07 Fillet 550 <2.34 2.34 25.8 <.43 <2.43* <.43 <A3 <.43 <2.43 LMB -3 4/30/07 Fillet 612 33 5/F 27 <140 <.40* <2.40 <.40 <.40 <240 LM13-4 4/30/07 Fillet 1023 39 7/M 44.9 <2.48 <.48* 2.48 <.48 <2.48 2.48 LMB -5 4/30/07 Fillet 877 37.5 7/M 84.4 <.30 <2.30* 2.30 <.30 2.88 <.30 1 LMB -1 5/2/07 Fillet 47 Elmo Lake Fish PFC anal sis Species & Sample ID Sample Date Tissue Wt lg) Ln (C-) Age/ sex s PFOS ng/g b PFOA ng/g b PFBA ng/g b PFOSA ng/g b PFDA ng/g b PFUnA ng/g b PFDoA ng/g b Blue ill BG -2 5/2/07 Fillet 16 10 21J 2914 <2.48 <2.48* <.48 <2.48 <2.48 <2.48 BG -4 5/2/07 Fillet 19 10 2/M 2174 2.49 <2.49* <2.49 <.49 <2.49 <2.49 BG -8 5/2/07 Fillet 42 13 3/1 149 <2.48 <.48 <.48 <.48 <2.48 2.48 BG -9 5/2/07 Fillet 30 115 31J 233 20.1 <4.24 <4.24 <4.24 <4.24 <4.24 BG -10 5/2/07 Fillet 35 13 3/F 345 <3.11 <3.11 <3.11 <3.11 <3.11 2111 BG -comp 5/2 {07 Fillet 302 <2.43 2.43 <2.43 <.43 2.43 4.43 Black Crappie BLC -1 5/2/07 Fillet 228 24 7/F 374 2.36 2.36 <.36 3.13 2.36 2.36 BLC -2 5/2/07 Fillet 369 28 8/F 574 2.42 2.42 2.42 6.38 2.42 <.42 BLC -3 5/2/07 Fillet 292 25.5 7/F 550 <2.34 2.34 2.34 3.42 234 4.34 BLC-4 5/2/07 Fillet 209 22 6/F 534 2.63 2.36 2.36 3.82 2.36 2.36 BLC -5 5/2/07 Fillet 189 23 6/F 443 2.56 2.56 2.56 3.14 2.56 <.56 Largemouth Bass LMB -1 5/2/07 Fillet 47 31 5/M 643 2.54 2.54 2.54 4.44 2.54 <.54 LMB -2 5/2/07 Fillet 672 35 6/F 431 2.43 <43* 2.43 <.43 2.43 <.43 LMB -3 5/2/07 Fillet 894 37 7/F 653 2.50 2.50* 2.50 3.94 250 2.50 LMB -3 du 5/2/07 Fillet 660 2.51 <.51* 2.51 4.06 <.51 2.51 LMB -4 5/2/07 1 Fillet 1062 39 7/F 711 <A0 2.40* 2.40 4.32 <.40 <.40 LMB -5 512/07 Fillet 698 33 5/M 281 <.55 <.55 <.55 <.55 2.55 2.55 2007 MPCA Metro Lakes PFC Fish Data - first 10 of 30 lakes August 17, 2007 Gervais Lake Fish PFC anal sis Age/ PFOS PPOA PFBA PFOSA PFDA PFUnA PFDoA Wt Ln Species & Sample Tissue sex nglg ng/g nglg ng/g ng/g ng/g ng/g Sample ID Date (g) (M) b b b b b b (yr s ) b Blue ill BG 5/1/07 Fillet 6 7.5 1/1 1754 107# <.69 <.69* <MV <.69 5.73 23 <2.69 -2 BG -5 5/1/07 Fillet 6 7 1/J <3.50 <3.50 5.43 3.57 <3.50 BG - 5/1/07 Fillet 75 16 5/F 148 <2.31 <2.31 <31 6.449 2.57# <.31 <231 <2.46 <2.46 BG -9 5/1/07 Fillet 90 17 6/F 90.5 <.46 <A6 <.46 BG -10 5/1/07 Fillet 68 15 4/F 39.9 <2.30 <.30 <.30 <.30 <2.30 <.30 BG -comp 5/1/07 Fillet 85 15 41F 100 <2.45 <2.45 <735 3.8 <.45 <2.45 BG -comp 4/30/07 Fillet 14.5 <.46 <.46 <.46 <.46 2A6 <.46 Black Cr ie BLC -1 5/1/07 Fillet 171 23 6/F 132 <2.36 <.36 <2.36 4.33 <.36 <.36 BLC - 5/l/07 Fillet 86 16 4/M 166 <.31 <.31* <231 9.5 3.37 <.31 BLC -3 5/1107 Fillet 122 19 51M 206 <2.35 <.35 <.35 11.4 4.08 2.78 BLC - 5/1/07 Fillet 180 22 6/M 170 <.29 <2.29* <38* <.29 10.9 5.09 8.41 BLC -5 5/1/07 Fillet 65 16 4/F 112 <.38 <.38 4.65 <2.38 <.38 LMB - 4 4!30/07 Fillet 1379 42 9 M 77.5 <.40 <.40* <.40* 2.87 <.40 <.40 Larg emouth Bass Fillet 1024 37 7/F 24.9 <.40 <.40* <.40 <A0 <.40 <.40 LMB -1 5!1/07 Fillet 2268 47 11/F 159 <A9 <.49* <.49 6.23 2.97 <.49 LM13 5/1/07 Fillet 488 31 5/M 153 <.31 <.31 <.31 6.24 3.95 <.31 LMB - 5/1/07 Fillet 385 29 4/M 227 <2.36 <2.36* <.36 10.7 5.79 2.38 LMB -4 5/1/07 Fillet 661 33 5/M 221 <.13 <EB 2.i3 8.67 6.23 5.87 La-5 5/1/07 Fillet 311 28 4/F 158 <.19 <39 <.19 7.42 3.85 <.19 Olson Lake Fish PFC anal sis Age/ PFOS PFOA PFBA PFOSA PFDA PFUnA PFDoA Species & Sample Tissue Wt Ln sex n n ng/g Sample ID Date (g) (em) n ng/g ppb ng/g �g g g rs b b b b b 6 b Blue gill BG -1 4/30/07 Fillet 19 10 2/F 7.84 <.34 <.34* <.34 <.34 <34 <.34 BG -2 4/30/07 Fillet 21 10 2/J 21.1# <.50 <M* <.50 <2.50 <2.50 <.50 BG -5 4/30/07 Fillet 33 13 3/J 24.7 <3.97 <3.97 <3.97 63.97 <3.97 <3.97 BG -8 4/30/07 Fillet 51 15 4/J 9.28 <44 <.44 <.44 <.44 <:44 <.44 BG -9 4130/07 Fillet 85 15 41F <4.85 <A3 <.43 <.43 <.43 <.43 <.43 BG -comp 4/30/07 Fillet 14.5 <.46 <.46 <.46 <.46 2A6 <.46 Largemouth Bass LMB -1 4/30/07 Fillet 1148 41 9/M 45.7 <.40 <.40* <.40 2.84 2.87 <40 UM 730/07 Fillet 1170 39 7/M 43.6 <.44 <.44* <44 2.51 2.85 <.44 LMB -3 4/30/07 Fillet 1159 39 7/M 19.7 <.45 <2.45* <.45* <45 3.04 <.45 LMB - 4 4!30/07 Fillet 1379 42 9 M 77.5 <.40 <.40* <.40* 2.87 <.40 <.40 LMB -5 4/30/07 Fillet 1024 37 7/F 24.9 <.40 <.40* <.40 <A0 <.40 <.40 LMB - 5(du 4/30/07 Fillet 24.5 <.49 < .49* <. 49 <.49 <.49 <.49 2007 MPCA Metro Lakes PFC Fish Data - first 10 of 30 lakes August 17, 2007 Lake Phalen Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln (cm) Age/ sex rs PFOS ng/g b b PFOA ng/g b PFBA ng/g b PFOSA ng/g b PFDA ng )b b PFUnA ng/g b PFDoA ng/g b Blue ill BG -2 5/1/07 Fillet 19 10 2/J 156# ¢.49 ¢.49* ¢.49 5.23 2.99 ¢.49 BG -4 5/1/07 Fillet 25 11.5 21J 82.7# ¢.50 ¢.50* ¢30 3.14 ¢.50 ¢.50 BG -6 5/1/07 Fillet 55 11.5 2/F 60.6 ¢.36 ¢.36 ¢36 ¢.36 <2.36 ¢.36 BG -9 5/1/07 Fillet 101 16 51M 93.4 <2.48 <2.48 ¢.48 2.484 <2.48 ¢.48 BG -10 5/1/07 Fillet 73 15 4/F 53.8 ¢.38 ¢.38 ¢.38 2.61# <2.38 ¢.38 BG -comp 5/1/07 Fillet 97 16 51M 45.3 ¢.42 ¢42 <2.42 ¢.42 ¢42 ¢.42 co m du 5/1/07 Fillet 55 ¢.24 <2.24 ¢.24 ¢.24 ¢.24 <2.24 Black Cra ie BLC -1 5/l/07 Fillet 26 12 2/J 42.19 <2.39 ¢.39* ¢.39 ¢.39 ¢.39 ¢39 BLC -2 5/1/07 Fillet 58 14 3/M 104 ¢.42 ¢.42* ¢.42 5.29 ¢.42 ¢.42 BLC -3 5/1/07 Fillet 67 17 41M 67,W ¢.36 ¢36* 12.36 3.05 <2.36 ¢.36 BLC -4 4/30/07 Fillet 50 15 3/J 60.4 ¢.31 ¢.31* ¢.31 ¢.31 <2.31 ¢.31 Largemouth Bass 4/30/07 Fillet 45 14 3/F 41.3 ¢.35 <2.35* ¢.35* <2.35 <2.35 LMB -1 5/1/07 Fillet 1212 41 9/F 183 <2.49 ¢.49* ¢.49 9.46 3.99 2.66 LMB -2 5/l/07 Fillet 596 33.5 5/M 136 <2.45 ¢.45 <2.45 7.64 4.67 ¢.45 LMB -2(du) 5/1/07 Fillet 725 32.5 5/M 129 ¢.48 ¢.48 ¢.48 6.14 3.88 ¢.48 LMB -3 5/1/07 Fillet 1279 43 10/F 128 <2.34 ¢.34* ¢.34 5.38 3.08 ¢.34 LMB -4 5/1/07 Fillet 1415 42 91F 147# ¢35 ¢.35* ¢35 4.96 <235 ¢.35 LMB -4 (dup) 5/1/07 Fillet 1084 36.5 7/M 1474 ¢.44 ¢.44* ¢.44 5.28 3.61 ¢.44 LMB -5 5/1/07 Fillet 1872 43 10/F 120 ¢.34 ¢.34* <2.34 3.63 ¢34 ¢.34 Ravine Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln (cm) Age/ sex rs PFOS ng/g PFOA ng/g PFBA n& PFOSA ng/g PFDA ng/b PFUnA PFDOA Blue ill BG -1 4/30/07 Fillet 30 10 2/M 10.3 ¢.46 <2.46 ¢.46 ¢.46 ¢.46 <2.46 BG4 4/30/07 Fillet 35 12 3/J 10.8 <4.67 <4.67 <4.67 <4.67 <4.67 <4.67 BG -5 4/30/07 Fillet 23 10 2/M 45.1 ¢.49 ¢.49 ¢.49 ¢.49 ¢.49 ¢.49 BG -9 4/30/07 Fillet 206 19.5 7/M 29.3 1 ¢.29 <2.29 ¢.29 ¢.29 <2.29 ¢.29 BG -9 du 4/30/07 Fillet 1 30.3 ¢.45 ¢.45 ¢.45 ¢.45 <2.45 ¢.45 BG -10 4/30/07 Fillet 97 16 51M 19.3 ¢.48 ¢.48 ¢.48 ¢.48 ¢.48 ¢.48 BG -comp 4/30/07 Fillet 19.4 <2.43 ¢.43 ¢.43 ¢.43 ¢.43 ¢.43 Black Cra ie BLC -1 4/30/07 Fillet 52 15 3/F 55.9 ¢.48 ¢.48* ¢.48* ¢.48 ¢.48 ¢.48 BLC -2 4/30/07 Fillet 43 15 35 64.5 ¢.42 ¢.42* ¢.42* ¢.42 ¢.42 ¢.42 BLC -3 4/30/07 Fillet 42 14 3/J 77.8 2.69 ¢.56* ¢.56 ¢.56 ¢.56 ¢.56 BLC -4 4/30/07 Fillet 50 15 3/J 60.4 ¢.31 ¢.31* ¢.31 ¢.31 <2.31 ¢.31 BLC -5 4/30/07 Fillet 45 14 3/F 41.3 ¢.35 <2.35* ¢.35* <2.35 <2.35 <2.35 Largemouth Bass LMB -1 4/30/07 Fillet 725 32.5 5/M 50.6 ¢.40 ¢.40* ¢.40* ¢.40 ¢.40 ¢.40 LMB -2 4/30/07 Fillet 890 35 6/M 36 ¢.13 ¢.13* ¢.13* ¢.13 ¢.13 ¢.13 LAM-3 4/30/07 Fillet 911 34.5 6/F 65.2 ¢.38 ¢.38* ¢.38* ¢.3M ¢.38 ¢.38 LMB -4 4/30/07 Fillet 1084 36.5 7/M 107, ¢.40 ¢.40* ¢.40* ¢.40 ¢.40 ¢.40 LMB -5 4/30/07 Fillet 1011 33 5/M 53.8 ¢.31 ¢.31* ¢.31* ¢.31 ¢.31 1231 0 2007 MPCA Metro Lakes PFC Fish Data —first 10 of 30 lakes August 17, 2007 < = less than the detection limit; number following this symbol represents the detection limit ** estimated values with a negative bias # estimated values with a positive bias For further information please contact Paul Hoff 651- 296 -7799 or Laura Solem 218 -529 -6254. 2007 MPCA Metro Lakes PFC Fish Data —first 10 of 30 lakes August 17, 2007 Samples were analyzed for the 13 different perfluorochemicals listed. numbers listed are: PFOS concentration (# fish) dl — detection limit z 5 ng/g as — not sampled composite — tissue from several fish is combined then PFCs are measured For information on the recommended meals per month for specific species, consult the Minnesota Department of Natural Resource's fish consumption reports for each lake. Average PFOS Concentration n/ b CAS # PFBA C4 perfluorobutanoic acid 375 -224 PFBS C-4 perfluorobutane sulfonate 375 -73 -5 PFPeA C -5 perfluoropentanoic acid 26 (5) PFHxA C -6 perfluorohexanoic acid 307 -24 -4 PFHxS C -6 perfluorohexane sulfonate 355 -46 -4 PFH A C -7 Perfluoroheptanoic acid 375 -85 -9 PFOA C -8 oerfluorooctanoic acid 335 -67 -1 PFOS C -8 erfluorooctane sulfonate 1763 -23 -1 PFOSA C-8 erfluorooctane sulfonamide 17 (5) PFNA 1 C -9 1 nertluorononanoic acid 375 -95 -1 PFDA C -10 perfluorodecanoic acid 335 -76 -2 PFUnA C -11 erfluoroundecanoic acid 23 (5) PFDoA C -12 erfluorododecanoic acid 307 -55 -1 numbers listed are: PFOS concentration (# fish) dl — detection limit z 5 ng/g as — not sampled composite — tissue from several fish is combined then PFCs are measured For information on the recommended meals per month for specific species, consult the Minnesota Department of Natural Resource's fish consumption reports for each lake. Average PFOS Concentration n/ b Bluegill Bluegill ( composite) Black Crappie Largemouth Bass Northern Pike Bald Engle <dl 5 <dl 5 8 5 6 5 ns Como 26 (5) 28 (5) 66 (5) 30(l) 42 (4 Demontreville 12 (5) 8 5 ns 46 (5) ns Elmo 242 (5) 302 (5) 495 (5) 544 (5) ns Gervais 93 (5) 100 (5) 157 (5) 184 (5) ns Olson 17 (5) 15 (5) ns 42 (5) ns Phalen 69 (5) 50 (5) 104 (3) 142 (5) ns Ravine 23 (5) 19 (5) 60 (5) 63 5 ns S uare <dl 5 <dl 5 5 5 <dl 5 ns White Bear 5 5 6 (5 ) 25 (2) 9 5 ns numbers listed are: PFOS concentration (# fish) dl — detection limit z 5 ng/g as — not sampled composite — tissue from several fish is combined then PFCs are measured For information on the recommended meals per month for specific species, consult the Minnesota Department of Natural Resource's fish consumption reports for each lake. Update: Urban Lakes PFCs Study January 29, 2008 The Minnesota Pollution Control Agency has completed analysis of additional data from a study of PFCs in fish in Twin Cities -area fishing lakes. The MPCA began the survey in April 2007 after finding relatively high levels of PFOS in Lake Calhoun fish in Minneapolis last spring. The latest findings represent another 381 fish taken from 20 lakes and two new river reaches. (The first results were released in August 2007.) The findings show a mix of results, from elevated levels of PFOS to no detection. However fish from several lakes had levels high enough to possibly be of concern. These lakes include Lake Johanna (Arden Hills), Cedar (Minneapolis), Harriet, Hiawatha, Jane, Keller, Powers, Red Rock and Tanners. For example, fish from Lake Johanna have levels similar to those previously found in fish from Lake Calhoun and Lake Elmo. Fish from a number of lakes or rivers in the survey show little or no trace of PFOS, including Cedar (Scott County), Centerville, Colby, Green Mountain, Hydes, Independence, Nokomis, Peltier, Upper Prior, Sarah, Silver, and the Mississippi River at Brainerd. The MPCA urban lakes study will be complete after results from Lake Minnetonka and Lake Josephine come in later this winter. Certified analysis can take several months due to the number of parameters included and the fact that only a few labs in North America can analyze PFCs in fish tissues. Fish were collected over the summer by PCA and DNR crews and analyzed for 13 different PFC compounds. Lakes were selected based on higher fishing pressure and prevalence of species such as bluegill and bass, which have shown relatively higher concentrations of PFOS. Of the 13 compounds, only PFOS has been found to accumulate in fish tissue. The Minnesota Department of Health is evaluating the MPCA fish data as part of the annual update of the Minnesota Fish Consumption Advisory. Each year MDH incorporates new data on many contaminants, including mercury and PCBs, into the update to provide Minnesotans with advice about how to benefit from the good nutrition available from fish with the least amount of contaminants. "The fish consumption advisory is based on long lifetime exposure a any changes to the advice, if indicated, would be similar to past advice for PFC- impacted waters," said MDH scientist Pat McCann. The current Minnesota Fish Consumption Advisory, including the general statewide advice, is available at http • / /www health state mn us /divs /eh/f b/i /index.h The results of the MPCA's urban lakes study provide some important clues about the presence of PFCs in parts of the Twin Cities that aren't near known sources of PFC wastes or manufacture. The widely varying fish- tissue results suggest that atmospheric deposition of PFCs likely is not a significant contributor to the elevated concentrations of PFCs in some metro -area lakes. Results of shallow groundwater sampling have shown similar variability, and atmospheric deposition would be expected to produce much more uniform concentrations of PFCs in shallow groundwater, lakes, and fish. The likelier explanation is that varying PFOS concentrations are due to runoff in stormwater associated with different land uses around lakes. The chemicals are in a wide variety of commercial, industrial, and consumer products, e.g., firefighting foam, lubricants, and water- and grease- resistant coatings on paper and fabric, and could be entering stormwater from those sources. Complete data for the study results thus far follow below. For more information on the findings contact Paul Hoff, 651- 296 -7799; Laura Solem, 218 -529 -6254; or Ralph Pribble, 651- 296 -7792. For information on the MDH's fish consumption advisory program contact Pat McCann, 651- 201 -4915. 2007 MPCA Metro Lakes PFC Fish Data — additional 20 lakes January 28, 2008 Bluegill I Bluegi`l I White Bass Walleye Washington County 23 (5) 12 (5) 82(l) 15 (5) 17 (5) ns Bluff Park area Mississippi River 10 (2) ns ns 13 (5) 9 (5) 7 (3) Brainerd area numbers listed are: average PFOS concentration (# of fish) <dl — less than the detection limit = 5 ng/g as — not sampled comp — composite; tissue from several fish is combined then PFCs are measured (# of fish combined) pending — analysis not completed For further information please contact Paul Hoff 651- 296 -7799 or Laura Solent 218 -529 -6254. 11 Average PFOS Concentration n/; b Bluegill Bluegili (comp) Black Crappie Black Cra ie comp Largemouth Bass Northern Pike Walleye Yellow Perch ( com p) Cedar enne in Cedar Scott 28 (5) <dl 5 34 (5) <di (5) as as ns as 72 (4) 6(5) ns ns as <dl 1 ns ns Centerville 9 5 9(5) as ns ns 9 7 ns as Colby 22 (5) 23 (5) 14 (5) 14 (5) ns as ns as Green Mountain <dl (5) <dl (5) as as as as ns as Harriet 114 (5 89 (5) ns ns 148 (5) ns ns as Hiawatha 26 5 27 (5) 40 (5) as as pendi n ns ns H des <dl (5) <dl 5 <dl 6 ns ns 5 5 ns ns Independence 5 5 <dl 5 <dl 5 as ns <dl (2) ns ns Jane 22 (5) 8 5 25 (81 us 47 (5) ns as as Johanna 212 (6) 250 (5) 222 (3) ns ns as as as Keller 69 (5) 70 (5) ns ns ns ns ns us Nokomis 10 (7) as 10 (5) as ns ns as ns Peltier Powers 12 (5) 40 (5) ns 65 Q as 51 (5 ns ns ns as 14 (5) 69 (3) as ns as 42 (5) jjpggjPrior 5 5 <dl 5 ns ns 6 5 as ns as Red Rock 41 (5) 35 (5) 103 5 as 69 (5) ns as ns Sarah 7 5 <dl 4 <dl 5 as ns 10 (5) as as Silver 24 (5) 34 (5) 33 (5) 35 (5) ns ns 17 (4) ns Tanners 76 (5) 55 Q 118 (5) ns 80 (5) ns ns as Bluegill I Bluegi`l I White Bass Walleye Washington County 23 (5) 12 (5) 82(l) 15 (5) 17 (5) ns Bluff Park area Mississippi River 10 (2) ns ns 13 (5) 9 (5) 7 (3) Brainerd area numbers listed are: average PFOS concentration (# of fish) <dl — less than the detection limit = 5 ng/g as — not sampled comp — composite; tissue from several fish is combined then PFCs are measured (# of fish combined) pending — analysis not completed For further information please contact Paul Hoff 651- 296 -7799 or Laura Solent 218 -529 -6254. 11 2007 MPCA Metro Lakes PFC Fish Data - additional 20 lakes January 28, 2008 Cedar Lake Fish PFC analysis enne in Coun Species & Sample ID Sample Date Tissue Wt 1g) Ln 1e�n) Age/ sex s PFOS ng/g b PFOA ng/g b PFBA ng/g b PFOSA ng/g b PFDA ng/g b PFUnA ng/g b PFDoA ng/g b Blue ill BG -1 BG -1 2007 Fillet 24 12 3/F 33.5 ¢.50 ¢.50 ¢.50 ¢.50 ¢.50 ¢.50 BG -5 2007 Fillet 56 15.5 5/J 31 ¢39 ¢39 <2.39 2.46 ¢.39 ¢.39 BG -6 2007 Fillet 25 11.5 2/F 17.9 ¢.50 ¢.50 ¢.50 ¢.50 ¢.50 ¢.50 BG -8 2007 Fillet 47 14.5 1 4/F 30.9 <2.37 ¢.37 ¢.37 3.11 ¢.37 ¢.37 BG -10 2007 Fillet 24 12 2/1 27.8 ¢.51 ¢.51 ¢51 5.25 3.77 1 ¢.51 BG -comp 2007 Fillet <4.85 34 <2.42 ¢.42 ¢.42 2.99 <2.42 1 2.56 Largemouth Bass Lar emouth Bass LM13 LMB - 1 2007 Fillet 531 33 51M 53.8 ¢.46 ¢.46 <2.46 4.88 3.54 2,58 LMB -2 2007 Fillet 488 31 51F 70.8 <2.40 ¢.40 ¢.40 6.7 3.49 339# LMB -3 2007 Fillet 1166 43 10/F 56.3 ¢.48 ¢.48 ¢.48 8.27 4.61 3.25# LMB -4 2007 Fillet 1592 46 t F 108 ¢.42 ¢.42 ¢.42 5.22 3.67 5.27# LM13 du Fillet Fillet <3.85 ¢.37 ¢.37* ¢.37 ¢.37 ¢.37 LMB -5 du Cedar Lake Fish PFC analysis Scott Conn Species & Sample ID Sample Date Tissue Wt (g) Ln cm) Age/ sex s PFOS ng/g b PFOA ng/g b PFBA ng/g 6 PFOSA ng/g 6 PFDA ng/g b PFUnA ng/g b PFDoA ng/g b Blue ill BG -1 8/24/07 Fillet 16 9 1/J <4.81 ¢.40 <2.40 ¢.40 ¢.40 ¢.40 ¢.40 BG -4 8/24/07 Fillet 19 10 2/J <6.76 ¢.49 ¢.49 ¢.49 ¢.49 ¢.49 ¢A9 BG - 5 8/24/07 Fillet 97 17 6/M <4.81 ¢.40 ¢.40 ¢.40 ¢.40 < A0 ¢.40 BG -6 8/24/07 Fillet 31 NA 4/M <4.95 ¢.48 <6.43 ¢.48 ¢.48 ¢.48 ¢.48 BG -9 8/24/07 Fillet 82 16 51M <4.81 ¢.40 ¢.40 ¢.40 ¢.40 ¢.40 ¢.40 BG -comp 8/24/07 Fillet <4.85 ¢.43 ¢.43 ¢.43 ¢.43 ¢.43 <2.43 Largemouth Bass LM13 8/24/07 Fillet 1292 41 9/M 6:24 ¢.46 ¢.46 ¢.46 ¢.46 ¢,46 ¢.46 LMB -2 8/24/07 Fillet 1528 NA 9/F <4.90 ¢.45 ¢.45 ¢.45* <2.45 ¢.45 ¢.45 LMB - 8/24/07 Fillet 1264 40 8/F <4.67 ¢.34 ¢.34 ¢.34* ¢.34 <2.34 ¢.34 LMB -4 8/24/07 Fillet 857 40 8/M <4M43<4.9 88 ¢.44 ¢.44 <2.44* ¢.44 ¢.44 ¢.44 LMB -5 8/24/07 Fillet 1110 <3.85 ¢.37 ¢.37* ¢.37 ¢.37 ¢.37 LMB -5 du Fillet ¢.51 ¢.51 ¢.51* ¢.51 ¢.51 ¢s1 Walie e WAE - 8/24/07 Fillet 714 2007 MPCA Metro Lakes PFC Fish Data - additional 20 lakes January 28, 2008 Centerville Lake Fish PFC anal sis Wt Ln Age/ PFOS PFOA PFBA PFOSA PFDA PPUnA PFDoA sex ng/g ng/g ng/g Species & Sample Tissue n Sample ID Date (g) (cm) s pb ng/g pb n pb b b b Blue 71 Sample ID Date (g) (cm) b b b b b Fillet 69 15 4/F 12.8 Q.43 Q.43 ¢.43 ¢.43 Q.43 ¢.43 BG -1 2007 Fillet 62 14.5 4/M 6.24 ¢.45 ¢.45 ¢.45 Q.45 Q.45 Q.45 BG -2 2007 2007 Fillet 42 12.5 3/J 9.94 Q.45 Q.45 ¢.45 ¢.45 ¢.45 ¢.45 BG -4 2007 Fillet 61 15 4/F <4.95 Q.48 Q.48 ¢.48 ¢.48 Q.48 ¢.48 BG -8 2007 Fillet 74 IS 4/M 6.74 Q.48 Q.48 Q.48 ¢48 Q.48 ¢.48 BG -9 Q.49 Fillet BG -comp 616/07 Fillet 8.71 Q.23 12.23 Q.23 Q.23 4.23 ¢.23 BG -COm 2007 Q.40 Northern Pike Fillet 1609 58 4/F 9.01 ¢.49 Q.49 Q.49 <2.49 Q.49 ¢49 NOP -1 2007 2007 Fillet 878 49 4/J 102 Q .48 Q .48 ¢ .48 ¢.48 Q .48 ¢ . 48 NOP -2 2007 Fillet 793 46 4/J 9.03 Q.43 ¢.43 Q.43 ¢.43 Q.43 ¢.43 NOP -3 NOP -4 2007 Fillet 1067 56.5 4/1 6.3 ¢.74 ¢.50 Q.50 ¢.50 ¢.50 Q.SO NOP -5 2007 Fillet 1183 54 4/M 7.84 ¢.51 <2.51 Q51 ¢.51 <2.51 <2.51 NOP -6 2007 Fillet 1546 65 51M 11.4 ¢.40 ¢.40 Q40 ¢.40 12.40 ¢.40 NOP -7 2007 Fillet 896 51 4 M 10.6 ¢44 Q.44 Q.44 ¢.44 Q.44 <2.44 Colby Lake Fish PFC anal sis Age/ PFOS PFOA PFBA PFOSA PFDA PFUnA PFDoA Wt Ln Species & Sample Tissue sex ng/g ng/g ng/g ng/g ng/g ng/g ng g n Sample ID Date (g) (cm) b b b b b rs b b Blue ill BG -4 6/6/07 Fillet 21 9.5 IN 21.7 ¢.44 Q.44* <144 3.01 Q.44 Q44 BG -5 6/6/07 Fillet 31 12 2/F 23.9# Q.46 <4.03* Q.46 Q.46 Q.46 Q.46 BG -7 6/6/07 Fillet 34 12.5 2/J 32.8 Q.49 <3.10* Q.49 ¢.49 Q.49 Q.49 BG-9 6/6/07 Fillet 35 12 2/F 134 Q.50 Q.50* ¢.50 ¢.50 Q.50 Q.50 BG -10 6/6/07 Fillet 29 Il 2/F 18.9# Q.49 Q.49* <149 Q.49 Q.49 Q.49 BG -comp 616/07 Fillet Fillet 23.4 ¢AO Q.40 Q.40 ¢.40 Q.40 Q.40 BlackCra ie 6/6/07 Fillet 42 14 3/F 16.6 Q.50 ¢.50* Q.50 2.84 Q.50 <150 BLC -2 BLC -4 6/6/07 Fillet 47 la.s 3/M 13.2# Q.as ¢.4s ¢.as ¢.as Q.as BLC -5 6/6/07 Fillet 47 14.5 3/M 12.6# Q.35 ¢.35 Q.35 ¢.35 <2.35 BLC -7 6/6/07 Fillet 46 15 3/M 14.6 ¢.44 Q.44 Q.44 <2A4 ¢.44 E 45 BLC -8 6/6/07 Fillet 34 13.8 3/F 12 Q.48 Q.48 ¢.48 Q.48 ¢.48 BLC -com 6/6/07 Fillet 14.3 Q.43 <2.43 ¢.43 ¢.43 <2.43 Green Mountain Lake Fish PFC anal sis Age/ PFOS PFOA PFBA PFOSA PFDA PFUnA PFDoA Wt Ln Species & Sample Tissue sex ng/g ng/g ng/g ng/g ng/g ng/g ng/g Sample ID Date (g) (cm) b b b b b b b Blue ill BG -1 5/9/07 Fillet 50 13.5 3/J <4.85 ¢.43 Q.43 Q.43 Q.43 Q.43 ¢.43 BG -3 5/9/07 Fillet 118 17.5 61M <4.98 ¢.49 4.49 ¢.49 ¢.49 12.49 ¢.49 BG -5 5/9/07 Fillet 133 19 7/M <4.90 ¢.45 Q.45 <2.45 <2,45 Q.45 ¢21141 45 BG -6 I B 5/9/07 Fillet 85 16 5/F 14.85 ¢.43 Q.43 ¢.43 Q.43 <243 5/9/07 Fillet 50 13.5 3/M 14.85 Q.43 ¢.43 Q.43 Q.43 12.43 BG -com 5/9/07 Fillet <4.88 <2A4 <2.46 ¢.44 <2 Q.44 2007 MPCA Metro Lakes PFC Fish Data - additional 20 lakes January 28, 2008 Harriet Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (9) Ln lem) Age/ sex PFOS ng/g b PFOA ng/g b PFBA ng/g b PFOSA ng/g b PFDA ng/g b PFUnA n9/9 b PFDoA ng/g b Blue ill BG -5 8/17/07 Fillet 17 9 1/1 108 <.40 12.40 12.40 4.91 12.40 <.40 BG -6 8/17107 Fillet 42 10 2/17 78.1 12.48 <.48 <.48 12.48 <48 12.48 BG -7 8/17/07 Fillet 12 7 1/1 124 12.43 12.43 12.43 6.98 <.43 <.43 BG -9 8/17/07 Fillet 30 11 2/M 95.9 12.46 12.46 1 <.46 <.46 12.46 <.46 BG -10 8/17/07 Fillet 73 NA 4/M 163 12.40 12.40 <2.40 4.98 5.274 4.12 BG -comp 8/17/07 Fillet 89.3 <2.44 12.44 <.44 2.59 12.44 12.44 Lar gmouth Bass LMB -1 8/17/07 Fillet 373 30 4/F 146 <5.38 <.49 <.49* 8.74 4.59 2.78 LMB -2 8/17/07 Fillet 554 34 6/F 20.5 <3.66 <.46 12.46* 5.4 <.46 <.46 LNIB -3 8/17/07 Fillet 355 29 4/J 150 <.39 <.39 <.39* 9.25 3.71 3.64 LAM-4 8/17/07 Fillet 963 39 8M 254 124.20 12.43 12.43* 10 5.28 7.1 LN1B -5 8/17/07 Fillet 866 40 8/F 170 12.42 <2.42 12.42 10.1 4.65 3.66 Hiawatha Lake Fish PFC analysis Species & Sample ID Sample Date Tissue wt Ig) Ln len) Age/ sex s PFOS ni b PFOA n b PFBA ng/g b PFOSA ng/ PFDA ng/g b PFUnA ni b PFDoA n b Blue ill BG -2 2007 Fillet 73 16 51M 35 12.48 12.48 <.48 <48 <48 12.48 BG -6 2007 Fillet 94 18 61M 15.7 <.48 <.48 12.48 <.48 12.48 <.48 BG -7 2007 Fillet 36 13 3/F 15.5 12.48 <.48 <A8 <.48 <.48 12.48 BG -9 2007 Fillet 8 8 Ili 31.8 12.43 1243 <.43 <.43 <2A3 12.43 BG -10 2007 Fillet 5 7.8 I/J 31.9 12.55 <3.55 <3.55 <3.55 <3.55 123.55 BG -comp 2007 Fillet 27.3 12.42 12.42 12.42 <2.42 <.42 <A2 Black mepi e BLC -1 2007 Fillet 73 19 51F 36.6 <2.50 <.50 <.50 2.7 <50 <.50 BLC -2 2007 Fillet 103 21.5 6/M 71.7 <2.35 <.35 <.35 3.94 <.35 4.75 BLC -3 2007 Fillet 71 18 4/F 35.1 12.30 12.30 <230 2.32 <.30 <30 BLC -4 2007 Fillet 83 18 4/F 33.5 <145 <.45 <.45 <.45 12.45 <.45 BLC -5 2007 Fillet 6a 17 4 F 21 <.50 <.50 <.50 <.50 1 12.50 <.50 4 2007 MPCA Metro Lakes PFC Fish Data - additional 20 takes January 28, 2008 H des Lake Fish PFC anal sis Age/ Pros PFOA PFBA PFOSA PFDA PFUnA PFD6A Wt Ln Species & Sample Tissue sex ng/g ng/g ng/g ng/g ng/g ng/g nglg Sample ID Date (g) (em) b b b b b (pp b) b Blue 71 7/24107 Fillet 9 7 1/1 <5.05 <2.53 <.53 Q.53 <.53 <.53 <.53 BG -1 7/24/07 Fillet 9 9 1/1 6.08 <.54 <.54 Q.54 <.54 <.54 <.54 BG -5 BG -6 7/24/07 Fillet 130 17 6/7 <4.85 <.43 <.43 ¢.43 <.43 <.43 <.43 BG -7 7/24/07 Fillet 127 17 6/M <4.83 <.42 <.42 <.42 <.42 <.42 <.42 BG -10 7/24/07 Fillet 123 17.5 6/F <4.95 <2.48 <.48 <.48 <.48 <.48 <.48 BG -10 d ) Fillet Fillet 15 4/M <4.85 <4.90 <.45 <.45 <.45 <.45 <.45 Q.45 BG -comp 7/24/07 Fillet <4.41 <.20 <.20 <120 <.20 <.20 <.20 BlackCr ie Black Cra ie 7/24/07 Fillet 124 20 5B <4.88 <.44 ¢.45 <.44* ¢.44 <44 <.44 BLC -1 BLC -l(dup ) 70 Fillet 4/7 <4.95 <.48 <4.93 <.46 <.46 <.46* <.46 <246 <.46 BLC -2 7/24/07 Fillet 178 23 6 F <4.90 <.9s Q.a5 <.45* <.45 <245 ¢.as BLC -3 7/24/07 Fillet 167 22.5 61F <4.78 <4.24 <.39 <.39* Q.39 <2.39 <.39 BLC -4 7/24/07 Fillet 206 24 7rn <a.88 <.44 <.4a <.aa* Q.44 <.44 <.44 BLC -5 7/24/07 Fillet 224 25 71M <4.90 <.45 <.45 <.45* Q.45 4.45 <.45 BLC -6 7/24/07 Filtet z20 zs 71F <4.90 <.s7 <.45 <2.45* <.as <245 <2.45 NOP -1 7/24/07 Fillet 2000 Northern Pike 4/1 <5.54 ¢.40 <.40 <.40 <2.40 4.40 4.40 NOP -2 1 7/24/07 Fillet 3700 76 NOP -1 7/24/07 Fillet 2170 68 5/M <4.93 <.46 4,46 <.46 <.46 <.46 <.46 NOP -2 7/24/07 Fillet 631 48 41M <4.41 <.20 <.20 <120 <2.20 <2.20 <.20 NOP -3 7/24/07 Fillet 741 46 4/F <4.52 <.26 Q.26 ¢.26 - 26 ¢.26 <.26 NOP -4 7/24/07 Fillet 2342 68 6/J <4.69 ¢35 i -F -i 4.35 <.35 NOP -4(dup ) <4.65 <33 <.33 233 <33 <.33 <.33 NOP -5 7/24/07 Fillet 3445 74 6/F 4.76 <37 <.37 <.37 <.37 <37 <.37 Independence Lake Fish PFC anal is Age/ PFOS PFOA PFBA PFOSA PFDA PFUnA PFDoA Wt Ln sex Species & Sample Tissue n ng/g fib ng/ nb nib gJb n \ Sample ID Date (g) (cm) bj ( Blue 'll BG -4 7/24/07 Fillet 13 10 2/J 5 .1 <.50 <. 50 <.50 <.50 - 'So <.50 BG -6 7/24/07 Fillet 14 10 2/J <4.88 4.44 <2.4a <.aa <.aa <.a4 <.aa BG -7 7/24/07 Fillet 14 9.5 1/J 5.41 <.50 <.50 <.50 Q.50 ¢.50 <.50 BG -8 7/24/07 Fillet 45 14 41F <4.83 <A2 <2A2 <.42 <.42 4.42 <.42 BG -9 7/24/07 Fillet 55 15 4/M <4.85 <.43 <.43 <.43 4.43 4.43 4.43 BG -com 7/24/07 Fillet 4.44 <.44 4.44 4.44 4.44 4.44 BlackCr ie BLC -1 7/24/07 Fillet 70 18 4/7 <4.95 <.48 <.48 4.48 4.48 4.48 4.48 BLC -2 7/24/07 Fillet 78 19 5/1 <4.65 433 <233 <33 <.33 <.33 <.33 BLC -3 7/24/07 Fillet 81 18 4/M 6.00 <s0 <322 <so 4s0 <so ¢so BLC -4 7/24/07 Fillet 81 19 5/M <4.93 4.46 4.46 <.46 ¢.46 4.46 4.46 BLC -5 7/24/07 Fillet 139 22 6/F <4.93 4.46 4.46 4.46 4.46 4.46 4.46 Northen Pike NOP -1 7/24/07 Fillet 2000 57 4/1 <5.54 ¢.40 <.40 <.40 <2.40 4.40 4.40 NOP -2 1 7/24/07 Fillet 3700 76 6/M <4.90 4.45 Q.45 <.45 <2.45 4.45 4.45 NOP -2 (du) <4.95 4.48 Q.48 <.48 4.48 4 4.8 <2.48 2007 MPCA Metro Lakes PFC Fish Data - additional 20 lakes January 28, 2008 Jane Lake Fish PFC analysis Species & Sample ID Sample Date Tissue W[ (g) La (em) Age/ sex s PFOS ng/g b PFOA ng/g b PFBA ng/g b PFOSA ng/g b PFDA nWg b PFUnA ng/g b PFDoA ng/g b Blue 'll BG -4 6/07 Fillet 16 10.5 21J 20.7 <.46 <.46* <46 <2.46 <2.46 <2.46 BG -6 6/07 Fillet 99 18 61F 8.62# <.50 <.50* <.50 <.50 <2.50 <.50 BG -7 6/07 Fillet 73 17.2 6/M 46.3 <.44 <.44* <.44 <.44 <.44 <.44 BG -7 du 6/19/07 Fillet 42 13 3/M 36.5# <.48 <.48* <.48 <.48 <.48 <.48 BG -8 6/07 Fillet 18 10.6 21J 12.24 <.So <.50* <.50 <.50 <.50 <50 BG -10 6/07 Fillet 95 NA 4/M <4.95 <.48 <.48* <48 <.44 <.48 <.48 BG -com 6/07 Fillet 7.76 <.46 <2.46 <2.46 3.24 <.46 <.46 Black Crapp BLC -1 6/07 Fillet 65 15 3/M 13.6# <.40 <.40* <.40 8.92 <.40 <2.40 BLC -2 6/07 Fillet 109 18.2 51M 26.2 <.40 <.40* <,40 1<2,45 <.40 <.40 BLC -3 6/07 Fillet 78 17.8 4/F 10.2# <.48 <.48* <.48 2.66 <A8 <.48 BLC -4 6/07 Fillet 63 16.5 4/M 39.7 <.48 <.48 <.48 <.48 <.48 BLC -5 6/07 Fillet 96 19.5 5/M 34.2 <245 <.45 <.45 <.45 <.45 BLC -6 6/07 Fillet 99 21 6/F 19.5 <.46 <.46 <2.46 <.46 <.46 BLC -7 6/07 Fillet 115 20 5/M 34.8# <.43 <.43 <.43 <.43 <.43 BLC -7 (du) 21.9# <.42 <.42 <.42 <.42 <2.42 <.42 BLC -8 6107 Fillet 108 19 51M 21,7 <.46 <.46 <46 <.46 <.46 <.46 Largemouth Bass LMB -1 6/07 Fillet 507 33 51M 35.1 <.49 <.49 <.49 <.49 <.49 <.49 LAO-2 6/07 Fillet 535 36 7/M 38.1 <.49 <.49 <.49 <.49 <.49 <.49 LNM -3 6/07 Fillet 599 33 5/M 83.4 <3.65 2.82 <.49 LMB -4 6/07 Fillet 525 36 7/M 25.8 <.43 <.43 <.43 <.43 <2.43 <.43 LMB -5 6/07 Fillet 809 1 NA 6/F 53.6 1 <2.44 <.97 1 <.44 <.44 1 <.44 <.44 Johanna Lake Fish PFC analysis Species & Sample 1D Sample Date Tissue Wt (g) Ln (cm) Age/ e sex PFOS n b PFOA ng/b PFBA ni b PFOSA ng/ PFDA n9/9 PFUnA 4 b PFDoA n b Blue ill BG -1 6/19/07 Fillet 71 16 5/M 183 <.44 <2.44* <.44 <.44 <.44 <.44 BG -2 6/19/07 Fillet 56 14.5 41M 1844 <.43 <.43* <A3 4.02 <.43 <.43 BG -3 6/19/07 Fillet 94 18 6/M 1769 <.40 <.40* <.40 3.85 3.86 7.34 BG -6 6/19/07 Fillet 42 13 3/M 207# <.46 <.46* <.46 5.69 4.3 3.58 BG -7 6/19/07 Fillet 55 16 4/M 230 <.49 <.52* <.49 3.73 <.49 <.49 BG -8 6/19/07 Fillet 57 15.5 4/M 292 <.44 <.44* <.44 <.44 <.44 <.44 BG -comp 6/19/07 Fillet 250 <.45 <.45 <.45 3.24 <.45 2.65 Black Lqppie BLC -1 6/19/07 Fillet 89 NA 41M 384 <.34 <2.34 <.34 8.92 3.94 3.31 BLC -2 6/19107 Fillet 83 20 5/F 213 <.44 <3.06 <.44 4.51 <.44 <.44 BLC -3 6/19/07 Fillet 94 20 5/F 70.3 <.48 <2.48 <.48 2.66 -248 <.48 2007 MPCA Metro Lakes PFC Fish Data - additional 20 lakes January 28, 2008 Keller Lake Fish PFC anal sis Age/ PFOS PFDA PFBA PFOSA PFDA PFUM PFDoA Wt Ln Species & Sample Tissue sex ng/g ngJg ng/g ng/g ng/g ng/g ng/g Sample ID Date (g) (cm) (pp b ( b ) (ppb b b b Blue ill 7/07 Fillet 50 13.5 31M 26.2 <.45 <.45 <.45 4.45 <.45 <.45 BG -1 7/07 Fillet 54 14.5 4/J 64.6 4.35 4.35 4.35 2.5 4.35 4.35 BG -2 BG -5 7/07 Fillet 56 14 4/M 97.1 4.46 4.46 4.46 4.88 4.31 4.46 BG - Q.50 Fillet 58 15 4/F 50.1 4.46 4.46 I1 2/M 7.71 4.46 BG - 7107 Fillet 58 15 4/M 106 <2.49 4.49 14 �46 AS 2.73 BG -Wm 7/07 Fillet <2.45 <.45 BG -6 70 <.10 <.10 14.5 4/F 7.23 4.10 Nokomis La lce Fish PFC anal sis Age/ PFOS PFOA PFBA PFOSA PFDA PFUnA PFDoA Species & Wt Ln Sample Tissue sex nWg ng(g ng/g ng/g ng/g ng/g ng/g Sample ID Date (g) (cm) b b b b b (Yr s) b b Blue 71 BG -1 7/17/07 Fillet 25 11 2/M 10.8 4.44 4.44 <.44 <144 <.44 <.44 BG - 7/17/07 Fillet 73 16 5/M 9.21 <.38 <2.38 ¢38 4.38 <.38 <.38 BG -3 7/17/07 Fillet 58 15 4/M 13.4 <.50 <.50 Q.50 <.50 4.50 <.50 BG - 7/17/07 Fillet 31 I1 2/M 7.71 <.49 <3.00 <.49 Q.49 <.49 <.49 BG -5 7/17/07 Fillet 55 14 4/F AS <.45 <.45 4.45 Q.45 <2.45 <.45 BG -6 7/17/07 Fillet 49 14.5 4/F 7.23 <43 <.43 <.43 <2.43 <.43 <.43 BG - 7/17/07 Fillet 69 15 4/M 11.4 <.45 <.45 <.45 4.45 <45 <.45 NOP -1 2007 Fillet 607 B1ackCr BLC -1 ie 7/17/07 Fillet 84 18.5 51M 11.7 4.49 <.49 <.49* <.49 449 <2.49 BLC - 7/17/07 Fillet 74 17.8 4/M 10.1 <.46 4.46 <2.46* 4146 4.46 4.46 BLC -3 7/17/07 Fillet 72 17.5 4/F ]2.3 4145 4145 4.45* 4145 Fillet 883 BLC -4 7/17/07 Fillet 67 1 16.2 41M 7.66 4.45 <4.34 <2.45* <.45 4145 ¢.45 BLC -5 7/17107 Fillet 91 1 19 1 51M 8.18 4.79 <.44 <2.44* ¢.44 4144 ¢.44 Peltier Lake Fish PFC anal sis Age/ PFOS PFDA PFBA PFOSA PFDA PFUnA PFDoA Wt Ln Species & Sample Tissue sex n n ng/g ng ng/g hg/g nag n Sample ID Date (g) (cm) ( b b b b b b b b pb Blue 71 BG -1 2007 Fillet 58 15 4/M 17.6 Q.44 4.44 Q.44* <.44 Q.44 Q.44 BG - 2007 Fillet 87 15.8 5/F 9.52 <48 4.48 <.48* <.48 4.48 4.48 BG -3 2007 Fillet 50 13 31F 15.1 <4.27 <.45 <.45* <.45 4.45 Q.45 BG - 2007 Fillet 34 12.3 3/J 10.9 <.50 <.so <.50* ¢.50 <.50 Q.50 BG -5 2007 Fillet 30 11.5 2/F 7.53 <3.43 <.50 <.50* 4.50 4.50 <.50 Northern Pike NOP -1 2007 Fillet 607 45 4/J 20.7 4.78 4165 <.49 <.49 <.49 4.49 NOP -2 2007 Fillet 658 43 41J 14.5 <A3 <.43 <.43 4.43 <.43 4.43 NOP -3 2007 Fillet 764 51 4/J 8.2 4.40 4.40 ¢.40 <.40 <.40 4140 NOP -4 2007 Fillet 883 50 41F 13.6 <2.49 <.49 4.49 <2.49 4.49 4.49 NOP -5 2007 Fillet 1161 1 54 1 4/J 1 13.1 <.48 <.48 4.48 4.48 4.48 1 4148 2007 MPCA Metro Lakes PFC Fish Data - additional 20 lakes January 28, 2008 Powers Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln ( Age/ sex s PFOS ng/g b PFOA ng/g b PFBA ng/g b PFOSA ng/g b PFDA ng/g b PFUnA ng/g b PFDoA ng/g b Blue gill BG -1 7/07 Fillet 31 13 3/F 48.5 <2.48 <248 <.48 <2.48 <2.48 <2.48 BG -2 7/07 Fillet 66 15 4/M 45 <.50 <2.50 <.50 <2.50 <2.50 <.50 BG -6 7/07 Fillet 59 16.5 6/M 44,8 <A8 <.48 <.48 <.48 <.48 <.48 BG -9 7/07 Fillet 58 17 6/M 26.6 <.40 <.40 <.40 <.40 <.40 <.40 BG -10 7/07 Fillet 40 NA 5/1 32.7 <.45 <.45 <.45 <.45 <2.45 <.45 BG -comp 7/07 Fillet 65.3 <.48 <.48 <.48 <.48 <.48 <.48 Black Crappie BLC -1 7/07 Fillet 99 20 5/M 63.9 <.39 <.39 <2.39* <.39 1 <239 <.39 BLC -2 7/07 Fillet 100 20 51F 59.9 <.35 <35 <.35* 2.49 <.35 <.35 BLC -3 7/07 Fillet 109 19 51F 53.3 <4.84 <.45 <.45* 2.47 <.45 <.45 BLC -4 7/07 Fillet 108 20 51F 33.6 <2.49 <4.64 <.49 <.49 <.49 <249 BLC -5 7/07 Fillet 105 19 5/7 42.9 <.34 <.34 <.34 <2.34 <.34 <234 Northern Pike NOP -1 7/07 Fillet 2233 70 61M 71,1 <.49 <.49 <.49 3.08 2,64 <.49 NOP -2 7/07 Fillet 1680 64 5/M 71.9 <.50 <.50 <.50 3.04 <.50 <.50 NOP -3 7/07 Fillet NA 70 61J 62.8 <.48 <.48 <.48 2.73 2.56 <.48 Yellow Perch YEP-comp 7/07 Fillet 41.6 <36 <2.36 <.36 <2.36 <2.36 <.36 Prior er Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt lg) Ln lem) Age/ sex s PFOS ng/g b PFOA ng/g b MBA ng/g b PFOSA ng/g b PFDA ng/g b PFUnA ng/g b PFDoA. ng/g b Blue ill BG -2 8/23/07 Fillet 29 12 3/M 5.25 <.46 <.46 <.46 <.46 <.46 <.46 BG -4 8/23/07 Fillet 27 11 2/1 <4.95 <.48 <.48 <.48 <.48 <.48 <.48 BG -6 8/23/07 Fillet 41 13 3/7 <4.81 <.40 <.40 <.40 <.40 <.40 <.40 BG -8 8/23/07 Fillet 48 13 3/F <5.00 <.50 <.50 <.50 <.50 <.50 <.50 BG -10 8/23/07 Fillet 85 16 51M <4.98 <.49 <.49 <.49 <.49 <.49 <.49 BG -comp 8/23/07 Fillet <4.98 <.49 <.49 <.49 <.49 <.49 <.49 Largemouth Bass LMB -1 8/23/07 Fillet 576 33 5/M <4.90 2.8 <.45 <.45* <.45 <.45 <.45 LMB -2 8/23/07 Fillet 653 35 6/F 6.14 <.49 <19.6 <.49* 2.62 <.49 <.49 LMB -3 8/23/07 Fillet 503 32 5/M <4.93 <.46 <.46 <.46* <.46 <.46 <.46 LNM - 8/23/07 Fillet 370 31 51F <4.76 <.38 <.38 <.38* <.38 <2.38 <.38 LMB -5 8/23/07 Fillet 744 37 7/F <4.95 <.48 <2.48 <.48* <.48 <.48 <.48 2007 MPCA Metro Lakes PFC Fish Data - additional 20 lakes January 28, 2008 Red Rock Lake Fish PFC anal sis Age/ PFOS PFOA PFBA PFOSA PFDA PFUnA PFDGA Wt Ln Species & Sample Tissue sex ng/g ng/g ng/g ng/g ng/g ng/g ng/g Sample ID Date (g) (cm) b b b b b b b Blue gill BG -6 8/17/07 Fillet 5 10 25 42 4.40 4.40 4.40 Q.40 4.40 4.40 BG -7 8/17/07 Fillet 43 13.9 4/J 32.7 4.48 4.48 4.48 4.48 2.48 4.48 BG -8 8/17/07 Fillet 61 15.2 5/M 42.2 4.43 4.43 4.43 4.43 2.43 4.43 BG -9 8/17/07 Fillet 130 18.2 7/M 58.3 Q.45 4.45 4.45 4.45 4.45 4.45 BG -10 8/17107 Fillet 57 14 4/F 29.2 -75-2- 4.44 4.44 Q.44 4.44 2.44 4.44 BG -comp8/17/07 9.2 Fillet <5.00 4.50 4.50 5 .2 2 .38 <3.02 2.38 4.38 2.38 Q.38 74.90 4.45 4.45 2.45 2.45 <2.45 4.45 Black Cra ie BlackCr to BLC -1 8/17/07 Fillet 81 17 4/F 79.9 4.48 4.48 4.48 2.73 4.48 4.48 BLC -2 8/17/07 Fillet 102 20 5/F 97.1 4.48 4.48 <2.48 3.07 2.48 448 BLC -3 8/17/07 Fillet 149 21 6/M 153 <2.49 4.49 2.49 3.69 Q.49 4.49 BLC -4 8/17/07 Fillet 283 27 8/F 115 4.43 443 . <2.43 3.62 2.43 4.43 BLC -5 8/17/07 Fillet 122 19 5/F 68.6 4.49 4.49 2.49 2.9 5 4.49 4.49 21 6/M <4.93 <2.46 2.46 2.46 4.46 4.46 Q.46 Lar emout h Bas s Northern Pike UO -1 8/17/07 Fillet 666 38 7/M 85.7 Q.76 2.42 4.42* 2.67 4.42 4.42 LNM -2 8/17/07 Fillet 527 33 5/F 60.6 4.60 4.44 2.44* 2.69 4.44 4.44 LMB -3 8/17/07 Fillet 566 33 5/J 64.5 2.46 Q.46 2.46* 3.22 Q.46 4.46 LMB -4 8/17/07 Fillet 591 33 S/F 57.4 Q.48 2.48 2.48* 4.48 4.48 4.48 LMB -5 8/17/07 Fillet 716 36 71M 74.4 <3.99 2.33 2.33* 3.07 4.33 4.33 Sarah Lake Species & Sample ID Fish PIT C anal sis Wt Ln Age/ PFOS PFDA PFBA PFOSA PFDA PFUnA PFDoA Sample sex Date Tissue (g) (CM) ng/g pb ng/g ppb ppb ppb ng/g ng/g ng/g rs b b b b b b b Blue ill BG -3 7/16/07 Fillet 70 17 6/17 6.12 4.48 4.48 2.48 2.48 248 4.48 BG -4 7116/07 Fillet 86 18 7/M 6.21# 4.49 Q.49 2.49 2.49 2.49 4.49 BG -6 7/16/07 Fillet 74 17 6/F 7.97 4.49 2.49 4.49 Q.49 4.49 4.49 BG -7 7/16/07 Fillet 10 7 1/1 8.51 4.43 443 2.43 Q.43 <2.43 Q.43 BG -9 7/16/07 Fillet 15 9.2 1/1 <5.00 4.50 4.50 2.50 2.50 2.50 4.50 BG -comp 7/16/07 Fillet 74.90 4.45 4.45 2.45 2.45 <2.45 4.45 BlackCr to BLC -1 7/16/07 Fillet NA 2I 6/F <4.95 Q.48 4.48 2.48 2.48 2.48 <148 BLC -2 7/16/07 Fillet NA 20 5/M <5.00 <2.50 2.50 2.50 2.50 <2.50 Q.so BLC -3 7/16/07 Fillet NA 24 7/F <4.83 <2.42 2.42 2.42 4.42 4.42 2.42 BLC -4 7/16/07 Fillet NA 20 5/M <4.76 2.38 <9.45 2.38 4.38 438 4.38 BLC -5 7/16/07 Fillet NA 21 6/M <4.93 <2.46 2.46 2.46 4.46 4.46 Q.46 Northern Pike NOP -1 7/16/07 Fillet 3440 70.7 6/F 7.88 4.64 4.45 4.45 4.45 445 2.45 NOP -2 7/16/07 Fillet 4052 85 7/F 10.8 4.49 4.49 4.49 4.49 449 2.49 NOP -2(dup Fillet 14.4 4.43 4.43 4.43 4.43 <2.43 2.43 NOP -3 7/16/07 Fillet 3821 85 81F 13.6 4.45 2.45 4.45 4.45 2.45 4.45 NOP -4 7/16/07 Fillet 3229 81.5 7/F 7.45 Q42 2.42 4.42 4.42 4.42 2.42 NOP -5 7/16/07 Fillet 1757 66 5/M 9.6 2.39 Q .39 Q.39 2.39 Q.39 2.39 2007 MPCA Metro Lakes PFC Fish Data - additional 20 lakes January 28, 2008 Silver Lake Fish PFC analysis Species & Sample ID Sample Date Tissue Wt (g) Ln ( Age/ sex NO) PFOS ng/g b PFOA ngg b PFBA ng/g b PFOSA ng/g b PFDA ng/g b PFUnA ng/g b PFDoA ng/g b Blue ill BG -3 5/4/07 Fillet 64 16 51M 24 2.40 Q.40 1.40 Q.40 3.38 1.40 BG -4 5/4/07 Fillet 38 13 3/F 19.6 1.43 1.43 2.43 1.43 2.53 143 BG -5 5/4/07 Fillet 36 13 31F 24.44 1.42 Q.42 2.42 Q.42 2.42 1.42 BG -7 5/4/07 Fillet 43 14 4/F 31.3 148 2.48 <2.48 1.48 2.48 <2.48 BG -9 5/4/07 Fillet 32 13 3/F 21.4 1.42 2.42 Q.42 2.42 <2.42 Q.42 BG -comp 5/4/07 Fillet 33.7 1.44 1.44 1.44 Q.44 1.44 2.89 Black Crappie BLC -1 5/4/07 Fillet 69 16 51F 26.6# 2.46 2.46 2.46 2.92 <2.46 2.46 BLC-4 5/4/07 Fillet 63 17 4/M 36.6 1.48 1.48 2.48 3.39 Q.48 3.38 BLC -6 514/07 Fillet 67 18 5/M 45 <2.49 2.49 149 4.52 1.49 2.89 BLC -7 5/4/07 Fillet 67 18 51M 28.6 1.50 Q.50 1.50 3.88 111 3.05 BLC -10 5/4/07 Fillet 296 27 8/F 29.3# Q.43 1.43 1.43 3.77 3.08 1.43 BLC- 10(dup) 26.2 <244 <2.44 2.65 Q.44 2.44 <2.44 BLC -comp 5/4/07 Fillet 34.9 1.45 1.45 2.45 1.45 2.45 <2.45 BLC- com du Fillet 378 NA 4/F 96.5 33.5 <2.48 2.48 2.48 2.48 2.48 1.48 6/12/07 Fillet 619 NA 5/F 75.7 2.44 g<244 1.44 486 4.42 8.37 LMB -3 Walle e Fillet 576 35 6 F 76.6 1.39 Q.39 3.56 4.73 3.4 WAE -1 5/4/07 Fillet 453 50 9/M 10.2 <2.40 <4.84 2.71 1.40 2.40 2.40 WAE -1(du 6/12/07 Fillet 1570 50 12/F 10.8 Q.42 <2.42 4.2 1.42 2.42 <2.42 WAE -2 5/4/07 Fillet 486 52 10/M 18.8 1.44 2.44 4.65 2.8 2.85 Q.44 WAE -3 5/4/07 Fillet 371 27 4/M 10.5 <2.49 1 Q.49 5.31 2.49 2.49 1.49 WAE -4 5/4/07 Fillet 1200 46 8MI 26.6 2.33 Q.33 4.82 2.99 2.49 2.96 Tanners Lake Fish PFC analysis Species 11 Sample ID Sample Date Tissue Wt ( Ln ( Age/ sex s PFOS nBlB b PFOA nF1g b PFBA ng/g b PFOSA ng/g b PFDA W9 b PFUnA MJg b PFD0 ng/g b Blue ill BG -1 6/12/07 Fillet 89 17 61M 61.1# 2.46 Q.46 1.46 1.46 <2.46 2.46 BG -2 6/12/07 Fillet 32 12.5 3/F 87# <230 2.30 -Q.30 2.30 Q.30 1.30 BG -5 6/12/07 Fillet 93 18 7/F 56.G Z48 <2.48 2A8 Q.48 1.48 2.48 BG -7 6/12/07 Fillet 89 1 16.5 61F 70.4 1.44 <2.44 1.44 1.44 2.44 Q.44 BG -10 6/12/07 Fillet 12 10 25 105 1.49 1.49 2.49 436 1.49 2.49 BG -comp 6/12/07 Fillet 55 <2.44 1.59 2.44 <2.44 <2.44 Q.44 Black gEpyze BLC -1 6/12/07 Fillet 69 18 4/M 265 1.45 <2.45 1.45* 6.3 2.45 2.45 BLC -2 6/12/07 Fillet 63 15 3/M 75.9 1.46 1.46 2.46 Q.46 Q.46 1.46 BLC -3 6/12/07 Fillet 56 18 4/F 91.2 2.38 <3.96 2.38 2.82 2.38 Q.38 BLC -4 6/12/07 Fillet 80 18.5 4/M 94.6 2.39 1.39 139 139 <239 Q.39 BLC -5 6/12/07 Fillet 56 17 4/F 64 2.81 Q.40 2.40 1.40 1.40 2.40 Largemouth Bass LMB -1 6/12/07 Fillet 378 NA 4/F 96.5 1.43 1.43 6.05 4.62 4.11 LAO-2 6/12/07 Fillet 619 NA 5/F 75.7 2.44 g<244 1.44 486 4.42 8.37 LMB -3 6/12 07 Fillet 576 35 6 F 76.6 1.39 Q.39 3.56 4.73 3.4 LMB -4 6/12/07 Fillet 823 37 71M 74.9 1.44 2.44 3.44 <2.44 4.2 LMB -5 6/12/07 Fillet 1570 50 12/F 74.( 1.56 1.56 1.56* 3.33 2.56 1.56 IN 2007 MPCA Metro Lakes PFC Fish Data — additional 20 lakes January 28, 2008 11 2007 MPCA Metro Lakes PFC Fish Data - additional 20 lakes January 28, 2008 St. Croix River Fish PFC analysis Species & Sample ID Sample Date Tissue Wt 18) La °m) Age/ sex s PFOS ng b PFOA n b PFBA n I PFOSA n b PFDA n b PFUnA ni b PFDoA n b Blue ill BG -3 7/19/07 Fillet 86 15.5 5/F <4.83 <2.42 2.42 Q.42 2.42 2.42 <2.42 BG -5 7/19/07 Fillet 83 14.5 4/F 33.1 Q.45 2.45 2.45 Q.45 2.45 2.45 BG -7 7/19/07 Fillet 122 18.5 71M <4.95 2.48 2.48 2.48 Q.48 <2.48 Q48 BG -8 7/19/07 Fillet 76 15 4/M 22.3 2.40 Q.40 1 2.40 2.40 Q.40 1 Q.40 BG -10 7/19/07 Fillet 80 15 4/M 13.1 2.44 2.65 Q.44 2.44 Q.44 2.44 BG -comp 7/19/07 Fillet 12 <2.42 2.42 Q.42 2.42 <2.42 Q.42 BG- com du 16.4 Q.46 <2.46 Q.46 2.46 <2.46 <2.46 Walleye WAE -1 7/19/07 Fillet 670 45 8/M 8.34 <2.45 <3.85 2.45* <2.45 2.45 2.45 WAE -2 7/19/07 Fillet 695 44 7/M 13.8 <2.35 1 2.35 235* Q35 <235 2.35 WAE-3 7/19/07 Fillet 641 42 6/M 12 2.42 2.42 2.42* Q.42 2.42 2.42 WAE -4 7/19/07 Fillet 919 48 9/M 40.2 2.42 2.42 Q.42* 2.42 2.42 2.42 WAE -5 7/19/07 Fillet 890 48 9/M 12.7 2.49 Q.49 2.49 <2.49 2.49 Q.49 White Bass WBB -1 7/7 Fillet 403 34 5F 81.8 2,50 <2.50 <250 2.63 Q.50 Q.50 Smallmouth Bass SMB -i 7/19/07 Fillet 573 35 3/M 12.3 2.29 <2.29 2.29 Q.29 2.29 Q.29 SMB -2 7/19/07 Fillet 730 38 4/M 29.1 2.45 Q.45 2.45 2.45 Q.45 2.45 SMB -2 du 31,4 2.22 <2.22 2.22 2.22 2.22 2.22 SMB -3 7/19/07 Fillet 425 30 1/M <4.90 <2.45 Q.45 Q.45 <2.45 2.45 2.45 SMB -4 7/19/07 Fillet 286 29 I/M 5.44 Q.33 2.33 2.33 Q.33 2.33 Q.33 SMB -5 7/19/07 Fillet 252 27 11M 11.2 2.48 2.48 2.48 248 Q.48 Q.48 12 2007 MPCA Metro Lakes PFC Fish Data - additional 20 lakes January 28, 2008 Mississi _.i River Brainerd area Fish Yl +'C an srs Age/ PFOS PFOA PFBA PFOSA PFDA PFUM PFDoA Species & Sample Tissue Wt Ln SC% ng/g nag ng/g ng n g/g ng/g ng/g Sample ID Date PFOA (g) (cm) 335 -67 -1 PFOS b ) ( b ) (ppb b b b 754 -9 -6 754 -91 -6 PFNA C -9 perfluorononanoic acid 375 -95 -1 s b ( 335 -76 -2 PFUnA C -11 perfluoroundecanoic acid Blue gill C -12 Fillet 50 la a/1 7.38 a.4a Q.a7 Q.aa* a.a4 Q.aa <244 BG -1 8/13/07 59 133 31F 12.3 Q.45 Q.45 Q.45* <245 Q.A5 12.45 BG -2 8/13/07 Fillet Walleye 8/13/07 Fillet 225 31 5/J 9.42 Q.35 Q.35 Q.35* Q.35 Q.35 Q35 WAE -1 8/13/07 Fillet 625 43 7/F 8 WAE -2 8/13/07 Fillet 325 32 5/F 7.69 Q.46 Q,46 Q.46 Q.46 12.46 Q.46 WAE -3 8/13/07 F111et 1425 49 9/M 10.4 <2.42 Q.42 Q.42* Q.42 Q.42 Q.42 WAE -4 Fillet 1850 54 Ii/ 8.75 Q.35 <2.35 Q.35 Q.35 Q.35 12.35 WAE -5 8/13/07 8.99 Q.43 <8.25 Q.43* Q.43 Q.43 <2.43 WAE -5 d ) Northern Pike Fillet 301 33 3/J 7.t5 <2.35 Q.35 Q.35* Q.35 Q.35 Q35 NOP -1 8/13/07 Fillet 1050 51 4/F 6.29 Q.46 Q.46 Q.46* Q.46 Q.46 12.46 NOP -2 8/13/07 1450 54 4/F 7.62 Q.27 Q.27 Q.27 Q.27 Q27 Q.27 NOP -3 8113/07 Fillet Smallmouth Bass Fillet 1275 44 6/F 12.5 Q.44 <3.29 Q.44* Q.44 Q.44 Q.44 SMB -1 8/13/07 8/13/07 Fillet 1300 39 12.1 <2.27 Q.27 Q.27* Q.27 Q.27 Q.27 SMB -2 8/13/07 Fillet 900 36 3 <2.33 Q.33 Q.33* Q.33 Q.33 Q.33 SMB -3 8/13/07 Fillet 1850 41 P4/M 8.82 <2.43 Q.43 Q.43 Q.43 Q.43 Q.43 SMB -4 Fillet 225 23 18 Q.40 <11.8 Q.92* Q40 Q.40 Q.40 SMB -5 8/13/07 < = less than the detection limit; number following this symbol represents the detection limit * estimated values with a negative bias # estimated values with a positive bias For further information please contact Paul Hoff 651 -296 -7799 or Laura Solem 218 -529 -6254. Samples were analyzed for the 13 different perfluorochemicals listed. 13 CAS# PFBA C -4 erfluorobutanoic acid 375 -22 -4 PFBS C -4 erfluorobutane sulfonate 375 -73 -5 PFPeA C -5 erfluoro entanoic acid 2706 -90 -3 PFHxA C -6 erfluorohexanoic acid 307 -24 -4 PFHxS C -6 erfluorohexane sulfonate 355 -46 -4 PFH A C -7 erfluorohe tanoic acid 375 -85 -9 PFOA C -8 erfluorooctanoic acid 335 -67 -1 PFOS C -8 erfluorooctane sulfonate PFOSA C -8 erflummoctane sulfonamide 754 -9 -6 754 -91 -6 PFNA C -9 perfluorononanoic acid 375 -95 -1 PFDA C -10 perfluorodecanoic acid 335 -76 -2 PFUnA C -11 perfluoroundecanoic acid PFDoA C -12 pertiuorododecanoic acid 307 -55 -1 13 Settlement Agreement and Consent Order 3M and MPCA, May 22, 2007 QUARTERLY PROGRESS REPORT 94 January 1 — March 31, 2008 On May 22, 2007, 3M and the Minnesota Pollution Control Agency (MPCA) entered into a Settlement Agreement and Consent Order (Settlement Agreement) for the investigation and assessment of fluorochemicals (PCs) at sites in Washington County and for the execution of certain other related matters. This report is provided to fulfill the requirement outlined in Part XIII.A of the Settlement Agreement. REPORTING PERIOD: January 1 to March 31, 2008 ACTIVITIES COMPLETED: Scone of Agreement — Washington County Landfill (Part V F) In the Settlement Agreement, 3M agreed to assist in identifying possible remedial approaches for the Washington County Landfill site. Towards this end, 3M has participated in several meetings with agency staff where technical and other input has been offered for consideration. In the same spirit, 3M reviewed the fact sheet entitled "Washington County Landfill containment remedy: MPCA Recommended altemative" that was published in February 2008 and provided written comments dated March 14, 2008 on MPCA's proposed remedy for the site. Remedial Investigations (Part VI) and Feasibility Studies (Part VII) Given the interrelatedness of the remedial investigation (RI) work and the feasibility studies (FS), these sections have been combined with the intent of providing a simpler, more straightforward update. Cottage Grove 3M conducted a public meeting on January 31, 2008 at Cottage Grove Junior High School, 9775 Indian Boulevard, in Cottage Grove for the purpose of informing interested individuals about results from the Remedial Investigation and seeking their input concerning alternatives under consideration for the Feasibility Study. The format for the meeting included a one -hour, informal poster session followed by a one -hour general session that included presentations and a time for questions and answers. Approximately 120 people attended and a constructive dialogue took place concerning options being evaluated and issues of interest to the public. Settlement Agreement and Consent Order — 3M and MPCA First Quarter 2008 Progress Report Page 2 of 7 The Feasibility Study Report for the site was submitted on March 13, 2008, per the schedule outlined in the Settlement Agreement and subsequent correspondence. 3M and Weston Solutions personnel also met with MPCA staff on this date to discuss the Feasibility Study and pre - design activities that 3M felt would be useful in preparing the Remedial Design package required under the Settlement Agreement. Specifically, and as outlined subsequently in a letter from 3M dated March 19, 2008, 3M proposed installing pilot borings at each of the locations or the proposed extraction wells, installing one of the new extraction wells, conducting a pump test on the new extraction well, collecting additional soil samples in the former D2 disposal area and collecting additional samples of the sand bar adjacent to the East Cove at the site. Oakdale The Feasibility Study Report for the site was submitted to the MPCA on January 28, 2008, per the schedule outlined in the Settlement Agreement and subsequent correspondence. A telephone conference call was conducted on February 21, 2008 to obtain preliminary MPCA comments on the FS Report and to discuss possible steps to expedite remediation at the site. Specifically, the concept of installing thirteen of the proposed groundwater extraction wells beginning in March, in part to take advantage of frozen ground conditions, was reviewed. 'Phis action was agreeable to MPCA staff, as documented in a March 7, 2008 e -mail from Mr. Doug Wetzstein. In March, installation of the thirteen groundwater extraction wells identified in the FS Report to be located in the south/south- central portion of the site commenced. In a letter dated March 13, 2008, the MPCA approved the Oakdale FS Report, with modifications. Specifically, the MPCA requested that additional information be provided concerning the final disposal location and handling of non - hazardous PFC- containing soil. 3M directed its consultant, Weston Solutions, to begin preparation of an addendum to address this matter. Woodbury In a letter dated January 9, 2008, the MPCA requested 3M to install four pair of monitoring wells in southern Washington County. The stated intent of this request was to better understand the presence of PFCs in certain areas of Cottage Grove and Woodbury. 3M indicated its willingness to complete this activity in a letter dated January 15, 2008 and subsequently submitted a work plan to the MPCA. In addition, several meetings were conducted with city personnel to inform and solicit their input. 3M conducted a public meeting on January 10, 2008 at Middleton Elementary School for the purpose of informing interested individuals about results from the Remedial Investigation and seeking their input concerning alternatives under consideration for the Feasibility Study. Settlement Agreement and Consent Order— 3M and MPCA First Quarter 2008 Progress Report Page 3 of 7 Approximately 200 people attended and a constructive dialogue took place concerning options being evaluated and issues of interest to the public. On January 17, 2008, a report entitled "Addendum to the Hydraulic Evaluation of the Barrier Well Recovery System" was submitted to the MPCA. This document provided additional information pertaining to the barrier well network and Site geologic, hydrogeologic, and groundwater analytical data collected since the hydraulic evaluation was performed in late May 2007 at the Site. This addendum was prepared per the agreements reached with the MPCA during a December 4, 2007 meeting. Also submitted on January 17, 2008 was a report entitled "Preliminary FC Assessment Report and Planned Future Activities for the Main and Municipal Disposal Areas". This document summarized a Geoprobe soil sampling program that was performed to further assess the waste material remaining in the disposal trenches at the Main and Municipal Disposal Areas and outlined additional proposed sampling for the areas. In a letter dated February 13, 2008, the MPCA approved the additional sampling program subject to modifications requiring that additional samples be collected at the Main Disposal Area. The Remedial Investigation/Feasibility Study for the site was submitted on February 18, 2008, per the schedule outlined in the Settlement Agreement and subsequent correspondence. This report included the finalized laboratory analytical results from the 3 Td round of groundwater sampling as outlined in the February 2007 Groundwater Monitoring Plan. In March, soil sampling at the Main Disposal Area and the 4 °i round of groundwater sampling for the site were completed. On March 31, 2008, a meeting was held with 3M Weston and the MPCA to present the results of the additional soil sampling in the Main Disposal Area. As an outcome from the meeting, it was agreed that additional archived soil samples would be analyzed. All Sites On February 15, 2008, 3M met with MPCA staff representing several different programs to introduce the candidate location for disposal of excavated soils generated from the three sites. Several subsequent meetings have occurred to address questions related to this matter and to advance permitting activities necessary to accomplish the proposal. Also related to this issue. and as noted above for the Oakdale site, the MPCA has requested that 3M prepare a FS Report addendum to provide more information on the final disposal location and handling of non- hazardous PFC- containing soils. Assembly of this information began in March. Settlement Agreement and Consent Order — 3M and MPCA First Quarter 2008 Progress Report Page 4 of 7 Resuonse Action (Part VII In a letter dated January 30, 2008, the MPCA requested 3M to begin discussions with Washington County regarding providing an alternative water supply for a well located within the Lake Elmo Park Reserve and to investigate ground water impacts in the area south of Eagle Point Lake in Lake Elmo, MN. 3M indicated its willingness to address both of these items in a letter dated February 18, 2008. Subsequently, 3M has worked with MPCA and MDH staff to finalize a location for installation of a Jordan aquifer monitoring well in the area south of Eagle Point Lake and has conducted two meetings with Washington County personnel concerning the Lake Elmo Park Reserve primitive campground well. Information- Sharing Process (Part XIILB) A regular schedule of meetings (generally every 2 -3 weeks) has been employed to enable 3M and MPCA personnel to discuss specific items relative to this information - sharing requirement under the Consent Order. A standard format to surnmarize and periodically update the various information requests has been used to guide the discussions. In the previous quarterly report, 3M indicated its belief that the obligations under this part of the Settlement Agreement had been satisfied. This matter was discussed in a meeting with MPCA personnel during the first quarter of 2008. At the request of the agency, additional information summarizing this item was recently submitted for consideration. Irrespective of the formal determination of completeness relative to this part, based on discussions with MPCA personnel, 3M and the MPCA agreed to continue regular meetings to share new developments and information that could be helpful in understanding PFC issues in Minnesota. An example of the outcome from such dialogue is the seminar that was arranged for April 18, 2008 to have Dr. Scott Mabury, University of Toronto, present his work on "PFAs in the Environment: Sources, Mechanisms, and Trends ". Health and Toxicological Studies (Part XIILC) 3M continued to cooperate with the Minnesota Department of Health (MDH) in providing health and toxicological information relative to PFCs. The process established in May -June of 2007 to share specific updates on various studies as they are underway has continued with 3M providing monthly written summaries to the MDH. For informational purposes, copies of these updates are now also being provided to the MPCA. Relative to the 90 -day feeding study for PFBA, the final report was completed and an electronic version of the full study report was sent to the Minnesota Departinent of Health on January 11, 2008. Settlement Agreement and Consent Order -3M and MPCA First Quarter 2008 Progress Report Page 5 of 7 ACTIVITIES UNDERWAY & /OR PLANNED FOR APRIL -JUNE 2008: Remedial Investigations (Part VI) and Feasibility Studies (Part VII) Given the interrelatedness of the remedial investigation (RI) work and the feasibility studies (FS), these sections Have been combined with the intent of providing a simpler, more straightforward update. Cottage Grove Tn a letter dated April 2, 2008, MPCA approved the initiating of pre - design activities as outlined in IM's aforementioned March 19, 2008 letter. Accordingly, 3M will commence installation of pilot borings and one of the proposed extraction wells and will also proceed with additional sampling of the former D2 disposal area and the sand bar adjacent, to the East Cove. Following installation of the extraction .yell, a pump test will be conducted to obtain design information on the quality and quantity of the extracted water, as well as to verify the extent of influence of the well. 3M will continue preliminary planning activities to be in a position to implement a remedy following MPCA final selection. Oakdale On April 16, 2008, 3M submitted an addendum to the FS Report for the site to address the disposal of excavated soil. This document was prepared at the MPCA's request to provide a description of off -site disposal facilities reviewed and considered, as well as a recommended facility. Installation of the new groundwater extraction wells identified in the FS Report to be located in the southdsouth- central portion of the site will be completed. Once this is accomplished, pump tests will be performed to obtain design information on the quality and quantity of the extracted water, as well as to verify the extent of influence of the wells. 3M will continue preliminary planning activities to be in a position to implement a remedy following MPCA Final selection. Woodbury In a letter dated April 4, 2008, the MPCA approved die FS Report, as modified, with a requirement that 3M submit additional information concerning the final disposal location and handling of PFC- containing soil. The addendum to the Oakdale Site FS Report submitted on April 16, 2008 may address this requirement. 3M will be discussing this matter in greater detail with agency staff in the near future. Settlement Agreement and Consent Order — 3M and MPCA First Quarter 2008 Progress Report Page 6 of 7 Analyses of the previously referenced archived soil samples from the Main Disposal Area will be completed and the results provided to the MPCA. Analyses of the 4" round of groundwater samples will be completed and the results provided to the MPCA. Coinciding with a planned utility shutdown at the 3M Cottage Grove 'facility over the Memorial Day weekend, the fieldwork associated with an additional hydraulic evaluation of the barrier well recovery system will be completed. The four pair of wells referenced in MPCA's letter dated January 9, 2008 will be installed and sampled. 3M will continue preliminary planning activities to be in a position to implement a remedy following MPCA final selection. All Sites As requested and appropriate, 3M will support efforts to obtain approvals necessary to accomplish disposal of excavated soils from the three sites. Response Action (Part VIII) Installation and sampling of a new Jordan aquifer monitoring well in the area south of Eagle Point Lake in Lake Elmo, MN will be accomplished. 3M will continue to work with Washington County personnel to provide an alternative source of drinking water for the primitive campground area within the Lake Elmo Park Reserve. Information Sharing Process (Part XIII.B) In the previous quarterly report, 3M indicated its belief that the obligations under this part of the Settlement Agreement had been satisfied. This matter was discussed in a meeting during the first quarter of 2008. At the request of the agency, additional information summarizing this item was submitted on April 14, 2008 for consideration. 3M awaits MPCA review and determination concerning this matter. Beyond the scope of Part XIII.B and based on discussions with MPCA staff, 3M and agency personnel plan to continue to meet on a regular basis to review new developments and information that could be helpful in understanding PFC issues in Minnesota. This may include Settlement Agreement and Consent Order — 3M and MPCA First Quarter 2008 Progress Report Page 7 of 7 additional meetings or seminars where subject matter experts are brought in to share knowledge on particular topics of interest. A seminar was conducted at MPCA offices on April 18, 2008 by Dr. Scott Mabury from the University of Toronto. The title of his presentation was "PFAs in the Environment: Souuces, Mechanisms, and Trends ". Health and Toxicological Studies (Part XIII.C) 3M will continue to share health and toxicological information on perfluorochemicals will. MDII as it becomes available. Monthly summary reports as previously described will continue to be provided. Recovery of Expenses (Part XXIII) In a letter dated February 11, 2008, the MPCA requested reimbursement for expenses related to PFC activities. Payment for the amount related to oversight costs related. to the three sites Oder the Settlement Agreement was submitted on April 14, 2008. Payment for the amount related to the point -of -use water filter study is anticipated to be submitted by April 30, 2008. Settlement Agreement and Consent Order 3M and MPCA, May 22, 2007 QUARTERLY PROGRESS REPORT #S April i —June 30, 2008 On May 22, 2007, 3M and the Minnesota Pollution Control Agency (MPCA) entered into a Settlement Agreement and Consent Order (Settlement Agreement) for the investigation and assessment of tiuorochemicals (FCs) at sites in Washington County and for the execution of certain other related matters. This report is provided to fulfill the requirement outlined in Part XiiLA of the Settlement Agreement, RF?PORTING PERIOD: April 1 to June 30, 2008 ACTIVITIES COMPLETED: Remedial lnvestiaations (Part VI and Feasibility Studies (Part VII Given the interrelatedness of the remedial investigation (Ri) work and the feasibility studies (FS), these sections have been combined with the intent of providing a simpler, more straightforward update. Cottage Grove In a letter dated April 2, 2008, the MPCA approved several pre - design field activities that had been discussed with agency staff in a meeting on March 13, 2008 and htrther described in a letter from Robert Paschke to Douglas Wetzstein dated March 19, 2008. Details of these activities were formalized in the Pre - Design Field Activities Work Plan that was prepared by Weston and submitted by 3M to the agency in May 2008. in a letter dated April 30, 2008, the MPCA provided a response to 3M concerning the I'S Report that had been submitted on March 13, 2008. Specific comments included the following: Concurrence on the recommended Sitewide Alternative SW -2 with specific requirements for the implementation of the institutional controls. ® Concurrence relative to enhancing the groundwater recovery system with technical comments regarding the proposed system in Groundwater Alternative GW -1. ® A recommendation that Soil and Sediment Alternative S /S -3 be implemented with technical comments regarding the bast Cove area. Settlement Agreement and Consent Order -3M and MPCA Second Quarter 2008 Progress. Report Page 2of9 • A request that the technical comments outlined in its April 30, 2008 be addressed in a I'S Report Modification. On May 30, 2008, 3M submitted the requested Feasibility Study Report AllodVicalion. In concert with the Pre - Design Field Activities bfork Plan, this report was intended to address comments from the MPCA's April 30, 2008 letter and to indicate how additional data collected during the prc- dcsign field activities will be used to support the final design of the groundwater extraction system and to refine areas of excavation. Luring this reporting period, the following field activities were completed at the site • Stratigraphic soil borings were drilled in the area of proposed extraction wells to provide lilhology and other information to be used in the extraction well network design. • Additional soil sampling was conducted in the 12 Area. • Additional sediment sampling was conducted in the East Cove Area. • Preliminary pre - acceptance soil sampling for non -PFC constituents for soils intended to be disposed of off -site was conducted, Vhas aforementioned soil and sediment samples were submitted for PFC analysis. Chi April 16, 2008, 3M submitted an addendum to the FS Report for the site to address the disposal of excavated soil and related debris. This document was prepared at the MPCA's request to provide a description of off -site disposal facilities reviewed and considered, as well as a recommended facility. This report was written to be applicable to all three Sites (Oakdale, Woodbury and Cottage Grove) and was approved by the MPCA in a letter dated May 12, 2008. On May 5 and .lune 9, 2008, meetings were held with MPCA staff concerning National Pollutant Discharge Elimination System (NPLES) ,permitting issues related to PFCs. More specifically, the liming of design activities pertaining to the extraction and treatment of groundwater were reviewed, as were possible permitting approaches. Oakdale As noted above, on April 16, 2008, 3M submitted an addendum to the FS Report for all three sites to address the disposal of excavated soil and related debris. Also during this reporting period, installation of new groundwater extraction wells (as identified in the FS Report) in the south/south- central portion of the site was completed. Twelve (12), instead of the planned thirteen (13), extraction wells were installed based on the field lithological conditions encomitered. These wells were developed and short-term pump tests conducted to Settlement Agreement and Consent Order— 3M and MPCA Second Quarter 2008 Progress Report Page 3 of 9 project influent loadings to the proposed new groundwater treatment system. A thirteenth dvcll will be installed north of Highway 5 after completion of the soil removal activities. In addition to completion of the new extraction wells, additional field activities during this reporting period included preliminary pre - acceptance soil sampling for non -PFC constituents fur soils intended to be disposed of off -site. in a letter dated May 12, 2008, 3M submitted a request to install pumps in the 12 new extraction wells and to construct conveyance piping from the new well network to the existing onsite sanitary sewer manhole. Furthermore, pending MPCA, Metropolitan Council Environmental Services (MCES) and City of Oakdale approvals, 3M proposed pumping the new extmetion wells for an extended period of'time (i,c., several months) in order to acquire design data for the proposed new groundwater treatment system. 3M and MCFS personnel met on May 22, 2008 to review a variety of topics relating to PFCs, including specifics concerning discharge of Oakdale Site groundwater to the MCFS system, Ina letter dated June 4, 2008, the MPCA approved 31vl's request for an extended pump -test. contingent upon MCES approval also being obtained. Following the May 22 meeting with MCES and receipt of MPCA's conditional approval, 3M supplied requested information to MCES personnel in a letter dated .tune 18, 2008. A modification to the existing industrial discharge permit for the Site is anticipated shortly. In meetings with MPCA staff on June 10 and June 25, 2008, 3M discussed the management of soils that could potentially be a source of odors during excavation in the area north of Highway S. As part of this dialogue, 3M proposed installing a temporary soil vapor extraction (SVI3) system in the portion of the excavation area that contains higher concentrations of VOCs. Givcn that SVF. is a proven technology for removing VOCs from vadose zone soils, its utilization would reduce the potential for VOC odors from the Site. Based on agreement reached in file meetings, 31M began preparation of a written request for approval to install a temporary SVI? system as an Interim Response Action, as outlined in Gxhibit C, Section IV.B of the Settlement Agreement (subsequently submitted on July 2, 2008). Woodbury As previously described, on April 16, 2008, 3M submitted an addendum to the FS Report tin' all three sites to address the disposal of excavated soil and related debris. Additional soil characterization involving analysis of archived soil samples collected in March 2008 was completed. Results from these analyses were presented and summarized in a report entitled Main Disposal Area Aelditional GeoprobeQo Sampling Program, Woodbury ,Site, Woodbury, Minnesota, submitted by 3M to the MPCA on May 22, 2008. During this reporting period, the following activities were also addressed Settlement Agreement and Consent Order — 3M and MPCA Second Quarter 2008 Progress Report Page 4 of 9 • Analytical results for the 0' round of groundwater sampling (samples collected in March 2008) were finalized in June 2008. • An additional hydraulic evaluation of the existing barrier well network at the site was performed during the Memorial Day weekend maintenance shutdown of the barrier wells. • Soil samples from the Main Disposal Area were re- analyzed for PFBA with an objective of lowering the Limit of Quantitation (LOQ) from 0.1 to 0.001 ppm. • Preliminary pre - acceptance soil sampling for non -PFC constituents for soils intended to be disposed of off -site was conducted. A meeting was held with MPCA staff on June 25, 2008 to review the additional soil characterization data and the results from the additional hydraulic evaluation of the barrier well system. Based on this discussion, it was determined that an additional addendum (Addendum 2) to the FS should be prepared and submitted for agency review. The report would provide a summary of the additional hydraulic evaluation that was performed in May 2008 and present a relined Soil Alternative S -3 based on the October 2007 RI results and the results of the March 2008 soil sampling program. (It should be noted that this document, Addendum 2 ra the Feasihility fitudy for the YYnndhauy Aire, YVoodbauy, A4innesota, was submitted by 3M to the MPCA on July 14, 2008.) In a letter dated January 9, 2008, the MPCA requested 3M to install four pair of monitoring wells in southern Washington County. The stated intent of this request was to better understand the presence of PFCs in certain areas of Cottage Grove and Woodbury. The three pair of wells to be located in Cottage Grove have been installed. Complications related to specific well location and access agreements have delayed installation of the pair of wells in Woodbury. All Sites — SKB Landfill 3M has participated in numerous meetings with MPCA and SKB personnel concerning repermitting of the SKB Rosemount Landfill to include a waste containment cell for nonhazardous PFC - containing soils and related debris from file three 3M Sites. In addition, 3M participated in sharing information at an open public forum in Rosemount on June 5, 2008. This meeting was hosted by SKB and was a voluntary initiative of the company to present information on the waste containment cell and to answer citizen's questions. Furthennore, in a letter dated June 20, 2008, 3M responded to several questions raised by the MPCA permit engineer assigned to the SKB facility. Settlement Agreement and Consent Order -3M and MPCA Second Quarter 2008 Progress Report Page 5 of 9 Respo Action ( Part VII11 In a letter (laced January 30, 2008, the MPCA requested 3M to begin discussions with Washington County regarding providing an alternative water supply for a well located within the Lake Eli Park Reserve and to investigate ground water impacts in the area south of Nagle Point Lake in Lake Elmo, MN. 3M indicated its willingness to address both of these items in a letter dated February 18. 2008. 3M has met with Washington County personnel concerning possible options to address the Lake Elmo Park Reserve primitive campground well. The County understands 3M's willingness to help address this situation and is currently considering various approaches. The location and construction details concerning the well to be installed south of Eagle Point Lake have been finalized with MPCA staff. Once access agreements are obtained from Washington County, installation of the well will commence. Information- Sharing Process (ParCXIII.k3) In the Octobcr- December 2007 quarterly report, 3M indicated its belief that the obligations under this part of'the Settlement Agreement had been satisfied. This matter was discussed in a meeting during the first quarter of 2008. At the request of the agency, additional information summarizing this item was submitted on April 14, 2008 for consideration. 3M awaits MPCA review and determination concerning this matter. A 3M- sponsored seminar was conducted at MPCA offices on April 18, 2008 by Dr. Scott Mabuty from the University of Toronto. The title of his presentation was "PFAs in the Environment: Sources, Mechanisms, and "trends". Health and Toxicological Studies (Part M 3M continued to cooperate with the Minnesota Department of Health (MDl - I) in providing health and toxicological information relative to PFCs. The process established in May -June of 2007 to share specific updates on various studies as they are underway has continued with 3M providing monthly written summaries to the MDhI. For informational purposes, copies of these updates arc also provided to the MPCA. Settlement Agreement and Consent Order -3M and MPCA Second Quarter 2008 Progress Report Page 6 of 9 Recover of 6xnenses (Part XXIII) In a letter dated February 11, 2008. the MPCA requested reimbursement for expenses related to P'FC activities. Payment for the amount related to oversight costs related to the three sites under the Settlement Agreement was submitted on April 14, 2008. Payment for the amount related to the point -of-use water filter study was submitted on April 30, 2008, In Pan XXIII.D of the Settlement Agreement, 3M agreed to provide to MPCA a grant in an amount up to (ivc million dollars for expenses incurred for the purpose of investigating and assessing the presence and effects in the environment of any PFC. This section of the Agreement also indicated that MPCA would consult with 3M on the scope of'such work and would consider 3M's comment in the selection of appropriate research. Towards this end. a meeting of 3M and MPCA personnel was held on June 19, 2008 where MPCA staff presented results from research recently completed or underway. In the course of this discussion, planned or possible future work was also reviewed. Settlement Agreement and Consent Order — 3M and MPCA Sceond Quarter 2008 Progress Report Pagc7of9 ACTIVITIES UNDERWAY & /OR PLANNED FOR JULY- SEPTEJMBER 2008: Scope of At?rc — VJashineton County Landfill Part V.F Under terms outlined in Section V, Part F, of the Settlement Agreement, 3M agreed to grant the MPCA up to eight million dollars for implementing remedial actions at the Washington County Landfill (Landfill). The Agreement requires 3M to pay five million dollars of this grant to the MPCA within 30 days after receipt of written notice from the MPCA of the selection of the remedial actions the agency intends to implement at the Landfill. In a letter dated June 25,2008, the MPCA informed 3M that the MPCA had selected the "Dig and Line" option as the remedy I'or PFCs at the Landfill and requested payment of the initial grant amount within thirty days of the letter. Payment in the amount of Five million dollars was made to the MPCA on July 24, 2008. Remedial Investigations (Part VD .and Feasibility Studies (Part VII) Given the interrelatedness of the remedial investigation (RI) work and the feasibility studies (FS), these sections have been combined with the intent of providing a simpler, more straightforward update. Cottage Grove As outlined in the Pre- Design Field Activilies fNork Plan and Fensihiliiy Study Report ModiJiculion. the following activities are anticipated: Instal fat ion of three piezometers in the Cast Cove Area to monitor water levels during a pump test of the extraction well to be installed on the west side of the cove. Installation, development and pump - testing of two new extraction wells. One well will be located near stratigraphic boring location S -I and the other will be at the western side of the Gast Cove. A twenty -Four (24) hour pump tests will be performed at each new extraction well to establish well yield and monitor water level changes in nearby wells and piezometers to determine the capture zone created by pumping. This information will be evaluated using the existing site groundwater model to confirm the spacing of future extraction wells. PFC analytical work for soil and sediment samples collected in (he D2 and East Cove Area will be completed. Settlement Agreement and Consent Order -3M and MPCA Second Quarter 2008 Progress Report Page 8 of 9 It is anticipated that discussions will continue relative to NPDES permit revisions necessary to allow the discharge of treated groundwater From the Woodbury and Cottage Grove Sites, as well as Icachate from the SKB 1.,andfill. 3M wilt continue remedial design activities, as appropriate, to be in a position to implement a remedy following MPCA final selection. Oakdale Qo July 23, 2008, 3M had a second meeting with MCES personnel to discuss management of extracted groundwater at the Site. Specifically, the information provided in 3M's letter dated June 18. 2008 was reviewed, including timing to conduct the proposed extended pump -test. Pending MCES and City of Oakdale approvals, pumps will be installed in the 12 new extraction wells and conveyance piping will be constructed to collect and discharge groundwater into the onsite sanitary sewer. Commencement of the extended pump -test is anticipated by mid - September. In a lever dated July 2. 2008, 3M submitted a written request for approval to install a temporary SVIi system as an Interim Response Action, as outlined in Exhibit C, Section IV.13 of the .Settlement Agreement. In a letter dated July 23, 2008, MPCA approved installation of this system with a request to provide detailed design information for review and approval. This information is being gathered and will be submitted shortly. Pending MPCA and City of Oakdale approvals, a temporary SVE system will be installed and commence operation north of' Highway 5. Per MPCA's request, nearby residences will be notified concerning the system. 3M will continue remedial design activities, as appropriate, to be in a position to implement a remedy following MPCA final selection. Woodbury As agreed upon in a meeting with MPCA staff on June 25, 2008, an addendum to the FS Report was prepared by 3M and submitted to the MPCA on July 14, 2008. The purpose of this document is to provide a summary of the additional hydraulic evaluation that was performer[ in May 2008 and to present a refined Soil Alternative S -3 based on the October 2007 RI results and the results of the March 2008 soil sampling program, 'this report, ddclendurn 2 to the Feasibility Study,jor the lPoodhury Sile, Woodhztry, Minnesota, contains the analytical results for the O tt ' round of groundwater sampling, the PFBA analytical results for the Main Disposal Area soil samples that were re- analyzed, and all of the data generated in performing the hydraulic evaluation over the recent Memorial Day weekend. Results from the previously referenced preliminary pre - acceptance soil sampling for non -PFC constituents will be used to complete the Remedial Design phase of the project and will be presented as part of the Remedial Design /Remedial Action (RD /RA) Plan, when it is submitted. Settlement Agreement and Consent Order — 3M and MPCA Second Quarter2008 Progress Report Page 9 of 9 3M will continue to work with the City of Woodbury to complete the installation of the remaining pair of wells referenced in MPCA's letter dated January 9, 2008. In addition. sampling and analysis of all wells that have been completed will be performed. 3M will continue remedial design activities, as appropriate, to be in a position to implement a remedy Iollowing MPCA final selection. All Sites As requested and appropriate, 3M will support efforts to obtain approvals necessary to accomplish disposal of excavated soils from the three sites. Res ponse Action (ParL V 1T11 3M will continue to work with Washington County personnel to provide an alternative source of drinking water for the primitive campground area within the Lake Elmo Park Reserve. AI present, 3M is awaiting County input concerning their preferred approach. 3M is working with Washington County to obtain an access agreement necessary to install a new Jordan aquifer monitoring well in the area south of Eagle Point Lake in Lake Limo, MN (i.e_ within the Take Elmo Park Reserve). Once this agreement is finalized, the well will be constructed, developed and sampled. Information S hdi•iit P rocessfPttrt XlTT.DI Pending MPCA's response to 3M's letter dated April 14, 2008 on this topic, 3M is available to meet with MPCA personnel on an "as- needed" basis to discuss specific items relative to information- sharing. Irrespective of the formal determination of completeness relative to this part, based on discussions with MPCA personnel, 3M and the MPCA have agreed to continua regular meetings to share new developments and information that could be helpful in understanding PPC issues in Minnesota. Health and'Poxicological Studies (Part XilLQ 3M will continue to share health and toxicological information on perfluorochemicals with MD) I as it becomes available. Monthly summary reports as previously described will continue to he provided. Settlement Agreement and Consent Order 3M and MPCA, May 22, 2007 QUARTERLY PROGRESS REPORT 96 July 1— September 30, 2008 On May 22, 2007, 3M and the Minnesota Pollution Control Agency (MPCA) entered into a Settlement Agreement and Consent Order (Settlement Agreement) for the investigation and assessment of perfluorochemicals (PFCs) at sites in Washington County and for the execution of certain other related matters. This report is provided to fulfill the requirement outlined in Part XIII:A of the Settlement Agreement. REPORTING PERIOD- July Ito September 30, 2008 ACTIVITIES COMPLETED: Scope of Agreement — Washington County Landfill (Part V.F) Under terms outlined in Section V, Part F, of the Settlement Agreement, 3M agreed to grant the MPCA up to eight million dollars for implementing remedial actions at the Washington County Landfill (Landfill). The Agreement requires 3M to pay five million dollars of this grant to the MPCA within 30 days after receipt of written notice from the MPCA of the selection of the remedial actions the agency intends to implement at the Landfill. In a letter dated June 25, 2008, the MPCA informed 3M that the MPCA had selected the "Dig and Line" option as the remedy for PFCs at the Landfill and requested payment of the initial grant amount within thirty days of the letter. Payment in the amount of five million dollars was made to the MPCA on July 24, 2008. Remedial Investigations (Part VI) and Feasibility Studies (Part VII) Given the interrelatedness of the remedial investigation (RI) work and the feasibility studies (FS), these sections have been combined with the intent of providing a simpler, more straightforward update. Cottage Grove As outlined in the previously submitted and MPCA- approved Pre - Design Field Activities Work Plan and Feasibiliry Study Report Modification, the following activities were conducted: Settlement Agreement and Consent Order — 3M and MPCA Third Quarter 2008 Progress Report Page 2 of 7 • Three piezometers were installed in the East Cove Area to monitor water levels during a pump test of the extraction well installed on the west side of the cove. • Two new extraction wells were installed in the eastern portion of the site. One well is located near stratigraphic boring location S -1 and the other is at the western side of the East Cove. On August 15, 2008, 3M submitted a- Groundwater Extraction [Yell Pump Test Work Plan to the MPCA for review and approval. The objectives of the pump tests to be performed at each new extraction well are to establish well yield and monitor water level changes in nearby wells and piezometers to determine the capture zone created by pumping. This information will be evaluated using the existing site groundwater model to confirm the spacing of future extraction wells. A written addendum to the Work Plan was submitted on September 22, 2008 providing additional details on the temporary treatment system to be used and on the monitoring plan for the tests. • PPC analytical work for soil and sediment samples collected in the D2 and East Cove Area was conducted. In addition to the activities noted above, non -Pl'C analytical work for soils intended to be disposed of off-site was also conducted. Oakdale The following progress was made concerning the new extraction well network for the Site: • On July 23, 2008, 3M had a second meeting with MCES personnel to discuss management of extracted groundwater at the Site. Specifically, the information provided in 3M's letter dated June 18, 2008 was reviewed, including timing to conduct the proposed extended pump test. In correspondence dated July 31, 2008, 3M received an amended Industrial Discharge Permit from MCES enabling the pump test to proceed. • On August 8, 2008, 3M requested an amenchnent to its Minnesota Department of Natural Resources (MN DNR) water appropriation permit for the Site. The amended permit was issued by MN DNR on September 17, 2008. • 3M continued to keep City of Oakdale personnel informed concerning developments and progress being made. City staff is in agreement that the pump test can proceed. • Conveyance piping from the 12 new extraction wells was installed to collect and discharge groundwater into the onsite sanitary sewer. The following progress was made concerning installation of a temporary soil vapor extraction (SVE) system at the Site: Settlement Agreement and Consent Order 3M and MPCA Third Quarter 2008 Progress Report Page 3 of 7 In a letter dated July 2, 2008, 3M submitted a written request for approval to install a temporary SVE system as an Interim Response Action, as outlined in Exhibit C, Section IV.B of the Settlement Agreement. In a letter dated July 23, 2008, MPCA approved installation of this system with a request to provide detailed design information for review and approval. This information was submitted to the MPCA in correspondence dated August 5, 2008. a The temporary SVE system_ has been installed north of Highway 5. A progress update on the cleanup project for the Site was provided to nearby residences in a letter dated August 11, 2008. Information concerning both the extraction well network and the SVE system was included in this update. Woodbury As agreed upon in a meeting with MPCA staff on .tune 25, 2008, an addendum to the FS Report was prepared by 3M and submitted to the MPCA on July 14, 2008. The purpose of this document is to provide a summary of the additional hydraulic evaluation that was performed in May 2008 and to present a refined Soil Alternative S -3 based on the October 2007 RI results and the results of the March 2008 soil sampling program. This report, Addendum 2 to the Feasibility Study far the Woodbury Site, Woodbury, Minnesota, contains the analytical results for the 4` round of groundwater sampling, the PFBA analytical results for the Main Disposal Area soil samples that were re- analyzed, and all of the data generated in performing the hydraulic evaluation over the recent Memorial Day weekend. Soil sampling was performed in the Former Main and Northeast Disposal areas during the week of July 21, 2008 for pre- acceptance testing of non -PFC parameters for waste disposal determination. Analytical results from these samples will be used to complete the Remedial Design phase of the project and will be presented as part of the Remedial Design/Remedial Action (RD/RA) Plan, when it is submitted. In an August 21, 2008 email from MPCA staff, a work plan was requested to collect a surface water sample from Gables Lake at the Site. In addition, several questions /comments were raised relative to the Woodbury water conveyance line. These items were addressed in a September 19, 2008 submittal to die MPCA. In response, agency staff approved the work plan, with modifications, in a letter dated September 30, 2008. In a letter dated January 9, 2008, the MPCA requested 3M to install four pairs of monitoring wells in southern Washington County. The stated intent of this request was to better understand the presence of PFCs in certain areas of Cottage Grove and Woodbury. The three pairs of wells to be located in Cottage Grove have been installed. Complications related to specific well location and access agreements have delayed installation of the pair of wells in Woodbury. Agreement has now been reached with the City to use a recently installed Prairie du Chien well and to construct a new monitoring well into the Jordan aquifer in close proximity. Settlement Agreement and Consent Order — 3M and MPCA Third Quarter 2008 Progress Report Page 4 of 7 Resnonse Action (Part VIII In a letter dated January 30, 2008, the MPCA requested 3M to begin discussions with Washington County regarding providing an alternative water supply for a well located within the Lake Elmo Park Reserve and to investigate ground water impacts in the area south of Eagle Point Lake in Lake Elmo, MN. 3M indicated its willingness to address both of these items in a Ietter dated February 18, 2008. 3M has met with Washington County personnel concerning possible options to address the Lake Elmo Park Reserve primitive campground well. The County understands 3M's willingness to help address this situation and is currently considering various approaches. 3M worked with Washington County to obtain an access agreement necessary to install a new Jordan aquifer monitoring well in the area south of Eagle Point Lake in Lake Elmo, MN (i.e., within the Lake Elmo Park Reserve). This well was constructed the week of September 8, 2008, consistent with location and construction details agreed upon with MPCA staff. Health and Toxicological Studies (Part XIII.C) 3M continued to cooperate with the Minnesota Department of Health (MDI-I) in providing health and toxicological information relative to PFCs. The process established in May -June of 2007 to share specific updates on various studies as they are underway has continued with 3M providing monthly written summaries to the MDH. For informational purposes, copies of these updates are also provided to the MPCA. Settlement Agreement and Consent Order — 3M and MPCA Third Quarter 2008 Progress Report Page 5 of 7 ACTIVITIES UNDERWAY & /OR PLANNED FOR OCTOBER — DECEMBER 2008: Remedial Investisrations (Part Via Feasibility Studies (Part VII Given the interrelatedness of the remedial investigation (RI) work and the feasibility studies (FS), these sections have been combined, with the intent of providing a simpler, more straightforward update. Cottage Grove Pump tests of the two new extraction wells (EW -I and EW -2) will be completed by October 17, 2008. Samples collected during the tests will be submitted for analyses. Analytical results for soilslsediments previously collected from the D2, East Cove and sandbar areas will be finalized. An addendum to the previously submitted Feasibility Study will be prepared. Submittal of this additional information is anticipated by the end of October 2008. Completion of the non -PFC analytical work for soils intended to be disposed of off -site is anticipated by the end of December 2008. It is anticipated that discussions will continue relative to NPDES permit revisions necessary to allow the discharge of treated groundwater from the Woodbury and Cottage Grove Sites, as well as leachate from the SKB Landfill. 3M will continue remedial design activities, as appropriate, to be in a position to implement a remedy following MPCA final selection. Oakdale The SVE system and vapor phase treatment columns have been installed. Power has been provided to the site by Xcel Energy. Tentative start -up of the system is projected for the week of October 20, 2008. Electrical and mechanical installation activities related to the new extraction well network are underway and scheduled for completion by the end of October 2008. Accordingly, start-up of the extraction well pumps is anticipated for the week of November 3, 2008. 3M will continue remedial design activities, as appropriate, to be in a position to implement a remedy following MPCA final selection. Settlement Agreement and Consent Order— 3M and MPCA Third Quarter 2008 Progress Report Page 6 of 7 Woodbury Sampling of Gables Lake was attempted on October 16, 2008. Since the water body was dry, sampling will be reattempted in the spring of 2009. 3M will continue to work with the City of Woodbury to complete the installation of the remaining well referenced in MPCA's letter dated January 9, 2008. It is anticipated that this last well will be installed during the week of November 3, 2008. Sampling of all of the regional wells that were the subject of the January 9, 2008 MPCA letter will be conducted in November 2008. 3M will continue remedial design activities, as appropriate, to be in a position to implement a remedy following MPCA final selection. All Sites The Solid Waste Management Facility Permit for the SKB Rosemount Industrial Waste Facility was reissued by the MPCA on October 3, 2008. This permit now enables the disposal of appropriately characterized excavated soils from the three sites. Response Action (Part VIII 3M will continue to work with Washington County personnel to provide an alternative source of drinking water for the primitive campground area within the Lake Elmo Park Reserve. At present, 3M is awaiting County input concerning their preferred approach. It is anticipated that the newly installed Jordan aquifer monitoring well in the area south of Eagle Point Lake in Lake Elmo, MN (i.e., within the Lake Elmo Park Reserve) will be sampled in November 2008. Infonnation Sharing Process (Part XIII.B) Pending MPCA's response to 3M's letter dated April 14, 2008 on this topic, 3M is available to meet with MPCA personnel on an "as- needed" basis to discuss specific items relative to information - sharing. Irrespective of the formal determination of completeness relative to this part, based on discussions with MPCA personnel, 3M and the MPCA have agreed to continue regular meetings to share new developments and information that could be helpful in understanding PPC issues in Minnesota. Settlement Agreement and Consent Order — 3M and MPCA Third Quarter 2008 Progress Report Page 7 of 7 Health and Toxicological Studies (Part XIILC) 3M will continue to share health and toxicological infonnation on perfluorochemicals with MDH as it becomes available. Monthly summary reports as previously described will continue to be provided. Settlement Agreement and Consent Order 3M and MPCA, May 22, 2007 QUARTERLY PROGRESS REPORT 98 January 1 March 31, 2009 On May 22, 2007, 3M and the Minnesota Pollution Control Agency (MPCA) entered into a Settlement Agreement and Consent Order (Settlement Agreement) for the investigation and assessment of perfluorochemicals (PFCs) at sites in Washington County and for the execution of certain other related matters. This report is provided to fulfill the requirement outlined in Part XIII.A of the Settlement Agreement. REPORTING PERIOD: January 1 to March 31, 2009 ACTIVITIES COMPLETED: Remedial Investigations (Part VI) and Feasibility Studies (Part VII) Given the interrelatedness of the remedial investigation (RI) work and the feasibility studies (FS), these sections have been combined with the intent of providing a simpler, more straightforward update. Cottage Grove Feasibility Study Report Addendum No. Z was submitted to the MPCA on January 6, 2009. The report presented a revised Soil and Sediment Alternative based on additional and recently acquired soil and sediment data. This addendum was approved by the MPCA in a letter dated February 19, 2009. Discussions continued relative to NPDES permitting options available to allow the discharge of treated groundwater from the Woodbury and Cottage Grove Sites, as well as leachate from the SKB Landfill. Several meetings were conducted with both MPCA and Minnesota Department of Health personnel in an effort to advance this issue. On March 19 -20, 2009, additional soil borings were installed and soil samples collected in the D9 former waste disposal area. Some of the samples were submitted for conventional constituent analyses (volatile organic compounds (VOCs)) while others are in the process of being analyzed for PFCs. The purpose of the conventional constituent data is to evaluate the potential benefits of installing a temporary Soil Vapor Extraction (SVE) system. Additional PFC information is being obtained to assist in developing an Excavation Plan once the final MPCA remedy decision is made. Settlement Agreement and Consent Order — 3M and MPCA First Quarter 2009 Progress Report Page 2 of 6 Remedial design activities, as appropriate, continued in order to be in a position to implement a remedy following MPCA final selection. Oakdale The Remedial Design/Response Action Plan for the Site was submitted on February 19, 2009. Design activities consistent with this plan were addressed throughout the reporting period. Operation of the SVE system and vapor phase treatment columns continued on essentially an uninterrupted basis. Significant removal of volatile organic compounds from the targeted soil area has been observed. Operation of the new extraction well network for the southern portion of the site continued on essentially an uninterrupted basis. Information being acquired, including flowrates and chemical composition data, is being utilized to design the groundwater treatment system for the site. Furthermore, experiments have been conducted on the extracted water to evaluate and optimize pretreatment processes that will be required prior to the granular activated carbon treatment to address PFCs. Dialogue in the form of meetings, phone conversations, e -mails and written correspondence has occurred relative to the Remedial Design/Response Action (RD/RA) Plan. Topics addressed include wetlands delineation, site drainage, excavation details, monitoring, waste management plans and the Quality Assurance Project Plan (QAPP). Specifically, these items were reviewed in a meeting on March 19, 2009 attended by 3M, Weston, AECOM and MPCA personnel and in follow -up correspondence dated March 31, 2009 from 3M to the MPCA. Formal meetings related to the future discharge of treated groundwater from the Site were held with Metropolitan Council Environmental Services and the City of Oakdale on February 4, 2009 and February 6, 2009, respectively. Woodbury Following written approval by the MPCA, a temporary soil vapor extraction (SVE) system was installed in the Main Disposal Area. This system commenced operation in amid- February and continues to be monitored for the extraction and removal of volatile organic compounds (VOCs). The Remedial Design/Response Action (RD; RA) Plan for the site was prepared in anticipation of the April 2, 2009 submittal due date. The essential content of this plan was reviewed with MPCA staff in a meeting on March 19, 2009. The analytical work was completed for samples collected December 16 -18, 2008 from the regional wells that were the subject of MPCA's January 9, 2008 letter. A report entitled Washinngtonn County Regional Well Installation and Sampling Results, Cottage Grove and Woodbury, MN, summarizing these results, was submitted to the MPCA on March 10, 2009. Settlement Agreement and Consent Order — 3M and MPCA First Quarter 2009 Progress Report Page 3 of 6 All Sites Site preparation, specifically grading and placement of the base said layer, commenced at the SKB Rosemount Industrial Waste Facility for the designated PFC disposal area. Resnonse.Action (Part VIII I 3M has been engaged in discussions with Washington County personnel concerning possible actions to provide an alternative source of drinking water for the primitive campground area within the Lake Elmo Park Reserve. On March 31, 2009, 3M received from Washington County Park personnel a draft copy of a Request for Proposal to install a new well and associated piping at the park. Review of the draft RFP and subsequent discussions are to follow. The analytical work was completed for samples collected on December 16, 2008 from the newly installed Jordan aquifer monitoring well in the area south of Eagle Point Lake in Lake Elmo, MN. A report entitled Washington County Regional bell Installation and Sampling Results, Lake Bltno, MY, summarizing these results, was submitted to the MPCA on March 19, 2009. Health and Toxicological Studies (Part XIII.C) 3M continued to cooperate with the Minnesota Department of Health (MDII) in providing health and toxicological information relative to PFCs. The process established in May -June of 2007 to share specific updates on various studies as they are underway has continued with 3M providing monthly written summaries to the MDH. For informational purposes, copies of these updates are also provided to the MPCA. Recovery of (Part XXIII) 3M received a request for payment from the MPCA dated January 23, 2009 pertaining to environmental studies as outlined in the Settlement Agreement. Payment in the amount requested was provided to the MPCA via correspondence dated February 11, 2009. Settlement Agreement and Consent Order — 3M and MPCA First Quarter 2009 Progress Report Page 4 of 6 ACTIVITIES UNDERWAY & /OR PLANNED FOR APRIL - JUNE 2009: Remedial Investigations (Part VD and Feasibility Studies (Part V11) Given the interrelatedness of the remedial investigation (RI) work and the feasibility studies (FS), these sections have been combined with the intent of providing a simpler, more straightforward update. Cottage Grove Options to enable treatment and discharge of leachate from the SKB Landfill in the near future, as well as groundwater from the Woodbury and Cottage Grove Sites, continue to be evaluated. 3M will continue to work with the MPCA to accomplish these remedial objectives. Analytical results for D9 area soil samples collected on March 19 -20, 2009 will be finalized. The conventional constituents data will be used to evaluate the potential benefit of installing a temporary SVE system. The additional PFC information will be incorporated into the Excavation Plan, as it is developed. 3M will continue remedial design activities, as appropriate, to be in a position to implement a remedy following MPCA final selection. Oakdale Operation and monitoring of the SVE system will continue. Periodic updates concerning performance will be provided to MPCA staff. Operation and monitoring of the new extraction well network for the southern portion of the site will continue. An application was submitted to Metropolitan Council Bnvironment<al Services on April 29, 2009 to modify the existing discharge permit for the site to reflect the expanded groundwater extraction and treatment system. 3M will continue to work with multiple entities involved in wetlands delineations for the Site. As necessary, potential wetlands impacts will be verified and permits obtained. Woodbury The RD /RA Plan for the site was submitted on April 1, 2009. The temporary SVE system in the Main Disposal Area will continue to be operated and monitored for the removal of VOCs. Sampling of six of the eight regional wells that were the subject of the January 9, 2008 MPCA letter was accomplished December 16 -18, 2008. One of the Woodbury wells, located in the Settlement Agreement and Consent Order — 3M and MPCA First Quarter 2009 Progress Report Page 5 of 6 Prairie du Chien aquifer and operated by the City of Woodbury as an irrigation well, had been shut down for the winter and could not be sampled. In addition, one of the Cottage Grove Prairie du Chien wells did not yield sufficient water to collect a sample. Attempts will be made in the spring of 2009 to resample these two wells. The water level in Gables Lake will be evaluated and, if possible, surface water samples will be collected. All Sites Site preparation and cell construction activities will occur at the SKS Rosemount Industrial Waste Facility for the designated PFC disposal area. This work is scheduled for completion by mid -2009. Response Action (Part. VIII) 3M will continue to work with Washington County personnel to provide an alternative source of drinking water for the primitive campground area within the Lake Elmo Park Reserve. 3M met with park personnel on April 10 2009 to review the draft Request for Proposal that had been provided to 3M for input. Funding and other details will be addressed shortly. Installation of a new well is anticipated by mid -2009. Information Sharing Process (Part XIILI3) Pending MPCA's response to 3M's letter dated April 14, 2008 on this topic, 3M is available to meet with MPCA personnel on an "as- needed" basis to discuss specific items relative to information - sharing. Irrespective of the formal determination of completeness relative to this part, based on discussions with MPCA personnel, 3M and the MPCA have agreed to continue regular meetings to share new developments and information that could be helpful in understanding PFC issues in Minnesota. Flealth and Toxicological Studies (Part XIILC) 3M will continue to share health and toxicological information on perfluorochemicals with MDH as it becomes available. Monthly srmunary reports as previously described will continue to be provided. Settlement Agreement and Consent Order — 3M and MPCA First Quarter 2009 Progress Report Page 6 of 6 Recovery f Expenses (Part XXIII) 3M. received separate reimbursement requests from the MPCA dated February 10, 2009 and April 7, 2009. Appropriate payments relative to these requests will be submitted during the April -June 2009 timeframe. Settlement Agreement and Consent Order 3M and MPCA, May 22, 2007 QUARTERLY PROGRESS REPORT 99 April l — June 30, 2009 On May 22, 2007, 3M and the Minnesota Pollution Control Agency (MPCA) entered into a Settlement Agreement and Consent Order (Settlement Agreement) for the investigation and assessment of perfluorochemicals (PFCs) at sites in Washington County and for the execution of certain other related matters. This report is provided to fulfill the requirement outlined in Part XIILA of the Settlement Agreement. REPORTING PERIOD: April I to June 30, 2009 ACTIVITIES COMPLETED: Remedial Investigations (Part VI) and Feasibility Studies (Part VIII Given the interrelatedness of the remedial investigation (RI) work and the feasibility studies (FS), these sections have been combined with the intent of providing a simpler, more straightforward update. Cottage Grove Analytical results for D9 area soil samples collected on March 19 -20, 2009 were finalized. Based on the of conventional constituents data, it was determined that installation of a temporary soil vapor extraction (SVE) system was not warranted. The additional PPC information will be incorporated into the Excavation Plan, as it is developed following issuance of the final MPCA remedy decision. 3M has been engaged in discussions with agency personnel concerning management of leachate to be generated at the SKB Landfill. At the agency's request, a draft Leachate Management Plan . was recently prepared and submitted for review. This plan was discussed in a meeting attended by 3M and MPCA personnel on June 12, 2009. As an outcome from the meeting, 3M revised . the plan and submitted it for approval. Remedial design activities, as appropriate, continued in order to be in a position to implement a remedy following MPCA final selection (anticipated in early August). Settlement Agreement and Consent Order — 3M and MPCA Second Quarter 2009 Progress Report Page 2 of 7 Oakdale Operation, maintenance and monitoring of the temporary soil vapor extraction (SVE) system in the area to be excavated north of Highway 5 have continued. Operation of the new extraction well network for the southern portion of the site continued on essentially an uninterrupted basis. On a related note, a revised Industrial Discharge Permit dated May 21, 2009 was received from Metropolitan Council Environmental Services (MCES). This updated permit allows for an increased discharge rate of extracted groundwater and requires the following: • Monthly monitoring and reporting for PFCs (already being done). • Submittal of the final groundwater treatment design plans prior to construction. • Notification if PPC concentrations in the effluent increase significantly prior to installation of treatment. • Operation of the pretreatment system by April 1, 2010 (consistent with the site RD/RA Plan). The engineering design for the groundwater treatment system continued to move forward. System review and approval by city officials have occurred and key pieces of equipment have been ordered. 3M has worked with multiple entities to ensure that wetlands- at the Site are delineated and addressed. All approvals have been obtained such that remediation activities can be completed. In a letter dated April 24, 2009, the MPCA approved the RD /RA Plan that 3M had submitted for the site on February 17, 2009. The Plan was approved with modifications, including those documented in a letter from 3M to the agency dated March 31, 2009. As follow -up to these items, in two separate letters, both dated May 28, 2009, 3M provided the following: « Revised pages to the RD /RA Plan (including within it the Construction Sampling Plan and the Soil Transportation Plan) outlining additional provisions 3M will include to address the potential for encountering unexpected material during excavation activities. ® A revised Quality Assurance Project Plan (Attachment 3 to the RDIRA Plan). Woodbury The Remedial Design/Response Action (RD /RA) Plan for the site was submitted on'April 2, 2009. Certain issues raised by the RD/RA Plan were discussed in a site visit attended by 3M, MPCA, AECOM (an agency- hired contractor) and Weston Solutions personnel on May 9, 2009. Settlement Agreement and Consent Order— 3M and MPCA Second Quarter 2009 Progress Report Page 3 o£7 In addition, 3M received comments concerning the Plan from MPCA staff and from AECOM on May 11, 14 and 15, 2009, Subsequently, 3M, MPCA, AECOM and Weston met on May 21, 2009 to discuss comments and details pertaining to the RD/RA Plan, In correspondence dated May 28, 2009, 3M provided the MPCA an extensive response to the comments and discussions on the RD /RA Plan. The MPCA approved the RD /RA Plan, with modifications, in a letter dated June 1, 2009. Operation, maintenance and monitoring of the temporary soil vapor extraction (SVE) system in the Main Disposal Area have continued. This system has been designed and installed to accomplish removal of VOCs from soils at the site. Based on operational data indicating a decreasing trend in soil vapor VOC concentrations and hazardous air pollutant (HAP) emissions below regulatory thresholds, 3M submitted a request to the MPCA on June 5, 2009 to discontinue use of the vapor phase granular activated carbon (GAC) treatment of the SVE exhaust. This request was granted by agency staff in an e-mail dated .Tune 9 2009. Gables Lake, a small, shallow water body at the site was sampled on May 5, 2009, per MPCA's request. Surface water samples were collected and submitted for PFC analyses. Subcontractor bid specification packages were prepared for distribution to prospective contractors for soil excavation in the Main Disposal Area. In situ soil profile sampling was performed at the Main Disposal Area on June 15 and 16, 2009 as defined in the Construction Sampling Plan (CSP). The CSP was provided as an attachment to the MPCA- approved RD /RA Plan. Sampling of six of the eight regional wells that were the subject of the January 9, 2008 MPCA letter was accomplished December 16 -18, 2008. These results were conveyed to the MPCA in a report dated March 2009. One of the Woodbury wells, located in the Prairie du Chien aquifer And operated by the City of Woodbury as an irrigation well, had been shut down for the winter and could not be sampled. In addition one of the Cottage Grove Prairie du Chien wells did not yield sufficient water to collect a sample. A second attempt to sample the two remaining wells was made on June 5, 2009. A sample was successfully collected from the Woodbury well but the Cottage Grove well remained dry. The single. sample was submitted for PFC analyses. All Sites Site preparation and cell construction activities were completed for the designated PFC disposal area within the SKB Rosemount Industrial Waste Facility. In a letter dated June 18, 2009, the MPCA approved the construction documentation report for this expansion. Accordingly, the site is in a position to begin receiving approved PFC - containing wastes. Settlement Agreement and Consent Order — 3M and MPCA Second Quarter 2009 Progress Report Page 4 of 7 Response Action (Part VIII) 3M has been engaged in discussions with Washington County personnel concerning possible actions to provide an alternative source of drinking water for the primitive campground area within the Lake Elmo Park. Reserve. On March 31, 2009, 3M received. from Washington County Park personnel a draft copy of a Request for Proposal W , P) to install a new well and associated piping at the park. 3M met with park personnel on April 10, 2009 to review the draft RFP that had been provided to 3M for input. Once the RFP was finalized by the county, it was sent to qualified bidders. In June and early July 2009, county personnel received three independent bids from state - approved contractors to complete this project. The county has been verifying and reviewing the bids received. Health and Toxicological Studies (Part XIII.C} 3M continued to cooperate With the Minnesota Department of Health (MDH) in providing health and toxicological information relative to PFCs. The process established in May -June of 2007 to share specific updates on various studies as they are underway has continued with 3M providing monthly w7itten summaries to the MDH. For informational purposes, copies of these updates are also provided to the MPCA. Recovery of Expenses (Part XXIII) In a. letter dated February 10, 2009, the MPCA requested reimbursement for oversight costs related to the three Sites tinder the Settlement Agreement. 3M submitted payment in the amount of $314,813.70 on. April 13, 2009 towards these expenses. In the same submittal, a question was raised concerning Minnesota Department of Health (MDH) laboratory expenses that had been listed in the February 10 request. Following agency staff review of this matter, in a letter dated June 30, 2009, the MPCA clarified the reimbursement request pertaining to this specific activity. Payment of the clarified amount will be submitted by July 31, 2009, as requested. In Part XXXIILD of the Settlement Agreement, 3M agreed to provide to MPCA a grant in an amount up to five million dollars for expenses incurred for the purpose of investigating and assessing the presence of PFCs in the environment. In a letter dated April 7, 2009, the MPCA requested payment in the amount of $496,693 towards this commitment. 3M submitted payment in the requested amount via correspondence dated May 14, 2009. Settlement Agreement and Consent Order — 3M and MPCA Second Quarter 2009 Progress Report Page 5 of 7 .ACTIVITIES UNDERWAY WOR PLANNED FOR JULY - SEPTEMBER 2009: ,Remedial Inv estigations (Part VII and Feasibility St udies (Part VII) Given the interrelatedness of the remedial investigation (RI) work and the feasibility studies (PS) these sections have been combined with the intent of providing a simpler, more straightforward update. Cottage Grove 3M will finalize a Leachate Management. Plan with the MPCA. This plan will address the handling, treatment and sampling of Leachate from the SKB facility at 3M Cottage Grove's wastewater treatment plant. 3M will continue remedial design activities, as appropriate, to be in a position to implement a remedy following MPCA final selection. Oakdale Operation and monitoring of the SVE system will continue. Periodic updates concerning performance will be provided to MPCA staff. Operation and monitoring of the new extraction well network for the southern portion of the site will continue. In addition, the engineering project to install a groundwater treatment system will continue with a goal of having it on -line by April 1, 2010. A contractor wi1l be selected to perform excavation activities at the site. These activities are anticipated to commence by late fall 2009. Clean fill materials to be brought to the site will be sampled and analyzed according to the Construction Sampling Plan previously submitted to the MPCA as part of the RD/RA Plan. Woodbury The temporary SVE system in the Main Disposal Area will continue to be operated, maintained and monitored for the removal of VOCs. A letter will be prepared and submitted to the MPCA requesting an agency determination on the regulatory status of soils pending excavation. The request will summarize recent results of in situ soil profile sampling from areas to be excavated at the site. (This correspondence was submitted on July 15, 2009.) A contractor will be selected to perform excavation activities in the Main Disposal Area. These activities are anticipated to commence in an August - September 2009 timeframe. Settlement Agreement and Consent Order— 3M and MPCA Second Quarter 2009 Progress Report Page 6 of 7 Clean fill materials to be brought to the site will be sampled and analyzed according to the Construction Sampling Plan previously submitted to the MPCA as part of the RD/RA Plan. SVE wells located within and near the Main Disposal Area that are no longer needed will be abandoned in order to facilitate pending excavation activities. A hydraulic evaluation of the Woodbury barrier wells will be started to determine drawdown effects and the extent of the groundwater capture zone at various pumping rates. Final analytical results will be received and, in turn, conveyed to the MPCA for the regional Woodbury Prairie du Chien well that was sampled on June 5, 2009. PFC analytical work for surface water samples collected from Gables Lake will be completed and submitted to the MPCA. Response Action (Part VIII) 3M will continue to work with Washington County personnel to provide an alternative source of drinking water for the primitive campground area within the Lake Elmo Park Reserve. County personnel are currently reviewing three bids recently received in response to their Request for Proposal to install a new well. Once the exact project scope is determined, 3M envisions making a grant to the county to address the project costs. Installation of a new well is anticipated in 2009. Information Sharing Process (Part XIII.B) Pending MPCA's response to 3M's letter dated April 14, 2008 on this topic, 3M is available to meet with MPCA personnel on an "as- needed" basis to discuss specific items relative to information- sharing. Irrespective of the formal determination of completeness relative to this part, based on discussions with MPCA personnel, 3M and the MPCA have agreed to continue regular meetings to share new developments and information that could be helpful in understanding PFC issues in Mitmesota. Health and Toxicoloeical Studies (Part XIII.C) 3M will continue to share health and toxicological information on perfluorochemicals with MDH as it becomes available. Monthly summary reports as previously described will continue to be provided. Settlement Agreement and Consent Order -3M and MPCA Second Quarter 2009 Progress Report Page 7 of 7 Recovery of Expenses (Part XXIII) 3M received separate reimbursement requests from the MPCA dated June 30, 2009 and July 17, 2009. 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M1 V r V M c0 tU c0 ro r m V N N o� V m (O o ro V ro N ro V <`0 GO ro C r W RY. r r d' N V N M1 � M1 O W h d' M1 M1 M 0 0 0 0 0 0 Z Z Z Z Z Z . 0 . . 0 0 . . 0 0 . . 0 0 . . 0 0 . . . 0 0 0 . . 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 0 e0 N O O O O O O O O O O O p 0 0 O O C C G G O p p 1� H r O O N N O N N N N N O O D W h O O 0 0 0 0 0 0 0 0 0 0 0 0 0 0 OJ r. O h N h W M of I� W O p 0 0 0 0 0 0 0 0 0 0 0 0 N N N N N N N N N N N N N N N N � Z Z y Z Z z Z M U a a a a a o K CC CC CL CC K 0 i a"i w a w � V U U U U U Q Q Q Q Q Q N N N N N N h O W O) N N N N N N M M OJ OJ OJ � OJ CO N O N O N O itJ cp d' V M O> m h h V to � to M to to N N � STATE OF MINNESOTA MINNESOTA POLLUTION CONTROL AGENCY In the matter of Releases and Discharges of Perfluorochemicals At and From Sites in Washington County, Minnesota, and Certain Related Matters. SETTLEMENT AGREEMENT AND CONSENT ORDER Pursuant to the Minnesota Environmental Response and Liability Act, Minn. Star. §§ 115B.01 to 115B.20, the Water Pollution Control Act, Minn. Star. ch. 115, and Minn. Stat. ch. 116. Based on the information available to the parties on the effective date of this SETTLEMENT AGREEMENT and CONSENT ORDER, and without trial or adjudication of any issues of fact or law, the parties hereto agree and it is hereby ordered as follows: L Jurisdiction In entering this SETTLEMENT AGREEMENT and issuing this CONSENT ORDER the Minnesota Pollution Control Agency (MPCA) is acting pursuant to the Minnesota Environmental Response and Liability Act, Minn. Star. §§ 115B.01 to 115B.20 (MERLA), and Minn. Star. chs. 115 and 116, for the purpose of providing for remedial investigations and response actions to address certain discharges to waters of the State and releases or threatened releases to the environment in order to minimize or abate pollution of waters of the State and to protect public health and welfare and the environment. A. The, parties to this Agreement have disputed and continue to dispute the jurisdiction of MPCA under MERLA with respect to releases and threatened releases of PFCs at the 3M Cottage Grove Site, the 3M Oakdale Disposal Site and the 3M Woodbury Disposal Site. MPCA asserts that all jurisdictional prerequisites necessary to act under MERLA with respect to releases and threatened releases of certain PFCs at the 3M Cottage Grove Site, the 3M Oakdale Disposal Site and the 3M Woodbury Disposal Site have been met. 3M disagrees with MPCA's assertion and specifically denies that releases of PFCs at these Sites constitute hazardous substances or pollutants or contaminants as those terms are defined in MERLA. 3M further affirmatively asserts that releases and threatened releases of PFCS at these Sites do not constitute hazardous substances or pollutants or contaminants as defined in MERLA. B. Notwithstanding the disagreement of the parties as stated in Paragraph A, for purposes of this Agreement from and after its effective date, and for no other purpose whatsoever, 3M consents to the issuance of this Consent Order, and to the application of MERLA to the interpretation, performance and enforcement of this Agreement consistent with the terms and conditions herein. 3M specifically agrees to undertake all actions required of it by the terms and conditions of this Agreement within the timeframes specified herein. C. In entering this Agreement, MPCA and 3M are settling a disputed matter, and do not waive or compromise their respective legal arguments on MERLA jurisdiction. 3M expressly retains the right to contest the applicability of MERLA to releases and threatened releases of PFCs at these Sites in a proceeding by MPCA to issue a Request For Response Action under MERLA for any of the Sites and in any other proceeding except a proceeding to implement or enforce this Agreement. Nothing in this Agreement shall be construed as an admission by 3M. D. Nothing in this Paragraph shall preclude 3M from seeking judicial review of a Commissioner's order as provided in Part X, Paragraph G or H, with respect to whether response 2 actions required or performed by the Commissioner are reasonable and necessary to protect public health and welfare and the environment. In an action to enforce Part XXIII (Recovery of Expenses), nothing in this Paragraph shall relieve the MPCA of the burden to show that the costs incurred are reasonable and necessary as provided in Part XXHL Paragraph F. II., Parties This Agreement shall apply to and be binding upon the following parties: A. 3M Company; and B. the Minnesota Pollution Control Agency. Unless specified otherwise in this Agreement, where this Agreement identifies actions to be taken by the MPCA, the action may be taken by the Commissioner or by a person delegated by the Commissioner to take such action. III. Statement of Facts For purposes of this Agreement, the following constitutes a summary of the facts upon which this Agreement is based. None of the facts related herein shall be considered admissions by either party with respect to any person not a party to this Agreement or to any proceeding other than a proceeding to implement or enforce this Agreement. 3M reserves the right to dispute any fact stated herein in a proceeding other than a proceeding to enforce this Agreement, including in any proceeding for the issuance of a Request For Response Action for one or more of the Sites. A. Facts Related To The 3M Cottage Grove Site. 9 1. The 3M Cottage Grove Site is located in the City of Cottage Grove, Washington County, Minnesota. A map of the 3M Cottage Grove Site is attached as Attachment 1. 2. The Site was listed on the State's Superfund Permanent List of Priorities (PLP) in October 1984. 3. On January 22, 1985, the MPCA issued a RFRA to 3M to address VOC contamination as a result of disposal of hazardous substances in disposal pits on the Site. 4. On May 30, 1985, the MPCA and 3M entered into a Consent Order which required 3M to investigate the releases of VOCs and implement appropriate response actions. The terms of the 1985 RFRA and Consent Order do not address the investigation and implementation of response actions concerning the release of PFOA or PFOS at or from the 3M Cottage Grove Site, and the Consent Order does not affect MPCA's authority to enter into this Agreement. 5. In February 2002, 3M informed the MPCA staff that PFOA and PFOS had been detected in ground -water production wells at the 3M Cottage Grove Site. Subsequent sampling requested by MPCA staff confirmed ground -water contamination by PFOA and PFOS near one of the on -site disposal areas on February 13, 2003. MPCA staff subsequently requested that 3M conduct a facility -wide assessment to determine extent and magnitude of potential releases of PFOA and PFOS to the environment. 6. In December 2004, 3M submitted a facility -wide work plan to assess releases of PFCs at the 3M Cottage Grove facility. This work plan was approved by the MPCA staff in January 2005. 3M implemented this work plan in 2005 and submitted reports to MPCA which documented releases of PFOA and PFOS to ground water, soil, surface water, and sediments at 0 the 3M Cottage Grove facility and in the adjacent Mississippi River. In June 2006, the MPCA staff requested that 3M conduct a second phase investigation to determine the extent and magnitude of releases of PFOA and PFOS to the environment at the 3M Cottage Grove Site, and to evaluate appropriate response actions to address the releases. This request included the requirement that 3M was to expand the sample analyte list for additional PFCs. This expanded list included PFBA and was to be used for all future investigations at the 3M Cottage Grove Site, the 3M Oakdale Disposal Site and 3M Woodbury Disposal Site. 7. In August, 2006, 3M submitted a phase 11 work plan in response to MPCA staffs request. The work plan was approved by MPCA staff in September 2006. Sampling activities have been completed for this second phase. 8. MPCA staff has requested reimbursement of agency oversight costs incurred for 2004 through 2006 related to the PFC investigations at the 3M Cottage Grove Site and 3M has reimbursed the MPCA for these oversight costs through the last annual request for reimbursement. B. Facts Related To The 3M Oakdale Disposal Site. 1. The 3M Oakdale Disposal Site is in the City of Oakdale, Washington County, Minnesota. A map of the Site is attached to this Agreement as Attachment 2. 2. The 3M Oakdale Disposal Site was listed on the PLP in October 1984. The 3M Oakdale Disposal Site was also listed on the Federal National Priorities List in September 1983. 3. On July 26, 1983, the MPCA and 3M entered into a Response Order by Consent (Consent Order) to investigate and implement response actions at the 3M Oakdale Disposal Site to address releases of VOCs at the Site. This Consent Order was amended on May 22, 1984. The USEPA was also a party to the 1983 Consent Order. The terms of the 1983 Consent Order 5 do not address the investigation and implementation of response actions concerning the release of PFOA or PFOS at or from the 3M Oakdale Disposal Site, and the Consent Order does not affect MPCA's authority to enter into this Agreement. 4. In July, 2004, the MPCA staff requested 3M to collect ground water samples from wells at the 3M Oakdale Disposal Site to be analyzed for PFOA and PFOS. In September, 2004, 3M informed the MPCA that PFOA and PFOS had been detected in on -site ground water wells at the 3M Oakdale Disposal Site. 5. MPCA staff subsequently requested 3M to develop a work plan and conduct an investigation to determine ground water impacts from PFOA and PFOS at the 3M Oakdale Disposal Site. This work plan was submitted by 3M and approved by the MPCA in January 2005. 3M implemented this work plan, and submitted a report to MPCA which documented releases of PFOA and PFOS to ground water and surface water at the 3M Oakdale Disposal Site. 6. Based on the information gathered during this 2005 investigation, in September 2005, the MPCA staff requested 3M conduct a supplemental investigation to determine the extent and magnitude of releases of PFOA and PFOS to the environment at the 3M Oakdale Disposal Site. 3M completed this supplemental investigation in September 2006. To assist in determining appropriate response actions to address the releases, 3M proposed additional investigative work to fill in data gaps and the MPCA subsequently approved of this additional work in December 2006. This investigation utilized the expanded PFC sample analyte list as requested by MPCA, which included PFBA. Sampling activities have been completed for this supplemental phase. 7. 3M has reimbursed the MPCA for its oversight costs related to the investigations at the 3M Oakdale Disposal Site. 8. In 2005, 3M entered into an agreement with the City of Oakdale to install a carbon treatment system to reduce the levels of PFOA and PFOS, which had been detected in municipal drinking water wells, to below Health Based Values for PFOA and PFOS set by the Minnesota Department of Health. C. Facts Related To The 3M Woodbury Disposal Site. 1. The 3M Woodbury Disposal Site lies on the border between the cities of Cottage Grove and Woodbury in Washington County, and is located in the area encompassed by Woodbury Drive (County Road 19) and Cottage Grove Drive. A map of the 3M Woodbury Disposal Site is attached to this Agreement as Attachment 3. 2. The 3M Woodbury Disposal Site is not listed on the PLP, and the MPCA has not entered any settlement, Consent Order, or other agreement with 3M or any other party with respect to the 3M Woodbury Disposal Site. 3. A report entitled "3M Woodbury, Minnesota Site History" dated August 1992 estimated that 3M disposed of approximately 200,000 yards of scrap wastes, including waste adhesive, rolls of film, rags, resins and off - specification materials, approximately 400,000 gallons of liquid waste solvents (of which 200,000 gallons was isopropyl ether), and 18,000 yards of wet scrap, at the 3M Woodbury Disposal Site. 4. 3M installed four "barrier" pumping wells at the 3M Woodbury Disposal Site between 1967 and 1973 and has operated them continuously since installation. The ground water withdrawn at the 3M Woodbury Disposal Site is conveyed in underground piping to the 3M Cottage Grove facility for use as non - contact process water at the facility and is ultimately discharged to the Mississippi River without treatment under a National Pollutant Discharge Elimination System (NPDES) Permit. 7 5. In 1992, 3M entered the MPCA Voluntary Investigation and Cleanup (VIC Program). Under the VIC program, 3M conducted response actions including installation of a soil cap over the former disposal area and ground -water monitoring. In addition, 3M recorded a Declaration of Restrictions and Covenants on the property which requires the approval of the MPCA Commissioner to discontinue the barrier well system or to conduct activities that disturb the soil. 6. In July, 2004, 3M reported to MPCA that pump out water from the 3M Woodbury Disposal Site contained PFCs including PFOA and PFOS. 7. In early 2005, 3M sampled each of the four barrier wells at the 3M Woodbury Disposal Site and the combined discharge from the barrier wells. With the exception of barrier well B -2, all sampling locations detected PFOA and PFOS. In June 2005, the MDH sampled 15 residential wells surrounding the 3M Woodbury Disposal Site for PFOA and PFOS, and neither chemical was detected. In December 2006, barrier and monitoring wells at the 3M Woodbury Disposal Site were sampled for seven PFCs including PFBA. PFBA results ranged from 0.476 to 118 parts per billion (ppb) of PFBA. 8. In 2006, municipal and private drinking water wells in southern Washington County downgradient from the 3M Woodbury Disposal Site were sampled for PFBA. The results showed that PFBA was present in municipal wells in Cottage Grove, Newport and St. Paul Park, and in private wells in that vicinity at concentrations up to 5 ppb. 9. In a letter dated February 1, 2007, the MPCA requested that 3M submit a comprehensive Response Action Plan for the 3M Woodbury Disposal Site by March 1, 2007, that addresses the following: 8 a. Evaluate the current barrier well system's ability to capture all PFC's including PFOA and PFOS and enhance the system as necessary. b. Install a network of sentinel monitoring wells between the 3M Woodbury Disposal Site a nd adjacent residences. Reassess the feasibility of reducing the volume of PFC- contaminated wastes C. including PFOA and PFOS remaining in the Northeast Disposal Area of the 3M Woodbury Disposal Site. d. Determine if the effluent discharge pipeline between the 3M Woodbury Disposal Site and the 3M Cottage Grove facility is leaking. e „ Develop a monitoring plan to conduct quarterly monitoring of PFCs including PFOA and PFOS in residential wells and sentinel wells that surround the 3M Woodbury Disposal Site. MPCA has conditionally approved Site Reports for the 3M Woodbury Disposal Site which were submitted to MPCA by 3M in a letter dated March 20, 2007. These reports address barrier well capture zone evaluation, sentinel monitoring well installation, assessment of the former northeast disposal area, conveyance line assessment, monitoring plan and reporting and schedule. D. Other Facts Leading To This Agreement. 1. On November 20, 2002, in response to a request from MPCA, Minnesota Department of Health (mDH) established Interim Soil Reference Values (SRVs) for PFOA and PFOS in soil, and Health Based Values for Groundwater (HBVs) for PFOA and PFOS. Residential SRVs were,set at 30 parts per million (ppm) for PFOA and 6 ppm for PFOS. The 2002 HBVs were set at 7 ppb for PFOA and 1 ppb for PFOS. On February 26, 2007, MDH established more stringent HBVs for PFOA and PFOS. The current MDH FiBV for drinking water for PFOA is 0.5 ppb and for PFOS is 0.3 ppb. 2. On April 24, 2007, the MPCA Citizens Board considered the issuance of a Request For Response Action (RFRA) to 3M under MERLA for releases and threatened releases of PFCs at and from the 3M Cottage Grove Site, the 3M Oakdale Disposal Site, and the 3M Woodbury Disposal Site. The Board voted to postpone consideration of the RFRAs and directed the Commissioner to negotiate a consent order to address response actions at the three sites and other related matters with 3M, and to make a recommendation to the Board regarding its e of the RFRAs at a subsequent Board meeting. approval of such a Consent Order or issuanc This Agreement is the result of those negotiations. IV. Definitions A. Unless otherwise explicitly stated, the definitions provided in Minn. Stat. § 115B.02 shall control the meaning of the terms used in this Agreement. B. For the purpose of this Agreement: 1, "MPCA Commissioner" or "Commissioner" means the Commissioner of the Minnesota Pollution Control Agency or a person exercising authority delegated by the Commissioner. 2. "Day" means calendar day, provided that when a deadline for an action or submittal under this Agreement falls on a Saturday, Sunday or legal holiday, the action or submittal is timely if taken or received by the first business day after the deadline. 10 3. "3M Cottage Grove Site" means the site formerly known as the 3M Chemolite Disposal Site in the City of Cottage Grove, Washington County, Minnesota, and shown in the map attached to this Agreement as Attachment 1. 4. "3M Oakdale Site" means the 3M Oakdale Disposal Site in the City of Oakdale, Washington County, Minnesota, and shown in the map attached to this Agreement as Attachment 2. 5. "3M Woodbury Site" means the 3M Woodbury Disposal Site in the City of Woodbury, Washington County, Minnesota, and shown in the map attached to this Agreement as Attachment 3. 6. "Sites" means the 3M Cottage Grove Site, the 3M Oakdale Site and the 3M Woodbury Site. 7. "Each Site" refers individually to the 3M Cottage Grove Site, the 3M Oakdale Site and the 3M Woodbury Site. 8. "Perfluorochemical" or "PFC" means any chemical in a family of synthetic chemicals manufactured by 3M which is a perfluorinated (fully fluorinated) carbon chain consisting of I to 16 carbon atoms with a functional end group consisting of at least one double bond. 9. "PFOA" or "perfuorooctonoate" refers to an eight- carbon caboxylate perfluorochemical, including the chemicals identified by Chemical Abstract Service (CAS) numbers in the document entitled "Data For Derivation Of Ground Water Health Based Value (HBV)," which is attached to the February 26, 2007 MDH Memorandum establishing an H13V for PFOA. 11 10. "PFOS" or "perfluorooctane sulfonate" means an eight- carbon sulfonate perfluorochemical, including the chemicals identified by CAS numbers in the document entitled "Data For Derivation Of Ground Water Health Based Value (HBV), " which is attached to the February 26, 2007 MDH Memorandum establishing an HBV for PFOS. "PFBA" or "PerfluorobutOnoate" means a four - carbon caboxylate 11. perfluorochernical. 12 "Health Based Value for Groundwater" or "HBV" means the concentration of a substance or chemical found in ground water which poses little or no risk to health even when consumed daily as drinking water over a lifetime. HBVs are developed by MDH and used as interim advice for human consumption of drinking water in which a substance or chemical has been detected. 13. "Health Risk Limit" or "IM" means a concentration of a groundwater contaminant, or a mixture of contaminants, that is considered safe when consumed daily in drinking water over a lifetime. An HRL is adopted by MDH by rule under Minn. Stat. § 103H.201. 14. "Volatile organic compounds" or "VOCs" means organic chemicals that have a high vapor pressure and easily form vapors at normal temperature and pressure including organic solvents. 15. "Washington County Landfill" means a closed, formerly MPCA- permitted mixed municipal waste landfill located in the City of Lake Elmo, in Washington County, Minnesota, which is a "qualified facility" as that term is used in Minn. Stat. § 115B.39. 12 0 Scope of Agreement A. Obligations of 3M for the Sites. 3M agrees to perform the following response actions to address the releases and threatened release of PFCs at each Site, and the release and threatened release of VOCs for the 3M Woodbury Disposal Site, in accordance with the terms and conditions of this Agreement: I. Design and implement a Remedial Investigation (RI) as described in Part VI of this Agreement and the appropriate Exhibit referenced in Paragraph B of this Part V; 2. Conduct a Feasibility Study (FS) as described in Part VII of this Agreement and the appropriate Exhibit referenced in Paragraph B of this Part V; 3. Develop a Response Action Plan (RAP) (to include a detailed design for response action) and implement the MPCA- selected Response Actions (RAs) as described in Part VIII of this Agreement and the appropriate Exhibit referenced in Paragraph B of this Part V; and 4. Reimburse the MPCAs costs as provided in Part XXIII of this Agreement. B. Exhibits. The Exhibits setting forth the response actions for each Site are as follows: 1. 3M Cottage Grove Site a. Exhibit A-- Remedial Investigation/ Feasibility Study; b. Exhibit B-- Remedial Design/Response Action Plan 2. 3M Oakdale Site a. Exhibit C-- Remedial Investigation/ Feasibility Study; b. Exhibit D-- Remedial Design/Response Action Plan 13 3. 3M Woodbury Site a. Exhibit E-- Remedial Investigation/ Feasibility Study; b. Exhibit F -- Remedial Design/Response Action Plan. Each of Exhibits A to F is appended to and is an integral and enforceable part of this Agreement. In the event of any ambiguity or inconsistency between Parts VI to VIII and the Exhibits to this Agreement, the Exhibits shall govern. C. Releases of PFCs Included Within Scope of Parts VI to VIII. It is understood and agreed by the Parties that, as of the effective date of this Agreement, the releases and threatened releases of PFCs to be addressed at each Site pursuant to Parts VI to VIII of this Agreement are releases and threatened releases of PFOA and PFOS. The parties further agree that, at such future time as the MDH adopts or issues an HRL or an HBV for purposes of advising the public concerning the safety of drinking water supplies with respect to any PFC other than PFOA and PFOS, including PFBA, the releases and threatened releases to be addressed pursuant to Parts VI to VIII of this Agreement shall include releases and threatened releases of such additional PFC for which an HRL or HBV has been issued and exceeded. D. Other Obligations of 3M. 3M agrees to: I. Provide information as required in Part XIII.B. of this Agreement. 2. Cooperate with MPCA and MDH in developing health and toxicological studies and data needed by MDH to develop HBVs and HRLs for PFCs as provided in Part XIII.0 of this Agreement. 3. Take actions with respect to discharges of PFCs other than those described in Part V.C. into waters of the State as provided in this Part V.E. 14 4. Perform the obligations related to the Washington County Landfill as provided in this Part V.F. E. Releases of Other PFCs. In addition to the requirements in Part V.C., if a PFC other than PFOA and PFOS, including PFBA, is detected in a release or threatened release from any of the Sites and the source of the other PFC is not effectively controlled by actions under Parts VI to VIII, 3M shall take reasonable and necessary investigative action as requested by the Commissioner to determine the scope and extent of any release or threatened release of such PFC from the affected Site or Sites. If investigation of the release or threatened release indicates that there is an ongoing discharge of the PFC into the waters of the state, 3M shall take such additional reasonable and necessary response action as requested by the Commissioner to evaluate and implement actions to control, minimize or abate the source of the discharge. The Commissioner shall set a reasonable schedule for submittals and actions under this Part V.E. F. Washington County Landfill. Releases and threatened releases of PFCs have been identified and alternative remedies are currently being evaluated by the MPCA at the Washington County Landfill under the Minnesota Landfill Cleanup Act, Minn. Stat. § 11513.39 to 11513.445. In the early 1970s, 3M disposed of wastes containing PFCs at the Washington County Landfill, which also received non -3M industrial waste and municipal waste. The State took over long -term operation and maintenance at the site. 3M has cooperated with the State in the implementation of the Landfill Cleanup Act. Investigations of releases of PFCs at the 3M Oakdale Disposal Site and at the Washington County Landfill indicate that there is a commingling of ground water containing PFCs from the two sites. 15 3M agrees to provide technical resources and to transfer any technology knowledge, including any proprietary process, to the MPCA to assist in identifying possible alternative remedial approaches to the current operation and maintenance program at the Washington County Landfill. In addition, 3M agrees to provide to the MPCA a grant of up to Eight Million Dollars ($8,000,000) for the purpose of implementing remedial actions at the Washington County Landfill selected by the MPCA. This grant is intended to provide for the incremental cost of the remedial measures attributable to the releases and threatened releases of PFCs. For purposes of this Agreement, the cost of implementing remedial actions includes the cost of design, construction, operation and maintenance of the actions. 3M agrees to pay Five Million Dollars ($5,000,000) of this grant to the MPCA within 30 days after receipt of written notice from the MPCA that the agency has selected remedial actions which MPCA intends to implement at the Washington County Landfill. To the extent that the cost of implementing MPCA's selected remedial actions for the Washington County Landfill exceeds $5,000,000, 3M agrees to pay 50 percent of that portion of the cost which exceeds $5,000,000, up to an additional amount of $3,000,000. In no event shall the total amount of the grant which 3M is obligated to make under this Paragraph F exceed $8,000,000. Subject to the limitations stated in this Paragraph F, 3M agrees to pay additional amounts for costs exceeding $5,000,000 within 30 days of written notice from MPCA that the agency has incurred obligations exceeding $5,000,000 under one or more contracts entered into by the agency for the implementation of remedial actions for the Washington County Landfill. 3M agrees not to seek reimbursement, indemnification or recovery of its grant or any portion thereof made under this Part V.F whether by a contribution action or by making any insurance claim against an insurer that has settled the liability of its policyholders, including 3M, ILO for the Washington County Landfill with the State of Minnesota under the Landfill Cleanup Act, as provided in the release given to that insurer under the Landfill Cleanup Act. VI. Remedial Investi ag tion 3M shall design, propose, initiate, complete and report upon an RI of each Site in accordance with the requirements and time schedules set forth in the appropriate Exhibit referenced in Part V.B. of this Agreement. The purpose of the RI is to identify the source and extent of the releases or threatened releases of PFCs at and from each Site, and VOCs from the 3M Woodbury Site. VII. Feasibility Study 3M shall propose, initiate, complete, and report upon an FS for each Site in accordance with the requirements and time schedules set forth in the appropriate Exhibit referenced in Part V.B. of this Agreement. The purpose of the FS is to identify and evaluate alternative actions for response to the release or threatened release of PFCs at and from each Site, and VOCs from the 3M Woodbury Site, as identified through the RI conducted pursuant to Part VI of this Agreement. VIll. Response Action Plan and Response Action Inllementation A. Following completion of the RI and the FS, and selection of RAs by MPCA, 3M shall design and propose a RAP and implement selected RAs for each Site in accordance with the requirements and time schedules set forth in the appropriate Exhibit referenced in Part V.B. of this Agreement. The purpose of the RAP is to provide a detailed design for the 17 implementation of MPCA- selected RAs. The purpose of implementing the MPCA- selected RAs is to prevent, minimize or eliminate the release or threatened release of PFCs at and from each Site, and VOCs from the 3M Woodbury Site, in order to protect public health and welfare and the environment. B. 3M's response action obligations under this Part VIII include all response actions, including construction, installation, replacement, and operation and maintenance, that are reasonable and necessary to provide alternative sources of drinking water for all persons whose drinking water is contaminated with PFCs in a concentration that exceeds an HBV or HRL issued or adopted by the Minnesota Department of Health, including water containing two or more PFCs for which HBVs or HRLs have been adopted if the combined PFC levels exceed a Hazard Index of 1.0 based on those HBVs or HRLs and MDH has issued an advisory against human consumption of the water. the contrary in the remedy selection criteria in the C. Notwithstanding anything to Exhibits referenced in Part V.B, and to the extent consistent with site - specific response action objectives specified by the Commissioner, response actions at the Sites shall address the source of releases and threatened releases of PFCs to ground water. Such response actions shall include (1) excavation and destruction of PFCs, or excavation, engineered isolation and containment of PFCs, and (2) other technically feasible response actions, which are reasonable and necessary to provide for a comprehensive and effective long -term response that protects public health and welfare and the environment. Primary consideration shall be given to alternative (1) consistent with Minn. Stat. § 11513.02, subd. 16 (c). For purposes of implementation of this Agreement, the MPCA agrees that it will not consider any excavated material from the. sites to be hazardous wastes under Minnesota or federal law or regulations solely by virtue of the presence of PFCs in 18 such wastes. Additionally the MPCA agrees to provide expedited permitting and approval processes to facilitate the management of any excavated material. D. Before selecting a remedy for a Site, MPCA shall hold a public meeting in the affected community to explain and receive public comment on the proposed remedy. This requirement is in addition to the public notice and opportunity for comment required under Minn. Stat. § 115B.17, subd. 2b. IX. Review and A»proval of Submitt The review of each submittal, document, report, or schedule (collectively referred to as "Submittal ") which is required to be submitted to and reviewed by the MPCA Commissioner under this Agreement shall be as follows: A. The MPCA Commissioner shall review each Submittal made by 3M within forty -five (45) calendar days of receipt and notify 3M in writing of the Commissioner's approval, disapproval, or modification of the Submittal. If the Submittal is approved, it shall become an integral and enforceable part of this Agreement. If the Submittal is disapproved in whole or part, the MPCA Commissioner shall notify 3M and shall explain the amendments or revisions that are necessary to bring the Submittal into compliance with this Agreement. If the Submittal is modified, the MPCA Commissioner shall notify 3M of the specific modifications made to the Submittal and the reasons for making them. B. Within thirty (30) calendar days of receipt of any notice of disapproval or modification 3M shall (1) submit revisions necessary to bring the Submittal into compliance with this Agreement, (2) respond to the modifications or (3) state in writing the reasons why the Submittal, as originally submitted, should be approved. M C. If, within thirty (30) calendar days from the date of 3M's submission under paragraph B above, the parties have not reconciled all issues with respect to the Submittal, the MPCA Commissioner shall make final modifications of the Submittal as the Commissioner deems necessary and shall notify 3M of the final modifications. Unless 3M initiates dispute resolution under Part X (Resolution of Disputes) within fourteen (14) days after receipt of notice of the final modifications, the Submittal with the final modifications made by the MPCA Commissioner shall become an integral and enforceable part of this Agreement. D. All Submittals or final modifications thereto shall be technologically feasible and in accordance with sound engineering practices. E. The MPCA and 3M shall provide the opportunity to consult with each other during the review of Submittals. X. Resolution of Disputes This Part X is intended to provide 3M with a means of seeking to resolve disputes that it may have with MPCA under this Agreement, including disputes regarding any MPCA final modification or disapproval of Submittals. 3M shall continue to implement those portions of the Agreement not in dispute which can be reasonably implemented pending final resolution of the issues in dispute and may request an extension of schedule under Part XX`dIII for obligations that 3M believes cannot be reasonably implemented during the dispute. A. Within fourteen (14) days after the receipt of notice of final modifications of a Submittal, or after the date that a dispute arises regarding any other matter under this Agreement, 3M shall provide the MPCA Commissioner with a written statement which includes:. (1) an explanation of the matter in dispute and of 3M's position on the matter; (2) a summary of the information 3M is relying upon to support its position; and (3) notice of whether 3M will suspend work on any portions of the response actions required under Parts V to VIII during the dispute. B. During the fourteen (14) days following the date the Commissioner receives a statement from 3M under Paragraph A of this Part, the MPCA Commissioner shall provide an opportunity to resolve the matter through informal negotiations. The Commissioner may exercise discretion to extend the informal negotiation period. C. If 3M and the MPCA Commissioner do not agree upon a written resolution of the dispute during the informal negotiation period, the MPCA Commissioner shall issue an order deciding the issues in dispute, which shall include an explanation of the reasons for the decision and a summary of the information upon which the decision is based. D. Within fourteen (14) days of the date of receipt of the MPCA Commissioner's order, 3M shall notify the MPCA Commissioner either that 3M intends to comply with the MPCA Commissioner's order, or that 3M does not intend to comply with the MPCA Commissioner's order in whole or in part, and intends to suspend work on those portions of the order that are in dispute. In the event that 3M does not notify the MPCA Commissioner as required in this Paragraph D within fourteen (14) days of the date of receipt of the MPCA Commissioner's order, 3M's failure shall be construed as a waiver of its right to challenge the order and the MPCA Commissioner's order shall become final and an integral and enforceable part of this Agreement. E. If the MPCA Commissioner receives a timely notice from 3M that it does not intend to comply with the MPCA Commissioner's order, the MPCA Commissioner shall notify 21 3M, within forty-five (45) days of the date that notice was received from 3M, whether the MPCA intends to perform any of the response actions which 3M has suspended or intends to suspend. P If the MPCA decides to perform any response actions that 3M has suspended or intends to suspend pursuant to its notice to the Commissioner under Paragraph D, the MPCA may recover any reasonable and necessary expenses incurred by the MPCA to perform the response actions under Part XXIII of this Agreement. G. If the MPCA decides to perform any response actions which 3M has suspended or intends to suspend, there shall be no judicial review of the MPCA Commissioner's order or of the response actions performed by the MPCA Commissioner unless the MPCA Commissioner brings an action to enforce Part XXIII of this Agreement to recover costs incurred to perform the response actions. In any such action, judicial review of the MPCA Commissioner's order, or of response actions performed by the MPCA Commissioner, shall be limited to review of whether by the the response actions required under the MPCA Commissioner's order or performed and MPCA Commissioner are reasonable a nd necessary to protect the public hea l and welfare the environment. The MPCA Commissioner's order shall be affirmed unless 3M shows that the decision of the WCA Commissioner in the disputed matter is not supported by substantial evidence in the administrative record or is otherwise contrary to law or to any term or condition shall relieve the MPCA of the burden to show that of this Agreement. Nothing in this Paragraph the costs incurred by the MPCA are reasonable and necessary as provided in Part XXIII, Paragraph F. H. If the MPCA Commissioner notifies 3M that the Commissioner does not intend to perform response actions which 3M has suspended or intends to suspend, 3M may bring an action to review the MPCA Commissioner's order within thirty (30) days after receipt of the 22 notice from the MPCA Commissioner. Such action shall be brought in Washington County District Court as an action to enforce this Agreement. In any such action, review of the MPCA Commissioner's order shall be limited to review of whether the response actions required under the MPCA Commissioner's order are reasonable and necessary to protect the public health and welfare and the environment. The MPCA Commissioner's order shall be affirmed unless 3M shows that the decision of the MPCA Commissioner in the disputed matter is not supported by substantial evidence in the administrative record or is otherwise contrary to law or to any term or condition of this Agreement. If 3M does not commence such an action within the time provided in this Paragraph H, the MPCA Commissioner's order shall become final and an integral and enforceable part of this Agreement. I. For the purpose of any review of an MPCA Commissioner's order as provided in this Part, the administrative record on which review shall be based shall consist of the following documents: this Agreement; any Submittals that have become an integral and enforceable part of this Agreement; any Submittal that is the subject of the dispute including any modifications made by the MPCA Commissioner and any response submitted by 3M under Part IX., Paragraph B; the statement submitted by 3M under Paragraph A of this Part; the MPCA Commissioner's order issued under Paragraph C of this Part; and any information referenced in 3M's statement under Paragraph A or in the MPCA Commissioner's order upon which 3M or the Commissioner have relied for support of their respective positions. of Permits A. The implementation of this Agreement may require the issuance of governmental permits, authorizations or orders (hereinafter referred to as "permit ") by the MPCA, other state or 23 federal agencies, or other governmental bodies. This Agreement is based upon the expectation that the terms and conditions of any necessary permits will be issued consistent with the response actions required by this Agreement. B. 3M shall notify the MPCA Commissioner of all non -MPCA permits which are needed to implement the requirements of this Agreement as soon as 3M become aware of the need for the permit. 3M shall provide the MPCA Commissioner with a copy of all such permit applications at the time the application is submitted to the governmental body issuing the permit. C. If a permit is not issued, or is issued or is renewed in a manner which is materially inconsistent with the requirements of the approved RI, FS, RAP or RAs, 3M shall notify the MPCA Commissioner of its intention to propose modifications to the RI, FS, RAP or RAs. Notification by 3M of its intention to propose modifications shall be submitted to the MPCA Commissioner within seven (7) calendar days of receipt by 3M (1) of notification that (a) a permit will not be issued; or (b) a permit has been issued or reissued; and (2) of notification that a judicial action with respect to issuance of a permit has been filed. Within thirty (3 0) days after the date it submits its notice of intention, 3M shall submit to the MPCA Commissioner its proposed modifications to the RI, FS, RAP or RAs with an explanation of its reasons in support thereof; however, if 3M decides in its sole discretion to contest the denial of a permit, or if a judicial action concerning the permit has been filed, modifications shall be submitted within fifteen (15) days of 3M's receipt of notification that a final judicial determination has been entered. b. The MPCA Commissioner shall review and approve, disapprove or modify 3M's proposed modifications to the RI, FS, RAP or RAs in accordance with Part IX [Review and Approval of Submittals] of this Agreement. 24 E. During any judicial review of any permit needed to implement this Agreement or during the MPCA Commissioner's review of any of 3M's proposed modifications as provided in paragraph D above, and during any subsequent judicial proceedings taken in accordance with the provisions of Part X [Resolution of Disputes], 3M shall continue to implement those portions of the RI, FS, RAP and RAs which can be reasonably implemented pending final resolution of the judicial proceedings. K." Creation of Daneer If the MPCA Commissioner determines that it is necessary to stop implementation of this Agreement because of a danger to the health or welfare of the people on one or more of the Sites or in the surrounding area or to the environment, the MPCA Commissioner may order 3M to stop further implementation of this Agreement for the period of time needed to abate the danger, or may petition a court of appropriate jurisdiction for such an order. 3M shall comply with the order from the MPCA Commissioner upon receipt. XIII. Re ortin • Information on PFCs• False Statements A. By 30 days after the end of each calendar quarter 3M shall submit to the MPCA Commissioner a written progress report which describes the actions which 3M has taken during the previous quarter to implement the requirements of this Agreement for each Site and for other obligations under this Agreement. Progress reports shall also describe the activities scheduled to be taken during the upcoming quarter. Progress reports shall be submitted beginning on July 30 following the effective date of this Agreement. The progress reports shall include a detailed statement of the manner and extent to which the requirements and time schedules set out in the 25 Exhibits to this Agreement are being met. 3M shall propose in the progress reports any additional activities it believes to be necessary which are not included in the approved RI, FS, RAP or RAs and shall describe the impact of the additional activities on the other activities conducted pursuant to this Agreement. The MPCA Commissioner may, in the Commissioner's discretion, direct that progress reports be submitted at extended intervals or that no further reports be submitted. B. Within 60 days after the effective date of this Agreement, 3M will establish a process satisfactory to MPCA to ensure that MPCA has access to all documents within 3M's possession or control, except for documents subject to attorney- client privilege or to protection as attorney work product, which address or relate to: (1) the health or environmental effects of any PFC; (2) actions or precautions considered or recommended by 3M for managing, treating or disposing of wastes containing any PFC; and (3) any characteristic of any PFC or PFC waste that might cause the PFC or waste to be considered a hazardous substance or a hazardous waste as those terms are used in MERLA or in the hazardous waste rules of the MPCA, Minn. R. ch. 7045. 3M will provide MPCA with copies of such documents that MPCA may request. 3M agrees to provide representatives to meet with MPCA, whether periodically or on specific request, to explain the context and substance of any documents relating to PFCs for which access or copies have been provided to MPCA under this Paragraph. MPCA agrees to classify any documents provided by 3M under this Paragraph as non - public data as provided in Part XXII of this Agreement. C. 3M agrees to cooperate with MPCA and MDH in developing and implementing health and toxicological studies needed by MDH to develop HBVs and HRLs for PFCs. It is 26 anticipated that a final report of the 90 day feeding study for PFBA will be available by March 31, 2008. Preliminary data from this study will be shared with MDH as it becomes available. D. 3M shall not knowingly make any false statement, representation or certification in any record, report, plan or other document filed or required to be submitted to the MPCA under this Agreement. 3M shall immediately upon discovery report to the MPCA and correct any errors in such record, report, plan or other document. XIV. Notification; Primary Co ntact All notices required under this Agreement shall be in writing. Unless otherwise specified by MPCA, notices, progress reports and any other Submittals made by 3M pursuant to this Agreement shall be sent by certified mail, return receipt requested or hand delivered to: Kathy Sather, Director, Remediation Division Minnesota Pollution Control Agency 520 Lafayette Road St. Paul, Minnesota 55155 Notices and other documents sent to 3M shall be addressed as follows unless 3M specifies otherwise: Gary A. Hohenstein Manager, Special Projects EHS Operations 3M Company Building 42 -2E -05 St. Paul, MN 55144 XV. pro iect Managers The MPCA and 3M shall each designate a Project Manager and Alternate (hereinafter jointly referred to as Project Manager) for each Site for the purposes of overseeing the 27 implementation of this Agreement. 3M's Project Manager for the Sites is Gary A. Hohenstein. Within ten (10) days of the effective date of this Agreement, 3M shall notify the MPCA Commissioner of the name and address of its Alternates. The MPCA Project Manager and Alternate for each Site are as follows: 1. 3M Cottage Grove Site. a. Project Manager - -Gary Krueger. b. Alternate - -Fred Campbell. 2. 3M Oakdale Site. a. Project Manager - -Gary Krueger. b. Alternate - -Fred Campbell. 3. 3M Woodbury Site. a. Project Manager -- Gerald Stahnke. b. Alternate - -Mike Connolly. Either party may change its designated Project Managers by notifying the other party, in writing, of the change. To the maximum extent possible, communications between 3M and the MPCA concerning the terms and conditions of this Agreement as they apply to response actions for the Sites shall be directed through the Project Managers. Each Project Manager shall be responsible for assuring that all communications from the other Project Manager are appropriately disseminated and processed. Each Project Manager shall have the authority to (1) take samples or direct that samples be taken; (2) direct that work at a Site stop for a period not to exceed seventy -two (72) hours if the Project Manager determines that activities at the Site may create a danger to public health or welfare or the environment; (3) observe, take photographs and make such other reports on the 28 progress of the work as the Project Manager deems appropriate;. (4) review records, files and documents relevant to this Agreement; and (5) make or authorize minor field modifications in the RI, FS, RAP or RAs or in techniques, procedures or design utilized in carrying out this Agreement which are necessary to the completion of those activities. Any field modifications shall be approved orally by both Project Managers. Within seventy -two (72) hours following the modification, the Project Manager who requested the modification shall prepare a memorandum detailing the modification and the reasons therefore and shall provide or mail a copy of the memorandum to the other Project Manager. The MPCA and 3M Project Managers shall either be on the Site or available on call by telephone during all hours of work at the Site. The absence of any Project Manager from the Site shall not be cause for stoppage of work. XVI. Samples Data Availability The MPCA Commissioner and 3M shall make available to each other the results of sampling, tests or other data generated by either party, or on its behalf, with respect to the implementation of this Agreement. MPCA and 3M agree to allow split or duplicate samples to be taken by the other party during sample collection conducted as part of the implementation of this Agreement. For sampling associated with 3M's obligations for the Sites under Parts VI to VIII, 3M's Project Manager for a Site shall endeavor to notify the MPCA Project Manager for that Site not less than ten (10) days in advance of any planned 3M sample collection. If it is not possible to provide ten (10) days prior notification, 3M shall notify the MPCA Project Manager as soon as possible after becoming aware that samples will be collected. For other sampling, a 91 parry planning to take samples shall endeavor to notify the other party's primary contact not less than ten (10) days before planned sample collection. XVII. Retention of Records Notwithstanding any document retention policy to the contrary, 3M shall retain and preserve for a minimum of three (3) years after termination of this Agreement all records and documents in its possession or in the possession of its divisions, employees, agents, accountants, contractors or attorneys which relate in any way to the presence of PFCs at the Sites or to the implementation of this Agreement. Following the three (3) year document retention period, 3M shall notify the MPCA a minimum of ninety (90) days before destroying any documents and shall relinquish such documents to the MPCA upon request. Should any portion of the work performed hereunder be undertaken through contractors or agents of 3M, then 3M agrees to include in the contract with such contractors and agents a document retention requirement meeting the terms of this paragraph. XVIIl. Access and Assurances Regarding Response Actions A. The MPCA and its authorized employees, agents and representatives shall have authority to enter each Site at all times for the purpose of enforcing and overseeing implementation of this Agreement, and 3M shall cooperate with the MPCA in taking such actions, including but not limited to: inspecting records, operating logs, contracts and other documents relevant to implementation of this Agreement; reviewing the progress of 3M in implementing .this Agreement; conducting such tests as the MPCA Commissioner or MPCA Project Manager deems necessary; verifying the data submitted to the MPCA by 3M; and taking ail response actions in the event that 3M fails to take response actions as required under this Agreement, including response actions suspended as a result of a dispute under Part X (Resolution of Disputes). If records required to be retained under this Agreement are kept at locations other than each Site, the MPCA and its authorized employees, agents or representatives shall have access to such other location at all reasonable times for the purposes of inspecting the records. 3M shall honor all reasonable requests for such access by the MPCA conditioned only upon presentation of proper credentials. B. With respect to property owned by 3M upon which 3M is obligated under this Agreement to construct, operate, maintain or monitor any wells, treatment facilities or other response actions 3M agrees not to disturb or interfere with the wells, treatment facilities or other response actions that are constructed, and not to convey any title, easement, or other interest in the property without such provision as the MPCA Commissioner deems necessary, including granting and recording by 3M of restrictive covenants or other use restrictions, to assure: (1) completion and continued operation, maintenance and monitoring of the wells, treatment facilities or other response actions required pursuant to this Agreement; (2) long -term effectiveness of the response actions to protect public health and welfare and the environment, including protection from exposure to any residual contamination after implementation of an MPCA- selected remedial action; and (3) access by the MPCA, its employees and contractors to enforce and monitor effectiveness of the response actions and use restrictions. 3M shall notify the MPCA Commissioner, by certified mail, at least thirty (30) days prior to any conveyance of the property, of 3M's agreement to convey any interest in the property and of the provisions made to assure that 3M's obligations under this Agreement will be carried out and the response actions will remain protective after the conveyance. The MPCA may require recording of a 31 restrictive covenant or other institutional control that meets the requirements of this Paragraph B as a condition of termination of this Agreement under Part XXXII. C. 3M shall use its best efforts to obtain access to property not owned by 3M upon which 3M, its contractors, and the MPCA and its authorized employees, agents or representatives will be required to enter or conduct work in order to carry out the terms of this Agreement. 3M shall be responsible for restoring to substantially its original condition any property to which access has been granted. Access agreements obtained by 3M under this Part shall provide authority for 3M and its employees, contractors, agents, successors and assigns, and for the MPCA and its authorized employees, agents or representatives, to enter the property at all reasonable times for the purpose of implementing their obligations or authorities under this Agreement. If 3M is unable to obtain access using its best efforts, the MPCA agrees to use its authority under the statutes and regulations it administers to assist 3M in obtaining access to property necessary for the implementation of this Agreement. If MPCA designates 3M, its contractors, employees or agents as agents or representatives of the State in order to obtain access under Minn. Stat. § 115B.17, subd. 4, such designation shall be for the sole purpose of entering the designated property to take actions necessary for the implementation of this Agreement. In the event of such designation, 3M and its assigns shall indemnify and save and hold the State, its agents, and employees harmless from any and all claims or causes of action arising from or on account of the entry on to the designated property or the performance of response actions by 3M, its contractors, employees or agents. D. If property upon which 3M is obligated under this Agreement to construct, operate, maintain or monitor any wells, treatment facilities or other response actions is not 32 owned by 3M, any access agreement with the owner obtained by 3M under Paragraph C of this Part XVIII must include provisions by which the owner agrees to the obligations set forth in Paragraph B. XIX. Hold Harmless Agreement A. 3M agrees to indemnify and save and hold the MPCA, its agents and employees, harmless from any and all claims or causes of action arising from or on account of acts or omissions of 3M, its officers, employees, agents, or contractors in implementing this Agreement. B. Within fourteen (14) working days of receipt by the MPCA Commissioner of notice of any claim or cause of action against MPCA arising from or on account of acts or omissions of 3M, its officers, employees, agents, or contractors in implementing this Agreement (hereinafter referred to in this Part XIX as a "claim "), the MPCA Commissioner shall give written notice to 3M of this claim. Failure of the MPCA to give such notice shall not relieve 3M of any obligation that they may have to the MPCA except to the extent 3M demonstrates that the defense of the claim is prejudiced thereby. C. 3M shall be entitled to participate in the defense of any claim and may elect to assume the defense if the MPCA and the Minnesota Attorney General's Office give their written approval of counsel employed for such defense. If 3M elects to assume the defense of a claim: (a) the MPCA shall have the right to employ separate counsel at its own expense and to participate in the defense thereof, (b) no compromise or settlement thereof may be effected by 3M without the written consent of the MPCA and the Minnesota Attorney General's Office (which shall not be unreasonably withheld) unless the sole consideration required by the settlement is a sum of money that is paid solely and in full by 3M and MPCA obtains a full 33 release and discharge of all claims which were or could have been brought against MPCA in the matter; and (c) 3M shall have no liability with respect to any compromise or settlement thereof effected by MPCA unless MPCA obtains written consent of 3M, which consent shall not be unreasonably withheld. D. If 3M is obligated to indemnify the MPCA but elects not to assume, or fails to assume, the defense of a claim, the MPCA shall be entitled to assume the defense and prosecute or settle the claim with counsel of its own choice, at the expense of 3M. E. If a claim is asserted against both 3M and the MPCA and there is a conflict of interest which renders it inappropriate for the same counsel to represent both 3M and the MPCA, 3M shall be responsible for paying for separate counsel for the MPCA. F. Nothing in this Part XIX waives or modifies any immunity from or limitation of liability of the MPCA under the Minnesota Tort Claims Act, Minn. Stat. §§ 3.732, et seq., or other applicable law. M other r_ Claims Nothing herein is intended to bar or release any claims, causes of action or demands in law or equity by MPCA or 3M against any person, firm, partnership or corporation not a signatory to this Agreement for any liability such other person or entity may have arising out of or relating in any way to the generation, storage, treatment, handling, transportation, disposal or release of any PFCs at, to, or from the Sites or of VOCs from the 3M Woodbury Disposal Site. The MPCA shall not be held as a party to any contract entered into by 3M to implement the requirements of this Agreement. 34 XXI. Other Applicable Laws All actions required to be taken pursuant to this Agreement shall be undertaken in accordance with the requirements of all applicable local, state and federal laws and regulations. If there is a conflict in the application of federal, state or local laws or regulations, the most stringent of the conflicting provisions shall apply. XXII. Confidential Information 3M may make a request in accordance with the procedural rules of the MPCA for non - public treatment of information submitted pursuant to this Agreement to the extent such treatment is authorized under Minn. Star. ch. 13 and Sections 11513.17, subd. 5, or 116.075. Information determined to be non - public by the MPCA Commissioner shall be afforded protection as provided in Minn. Star. ch. 13 and §§ I I5B.17, subd. 5 and 116.075 and applicable procedural rules of the MPCA. If no request for non - public treatment accompanies the information when it is submitted to the MPCA Commissioner, the information may be made available to the public by the MPCA Commissioner without further notice to 3M. XXIII. Recovery of Expenses A. Within thirty (30) days of the effective date of this Agreement, 3M shall pay to the State of Minnesota, by check payable to the Minnesota Pollution Control Agency, the sum of Five Hundred Ninety -eight Thousand Six Hundred Ninety -two Dollars ($598,692.00) as reimbursement of the MPCA's costs as provided in Part XXIII.C. Payment of this sum shall be 35 in full and complete satisfaction of 3M's obligation to reimburse costs under Part XXIII.C. incurred by MPCA through April 30, 2007. B. 3M agrees to reimburse the MPCA for reasonable and necessary costs incurred by MPCA to implement or oversee implementation of this Agreement including administrative and legal expenses, including costs incurred to perform response actions which 3M suspends or intends to suspend pending resolution of a dispute under Part X of this Agreement (Resolution of Disputes). C. 3M agrees to reimburse MPCA for all reasonable and necessary costs incurred by MPCA under Minn. Stat. § 11513.17, subd. 2, which are related to PFCs for which response actions are required as provided in Part V. A to C of this Agreement, whether the costs incurred relate to the Sites or to other releases that are associated with wastes generated by 3M facilities in Minnesota. Releases from the Washington County Landfill are not included in this Part XXIII.C. D. 3M agrees to provide to MPCA a grant in an amount up to Five Million Dollars ($5,000,000) for expenses not reimbursable under Paragraphs B and C incurred for the purpose of investigating and assessing the presence and effects in the environment and biota of any PFC for which response actions are required under Parts V to VIII of this Agreement, including sampling and analysis of any or all of the following: ground water and leachate at closed and operating landfills; discharges from wastewater treatment plants; ambient air and ground water; and surface water, sediment and biota samples. MPCA will consult with 3M on the scope of such investigation and assessment and will consider 3M's comments in the selection of appropriate research. 36 3M agrees to pay $2,000,000 of the grant agreed to in this Paragraph D thirty days after written request for payment by the MPCA. In addition, 3M agrees to pay 50 percent of the cost of research as described in this Paragraph D. incurred by MPCA in State fiscal years 2009 to 2011, up to an additional amount of $1,000,000 in each of those fiscal years. Subject to the limitations as provided in this Paragraph D, 3M agrees to make payments in fiscal years 2009 to 2011 within 30 days of written notice from MPCA that the agency has incurred contract obligations, or staff or administrative costs, in that fiscal year for research as described in this Paragraph D. In no event shall the total amount of the grant which 3M is obligated to make under this Paragraph F exceed $5,000,000. 3M agrees to meet and confer with MPCA during State fiscal year 2011 concerning MPCA's plans for additional research as described in this Paragraph D and the estimated cost of such additional research and, if requested by MPCA, 3M agrees to enter into discussions concerning 3M's possible future participation in the cost of such additional research. E. 3M shall pay any sum required to be reimbursed under Paragraph B or C of this Part to the State of Minnesota by check payable to the Minnesota Pollution Control Agency within sixty (60) days following receipt of the MPCA Commissioner's reimbursement statement. 3M shall pay interest determined pursuant to Minn. Stat. § 549.09, subd. 1(c), on any amounts not paid to the MPCA within the time required in this Part. F. In an action to enforce Paragraph B and C of this Part XXIII, the MPCA shall have the burden to show that the response costs for which MPCA seeks reimbursement are reasonable and necessary. For costs recoverable under Paragraph B or C, the MPCA is entitled to the presumption provided in MERLA, Minn. Stat. § 11513.17, subd. 6 37 XXIV. Liability Insurance Within 60 days of the effective date of this Agreement, 3M shall provide the MPCA Commissioner with current certificates of insurance for its work at each Site certifying coverage with respect to each Site for general liability with minimum limits of Three Million Dollars ($3,000,000) per occurrence and with an annual aggregate of at least Six Million Dollars ($6,000,000), exclusive of legal defense costs, for bodily injury and property damage liability that may arise from or on account of acts or omissions of 3M, its officers, employees or contractors in implementing this Agreement. The insurance coverage shall provide that it cannot be canceled for any reason except after thirty (30) days written notice to the MPCA Commissioner. The coverage shall include the MPCA as a named insured and, upon request of the MPCA Commissioner, shall include as a named insured any owner of real property where response actions are to be taken pursuant to this Agreement. These insurance limits are not to be construed as maximum limits. 3M is solely responsible for determining the appropriate amount of insurance 3M should carry for injuries or damages resulting from its activities in the implementation of this Agreement. 3M may satisfy the requirements of this Part XXIV by providing certificates of insurance showing that the required coverage has been provided by contractors retained by 3M to perform the work required under this Agreement, and that 3M is an additional named insured under such insurance. XXV. Covenant Not to Sue A. In consideration for and conditioned upon 3M's performance of the terms and conditions of this Agreement, subject to the reservations set forth in Paragraph B of this Part 38 XXV, and based on the information known to the MPCA on the effective date of this Agreement, the MPCA covenants not to bring against 3M any administrative, legal or equitable action available to the MPCA under Minn. Stat. §§ 115.071, 11513.04, 11513.17, subd. 6 (including claims for MPCA administrative and legal expenses), or 11513.18 (including civil penalties), or other state law to require 3M to take or pay the cost of response actions to address any discharge, release or threatened release of PFCs, at or from the Sites known to the MPCA on the effective date of this Agreement. B. Nothing in this Agreement shall preclude the MPCA from exercising any administrative, legal or equitable remedy available to it to require 3M to take or pay the cost of response actions in addition to the requirements of this Agreement in the event that: 1. MPCA discovers any discharge, release or threatened release of pollutants or hazardous substances at or from any of the Sites which was not known to the MPCA on the effective date of this Agreement; or 2. the implementation of the requirements of this Agreement is insufficient to protect public health or welfare or the environment with respect to any discharge, release or threatened release of hazardous substances at or from any of the Sites which is addressed under this Agreement. C. This Agreement shall not be construed to release 3M from any liability 3M may have for failing to disclose information responsive to Part XIII.B. to the MPCA before the effective date of this Agreement if 3M had a duty under any law to disclose such information to MPCA before the effective date of this Agreement. D. Except as specifically identified in Paragraph A, this Agreement .shall not be construed as releasing 3M from any liability arising out of or relating to the discharge, release or 39 threatened release of pollutants or hazardous substances at or from any of the Sites, including any liability for natural resource damages or related assessment costs. E. Nothing in this Agreement shall limit the authority of the MPCA to seek civil penalties under Minn. Stat. § 115.071, 115B.18, subd. 1, or any other law for noncompliance with this Agreement. F. 3M covenants not to sue and agrees not to assert any claim, which 3M could have brought against the MPCA at the time of execution of this Agreement and which arises out of or relates to the discharge, release or threatened release of PFCs or VOCs at or from any of the Sites. In addition, as of the effective date of this Agreement: (1) 3M's April 19, 2007 petition for rulemaking requesting MPCA to engage in rulemaking under Minn. Rule ch. 7045 shall be deemed withdrawn by 3M; and (2) 3M waives any rights which it may have to appeal the MPCA Board's denial of its April 19, 2007 requests for contested case hearing under Minn. R. 7045.0218 and Minn. R. 7000.1900. XXVI. Enforceability The terms of this Agreement shall be legally enforceable by either party in Minnesota District Court for Washington County. XXVIl. Failure to CoWlly With Obligations Under The Agreement A. For each day that 3M fails to comply with an obligation under this Agreement, within the time required in this Agreement or any Exhibit to this Agreement, or under any other schedule approved or modified by the MPCA Commissioner pursuant to this Agreement, 3M 40 shall be obligated to pay to the State of Minnesota, by check payable to the Minnesota Pollution Control Agency, the sum of Five Hundred Dollars ($500). B. 3M shall not be liable for payment under this Part if 3M has submitted to the MPCA Commissioner a timely request for an extension of time to comply with the obligation under Part XXIX (Extension of Schedules) of this Agreement and the request has been granted. C. Upon determination by the MPCA Commissioner that 3M has failed to comply in a timely manner with an obligation under this Agreement, the MPCA Commissioner shall give written notice to 3M of the failure, specifying the provision of the Agreement which has not been complied with and the date that penalties began to accrue under this Part XXVII. 3M retains the right to dispute under Part X (Resolution of Disputes) the factual basis for the MPCA Commissioner's determination that 3M has failed to comply with an obligation under this Agreement in a timely fashion. Notwithstanding the provisions of Part X, Paragraphs D to H, if 3M initiates a dispute under Part X of this Agreement regarding the MPCA Commissioner's determination of failure to comply, and the MPCA Commissioner issues an order deciding the dispute under Part X, Paragraph C, 3M shall have fourteen (14) days from receipt of the Commissioner's order to commence an action to review the Commissioner's decision. If an action is not commenced within that period, the Commissioner's order shall become final and an integral and enforceable part of this Agreement. In all other respects, the review of the Commissioner's decision shall be as provided in Part X, Paragraphs H and I. D. Penalties under this Part shall accrue from the date on which 3M was required to comply with the obligation. Payments required by this Part shall cease to accrue when 3M complies with the obligation. 3M shall pay the required penalty within thirty (30) days of receipt of the MPCA Commissioner's notice of non - compliance, and shall pay any subsequently 41 accruing penalties within thirty (30) days after correcting the non - compliance for which the penalties were imposed. XXVIII. Extension of Schedules 3M may request an extension of time to comply with any obligation under this Agreement, including any deadline under Exhibits A to F to this Agreement, by submitting the request in writing at least ten days before the scheduled deadline, or as soon as possible before that date if the reason for the extension request arises less than ten days before the deadline. The request shall specify the reason why the extension is needed. Extensions shall only be granted for good cause and for such period of time as the MPCA determines is reasonable under the circumstances. A requested extension shall not be effective until approved by the MPCA. The burden shall be on 3M to demonstrate that the request for extension is timely and that good cause exists for granting the extension. Good cause for granting an extension includes, but is not limited to: A. "Force majeure". For the purposes of this Agreement, "force majeure" is defined as any event arising from causes beyond the control of 3M that cannot be overcome with the exercise of due diligence and that delays or prevents the performance of any obligation under this Agreement. "Force Majeure" shall not include financial considerations such as increased costs of the remedial action or the financial condition of 3M, or the failure to timely apply for any required approvals or to provide all required information therefore in a timely manner; B. Stoppage of work under Part XII (Creation of Danger) if the work stoppage was not the result of any noncompliance by 3M with this Agreement, including the Exhibits thereto; M C. Delays associated with the good faith invocation by 3M of Part X (Resolution of Disputes) of this Agreement, when portions of this Agreement cannot reasonably be implemented pending resolution of the dispute; and, D. Delays which are directly attributable to any changes in permit terms or conditions or refusal to issue a permit needed to implement the requirements of this Agreement, as contemplated under Part XI (Permits) of this Agreement, if 3M filed a timely application for the necessary permit. Good cause for an extension does not include unanticipated costs or delays in MPCA review of Submittals when the Submittals are not provided to MPCA in complete and approvable form. Financial Responsibility Before 3M commences construction of an MPCA- approved remedial action, MPCA may require 3M to submit to the MPCA evidence of financial assurance regarding the financial ability of 3M to complete construction of the remedial action, carry out long -term operation, maintenance and monitoring of the remedial action, and take contingency actions in the event that the remedial action fails to meet remedial objectives or cleanup levels. The amount and form of financial assurance required by this Part are subject to approval by the MPCA. Amendment of Agreement This Agreement may be amended only by a written agreement between 3M and the 43 XXXI. Successors This Agreement shall be binding upon 3M Company, its successors and assigns, and upon the MPCA, its successors and assigns. Termination and Survival of Certain Provisions The provisions of this Agreement shall be deemed satisfied and terminated upon receipt by 3M of written notice from the MPCA Commissioner that 3M has demonstrated to the satisfaction of the MPCA Commissioner that all the terms of this Agreement have been completed. The provisions of Parts XVII (Retention of Records), XIX (Hold Harmless Agreement), XX (Other Claims), XXV (Covenant Not To Sue), XXXI (Successors), and to the extent necessary to enforce those sections, Section XXVI (Enforceability), shall survive the termination of this Agreement. THE REMAINDER OF THIS PAGE IS DELIBERATELY LEFT BLANK 44